PRIVACY POLICY

MAISON MUNZ has drawn up this privacy policy (the “Policy”) to inform data subjects (the “Data Subjects“ or “You“) of the terms and conditions under which it processes personal data for the purpose of its business activities.

More precisely, registering for training courses with MAISON MUNZ involves the collection and processing of certain personal data, as defined by Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016 on data protection and privacy (General Data Protection Regulation – hereinafter, the “GDPR”) and French Law No 78/17 of January 6, 1978 (Loi Informatique & Libertés – hereinafter, the “Data Protection Act”) in its currently applicable version (together, the “Applicable Laws”).

This Policy may be amended periodically. Data subjects will be informed of any such amendment by any available means. In such case, the date of “Last update” indicated above will be modified and the new version of the Policy will take effect on that date. 

This Policy completes the provisions of MAISON MUNZ’s terms and conditions, applicable to registrations for training courses, in particular.

1. Definitions

In this Policy, in accordance with the Applicable Laws, the capitalized terms and expressions below will have the following meanings: 

“Data“: means any information concerning an identified or identifiable individual, including their name, identification number, location data, online ID, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity; 

“Data Subject”: means any natural person interacting with MAISON MUNZ, i.e., in particular, any person who registers for training courses with MAISON MUNZ or any person who browses MAISON MUNZ’s website.

2. Who is the data controller for the Data processing implemented? 

The data controller for the Data processing implemented is MAISON MUNZ, a Société par Actions Simplifiée (simplified joint stock company) with a share capital of EUR 1,000 registered in Marseille (France) under company number 918 352 261, whose head office is located at 283 boulevard Chave, 13004 Marseille (France), represented by its President (hereinafter, “MAISON MUNZ” or “We/Us”).

3. When does MAISON MUNZ collect and process Data? 

MAISON MUNZ may collect and process the Data as follows: 

• when it is contacted via the website www.maisonmunz.com: there is a contact form on MAISON MUNZ’s website in the Contact section to enable interested persons to write to MAISON MUNZ and request information on its activities, and particularly its training courses;
• when someone registers for a training course provided by MAISON MUNZ: in this case, MAISON MUNZ collects Data to assess the application submitted to it and then potentially register the Data Subject. Data may also be collected via the BAND application, which MAISON MUNZ uses to communicate with practitioners who have signed an Agreement with it;
• in the framework of MAISON MUNZ’s contractual relations: this concerns, in particular, MAISON MUNZ’s suppliers; 
• in the scope of the use of the website www.maisonmunz.com: when the website is browsed, certain Data can be generated by way of cookies. There is a cookie management module on MAISON MUNZ’s website enabling users to accept or refuse cookies.

4. What personal data does MAISON MUNZ collect and process?

MAISON MUNZ complies with the data minimization principle, which means that it only collects and processes Data that is strictly necessary for its business activities. MAISON MUNZ does not trade personal data. 

MAISON MUNZ collects and processes the following data:

• when it is contacted via the website www.maisonmunz.com: the Data collected is limited to the name and first name, email address, profession, place of residence, and any Data that the Data Subject may share with MAISON MUNZ in the contact form; 
• when someone registers for a training course: the Data collected concerns the Data Subject’s name, first name, profession and their date of birth, age, gender, contact information (postal address, email address, telephone number), their choice of training course, and the training level, as well as information concerning the bank card used for payment;
• when the BAND application is used: the application enables MAISON MUNZ and practitioners to communicate and share information together. MAISON MUNZ does not collect any specific Data in the framework of the application. Practitioners can, at their own initiative, share certain Data concerning them with MAISON MUNZ (e.g. their schedule);
• for the purpose of its contractual relations: MAISON MUNZ may automatically collect certain Data for the purpose of the performance of an agreement and, in particular, for issuing invoices and implementing payments; 
• in the scope of the use of the website www.maisonmunz.com: certain Data concerning the use of the website, such as the pages browsed, time spent on the website, etc., can be automatically collected. 

5. On what legal basis is the personal data collected and processed? 

MAISON MUNZ does not collect and process Data illegally. All the Data collected and processed by MAISON MUNZ is effectively done so on a duly identified legal basis: 

• contract or precontract requirements: most of the Data collected by MAISON MUNZ is necessary to implement the training courses it provides;
• consent: the other Data collected and processed by MAISON MUNZ is done so based on the consent of the Data Subjects, who choose to share it with MAISON MUNZ;
• MAISON MUNZ’s legitimate interests: MAISON MUNZ processes Data collected automatically to generate statistics and improve its website. MAISON MUNZ may also use the Data for marketing purposes, for example to inform practitioners of new training courses. 

6. For what purposes does MAISON MUNZ collect the Data? 

MAISON MUNZ uses the Data collected in the cases described above solely for specific and legitimate purposes, mainly related to the training courses it provides:

In summary, such purposes are the following:

• to enable Data Subjects to obtain information on MAISON MUNZ’s training courses offering and/or the courses provided by MAISON MUNZ’s authorized coaches; 
• to enable Data Subjects to apply for training and potentially attend the training courses;
• to enable MAISON MUNZ to correspond with Data Subjects who attend its training courses, and send them information via email concerning its training courses offering;
• to enable MAISON MUNZ’s contracting partners to perform their mission. 

7. With whom is the collected Data shared?

The collected Data is solely intended for MAISON MUNZ. When a Data Subject wishes to attend courses based on the MUNZ Method, a list of authorized coaches is sent to them. MAISON MUNZ does not disclose any contact information of Data Subjects who contact it to the authorized coaches. 

On an exceptional basis, some Data concerning practitioners may be shared with MAISON MUNZ’s service providers, such as its accountancy or law firm. 

8. For how long does MAISON MUNZ store the Data?

MAISON MUNZ stores the Data concerning Data Subjects in an identifiable form solely for the time strictly necessary to fulfil the purpose of the processing concerned. Thus, in summary:

• Data concerning potential customers (individuals) is not stored; 
• Data concerning practitioners is stored for the term of the agreement with them and up to three (3) years after the end of the agreement 
• Data concerning MAISON MUNZ’s suppliers is stored for the term of the contractual relationship and for the time required by law and regulations following such term.

9. What rights do You have in respect of Your personal data?

MAISON MUNZ complies with the rights granted to natural persons by the GDPR and the Data Protection Act. 

Thus, all Data Subjects whose Data has been collected by MAISON MUNZ have the right to request access to the Data stored by MAISON MUNZ concerning them and the correction or erasure thereof, or the restriction of the processing of personal data concerning them, as well as the right to refuse the processing thereof. 

It should be noted that, in the event of any restriction or refusal of processing, MAISON MUNZ may no longer be in a position to provide the training courses subscribed, for example. Furthermore, if the right of refusal or the right to be forgotten is exercised, some information may nevertheless be stored by MAISON MUNZ to comply with its legal obligations.  

Data Subjects can also give instructions concerning the storage, erasure, and disclosure of their Data after their lifetime. In the absence of any such instructions, the Data will be stored as indicated above, unless their heirs request its earlier erasure.

To exercise these rights, Data Subjects can send an email to the following address: info@maisonmunz.com or send a letter by post to the following address: 

MAISON MUNZ

Personal Data Protection

283 boulevard Chave, 13004 Marseille

FRANCE

 All correspondence must be accompanied by proof of the Data Subject’s identity. The identity document is not kept after verification of the Data Subject’s identity. 

Data Subjects can refuse cold calling by registering on the www.bloctel.fr application.

Lastly, Data Subjects have the right to lodge a complaint at any time with the relevant data protection supervisory authority, i.e., the CNIL in France, at the following address: www.cnil.fr.

10. How is Your personal data protected? 

In its capacity as data controller, MAISON MUNZ undertakes to implement and maintain, at its cost, appropriate technical and organizational measures for the processing and security of the Data, in accordance with Articles 32 to 34 of the GDPR and Article 70-13 of the Data Protection Act.

MAISON MUNZ ensures that such technical and organizational measures are always adapted to the specific risks inherent to its processing operations, especially to protect the Data against any accidental or unlawful destruction, loss or alteration and any unauthorized disclosure or access.

Thus, the technical measures taken by MAISON MUNZ are as follows:

• all the Data is hosted by service providers carefully selected by MAISON MUNZ (Dropbox, Apple iCloud and Google Drive) on servers located in the European Union or in the United States, protected by security measures defined by the service providers and offering adequate security guarantees for the risks involved. In particular, the Data is fully encrypted, and the servers are secured in accordance with the highest standards.

The organizational measures are as follows: 

• the Data can only be accessed by MAISON MUNZs management and personnel.

Furthermore, MAISON MUNZ undertakes to maintain, update and store complete and accurate records of the personal data processing it implements. These records contain details of its processing operations. 

11. Is any data transferred abroad?

As a principle, the Data collected by MAISON MUNZ is stored on computer servers located in the European Union (Apple iCloud, Google Drive).

If necessary, certain Data may be transferred to MAISON MUNZ’s data processors located outside the European Union, such as Dropbox. In this case, MAISON MUNZ makes sure that such transfers are made to countries recognized as providing an adequate level of protection for personal data or at least equivalent to the appropriate contractual guarantees provided for by European law and regulations.

12. Any further questions?

For any questions concerning how MAISON MUNZ collects and processes the Data, please send an email to the following address: info@maisonmunz.com. 

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