POLITIQUE DE CONFIDENTIALITÉ DES DONNEÉS PERSONNELLES SQP

https://www.shortfilmwire.com
Updated 12 JANUARY 2021

THIS PERSONAL DATA PRIVACY POLICY APPLIES TO ALL USERS, WHO ACKNOWLEDGE FULL AWARENESS THEREOF AND WAIVE ANY RIGHT TO INVOKE THE PROVISIONS OF ANY CONFLICTING DOCUMENTS.
SQP takes personal data protection and respect for privacy seriously. Data protection is everyone's responsibility, so we feel it is important for you to be fully informed about the measures we've put in place, what measures you'll need to adhere to, and what your rights are.
We may modify this document at any time, in particular to reflect any changes made to laws or regulations. In such case you will be notified by a posting on our website.

I. Who is the data controller?

The data controller for personal data processing is:
Sauve Qui Peut Le Court Métrage (SQPLCM)
6 Place Michel-de-l’Hospital
63058 Clermont-Ferrand Cedex 1
France
A non-profit organization under the law of 1901: VAT FR 01323874040

If you have any questions about the personal data regulations in place, please contact our Personal Data Coordinator:
• Postal mail: Sauve Qui Peut Le Court Métrage (SQPLCM) -6 Place Michel-de-l’Hospital- 63058 Clermont-Ferrand Cedex 1- France
• E-mail: info@clermont-filmfest.org
• Telephone: +33 (0)4 73 91 65 73

II. For whom is our personal data privacy policy intended?

This privacy policy applies to:
- All Internet users using our site https://www.shortfilmwire.com (hereinafter referred to as "Users")
- All Users and Subscribers who have created a Private Page (hereinafter referred to as "Clients")

III. What constitutes personal data and personal data processing?

Personal data is protected under:
- Information Technology and Civil Liberties Law no. 78-17 of 6 January 1978 as regularly amended (the "Information Technology and Civil Liberties Law"), and,
- The European General Data Protection Regulation no. 2016/679 of 27 April 2016, which came into force on 25 May 2018 ("GDPR").

> What constitutes personal data?

Personal data is information directly or indirectly linked to a physical person. Personal data may for example include user credentials, names, identification numbers, IP addresses, photographs, telephone numbers, etc.

> What constitutes sensitive data?

Among this personal data, certain data are considered sensitive. Sensitive data may in particular include a person's racial or ethnic origins, political, philosophical or religious views, trade union membership information, or information concerning their health or sex life. In principle, sensitive data may be collected and used only upon the individuals' explicit consent.

> What constitutes data processing?

Personal data processing is defined as any operation performed on personal data: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or other form of provision, alignment or combination, restriction, erasure or destruction.
In summary, this covers any operations where your data is to be used and/or consulted.

IV. What data do we collect and for what purpose?

As part of your relationship with our organisation, you have provided and/or may provide us with personal data, in particular for the following purposes:

Description of processing activity Primary purpose Legal basis
Management of Customers, Users and prospects • Creation of private page • Website connection request • Information request • Subscription management • Management of invoicing for subscriptions, accounting, • Management of relationship with Users and Customers (after sales service - help - complaints) • Prospecting and follow up of Users and Customers and prospects (management of technical prospecting operations; development of commercial statistics; organization of promotional operations; • Management of unpaid bills and disputes; • Management of personal reviews of services or content. Execution of pre-contractual measures and execution of contracts and legitimate interest of optimizing SQP's services
Establishment of a Participants Directory Creation of contact files Information exchange between Participants and Customers Consent of Participants and Legitimate Interest of Participants
Video library Creation of film list for viewing and archiving Creation of datasheets on films Management of access to video library Management of payment of fees to rights-holders Execution of pre-contractual measures and execution of contracts and legitimate interest of optimizing SQP's services
Internal messaging Management of internal messaging, without access to message content Retention of identifying data in compliance with the postal and electronic communications code Execution of pre-contractual measures and execution of contracts and legitimate interest of optimizing SQP's services Legal obligations

V. Who has access to your data?

SQP undertakes to disclose and/or provide access to your data only to persons with a need to know, namely:
- Persons in charge of Customer and User management within SQP;
- Other Participants and/or Users, for data contained in Film datasheets and/or Contact Information records;
- Legal entities in charge of implementing the aforementioned activities: banks, banking or payment institutions, insurance providers;
- The service providers we have identified and selected to act on our behalf to perform all or part of our activities, such as our consultants, accountants and technical service providers (particularly our hosting providers, but also solutions publishers, maintenance service providers, etc.), and any other professional enlisted to act on our behalf;
- Any auditors in the context of restructuring operations
- Public authorities in the context of compliance with legal obligations.

Any other data that may be transmitted by you is transmitted under your sole control and responsibility, in particular when sharing the Film list or using the internal messaging system. SQP is in no way responsible for this type of exchange and encourages you to remain vigilant about any transfer of such data.

VI. How are the security and confidentiality of my data "guaranteed"?

The confidentiality and security of data is the responsibility of each and every one of us at our organization.
- The premises where the data are held are kept locked and are accessible only to authorized persons.
- Access to IT resources is password-protected. Passwords are changed regularly in accordance with SQP's instructions, and we have implemented an authorization management process.
- We perform regular backups
- All data collected is hosted on secure servers.
- All employees involved in processing personal data are bound by confidentiality agreements.
- Our service providers are all signatories of agreements including security and confidentiality commitments, and/or are in the process of entering such commitments.
SQP emphasizes that the security of your personal data also depends on your compliance with good password-management practices. For more information please consult the recommendations provided by CNIL:https://www.cnil.fr/fr/authentification-par-mot-de-passe-les-mesures-de-securite-elementaires

VII. How long is your data retained?

Data concerning you shall be retained for the entire contractual period and will then be archived for the amount of time required by law. These time requirements vary based on the type of data; if you would like further information on this subject, please contact us.
For example, Customer, User or prospect contact data shall be kept for prospecting purposes for a period of three (3) years; for Customers this period shall be counted from the end of the commercial relationship, and for prospects from the date they last contacted us, unless such Clients or prospects choose to exercise their right of opposition.
Other data shall be kept only for the period of time necessary for the performance of the services, and shall then be archived for the amount of time required by law (5 years for contracts, 10 years for contracts entered electronically, and 10 years from the financial year-end date for accounting documents). Certain data concerning the Datasheets are kept for a limited period of time for archival purposes, and at least for as long as the Films remain accessible.
For more information on data retention periods please contact our Personal Data Coordinator by using the contact details provided at the top of this document.

VIII. Will this data be transferred outside the European Union?

In principle, your data will not be transferred outside the European Union, and will be stored on servers hosted in France.
If we enlist a technical service provider or subcontractor to process data on our behalf, we will ensure that:
- Either the provider or subcontractor will not transfer any data outside the European Union
- Or the transfer will be performed in a country subject to a finding of adequacy
- Or the transfer will be performed only after appropriate guarantees have been put in place, such as:
o Establishment of binding corporate rules
o Establishment of standard data protection clauses
Some videos are hosted by VIMEO (located in the USA), which has committed to compliance with the provisions of the European General Data Protection Regulation. For more information, you may consult their webpage (https://vimeo.com/privacy).

IX. What rights do I have?

You have several rights regarding your data:
• the right to access your personal data,
• the right to rectify or delete your personal data,
• the right to restrict its processing,
• the right to oppose its processing,
• the right to data portability, subject to the terms and limits provided by European Personal Data Regulations,
• The right to withdraw consent at any time, where data processing requires your consent. This withdrawal of consent will be effective for the future only, starting as soon as we are able to confirm the legitimacy of your request.
• The right to establish general and specific guidelines for your intended exercise of these rights after your death,
• The right to file a complaint with the CNIL https://www.cnil.fr/fr/plaintes (Copy and paste this URL into your browser address bar)

No automated decisions (such as profiling) will be made based on your data.

When data is to be collected for the performance of a contract and/or compliance with pre-contractual procedures, provision of this data is mandatory. Any missing information shall preclude the entitlement for which the data is collected.

X. Who should you contact to exercise your rights?

SQP is not subject to the obligation to appoint a Data Protection Officer (DPO), insofar as:
- it is neither a public authority nor a public agency,
- it does not perform processing operations which, by virtue of their nature, their scope and/or their purposes, require regular and systematic monitoring of data subjects on a large scale; and
- its core activities do not consist of processing on a large scale of special categories of sensitive or personal data relating to criminal convictions and offences.
Nevertheless, SQP has chosen to appoint a Personal Data Coordinator, who may be contacted by using the contact details provided at the top of this document.
Please contact the Personal Data Coordinator for further information concerning your rights, your data and/or any other questions you may have regarding your data.

XI. COOKIES

SQP collects information in the form of Cookies. Customers may find more information about their rights and obligations concerning cookies, and about how to manage them, by clicking on the "Cookies" tab.

XII. PRIVACY POLICY UPDATES

This Privacy Policy shall apply as long as it is displayed on the website.
It may be revised at any time, in particular in order to reflect any new legislation and/or regulations that may apply, recommendations issued by the CNIL and the European Data Protection Committee, or relevant rulings issued by courts and tribunals.
In such case, an indication of the date of the most recent update will be provided at the top of the Privacy Policy. Only the revised version shall be considered admissible.