This privacy policy applies to all data processing carried out by MOMA GROUP, its subsidiaries and its endowment fund.
This confidentiality policy covers both online and offline data collection, in particular information collected via the websites of MOMA GROUP and its subsidiaries, the applications of the group and its subsidiaries, reservations made by customers and Users or events, seminars, etc.by customers and Users, or events, seminars and operations organized at the request of customers, users of the websites (hereinafter referred to as "Users") or directly by MOMA GROUP, its subsidiaries or its endowment fund.

This privacy policy is updated on a regular basis and MOMA GROUP recommends that all clients and Users consult it regularly.
MOMA GROUP attaches the greatest importance and care to the protection of personal data (hereinafter referred to as "Personal Data") of its customers and Users.

PERSONAL DATA

WHAT IS PERSONAL DATA?

Personal Data refers to any information or set of information enabling a person to be identified directly (e.g. surname, first name, e-mail address, home address, etc.) or indirectly (e.g. by means of pseudonymized data such as a unique identification number, etc.). Unique identifiers may also be considered Personal Data, such as your computer's IP address.
This therefore includes all information concerning you as an individual that you voluntarily provide to us or that we collect as part of your browsing on our websites, our mobile applications or when booking and/or providing services for you and which, whatever its nature, enables us to identify you directly or not.

DATA CONTROLLER

MOMA GROUP, its subsidiaries and its endowment fund are responsible for processing the Personal Data they collect, unless expressly stated otherwise.
Personal Data processed by partners of MOMA GROUP, its subsidiaries or its endowment fund are the responsibility of these third parties. No Personal Data collected by MOMA GROUP, its subsidiaries or its endowment fund will be transmitted to a third party without prior information and/or your consent, depending on the purpose.

METHODS OF COLLECTING PERSONAL DATA

We collect your Personal Data in several ways:

- directly from you when you use our websites, our online booking services and our partner booking applications, when you apply for our job offers or subscribe to our newsletters, or when you interact with us (by filling in various forms made available to you, by communicating directly with our teams, etc.) ;
- automatically when you access one of our websites, mobile applications or partner reservation applications (technical data, IP address, browsing information, etc.).

CATEGORIES OF PERSONAL DATA COLLECTED

The categories of Personal Data we collect include:
- Identification and contact information: i.e. your last name, first name, e-mail address, information needed to identify you when you interact with us;
- Information relating to job applications: i.e. your surname, first name, e-mail address, telephone number, professional experience and any other information you provide when submitting your application and/or curriculum vitae: photo, skills, level of education, languages spoken, salary expectations, home address, hobbies, family situation, etc. We collect and store this Personal Data solely for the purpose of managing our own job offers and do not use it for any other purpose, in particular for commercial purposes;
- Payment (to be verified / prepayment by credit card): As part of the payment of services offered by our mobile applications, these record financial data relating to the user's bank account or credit card ;
- Technical data: We collect information relating to the device you use to connect to our websites and mobile applications, and to your use of them (such as the version of the operating system, the type of browser used, the number of visitors, etc.).operating system version, type of browser used, whether or not a proxy is used, IP address, access times, pages visited and the link that enabled you to access our websites).

LEGAL BASIS FOR THE COLLECTION OF PERSONAL DATA

In accordance with applicable European and French regulations on the protection of Personal Data, your Personal Data is collected either :
- on the basis of your consent ;
- in our legitimate interest;
- in order to fulfill our legal obligations.

PURPOSES OF PERSONAL DATA COLLECTION

We collect your Personal Data on the basis of your consent for the following purposes:
- Managing your requests and questions: We use your Personal Data to send you the information you request;
- To send you newsletters to which you have subscribed;
- Manage job applications you send us;
- Manage the table/seat/event reservations you ask us to make and send you confirmations/non-confirmations;
- Send you commercial information about our establishments and events, or about the activities of our endowment fund. We collect Personal Data on the basis of our legitimate interest for the following purposes:
- To defend our interests in the event of litigation or legal action;
- To manage the cybersecurity of our websites;
- Preventing fraudulent acts in order to ensure the security of our assets and content. We may also retain your Personal Data where we are required to do so by law or in order to enforce our legal rights.

ACCESS TO YOUR PERSONAL DATA

Your Personal Data is processed for the purposes set out above and is only accessible to members of the staff of MOMA GROUP, its subsidiaries and its endowment fund who need to know it in the course of their duties.
Your Personal Data may also be made accessible to third parties, namely :
- Our subcontractors and service providers involved for technical and logistical reasons.
These may include hosting, security and maintenance service providers for our websites and mobile applications, fraud management service providers, technical service providers in charge ofthese may include hosting, security and maintenance service providers for our websites and mobile applications, fraud management service providers, technical service providers in charge of sending emails and newsletters, anti-spam and anti-robot service providers, recruitment agencies that can advise us on the management of our candidate databases and help us select profiles from these databases, and so on.), or third-party banking and financial companies for your credit card payments.
These service providers have limited access to user data for the purposes of providing these services, and are contractually obliged to use it in compliance with the provisions of the applicable regulations on the protection of personal data.
We impose the same security and confidentiality conditions on our service providers and subcontractors who have access to your Personal Data as we do ourselves.
- Our partners in the context of specific events, and in particular those of our endowment fund.
- Any authority, court or other third party where such disclosure is required by law, regulation or court order, or where such disclosure is necessary to protect and defend our rights.

TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN UNION

The Personal Data we collect is hosted by a service provider whose servers and back-ups are located within the European Union.
However, MOMA GROUP, its subsidiaries and its endowment fund may call on the services of certain service providers located abroad or who themselves call on the services of subcontractors located abroad, including outside the European Union in countries whose regulations on the protection of personal data differ from those applicable within the EU.
Any transfer of Personal Data outside the European Union is subject to appropriate safeguards that comply with applicable data protection regulations (EU standard contractual clauses, BCR, etc.).
Because of the international organization of MOMA GROUP, each customer or User is informed of these possible transfers and authorizes MOMA GROUP, its subsidiaries and its endowment fund to transfer, store and process their Personal Data outside the European Union and in particular in the United States. The laws in force in this country may differ from the laws applicable in the user's place of residence within the European Union.

PERSONAL DATA OF MINORS

MOMA GROUP, its subsidiaries and its endowment fund collect Personal Data from adults only. This is why we may ask you for your age or date of birth.
Please contact us if you believe that we are processing data from minors, so that we can delete it if necessary.
We may collect personal data from minors insofar as they have been communicated by a legal representative of such minors, either to manage their business or to ensure their privacy.gal of these minors, either to manage bookings, or to provide specific services to these minors or to respond to a particular request from you. By providing us with personal data about a minor, you warrant that you are an adult, parent or legal representative of the minor.

SECURITY AND CONFIDENTIALITY

MOMA GROUP, its subsidiaries and its endowment fund implement organizational, technical, software and physical security measures to protect the Personal Data collected against alteration, destruction and unauthorized access. These measures ensure the security and confidentiality of your Personal Data.

MOMA GROUP, its subsidiaries and its endowment fund also require their service providers, subcontractors and partners to provide guarantees and implement security measures that are sufficient to ensure the protection of Personal Data. to ensure the protection of the Personal Data they have undertaken to process, in accordance with the requirements of the applicable regulations on the protection of personal data.
However, each customer and User acknowledges that the Internet is not a completely secure environment and our websites cannot guarantee the security of the transmission or storage of information over the Internet
transmission or storage of information over the Internet.

LINKS TO THIRD-PARTY SITES

Our websites may provide links or functionality to other third-party websites, which we do not own or control. If you click on one of these links or use these functionalities, you do so at your own risk
features, you do so at your own risk.
We are not responsible for the content or practices of any third-party site, application or feature. This privacy policy does not apply to such third-party sites.
We therefore invite you to consult the privacy and data protection policies of these third-party sites.

STORAGE OF PERSONAL DATA

We store your Personal Data for a period of time that is proportionate and consistent with the stated purpose of processing, in order to comply with European and French legal and regulatory requirements and within the limits imposed by them.
- For commercial and marketing communications, your data is kept for a maximum of three years from the end of our commercial relationship if you are a
customer of MOMA GROUP or one of its subsidiaries, or three years from your last contact if you are not a customer but simply a user of our websites or subscriber to our newsletters.
- The Personal Data you send us to apply for our offers are kept for a period of two (2) years from the date of communication of your Personal Data or from the last contact with you. At the end of this period of two (2) years, we may contact you to find out whether you wish us to keep your Personal Data in order to
to inform you at a later date of any new opportunities that may correspond to your professional aspirations and skills.
- Personal Data collected in response to a specific request from you will be retained for as long as is necessary to manage your requests and queries. Your Personal Data will then be destroyed or anonymized, unless we are required to retain it to meet our legal obligations for the applicable prescription period.
- Video recordings made on our premises are kept for a period of one month, unless extended due to investigations linked, in particular, to suspected fraud.
- Your credit card details are deleted from our operational databases once the transaction has been completed.however, it may be kept in an archive for a period of 13 months after it has been collected, in case the transaction is contested.
- With the exception of technical cookies, the recording of cookies on your terminal (computer, tablet, cell phone) is kept for a period of 13 months.

EXERCISING YOUR RIGHTS

In accordance with applicable regulations, you have the following rights:
- the right to access the Personal Data we hold about you;
- the right to ask us to update or correct any out-of-date or incorrect Personal Data concerning you;
- the right to object to receiving commercial communications;
- the right to erasure of your Personal Data where the conditions of Article 17 of the RGPD are met;
- the right to limitation of the processing of your Personal Data when the conditions of Article 18 of the RGPD are met;
- The right to portability of your Personal Data insofar as the conditions of Article 20 of the RGPD are met ;
- The right to define directives concerning the fate of Personal Data after your death ;
- The right to object to the processing of your Personal Data, insofar as the conditions of Article 21 GDPR are met; and
- the right to lodge a complaint with a regulatory authority, namely in France the CNIL (https://www.cnil.fr/fr/plaintes);
Where the processing of your Personal Data is based on your consent, you may withdraw it at any time, without justification. This right can be exercised by modifying your newsletter subscription options by clicking on the link provided for this purpose on our websites.
In order to respond to your requests, we may ask you to provide proof of identity. We may also ask you to provide additional information or proof of identity.
Please also note that notwithstanding the exercise of your right to erasure of your Personal Data or limitation of processing, we will retain some of your Personal Data where required to do so by law or in order to exercise or defend our rights.

HOW TO EXERCISE YOUR DATA PROTECTION RIGHTS

You may exercise your rights regarding the protection of your Personal Data in the following ways:
By post to the following address Délégué à la Protection des Données Personnelles, 12 rue de Presbourg 75116 Paris - France
By e-mail to the following address: dpo@moma-group.com

COOKIE MANAGEMENT POLICY

WHAT IS A COOKIE?

Your Internet browser has a function called "cookies". A cookie is the equivalent of a small text file stored on your terminal. For the duration of the cookie's validity, it is used to store status information when a browser accesses different pages on a website, or when the browser returns to the website at a later date.

WHICH COOKIES DO WE USE?

The cookies we issue on our websites and social networks are used for the purposes described below, subject to the choices you make during your visits, which you can modify at any time.
Technical cookies
These cookies are necessary for navigation. Without them, our site would not function properly.
These cookies enable us, for example, to adapt the presentation of the sites to your terminal's display preferences (language used, display resolution), and to memorize passwords and other information relating to a form you have filled in on the sites.
Statistical cookies
These cookies make it possible to compile statistics and volumes of visits to and use of the various elements making up our sites (sections and content visited, route taken, time spent on site), enabling us to improve the interest and ergonomics of our services.
Social network cookies
These cookies enable us to share our content with other people on social networks such as Facebook, Twitter, LinkedIn, etc. Even if you have not used these sharing buttons or applications, it is possible that the social networks track your browsing if your account or session is activated on your terminal at that time. If you do not want the social network to link the information collected via our sites to your user account, you must first log out of the social network.
Advertising cookies
These are cookies used to display advertising or send you information tailored to your interests on or off our sites while you are browsing the Internet. In particular, they are used to limit the number of times you see an ad and to help measure the effectiveness of an advertising campaign. These cookies depend mainly on advertising agencies.

PURPOSES OF COOKIE USE

When you visit our sites and social networks, we may, depending on your choices as expressed by the
your browser settings, we may or may not install cookies on the hard disk of your computer,
tablet or telephone.
We may read the cookies we have installed during the validity period of each cookie
or until you delete the cookie.
We use cookies for the following purposes on our websites:
- To facilitate your browsing and enable correct display of our web pages (session cookies);
- To remember your preferences, display settings or language choices;
- Identify whether you are coming from another MOMA GROUP site or from a partner site;
- Analyze the performance of our site based on anonymous information about your browsing (e.g. page views, number of visits....). To do this, we use the "
Google Analytics" analysis tool.
The cookies we use do not allow us to identify you personally and are designed to be used solely by MOMA GROUP.

MANAGEMENT OF CONSENT TO THE COLLECTION OF COOKIES

Article 5(3) of Directive 2002/58/EC, amended in 2009 and transposed into French law by Article 82 of the French Data Protection Act, lays down the principle of :
- prior consent must be obtained from the user before information can be stored on his or her terminal, or before information already stored on the terminal can be accessed;
- unless these actions are strictly necessary for the provision of an on-line communication service expressly requested by the user, or are exclusively intended to enable or facilitate communication by electronic means.
We respect these provisions. This is why, when you first visit our websites and social networks, you are asked to give your prior consent to the collection of data we propose to carry out for our cookies.for our cookies related to personalized advertising operations or our social network cookies, in particular those generated by their sharing buttons.
You can then choose to deactivate these cookies at any time.
On the other hand, you will note that we do not require your prior consent for the collection of the following cookies:
- cookies that keep track of the user's choice to deposit cookies;
- cookies intended for authentication to a service, including those designed to ensure
the security of the authentication mechanism, for example by limiting robotic or unexpected access attempts;
- tracers for personalizing the user interface (for example, for choosing the language or presentation of a service), when such personalization constitutes an intrinsic and expected element of the service;
- tracers for balancing the load of equipment involved in a communication service.

Commented [NTV1]: To be discussed: the CNIL prohibits it unless adequate proxyfication measures are used

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