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Privacy Policy


This confidentiality policy defines and informs you of the manner in which Responsabilitas uses and protects the information that you may send to us while using this Website which can be accessed via the following URL:

Please note that this privacy policy may be modified or added to at any time by Responsabilitas, in particular in order to comply with any legal or technological developments. In such a case, the date of the update will be clearly identified at the top of this policy. These amendments bind users as soon as they are published online. Therefore, users should regularly consult this privacy policy to be aware of any changes.

Article 1 : Parties

This privacy policy applies between Responsabilitas, hereinafter « the publisher », and any person connecting to the Website, hereinafter « the User ».

Article 2 : Definitions

Website content : elements of any type that are published on the Website, whether protected by intellectual property rights or not, such as texts, images, designs, presentations, videos, diagrams, structures, databases or software.

User : any person connecting to the Website.

Website : the internet website accessible at the URL, as well as any sub-sites, mirror sites, portals and related URL variations.

Personal data : any information relating to a person identified or identifiable directly or indirectly (hereinafter « data » or « personal data »).

Personal data processing : any operation relating to personal data, such as collection, recording, extraction, modification, etc. (hereinafter « processing » or « personal data processing »).

Data subjects : any individual whose personal data is processed (hereinafter « you », « your » or « data subjects »).

Data controller : individual or legal entity who defines the purpose and means of data processing.

Data Protection Officer : person appointed by the data controller to ensure compliance with regulations, act as the contact point for questions relating to the rights of data subjects and cooperate with the French Data Protection Authority (CNIL).

Cookies : data files (cookies) deposited and read, in particular, when consulting a website, reading an e-mail or using an application or software, regardless of the terminal used.

Article 3 : Scope of application

This privacy policy applies to all Users. By connecting to and/or browsing the Website, you are deemed to have fully and unreservedly agreed to this privacy policy. Furthermore, by clicking on « Accept all » in the information banner relating to cookies displayed on the Website, you confirm your agreement. Similarly, you confirm you have read and fully understood this policy and accept it without restriction.

Article 4 : Personal data

In general, you can visit the Website without deliberately communicating any of your personal information. Under no circumstances will you be bound to voluntarily provide that information to the « publisher ».

However, if you refuse, you may not be able to access the information or services you have requested. The publisher may in some cases ask you to provide your full name, e-mail address, telephone number, company and job title. By providing this information, you expressly agree that it can be processed by Responsabilitas, for the purpose stated in the document and the purposes listed at the bottom of each form.

In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on 14 April 2016 and current French legislation, the “publisher” hereby provides you with the following information :

Identity of data controller

The controller for the data processed on the Website is Responsabilitas.

Identity of data protection officer

The Data Protection Officer is Responsabilitas.

Head office : Room A 20/F Thomson Commercial Building 8 Thomson Road, WanChai Hong Kong
Phone : (+86)1852 1737 709
Mail :

Data collection by the « publisher »

Data collected while browsing

While browsing the Website, you agree that the “publisher” can collect information relating to: your use of the Website; the content you view and click on; your demographic data; the device and software environment you use; tracers, web beacons, web storage, and unique advertising identifiers; connection data (times, pages viewed, IP address, etc.); and/or the website pages visited before or after using the Website.

Data collected when using a contact form or sending an email

When Users submit a contact form, this implies that the Publisher will collect your following personal data: full name, email address, and information deliberately provided by you for your request to be processed.

Users who do not want to provide the information required when using the contact form cannot send a message to the ” publisher ” directly through the Website.

Purpose of personal data processing

Processing of personal data is based on the data controller’s legitimate interest in facilitating exchanges and communication with the general public.

Data collected while browsing is automatically processed for the purpose of :

  • Ensuring proper operation and improvement of the Website;
  • Ensuring and improving Site security;
  • Contextualizing and enhancing user experience;
  • Initiating legal proceedings;
  • Ensuring compliance with the Website’s terms and use;

Data collected when using the contact form or sending an e-mail is subject to automated processing for the purpose of :

  • Checking user’s identity;
  • Sending information and contacting Users, including by e-mail, telephone and push notifications;
  • Performing contractual commitments;
  • Initiating legal proceedings;
  • Ensuring compliance with the Website’s terms and use;

Data Recipient

The data collected are only viewable by the « editor » and are never made viewable by a third party.

Data retention period

Data collected is stored for a limited period of time, necessary to achieve the aforementioned purposes. Generally this is the time required to process your request.

Connection data is stored for a maximum of 12 months, in order to improve the Website and maintain an appropriate level of security.

Personal data collected when using the contact form is stored during the contractual relationship and up to 12 months after the completion of the assignment for the benefit of the User.

Personal data security

he data controller commits to guaranteeing the confidentiality and security of personal data processed. It also ensures that subcontractors are committed to implementing technical and organizational measures to guarantee an appropriate level of security.

Article 5 : Your rights

According to the regulations, you have the right to access your personal data. You can exercise these rights by writing to us at our postal address Room A 20/F Thomson Commercial Building 8 Thomson Road, WanChai Hong Kong, China, or by completing our online contact form.

Data information, access and communication rights

You have the right to access your personal data.

In view of the obligation of security and confidentiality in the processing of personal data incumbent on the “publisher”, your request will only be processed if you provide proof of your identity, in particular by producing a signed photocopy of your valid identity document ( in case of a written request), both with the endorsement “I hereby certify that the copy of this identity document is a true copy of the original. Signed at(town/city), on (full date)”, followed by your signature.

To help you submit your request, you can find a model letter created by the CNIL (the French National Commission for Information Technology and Civil Liberties) here.

Right to correct and delete data and the right to be forgotten

You have the right to request that your personal data, which may be inaccurate, incorrect, incomplete or obsolete, be rectified, updated, blocked or deleted.

You also have the right to stipulate directives relating to the retention, deletion and communication of your personal data after your death.

To help you submit your request, you can find a model letter created by the CNIL (the French National Commission for Information Technology and Civil Liberties) here.

Right to oppose data processing

You have the right to oppose the processing of your personal data.

To help you submit your request, you can find a model letter created by the CNIL (the French National Commission for Information Technology and Civil Liberties) here.

Data portability rights

You have the right to receive the personal data you have provide to us in a transferable, open and readable format.

Right to restrict processing

You have the right to request that the processing of your personal data by the « publisher » be restricted. This means that your data cannot be retained and can no longer be used by the « publisher ».

Response time

« Publisher » will reply to your request to access, correct or dispute your personal data or any other request for additional information within a reasonable period of time, which will not exceed (1) month from the date your request is received.

Article 6 : Data transfer outside the European Union

Some processing operations may be subject to transfers of personal data to countries whose level of protection is not recognized as equivalent by the European Commission. In the absence of an adequacy decision, this transfer is subject to appropriate guarantees or guarantees approved by the European Commission.

Article 7 : Cookies

The first time you access the publisher’s website, a notification banner will appear at the top or bottom of your screen notifying you that information relating to your browsing may be stored in files known as “cookies”. Our policy on cookies allows you to better understand the measures that we implement in terms of browsing on our Website. It provides information about all the cookies on our website, their purpose and how to configure them.

Functionality of cookies used on the Website

When browsing the Website, tracking tools may generate and deposit one or more cookies on your terminal. In particular, they can facilitate your browsing (e.g. by saving your user ID), compile statistics and measure the audience in order to improve the Website, and enable targeted advertising.

Functional cookies are strictly necessary for the provision of the service expressly requested by the User and for browsing (e.g. adapting the display to your terminal, choosing the language, accessing a personal area, etc). For this reason, consent is not required.

Analytical cookies generate statistics on usage, general traffic and Website performance with a view to improving the Website.

Cookies used and/or deposited by our website

As part of the processing of external communications, we use various cookies. This list is available in a specific « cookie management » section at the bottom of each website page. For more information, we encourage you to consult the data management policy implemented by each publisher of tracking tools (cookies).

Retention period for cookies

Tracers are intended to be stored on the User’s terminal for a period of up to (13) months. These data are stored in secure conditions, according to current technical means, in accordance with the provisions of the General Data Protection Regulation and current French legislation.

Setting cookies

You can either approve, reject or specify your cookie preferences directly via the cookies information and consent form which appears on your first browsing of the Website.

This can also be accessed via a specific “cookie management” section available at the bottom of each page of the website. This will allow you to change your choices at any time.

Refusing to deposit social cookies will prevent any interaction with social networks. Refusing to deposit targeting (advertising) cookies will also prevent you from viewing certain multimedia content.

Browser settings

You can configure your browser software in such a way that cookies are stored on your terminal or, conversely, that they are rejected, either systematically or depending on the sender. You can also configure your browser so that you are offered the option of accepting or rejecting cookies before a cookie is stored on your terminal.

Each browser has different settings to manage cookies and your choices. You can find out how to modify your cookie preferences in your browser’s help menu :