Date of first edition: February 21, 2021
Minassian strives to protect your Personal Data and therefore committed to ensure the best level of security and privacy, in compliance with French and European regulation (Regulation (EU) 2016/679 and law n°78-17 voted on 6 Jan 1978 and subsequently amended several times).
The Personal Data Processing policy of the G. Minassian is based on the following principles:
- Lawfulness of Processing: Personal Data collection and Processing are legitimate and based on a legal basis identified in accordance with the objective (or purpose) and the context in which it is processed.
- Purpose of Processing: Minassian does not use your Personal Data for any other purpose. We collect your Personal Data strictly for the defined purposes.
- Period for keeping Personal Data: Minassian establishes a limited period for keeping your Personal Data, in accordance with the purposes and lawfulness of Processing.
- Security and privacy: Minassian strives to protect and secure your Personal Data. We take all reasonable measures needed to ensure a level of security appropriate to the risk between the Controller and the processor. In assessing the appropriate level of security, we take into account the risks of each type of Processing (sensitive data, purpose of Processing).
- Transparency: when Minassian collects your Personal Data, we will tell you how we intend to use it and if we need to share it with other parties.
- Right of access: You shall have the right to obtain from Minassian the confirmation of your Personal Data. You can request the modification, the erasure, and the portability of your Personal Data. You can also object to this Processing for a legitimate reason.
The purpose of this document is to inform you of the terms and conditions governing the collection, Processing and use of your Personal Data, and of the rights you have in connection with the use of the website and online platform of G. Minassian.
Data or Personal Data: means any information relating to a Concerned Person.
Concerned Person: refers to an identified or identifiable physical person; is deemed to be an “identifiable physical person”, i.e. a physical person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, psychological, economic, cultural or social identity of that physical person.
Controller: means the physical person or legal entity, the public authority, the service or whatever other body that, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
Processing or Process: means any operation or set of operations performed using processes that may or may not be automated, applied to Personal Data or sets of Personal Data, such as the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, or disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
User: means any physical person who accesses a Site, even without logging in.
Personal Data protection
Identity and contact details of the Controller
Personal Data is collected and processed by:
Your Data is collected directly by G. Minassian when you enter your Data in the contact forms, questionnaires and other means provided to you as part of use of the Site’s services.
Your Data may also be collected indirectly during your browsing on the Site (for example, via cookies) or directly when you share them with G. Minassian. Your Data may be transferred to service providers.
Within the scope of collection, the following Data is processed:
- Identity data (last name, first name, address, telephone number, email address, etc.)
- Data pertaining to personal life and living conditions, having a connection with the artistic activities of G. Minassian (civil status, Artists and type of works looked after, etc.)
- Data pertaining to professional and non-professional life, having a connection with the commercial relationship (occupation and professional field, desires/preferences in the field of Art and Aestheticism, etc.)
- Location and connection data
Purposes and legal basis of Data Processing
Minassian processes your Personal Data for the following legal purposes and on the following legal bases:
|Purpose (objective sought)||Legal bases (basis or reason for the Processing)|
|Management of access, security, maintainability, evolutions and audiences of Sites and platforms accessible online (Google Analytics)||G. Minassian’s legitimate interest in ensuring the availability and proper functioning of its Sites, as well as the promotion of its businesses through its Sites|
Mandatory/optional nature of the collection
Minassian informs you when the provision of an information item is mandatory (including when due to a legal, regulatory or contractual obligation, or simply in order to process your request or respond to you). If you do not provide this so-called “mandatory” information, G. Minassian may be unable to respond to the request or form in question.
Fields on a form that are not specified as mandatory are left to your discretion. It is up to you to choose to whether to fill them in or not.
Data recipients/Data transfer
Your Data is primarily intended for G. Minassian but may also be transferred to external partners.
As part of the Processing, G. Minassian may also transfer your Data to service providers, agents and suppliers to complete internal operations of the Site, or for any operation related to the activities of G. Minassian, for the purposes specified in this document. These service providers, agents and suppliers are required to maintain the confidentiality and security of your Data, and to implement the appropriate measures.
Minassian may also transfer your Data if such disclosure is required by law, a regulatory provision or a court order, or if such disclosure is reasonably necessary to comply with court proceedings and respond to any complaints or protect the security of your Data or your or G. Minassian’s rights.
Data stored period
Depending on the purpose of the Processing, your Data is stored for the periods of time stated below:
|Management of access, security, maintainability, evolutions and audiences of Sites and platforms accessible online||Username, including IP address, browser, load time, date of visit, pages visited, etc||1 year|
(See also below under “Cookies and other means of tracking”)
|The saving of cookies on your device||13 months as from the saving|
Your rights as Concerned Person
In accordance with the applicable Data Protection Regulations and under the terms of these Regulations herein, you have the following rights:
|Rights||Cases in which these rights apply||Conditions|
|Right of access||– Applies to all Processing
With the exception of Processing pertaining to the prevention of money laundering and the financing of terrorism, in compliance with Article L 561-45 of French monetary and financial legislation [Code monétaire et financier], for which the right of access is exercised with the CNIL via an indirect right of access procedure (except for the case of Processing used to identify persons subject to an asset freeze measure or a financial sanction)
|By proving your identity and stating the subject of your request to the addressee below (see contact information)|
|Right to rectification||In case of inaccurate, outdated or incomplete Data||By proving your identity and stating the subject of your request to the addressee below (see contact information)|
|Right to erasure||In the following cases:
– Data is no longer necessary for the purpose for which it was collected
– In application of your right of withdrawal of consent
– In application of the right to object, as provided below
– The Data Processing is illegal
Data must be erased to comply with a legal obligation
|By proving your identity and stating the subject of your request to the addressee below (see contact information)|
|Right of withdrawal of consent||At any time, when the Processing is based on consent from the Concerned Person|
|Right to restriction of Processing||In the following cases:
– You dispute the accuracy of the data
– The Processing is illegal, and you want to limit it
– G. Minassian no longer needs the Data for the purposes
You opposed the Processing but G. Minassian checks to see whether there are not legitimate and compelling reasons for proceeding with this Processing
|By email or postal mail to the addressee below (see contact information) stating the subject of your request and the reasons for your limitation request, and proving your identity|
|Right to specify guidelines concerning the fate of one’s Data after one’s death||To all Data Processing (except those for which legal provisions preclude such guidelines)|
|Contact information for the exercising of rights||Garo Minassian
Post address: 25 rue du Général Delestraint – 75016 Paris
You also have the possibility of filing a complaint with the CNIL:
- Directly online at the following address: https://www.cnil.fr/fr/plaintes
- By postal mail: 3 Place Fontenoy, TSA 80715, 75334 Paris Cedex 7
Data security and privacy
Within the scope of its business, and in compliance with the applicable Data Protection Regulations, G. Minassian undertakes to take all appropriate technical and organizational measures to ensure the security, availability, integrity, authenticity and confidentiality of your Personal Data and the resilience of its information systems.
Cookies and other means of tracking
The Site may automatically collect information by means of cookies or means of tracking saved on your device during your consultation of the Site.
What is a cookie?
Cookies (or means of tracking) are small text files that can be saved on your device through its browser (computer, tablet, smartphone, etc.) during your time visiting the Site, and that fulfil various functions, notably including allowing the party that places the cookie to identify your device.
What cookies are used on the Site, and how can you manage these cookies?
Minassian informs you that the following cookies may be deposited and used, subject to your settings/acceptance:
- Technical cookies: these cookies are essential for navigation on the Site, and enable its various functionalities to be used
- “Analytical” Cookies: These cookies make it possible to know how the Site is used, and to establish its performances and improve its operation. Such is the case of audience measurement cookies, but only using your session data (date, time, IP address, transmission protocol, and page viewed). This information is not cross-checked with other Processing Operations such as customer or Insured Party files
- Persistent cookies for distribution of sessions over the various servers of G. Minassian
- Targeting and advertising cookies: These cookies allow you to adapt advertising content and other content according to your interests established on other websites
With the exception of so-called “technical” cookies, which you cannot disable, these cookies can be disabled at any time, either individually or in completely.
The method of configuration of each browser is different. How to change your cookie settings will be explained in your browser’s help menu.
What happens when cookies are rejected?
How long are cookies stored on your device?
In compliance with CNIL recommendations, cookies are stored for a maximum period of 13 months.