Privacy policy

Welcome to 11 Speak !

This privacy policy (the "Policy") formalizes 11 Speak ‘s commitment to respecting the privacy of its Users and their personal data when using the website http://11speak.app (the "Site"), in accordance with the General Data Protection Regulation 2016/679 of April 27, 2016 ("GDPR") and the amended French Data Protection Act of January 6, 1978.

1. Definitions

“Data”: Refers to any personal information relating to an identified or identifiable natural person. An "identifiable natural person" under the GDPR is one 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 specific factors relating to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“Regulation”: Refers to the General Data Protection Regulation 2016/679 of April 27, 2016 ("GDPR"), which entered into force on May 25, 2018, the French Data Protection Act of January 6, 1978, as amended by Law No. 2018-493 of June 20, 2018, and its implementing decrees, as well as any other texts complementing the existing legal framework (including decisions and opinions of the French Data Protection Authority, CNIL).

“Data Controller”: MAK CONSEIL, as the data controller, collects and processes Users' Data in accordance with applicable regulations, as outlined below.

“Service”: Refers to the specialized football consultancy and translation services offered by MAK CONSEIL on the Site.

“Site”: Refers to the 11 Speak website accessible at the following address: http://11speak.app

“User”: Refers to any individual internet user navigating the Site.

2. Acceptance of 11 Speak’s Privacy Policy

By browsing the Site or contacting 11 Speak, the User authorizes 11 Speak to process their Data in accordance with the Policy. If the User disagrees with the terms of this Policy, they should refrain from browsing the Site. The User warrants and confirms hereby that they have the full legal capacity to consent to the Policy.

3. For what purposes and on what legal basis are User Data collected?

The data requested from the User may be collected for the following purposes and legal bases:

- Based on User Consent :

o To communicate with the User.

o For commercial prospecting purposes regarding products and services offered by 11 Speak.

- For the Performance of a Contract with the User :

o To provide the Service and fulfill contractual obligations in accordance with the terms of use and applicable service conditions.

- Based on 11 Speak ‘s Legitimate Interests :

o For research and statistical purposes.

- To Fulfill Legal or Regulatory Obligations :

o For managing potential disputes.

o For handling security incidents.

o As part of fraud prevention measures.

o To comply with any requests from regulatory, judicial, criminal, or competition authorities.

If User Data are used for purposes other than those described above, 11 Speak will inform the registered User and seek their consent if the intended processing is based on consent.

Users are encouraged to regularly review this Privacy Policy on the Site and check for any updates.

4. In what cases are User Data collected and which Data are concerned?

11 Speak may collect, process, and retain:

- Connection data (including IP address, MAC address of the computer, date and time of connection, and location of the connection).

- Browsing data (including default language of the device, cached site favorites on the phone, and search history via cookies).

- Data voluntarily provided by the User during contact, such as name, surname, postal address, phone number, email address, company name, and job title.

5. How are User Data protected?

11 Speak has implemented reasonable technical, organizational, physical, and logical measures to protect online data against breaches of confidentiality, integrity, or availability, considering the state of knowledge, implementation costs, and the nature, scope, context, and purposes of the processing activities, as well as the risks to the rights and freedoms of individuals. However, the User acknowledges that transmission over the Internet inherently carries security risks. Similarly, the User recognizes that Internet and telecom networks have technical specificities that make it impossible to guarantee uninterrupted access to the Site.

6. In what cases are User Data shared?

6.1. Sharing User Data with Third Parties

Personal data provided by you is kept internally. Data is not shared with third parties.

6.2. Sharing User Data with Competent Authorities

In cases expressly provided by law, 11 Speak may be required to disclose Data to comply with any official request from a regulatory authority, judicial authority, law enforcement agency, or competition authority.

6.3. Absence of Data Transfers outside the European Union

By default, Data is stored in Cyprus at the hosting provider HOSTINGER INTERNATIONAL LTD, 61 Lordou Vironos Street, 6023 Larnaca, Cyprus.

7. How long are User Data kept?

According to applicable regulations, 11 Speak retains User information for as long as necessary for the purposes for which 11 Speak collected them and to comply with legal or regulatory obligations as applicable. Customer data is kept throughout the duration of the business relationship and for 10 years for billing and accounting management. Following the end of the business relationship, aligning with the statute of limitations in civil and commercial matters, 11 Speak may retain User contact details for 5 years. Additionally, personal data related to a non-customer prospect may be retained for a period of three years from collection by 11 Speak or from the last contact initiated by the prospect.

8. How are cookies used?

8.1. What is a cookie?

The CNIL has defined a cookie as 'a small piece of data, typically of small size and identified by a name, which can be transmitted to the browser by a website that the User connects to. The web browser will store it for a certain period and send it back to the web server each time the User reconnects.' Cookies can be used to remember the client's identifier with a website, an identifier allowing tracking of navigation for statistical or advertising purposes, etc. Technical cookies are distinguished from tracking cookies. Technical cookies optimize navigation on the Site as well as its proper functioning. Tracking cookies allow for personalized offers, relationships, or advertisements. They are recommended to enhance the User experience on the Site.

8.2. What are cookies used for on the Site?

Some cookies installed on the User's terminal may be necessary for:

- Adapting the Site to the display preferences of the User's terminal (display resolution, operating system used, language used, etc.).

These cookies are technical cookies intended for the User experience. There are no tracking cookies.

Data collected through cookies is stored for a maximum period of 13 months and then deleted.

If applicable, the Site may also use third-party software (plugins, widgets) to add features (such as official Facebook Like buttons, Facebook comments, Twitter tweets) or include embedded content from third-party sites. These third-party software or content may send requests to third-party APIs through the web browser to retrieve information about you.

11 Speak does not store any data retrieved by third parties on its servers. 11 Speak is in no way responsible for data collected and processed by third-party software or content, including but not limited to Facebook, Twitter, YouTube, Pinterest, Instagram, TikTok, etc.

For more information on the data collected by them and how they use it, Users are encouraged to consult their privacy policies on their dedicated websites.

For more information on cookies, Users can visit the website of the French Data Protection Authority (CNIL): https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs.

9. What rights do Users have over their Data?

Under the conditions and within the limits laid down by the Data Protection Regulations, and after having provided proof of his/her identity (for example by sending a copy of his/her identity card), the User has the following rights with regard to his/her Data:

- Right of access to his/her Data: the User has the right to request access to his/her Data;

- Right to rectify their Data: the User has the right to request that their Data be corrected or updated so that it is always accurate;

- Right of deletion of his Data: the User has the right to request the deletion of his Data, if they are no longer necessary for the purposes for which they were collected or processed by 11 Speak;

- Right to decide on the fate of his/her Data after his/her death: the User has the right to send instructions to 11 Speak concerning the fate of his/her Data after his/her death (deletion of data that would be kept, transmission of data and access to the account to a beneficiary, spouse, etc.);

- Right to request the limitation of processing, right to object to processing, right to withdraw consent: in the event that the processing concerned is based solely on the User's consent, the User may request the limitation of the processing of his/her Data, object to the processing of his/her Data or withdraw consent, in accordance with the assumptions set out in the Regulations in force;

- -Right to Data Portability: Users have the right to request the portability of the Data they have provided to 11 Speak, so that it can be transferred to a third party with their authorisation or transferred directly to them. The data will be communicated in a non-proprietary, readable and reusable open format.

The User may contact 11 Speak in order to exercise his or her rights, by enclosing a copy of an identity document with his or her request:

- by registered post with acknowledgement of receipt to 11 Speak ‘s head office address;

- to the following e-mail address contact@11speak.app with acknowledgement of receipt, indicating "MY PERSONAL DATA" in the subject line.

10. What are the User's obligations with regard to their Data?

It is the responsibility of each User to ensure the truthfulness, completeness, comprehensiveness, and accuracy of the information and Data they communicate to 11 Speak.

In accordance with Article 9 of the Terms of Use, it is also the User's responsibility to maintain the confidentiality of their Data.

11. Can this Policy be modified?

11 Speak reserves the right to modify this Policy at any time. In the event of a modification, 11 Speak will publish the updated version on the Site.

It is the User's responsibility to regularly review this Policy. By continuing to use the Site after any modifications to the Policy, the User signifies acceptance of those changes. If the User does not agree to any substantial modifications made to the Policy, they should cease accessing and using the Site.

11 Speak encourages Users to regularly review the latest updated version, which is publicly available and accessible at all times on every page of the Site by clicking on 'Privacy Policy' in the footer of the Site.

12. How to contact 11 Speak ?

For any questions or to exercise their rights, Users can contact 11 Speak :

• by registered mail with acknowledgment of receipt at the following postal address: 24 B rue des Canadiens, 76260 EU

• by email with read receipt to the following address: contact@11speak.app

13. Right to lodge a complaint with the competent supervisory authority

According to applicable regulations, the User has the right to lodge a complaint with the competent supervisory authority if they do not receive a response from 11 Speak. The list and contact details of the relevant supervisory authorities for each European Union member state are available at the following address: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm