Privacy Policy

The terms “you”, “your” and “your” will refer to the user who browses the site of Carat Diffusion.

The terms “Carat Diffusion”, “we”, “us” and “our” refer to Carat Diffusion.

Carat Diffusion is committed to maintaining the confidentiality of data and protecting the data entrusted to it. Due to its fundamental obligations, Carat Diffusion is committed to implementing an adequate level of protection of personal data collected online from users.

In general, we seek to collect only personal data voluntarily provided by users of our sites, to provide them with information and / or services, or to provide them with information on job offers within entities of Carat Diffusion.

We kindly ask you to review this Privacy Statement online to learn more about how we collect, use, share and protect personal information obtained from you.

Collection and use of personal data

1 What information do we collect?

We obtain personal data about you when you decide to communicate it to us, for example when you contact us by mail or you register on our sites to benefit from certain services. In some cases, it is also possible that you have previously provided personal data about you to Carat Diffusion (for example, if you are a former employee).

When you decide to sign up or log in to Carat Diffusion sites through a third-party sign-in service that authenticates your identity and connects your social network credentials (such as LinkedIn, Google, or Twitter) to the site. In Carat Diffusion, we collect from the provider of the social network the data and contents necessary for the registration or connection that you have authorized, such as your name and email address. The other data we collect depends on the privacy settings that you set up with your social network provider, so we encourage you to review the privacy policy for that service.

By registering and / or providing personal data to Carat Diffusion, you also agree to the use of such personal data in accordance with this Online Privacy Statement. We do not use your personal data for any other purpose unless we obtain your consent for it, or if the law or professional standards permit or require it. For example, if you register with Carat Diffusion and provide data about your preferences, we will use them to personalize your experience.

If you sign up or sign in with a third-party SSO service, we will also be able to identify you as a single user on all devices you use, to personalize your usage experience on all others. Carat Diffusion sites you are visiting. If you have sent us your resume (CV) to apply online for a job offer within Carat Diffusion, we will use the personal data you have provided to study your application and / or offer you offers Carat Diffusion job in your profile

In some cases, when you sign up for certain services, we may temporarily keep your email address until we receive confirmation of the information you have provided to us by email (ie , when we send an email to the address provided during your registration to confirm your subscription).

2 The legal basis applicable to the processing of your personal data

In general, Carat Diffusion collects only the personal data that is necessary to answer your requests. When we request additional optional data, you are informed when it is collected. The law in Europe allows us to process personal data, provided we have a legal basis for doing so. We are also required to tell you the nature of it.

Therefore, when we process your personal data, we will rely on one of the following legal bases:

  • Execution of a contract: when the processing of your personal information is necessary to fulfill our obligations under a contract to which you are a party.
  • Obligation imposed by law: when we are required to process your personal data to comply with a legal obligation, including archiving in order to comply with our tax obligations, or communication of information to a public body or to an enforcement authority.
  • Legitimate Interests: We will treat your personal data if it is in our legitimate interest to do so, in order to best manage the business of our business in accordance with the law, and to the extent that this interest does not exceed your own interests.
  • Your consent: In some cases, we will ask you for specific permission to process some of your personal information, and we will only process it for the purposes for which you consented. You may withdraw your consent at any time by contacting the Data Protection Officer at Carat Diffusion (plans@carat-diffusion.com).

Examples of “legitimate interests” referred to above:

  • Provide information and / or services to visitors to our sites or provide information on employment opportunities;
  • Prevent fraud or criminal activity and safeguard our computer systems (IT);
  • Customize your online user experience and improve the performance, usability and efficiency of Carat Diffusion online presence;
  • Realize and measure the effectiveness of our marketing activities;
  • Comply with our corporate social responsibility obligations.
  • Exercising our fundamental rights within the European Union, in accordance with Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom of enterprise and our right to property.

In some cases, and to the extent that this is expressly provided for or permitted by law, the personal data we collect may include special categories of data, such as information related to diversity (including information about race, ethnic origin, religious beliefs and other similar signs of belonging, trade union membership and data concerning a person’s sexual life or sexual orientation), health data or data relating to offenses.

3 Automatic collection of personal data

In some cases, Carat Diffusion and its providers use cookies, web beacons and other technologies to automatically collect certain types of data when you visit our sites online, and as part of emails we are likely to exchange. Collecting this data allows us to personalize your online experience, improve the performance, usability and efficiency of Carat Diffusion online presence, and measure the effectiveness of our marketing activities.

3.1 IP addresses

An IP address is an address assigned to your computer each time you access the Internet. This allows computers and servers to recognize each other and communicate with each other. The original IP addresses of our visitors are likely to be collected for security and diagnostic purposes of computer systems. We can also use this aggregated data to analyze the trends and performance of our sites.

3.2 Cookies

We may store cookies on your computer or connected device when you visit our sites online. This allows the site to remember your computer or device, and thus allow cookies to fulfill several purposes.

Some of our sites display an information banner that requires your consent to collect cookies. In case of refusal, we will not be able to follow your connected computer or device for marketing purposes.

However, a second type of cookies, “user input” cookies, is still necessary to perform certain functions. The information banner does not block them. Your decision is saved in a cookie kept for 90 days.

You can revoke your choice at any time by deleting your browser’s cookies. If most browsers automatically accept cookies, you can decide to accept them or not by setting your browser (most often, in the Tools menu or Browser Preferences). You can also delete cookies from your devices at any time.

However, you must understand that if you refuse cookies, you will not be able to fully benefit from certain features of our sites. You will find more information on the management of cookies in the help tab of your browser and on some sites like www.allaboutcookies.org.

You will find below a list of the types of cookies used on our sites:

Purpose of the Cookie Description Type and Expiration
Performance (i.e. user’s browser) Our sites are developed from common Internet platforms. Built-in cookies help to solve compatibility problems (eg, by identifying browser type) and improve performance (eg, to load content faster). Session

Deleted at the close of the browser

Security cookies (e.g. Asp.NET) If you register to access a restricted area, our cookies will keep your device connected during your visit. To access restricted spaces, you will need a username and password. Session

Deleted at the close of the browser

Preferences Our cookies also allow you to remember your preferences for the site (eg, language) or to improve your user experience (eg by personalizing a greeting or content). This applies to the areas for which you have specifically subscribed or for which you have created an account. Session

Deleted at the close of the browser

Analyzes We use several third-party analytics tools to better understand how our visitors use our site. This allows us to improve the quality and content of Carat Diffusion for our visitors. Aggregated statistical data covers such things as the total number of visits or pageviews, and referencing to our sites. Persistent, but automatically deleted after two years if you no longer visit Carat Diffusion.
Feedback from site visitors We use a third-party survey tool to invite a number of visitors to share their comments. We use cookies to avoid soliciting several times the same visitor.

The first cookie (A) is saved if the visitor is not invited to participate in the survey, to ensure that visitors are not invited after their first consultation of a page.

The second cookie (B) is recorded if the visitor is invited to participate in the survey, to ensure that the visitor is not requested more than once for a period of 90 days.

A Session

Deleted at the close of the browser

B Persistent

Deleted automatically after 90 days or upon presentation of an invitation to participate in the survey.

Sharing on social networks We use social network widgets or buttons to provide you with additional features to share the content of our web pages on sites, social networks and e-mail. When using these widgets and buttons, cookies may be saved on your device to facilitate the use of the service, ensure the display of your interactions on our web pages (eg update of the counting cache of social networks) and record information about your activities on the Internet and on our sites. We invite you to inquire about each provider’s data protection policy before using these services. For more information on our use of widgets and social networking applications, see § 1.4 below. Persistent, but automatically deleted after 13 months if you no longer visit Carat Diffusion.



3.3 Google Analytics

GS Consulting uses Google Analytics. You can find more information about how Carat Diffusion uses Google Analytics at http://www.google.com/analytics/learn/privacy.html.

To give site visitors more choice as to how their data is collected by Google Analytics, Google has developed a browser add-on for disabling Google Analytics. This add-on communicates with Google Analytics JavaScript (ga.js) to indicate that it should not send data for this site to Google Analytics. The browser add-on for the deactivation of Google Analytics does not prevent the sending of data to the site itself or to other web analytics services.

3.4 Web Beacons

A web beacon is a small image file of a web page that can be used to collect certain data from your computer, such as the IP address, the time of consultation of the contents, the type of the browser and the existence of previously saved cookies by the same server. Carat Diffusion uses only web beacons in accordance with applicable law.

Carat Diffusion or its service providers may use web beacons to monitor the effectiveness of third-party sites providing them with recruitment or marketing services, or to collect aggregated visitor statistics and manage cookies.

You have the possibility to make some tags unusable by refusing cookies. The web beacon will still record an anonymous visit to your IP address, but no data cookie will be saved.


For some newsletters and other communications, we may be able to control the actions of recipients, such as the opening rate of emails, through links embedded in messages. We collect this data to assess interest in our communications and improve subsequent usage experiences.

3.5 Geolocation tools

Carat Diffusion may collect and use data on the geographical location of your computer or mobile device. These location data are collected to provide you with information about services that may be of interest to you and to improve our location-based products and services.

4 Widgets and Social Network Apps

Carat Diffusion sites may include features to enhance sharing by third-party social media applications, such as the Facebook Like button or the Twitter widget. These social media applications may collect and use data about your use of Carat Diffusion sites (for more information, please refer to the “Sharing on Social Networks” section of the Cookie Table. above). The personal data that you provide through these social networking applications may be collected and used by other members of those applications. These interactions are governed by the data protection policies of the companies providing the application. We do not exercise any control and accept no responsibility for the use of your data by these companies.

In addition, Carat Diffusion website may host a blog, forum, applications and collaborative finance services and the like (hereinafter collectively “social networking features”). These social networking features are intended to facilitate the sharing of knowledge and content. The personal data that you provide through Carat Diffusion social networking features may be shared with other users of these features (unless otherwise stated at the collection point), over which we do not exercise any control or only limited control.

5 Children

Carat Diffusion understands the importance of protecting the privacy of children, especially online. Thus, our sites have not been intentionally designed for or intended for children under 13 years. It is our policy never to knowingly collect or store data on minors under the age of 13 unless it is necessary as part of a commitment to provide professional services.


Sharing and transfer of personal data

1 Transfer within the entities Carat Diffusion

We share your personal data between the entities of Carat Diffusion in the framework of international commitments or when it is desirable to respect our legal and regulatory obligations around the world. Other parts of Carat Diffusion are also used to provide us services, for example, we host and manage computer applications, and provide certain forms of insurance to member companies and their customers, we conduct conflict checks with clients and controls for the fight against money laundering, with customer engagement services and as needed to continue to run the business of Carat Diffusion.

2 Transfer to third parties

We do not share any personal data with unaffiliated third parties, except where necessary for our legitimate business and commercial interests, to process your requests and / or if permitted by law or professional standards.

In addition, Carat Diffusion may transfer some of your personal data outside the EEA to outside companies working with us or on our behalf for the purposes set out in this Online Privacy Statement. In this case, your personal data will continue to be protected under contracts with these non-EEA organizations, which contain standard data protection clauses, the wording of which is approved by the European Commission.

Carat Diffusion will not transfer your personal data to third parties who would use them for commercial prospecting purposes.

3 Consent

In general, you are not required to provide personal data to Carat Diffusion online, and we may ask you to provide certain personal data to provide you with additional information about our services and events. Carat Diffusion may also request your consent to certain uses of your personal data, which you may choose to give or refuse. If you request specific services or communications, such as e-newsletters, you can unsubscribe at any time by following the instructions in each communication. If you decide to unsubscribe from a service or communication, we will delete your data promptly, but we may need additional information before we can process your request.

As mentioned in the section “Cookies” above, if you do not want cookies to map your browsing on our sites, you can set your browser to refuse all cookies, or to notify you of the sending of a cookie. cookie. However, you must understand that some parts of our site may not work properly if you choose to refuse cookies.

4 Your Rights

If Carat Diffusion  processes your personal data, you have the following rights:

Access and rectification: you have the right to access your data (“Request for access rights”). If we respond favorably to your request, we will give you free personal data about you. Prior to this, we are entitled to ask you for proof of identity and some relevant information about the relationship you have with us, so as to locate your personal data. If the information we have about you is inaccurate, you have the right to ask us to rectify it.

Opposition to processing: You have the right to object to us processing your personal data for legitimate reasons.

Other rights: In addition, you have the right to delete your personal data, limit their processing in certain circumstances and / or obtain a copy of the personal data we hold in a structured electronic format (portability).

You may exercise these rights by contacting the Data Protection Officer of Carat Diffusion (plans@carat-diffusion.com) and we will make sure to respond to your request, provided that it complies with applicable laws and professional standards.

5 Security and integrity

Carat Diffusion has reasonable security procedures and policies in place to protect personal data against unauthorized abuse, loss, alteration or destruction. Despite all the efforts put in by Carat Diffusion, absolute protection against all threats can not be provided. We strive to ensure that access to your personal data is limited to those who need to know it. People with access to the data are required to treat them confidentially.

6 Links to other sites

When you register on one of Carat Diffusion websites and then navigate to another site of Carat Diffusion without logging out, you agree to the use of your personal data in accordance with the Online Privacy Statement. from Carat Diffusion you are browsing.

7 Amendment of this Declaration

Carat Diffusion has the possibility to modify this Privacy Statement online periodically to reflect the evolution of our practices in this area. When we make changes to this Online Privacy Statement, we also change the “Last Updated” date at the top of this page. Any changes in the way we treat personal data as described in this Online Privacy Statement will be communicated to you in an appropriate manner, depending on how we usually communicate with you. We encourage you to periodically review this Online Privacy Statement to be informed of how Carat Diffusion protects your data.

8 Issues related to the policy and its application

Carat Diffusion is committed to protecting your personal data online. For any comments, questions or complaints regarding the management of your personal data, please contact us at plans@carat-diffusion.com You can also use this address to inform us of any questions you may have regarding the respect of this Online Privacy Statement.

We have the right to accept your complaint (in which case we will implement one of the measures mentioned in the section “your rights” above) or refuse to act on it for legitimate reasons.

In all cases, you have the option to lodge a complaint with the CNPD (National Commission for the protection of data in Luxembourg, https://cnpd.public.lu)