PRIVACY POLICY

Effective from  02 October 2018

We have established a privacy policy (hereinafter "Privacy Policy") to explain to you how Willo 32 SAS and/or its parent company, Willo 32, Inc. and its affiliates (hereinafter collectively "Willo 32”, “Us”, “our”,”our”), treat your personal data with great importance.

You are informed that for the purposes of this Privacy Policy, personal data, within the meaning of Article 4 of EU Regulation 2016/679, means "any information relating to an identified or identifiable natural person; is deemed to be an "identifiable natural person" a natural 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 specific elements specific to their physical, physiological, genetic, psychic, economic, cultural or social identity".

By accessing and using our sites, applications and services, you acknowledge that you have read and fully accept this Privacy Policy.

We have appointed a privacy representative who can be contacted at legal@willo.com.

 

WHAT ARE THE PERSONAL DATA COLLECTED?

The use of our products and Services requires the collection of your personal data which allow us to identify you directly or indirectly.

Directly or as part of your use of the Services, we collect the following categories of data:

PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data are processed by Willo 32 for the sole purpose of providing, operating, maintaining and improving our Products, Services and customer relationship management.

For the purposes of this Privacy Policy, Processing means “any transaction or set of transactions that may or may not be performed using automated processes and applied to data or sets of personal data, such as collection, the recording, organization, structuring, preservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, reconciliation or interconnection, limitation, erasure or destruction”.

The processing implemented by Willo 32 serves the following purposes:

The legal basis of this processing is the necessity for the purposes of the execution of the contract concluded between you and Willo 32.

The legal basis of this processing is the legitimate interest of Willo 32 to improve its products, and to present to its customers and prospects with information, news and offers on its products.

COOKIES

Cookies are data files stored on your device (computer, tablet, mobile phone or device ...) when you browse our Sites and when you use our Applications and Services. These cookies allow our website to recognize your browser and to enter and retain certain information, including personal data.

The cookies deposited and read on the hard disk of your terminal by Willo 32 have the following purposes:

During your first connection to the website, you are informed of the use of cookies and your consent to the installation and exploitation of these cookies will be required by any appropriate technical process.

The retention period of cookies accepted by the person concerned shall in no case exceed thirteen (13) months.

To refuse the installation of cookies, or withdraw your consent to their deposit, you can adjust the settings of your browser for this purpose, and the site will automatically switch to a browsing mode without cookies.  

LIMITS OF THE PRIVACY POLICY

Willo 32 may refer to websites, applications, products or services of others. We can not be responsible for the practices of the third party websites made available or referred to by our Services, or their information or content.

Note that when you use a link to another website, our Privacy Policy is no longer applicable. Your browsing and your actions on any other site, including those to which we refer, are subject to the own rules and policies of this site.

SAFETY MEASURES AND ADDRESSEES

Willo 32 undertakes to put in place all relevant physical, organizational and technical safeguards to protect your personal data against loss, misuse, unauthorized access, disclosure, alteration and/or destruction.

Willo 32 gives access to your personal data only to those employees who have a real need to know about it in order to provide, operate, maintain and improve our Products, Applications and Services.

Your personal data will not be sold, exchanged, transferred or transferred without your consent for any reason.

Your personal data may nevertheless be communicated to our technical service providers (hosting, CRM), or to third parties to the extent required by law or by an administrative or judicial authority.

INTERNATIONAL TRANSFERS

The data collected may be consulted by the staff of the company Willo 32, Inc. located in the United States of America (115W 30th, Suite 709, New York City, NY 10001, USA) to test tracking purposes or products customer relationship management (complaint, after-sales service, satisfaction survey ..)

In this context, Willo 32, Inc. and Willo 32 SAS have concluded contractual clauses

from processing manager to processing manager, which you can

access by writing to legal@willo.com or the contact address below.

In addition, as mentioned above, technical service providers located in the United States may also have access to your personal data. This is the case of Heroku (hosting) and Hubspot (CRM).  These providers are both Privacy Shield certified:

- Heroku: https://www.privacyshield.gov/participant?id=a2zt0000000KzLyAAK&status=Active

- Hubspot:

https://www.privacyshield.gov/participant?id=a2zt0000000TN8pAAG&status=Active 

DURATION OF DATA CONSERVATION

Willo 32 retains your personal data for a period not exceeding the period strictly necessary for the purposes set forth in this Privacy Policy.

In this context, the personal data concerning you, relating to your orders, are kept by Willo 32 for the duration of the contractual relationship, and may be used for commercial prospecting purposes for a period of three (3) years.

The personal data of our prospects are kept for a maximum of three (3) years from the last contact.

In addition, you are informed that Willo 32 keeps the data related to the use

of your connected devices, in a pseudonymised form, for the duration

necessary to enable us to carry out analyses and statistics in order to improve our

products, and for a maximum of ten (10) years.

Beyond this, your personal data may be archived to comply with legal and regulatory requirements or applicable limitation periods.

Personal data that establishes proof of a right or contract, or which is kept in accordance with a legal obligation by Willo 32, are archived in accordance with the provisions in force.

CHANGES TO THIS POLICY

This Privacy Policy is applicable as of the date indicated above.

We reserve the right to modify or correct it at any time, and without notice in particular to take into account the evolution of the regulations applicable to the protection of personal data.

In any case, you are invited to regularly review this Privacy Policy to be aware of any update or modification.

GET IN TOUCH - EXERCISE YOUR RIGHTS

You have a right to access, rectify, and delete your personal data, and in certain circumstances, a right to request the limitation of their processing by Willo 32.

For reasons relating to your particular situation, you may object to the processing of your personal data. Please note that you can also object to their processing for marketing purposes at any time and for no reason.

You also have a right to the portability of your data and the right to set general and specific guidelines defining how you intend to exercise these rights after your death.

If you can not find the answer to your questions or to exercise your rights, do not hesitate to contact us by email at: legal@willo.com  or write to us at:  

WILLO 32 SAS

12 Rue Gemini

  87280 Limoges

Your application must be signed and accompanied by a photocopy of an identity card bearing your signature and specify the address to which the reply must be sent. An answer will be sent to you as soon as possible

We undertake to examine and attempt to amicably resolve any complaint, claim or dispute in a reasonable time.

Any complaint, claim or any dispute concerning the way we use or protect your personal data that could not be settled amicably is subject to French law. Finally, you can at any time submit your complaints to the competent data protection authority (in France, the CNIL).