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Privacy Policy
Applicable starting May 25th 2018

Please carefully read the following policy (the “”Privacy Policy””) which describes how A-Volute (the “”Data Controller””) collects, uses, discloses when necessary, stored, and otherwise manages personally identifiable information (the “”Personal Data””).
The Privacy Policy applies to all and any website, application, or service managed or offered by A-Volute.
A-Volute may amend this policy from time to time by posting a revised version on its website, and without giving you notice, so please check this policy each time you visit the Site and note the date of publication.

When you provide us with Personal Data in the manner described in Article 2 of this Privacy Policy, you allow us to collect it, store it and use it to:

a) Fulfill our contractual and business obligations towards you;
b) To administer, support, improve and develop our business in a legally justified manner (as explained in Article 3 of this Privacy Policy);

All of this with being done with your consent, that you are allowed to withdraw anytime as described in Article 6 of this Privacy Policy.
The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy. The key articles of the GDPR, as well as information on its business impact, can be found throughout this site: https://www.eugdpr.org/

Article 1 – Data Controller

The Data Controller of the Personal Data is A-Volute, a French company with its headquarters situated at Polygone Square Bâtiment 2, 19 Rue de la Ladrie – 59650 Villeneuve d’Ascq, France, registered in the Company Register of Lille Métropole under the number 453 587 420.

Article 2 – Data collection

Subject to applicable laws, we collect information about you or any third party whose information you provide to us when you:

• Register to use our websites, applications or services (including free trials); this may include your name (or company name, if any), address, email address and phone number. We may also ask you to provide us with additional information about your business and your preferences;
• place an order using our websites, applications or services; this may include your name (or business name), your address and contact information (including phone number and email address) and payment;
• complete online forms (including reminder requests), take surveys, download information, such as white papers or other publications, or participate in any activity offered on the various interactive spaces present on our website or on our application or service;
• interact with us using social networks;
• provide your contact details when you register or access any website, application or service that we make available or when you update these details; and
• contact us offline, for instance by phone, fax, SMS, e-mail or mail.

We will also collect your Personal Data when you fill only a part of the fields to be filled on our site and / or on other online forms and / or when you abandon this entry along the way. We may use this data to contact you to remind you to enter missing information and / or for marketing purposes.

We may also collect information from your electronic devices (including mobile phones) and applications used by you or your users to access and use any of our websites, applications or services (for example, we may collect the identification number and the type of device used, geolocation and connection information, such as statistics on pages visited, traffic to and from sites, link referral URL, ad data, your IP address, your browsing history and your web log information). We will ask your authorization in advance, when it is legally required, before any step.

Subject to applicable law, we may supplement the Personal Data we collect with information obtained by third parties who are authorized to share it; for instance, information from credit institutions, providers seeking information or public sources (for instance, for the purpose of customer due diligence).

Third party data

If you provide us with Personal Data concerning a third party, it is your responsibility to ensure that you comply with applicable regulations regarding the protection of Personal Data and in particular with your obligations to obtain the prior consent of individuals. of which you provide us with the Personal Data. As such, in accordance with the applicable data protection regulations, you must have notified the data subject and obtained his express consent to provide us with his Personal Data and to have informed him of the manner in which we collect, use, disclose and retain Personal Data about him or invite him to read our Privacy Policy.

Article 3 – Use of Personal Data

Subject to applicable laws, we collect and process your Personal Data for the following purposes:

• provide any information and services you have requested and the applications or services you have ordered;
• compare the information for the purpose of checking its accuracy and corroborating it with third parties’s data;
• provide, maintain, protect and enhance the applications, products, services and information you have requested from us;
• manage and administer the use you make of the applications, products and services you have asked us to provide;
• manage our business relationship (for instance, customer services and support activities);
• monitor, measure, enhance and protect our content, websites, applications and services and provide you with a personalized and quality user experience;
• perform, internally, controls on our websites, applications, systems and services to test and improve their security, provision and performance. Where applicable, we will use a pseudonymized form of any information used for such purposes, and we will ensure that such information is presented in a package and will not be binding on you or any other person involved;
• provide you with any information we are required to provide to you in order to comply with our regulatory or legal obligations;
• detect, investigate or prevent criminal, illegal or prohibited activities, or protect our rights (including liaising with law enforcement and regulatory agencies for these purposes);
• contact you to find out if you want to participate in our customer surveys (for example, feedback on your use of our applications, products and services);
• track and analyze statistics and comparisons jointly to avoid being identified or identifying any other individual;
• provide you with advertisements, marketing messages or targeted information that may be useful to you, based on your use of our applications and services;
• deliver content and services jointly with third parties with whom you have a separate relationship.

To the extent permitted by applicable law, we will retain your information after you cease to use A-Volute websites, applications or services, for a limited time. This information will be kept and used for legal, regulatory, anti-fraud and legitimate conduct of our activities for the legally permitted duration.

Our websites, applications (including mobile apps) and services may contain technologies that allow us to:

• verify specific information from your device or systems necessary for your use of the websites, applications or services in relation to our records to ensure that the websites, applications or services are used in compliance with our Terms and Conditions and our agreements with the end user and for the purpose of solving potential problems;
• obtain information about technical errors or other issues related to our websites, applications and services;
• gather information about how you and the users make use of the features of our websites, applications and services.

You can manage your privacy settings in your browser or on our apps or services (if applicable).

A-Volute uses marketing automation platforms

A-Volute sends e-mail communications, particularly via third parties. The functionalities and integrations of the marketing automation platforms allow their customers to send marketing e-mails, automated messages and targeted campaigns.

Article 4 – Sharing of Personal Data

We may share your Personal Data with:
• our service providers and agents (including their subcontractors) or third parties who process information on our behalf (for instance, Internet platform or service providers, payment processors and companies we use to help us send you communications) so that they can help us provide you with the applications, products, services and information you have been interested in receiving or which, from our point of view, would be likely to interest you;
• partners, including system builders, resellers, distributors, software vendors, and developers, who help us provide you with the applications, products, services, and information you’ve requested, or who our point of view, are likely to interest you;
• third parties that we have used for the execution of payment transactions, such as clearing companies, clearing systems, financial institutions and transaction beneficiaries;
• third parties, when you have a relationship with that third party and have consented to us transmitting information (for instance, social networking sites or other third-party application providers);
• third parties for marketing purposes (eg our partners and other third parties with whom we work and whose products, from our point of view, may be of interest to you in the conduct of your business activities. For instance: financial service providers (such as banks, insurers and financial service providers), payment solution providers, software providers and service providers that provide business solutions);
• credit reference and fraud prevention agencies;
• regulators, to meet the legal and regulatory obligations of A-Volute;
• police authorities, so that they can detect or prevent crimes or prosecute offenders;
• any third party, in the context of existing or pending legal proceedings, provided we are legally entitled to do so (for example, in response to an order issued by a court);
• any third party to comply with our legal and regulatory obligations, including legal or regulatory reporting and the detection or prevention of unlawful acts;
• our own auditors and consultants, to fulfill our audit responsibilities;
• another company, if we sell or buy an activity or assets (or negotiate the sale or purchase of an activity or assets);
• any other company to which we may be liable to assign the contract which binds us; and
• public bodies that the law in force requires to inform.

We may share, publicly or with third parties, information about our websites, applications, products or services to the exclusion of any information that may identify you.

Article 5 – Marketing

We may occasionally use your information to contact you for the purpose of providing you with information about our applications, products and services that may be of interest to you. To this end, you can be contacted by phone, mail, SMS or e-mail. You have the right to ask us to stop contacting you for marketing purposes at any time. If you wish, you may exercise these rights by selecting your contact preferences where you provide us with your Personal Data on our websites, applications or services, using any preference center to which we give you access or in us, by sending an e-mail to dpo@a-volute.com.

You can also unsubscribe from any marketing campaign and / or advertising by e-mail by clicking on the link included in the emails we send you.

Article 6 – Your rights

If you live in the EEA or in another region governed by comparable data protection laws, in some cases you will have the following rights:

• the right to know how we use your data and the right of access to your data;
• the right to request the modification or deletion of your data as well as to limit the processing of your data;
• the right to oppose the processing of your data, for example for marketing purposes or when their use is based on our legitimate interest;
• the right to receive data about you that you have provided automatically in a structured, commonly used and machine-readable format, or to have it sent directly to another company, if technically feasible (“”Data Portability””);
• when you have consented to the processing of your data, the right to withdraw your consent in accordance with legal or contractual limitations;
• the right to refuse any decision based on automated processing of your personal data, including profiling; and
• the right to lodge a complaint with the supervisory authority responsible for data protection issues (for instance, the National Commission for Data Protection and Freedoms).

If you request to receive a copy of your data, you may be required to pay certain fees.

If we have incorrect information about you or if your contact information has changed, we thank you for informing us so that we can correct and update our files.

If you withdraw your consent to the use of your personal data for the purposes set out in our Privacy Policy, we may, as a result, no longer be able to provide you with access to all or part of our websites, applications and services.

We will retain your personal data for the duration of our business relationship and after its expiration for the period of time necessary for the legitimate conduct of our business, or to comply with applicable laws and regulations. In cases where we no longer need your Personal Data, we will destroy it in a secure way (without sending you any other notice).
Article 7 – Storage and Processing
We ensure the security of your data by taking the necessary technical and structural measures to prevent their unlawful or unauthorized processing or accidental loss, destruction and / or damage. We strive to protect our Personal Data as much as we can. However, we can not guarantee the security of your data transmitted to our Internet sites, applications or services or to other Internet sites, applications and services via an Internet connection or any other connection. If we have given you (or if you have chosen) a password that allows you to access certain areas of our websites, applications or services, please keep it confidential; we will not share this password with anyone.

If you believe that your account has been hacked, please contact us at dpo@a-volute.com.

Article 8 – Data transferred outside the EEA

In the European Union, Personal Data is protected by data protection laws. However, other countries do not necessarily protect your Personal Data in the same way.

Our websites, our services and applications may also be hosted in the United States or outside the EEA (which is made up of European Union as well as Norway, Iceland and Liechtenstein). This implies that we may transfer any data transmitted to us via the website, application or service outside the European Economic Area (“”EEA””) to the United States or Canada. other territories outside the EEA.

We may use the services of providers located outside the EEA to help us provide you with our websites, applications and services (such as, for example, platform or payment service providers who help us to deliver our services and applications or execute your payments). This means that we may transmit your data to service providers located outside the EEA for the purpose of providing you with our applications and services.

We make sure that when your service providers and hosting providers transfer your data outside the EEA, appropriate measures and controls are implemented in compliance with applicable laws and regulations to protect them. In each case, these transfers are made in accordance with the requirements of Regulation (EU) 2016/679 (General Data Protection Regulation) and may be based on the use of standard clauses on transfers of personal data outside the EEA of the European Commission.

By using our websites, products and services or interacting with us under the conditions described in this Privacy Policy, you consent to the transfer of your data outside the EEA in the cases provided for in this Privacy Policy. If you refuse to transfer your data outside the EEA, you will not be able to use our websites, applications or services.

Article 9 – Hypertext links, Cookies and Google Analytics

The A-Volute websites contain a number of hypertext links to other sites, set up with the permission of A-Volute. However, A-Volute has no opportunity to check the content of the sites visited, and therefore assumes no liability for this fact.

Browsing A-Volute websites may cause the installation of cookie (s) on the user’s computer. A cookie is a small file, which does not allow the identification of the user, but which records information relating to the navigation of a computer on a site. The data thus obtained are intended to facilitate subsequent navigation on the site, and are also intended to allow various measures of attendance. The refusal to install a cookie may make it impossible to access certain services. The user can however configure his computer to refuse the installation of cookies.

Google Analytics uses cookies to enable the websites to analyze how users use the websites, applications and services. Information about your use of the Internet sites, applications or services (including your IP address) generated by the cookie are transmitted to Google for storage on servers located in the United States. Google will use this information to evaluate your use of websites, applications and services, to compile reports on website activity for site operators and to provide other services related to the activity of the website and the use of the Internet. Google may also disclose this information to third parties when required by law or when such third parties process the information on Google’s behalf. Google will not associate your IP address with other data held by Google. For more information, refer to “”How Google Uses Certain Data Collected When You Use Partner Sites or Applications”” (available at www.google.com/policies/privacy/partners/ or any other link that Google may provide to you).

If you want Google Analytics to stop following you on all websites, visit http://tools.google.com/dlpage/gaoptout.

Article 10 – Questions or comments
If you have questions or comments about this privacy policy, please email us at dpo@a-volutecom or write to A-Volute, Polygone Square Bâtiment 2, 19 Rue de la Ladrie – 59650 Villeneuve d’Ascq, France.

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