Privacy Policy for the benefit of users

1. Definition and nature of personal data

The following words and expressions, when used with initials in capital letters, have the meanings given to them in the General Terms and Conditions of Use.
As a result of your use of the Website, we may require you to provide us with your personal data, so that you have the possibility to use the services provided by Terality.

The word "personal data" means any data that enables a person to be identified, which includes your family name, first name, email address, phone number, as well as any other information about you that you choose to provide us with.

Any personal data related to the browsing pattern of Users on the Application or the Website may also be collected by Terality for the exclusive purpose of improving them, after having been previously anonymized.

2. Purpose of this privacy policy

The purpose of this privacy policy is to inform you of the means that we use to collect and process your personal data, with the strictest respect for your rights.
In this regard, we inform you that we collect and process your personal data in compliance with the French law N° 78-17 dated 6th January 1978 on Information Technology, Data Files and Civil Liberties (hereinafter referred to as the “French Data Protection Act”), as well as the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 as from its entry into force, namely 25th May, 2018 (hereinafter referred to as the “GDPR”).

3. Identity of the entity responsible for collecting data

The entity responsible for collecting and processing your personal data is the company Terality, a French simplified joint stock company (“Société par Actions Simplifiée”) registered under number 883 163 214 with the Registry of Trade and Companies of Paris, whose head office is located at 15 Rue des Halles 75001, Paris, FRANCE (hereinafter referred to as "us" or "we").

4. Data Protection Officer (DPO) / Person in charge of data privacy

We have appointed a data protection officer/person in charge of data privacy, who can be contacted at the following address: 
dpo@terality.com

5. Collecting personal data

The legal basis of our processing of your personal data is the following: 

i) The legitimate interest resulting from your voluntary provision of your personal data when visiting the Website, as these data are aimed at enabling us to better answer to your information requests about our Services 

ii) Your consent to our use of cookies, as set forth in article 11;

iii) Processing is necessary for the performance of the Agreement to which you are party for purposes of using our Services on our Website.

Your personal data is processed to meet one or several of the following requirements:
i) To manage your access to the Services provided through the Website and their use;
ii) To constitute a file of registered Clients and prospects;
iii) To send newsletters, entreaties and promotional advertisements. In case you do not wish so, you have the possibility to opt-out of receiving such communications when your data are collected;
iv) To provide commercial and service use statistics;
v) To customize our answers to your information requests;
vi) To respect our legal and regulatory requirements.

We inform you, when collecting your personal data, whether some of these data are mandatory or optional. Mandatory data are necessary for the provision of the Services. You are free to provide or not optional data. We will also inform you of the possible consequences of failure to reply.

We also inform you that we may process indirectly your data, from your company, which gives you access to our Services.

6. Recipients of the collected data

The only persons who have the right to access to your personal data are:
i) our personnel, the services in charge of control (including external auditor) and our processors;
ii) our processors (hosting or monitoring software)

We may also give access to your personal data to government agencies, for the sole purposes of meeting legal requirements, or to representatives of the law, ministerial officers and organizations responsible for the collection of debts.

7. Transfer / sale of personal data

Your personal data may be sold, transferred, leased-out to or exchanged with third-parties. In case you accept so, we provide you with the option to express your consent by checking a box when your data are collected.

8. Personal data storage period

(i) Data concerning current and potential Client management:

Your personal data shall be stored no longer than the time strictly necessary for the management of our commercial relations with your company. However, any data providing the proof of a right or a contract and that must be stored in compliance with a legal obligation shall be so for the period stated by the legislation currently in force.

With regard to possible promotion operations towards Clients, their data may be stored for a period of three years from the end of the commercial relations with them.

Personal data relating to potential Clients may be stored for a period of three years from their collection or the last contact from the potential Client.

Beyond that three-year period, we may contact you again to find out if you still wish to receive commercial solicitations.

(ii) Management of opt-out systems:

All information taking into account your right to object shall be stored for at least 3 (three) years from the exercise of this right.

(iii) Management of your requests for the exercise of your rights under GDPR:

All information enabling to manage your requests for the exercise of your rights under GDPR shall be stored for at least 2 (two) years from the request.

9. Safety

We inform you that we take all necessary precautions, as well as all appropriate organizational and technical measures, to maintain the security, the integrity and the confidentiality of your personal data, including to prevent that they be distorted or damaged and that any unauthorized third-party access to them. 

10. Hosting

We inform you that your personal data are stored, for the term set forth above, on the servers of AWS, located in the European Union.

Your data will not be transferred outside the European Union in the context of the use of our Services.

11. Cookies

For more information on Cookies, please read our attached Cookies Policy. 

12. Access, rectification and erasure of your personal data

In compliance with the French Data Protection Act and the GDPR, you have the right to access, rectify and delete any information concerning you. You can exercise this right and have the information concerning you by contacting us at the:
- Email Address: dpo@terality.com
- Postal Address: 96 Bis Boulevard Raspail, 75006 Paris

13. Right to define instructions related to the processing of data after your death

You have the right to define instructions with regard to the storage, the erasure and the communication of your personal data after your death.

These instructions may be general directions, which are focused on all personal data concerning you. In such case, they must be registered with a digital trusted third party who is certified by the French data protection authority (CNIL).

These instructions may also be specific to the data processed by our company. You are then required to provide these instructions to us at the:
- Email Address: dpo@terality.com
- Postal Address: 96 Bis Boulevard Raspail, 75006 Paris

By providing to us these instruction, you hereby expressly consent that they be stored, transmitted and carried out on the terms and conditions set forth herein.

You have the right to appoint in your instructions a person in charge of their execution. After your death, this person shall be entitled to take knowledge of these instructions and to request to us their implementation. Failing to such appointment, your heirs shall be entitled to take knowledge of these instructions and to request to us their implementation.

You may modify or revoke your instructions at any time, by writing to us at the above mentioned contact addresses.

14. Portability of your personal data

You have a right to portability of the personal data you have entrusted to us, understood as the data you have actively and deliberately declared when accessing to and using our Services. You are reminded that portability right does not apply on data that were processed on another basis than consent or the execution of a contract between us.

This right may be exercised free of charge, at any time, including when closing your account on the Site, so that you may recover and store your personal data.

In this context, we shall provide your personal data, by any appropriate means, in an open standard, currently used and machine-readable format, in compliance with the state of art.

15. Submission of a complaint before a supervisory authority

You are informed that you have a right to submit a complaint before a supervisory authority which is competent in the member State in which your ordinary residence, your place of work or the place in which the infringement of your rights was committed (in France, the French Data Protection Authority – CNIL), if you consider that the personal data processing under this Privacy policy is a violation of the applicable regulations.

This complaint submission may be exercised without prejudice of other legal action before any administrative or judicial court. In fact, you have also a right to effective administrative and judicial redress if you consider that the personal data processing under this Privacy policy is a violation of the applicable regulations.

16. Restriction of processing

You have the right to obtain restriction of your personal data’s processing where one of the following applies:

- Within the period of verification that we carry out, if you contest the accuracy of your personal data;
- When the processing of these data is unlawful et you request the restriction of this processing, instead of erasing your data;
- When we no longer need your personal data, but you require their maintenance for the exercise of legal claims;
- Within the period of verification of the legitimate interests, if you have objected to the processing of your personal data.

17. Modifications

We reserve the right, at our sole discretion, to modify this Privacy policy, in whole or in part. Any changes will be effective from the time of publication of the new Privacy policy. Your use of the Website after the changes have been implemented implicitly expresses your acknowledgement and acceptance of the new Privacy policy. Otherwise, and if the new Privacy policy does not suit you, you must no longer use the Services provided by the Website.


18. Entry into force

This Privacy policy came into force on May 7th, 2021.


Appendix 1 – Cookies Policy

What is a Cookie? 

When browsing our Website or Application, Cookies, pixels, tags or other trackers (hereafter referred to as the “Cookies”) are installed on your terminal.
A cookie is a small file, often encrypted, that is stored in your browser or device and is identified by a name. It is installed when you visit a site or application. Each time you return to the said site or application, the Cookie is retrieved from your browser or device. This ensures that each time you visit the site or application, the browser is recognized.
The installation of these Cookies is likely to enable us to access your browsing data and/or personal data concerning you.

Cookies Identification

Technical and functional Cookies
Technical and functional Cookies are necessary for the proper functioning of our Website and Application and to provide you with our Services. They are used throughout your navigation, in order to facilitate it and to carry out certain functions.
For example, a technical Cookie may be used to store your responses to a form or your preferences regarding the language or layout of the Application, where such options are available.
We use the following technical and functional Cookies: 

Cookie’s name Cookie’s FunctionShelf life


Analytical Cookies
These Cookies allow us to measure the number of visits, page views and user activity. If necessary, they may collect your IP address to know the city from which you are connecting. Analytical Cookies allow us to generate statistics on the use and navigation of our Application or Website in order to improve our performances. The Cookies used also allow us to identify navigation problems and eventually to solve them.
We use the following Analytical Cookies:

Cookie’s name Cookie’s
-
Google Analytics
- Hotjar

Your Cookies preferences

Cookies that can be installed without consent

Some cookies do not require your consent, such as:Technical or functional Cookies that are necessary for the operation of the Application or the Webiste;Certain Cookies for audience measurement or Cookies that enable to test different versions of the Application or the Website for the purpose of optimising editorial choices.

Acceptance or refusal of Cookies subject to your express consent

All other Cookies require your consent. These include Advertising Cookies, Social Networking Cookies, Content Personalization Cookies and some Audience Analysis Cookies. You may freely choose to accept or decline the use of these Cookies.
You can accept or refuse these Cookies the first time you consult the Website or the Application.

Your choices to accept or refuse these Cookies will be retained for a period of 6 (six) months.

You are free to withdraw your consent and more generally to change your preferences at any time via the following link.

Your browser settings

It is also possible to set your browser to accept or reject certain Cookies. 

Each browser offers different settings:
- For Internet Explorer: go to the "Settings" menu, then "Internet Option". Click on "Privacy" and then "Advanced Privacy Settings";

- For Chrome: go to the “Settings” menu, then click on “Confidentiality and Security”. Finally, click on “Authorisation” and “Cookies and website data”;

- For Safari: go to the application “Settings”, then go to “Safari”. Click on “Confidentiality and Security”. You can now choose to block all Cookies;

- For Iphone: go to the “Settings” menu, then “Safari”, click on “Cookies”. You can now choose to block all Cookies;

For Android: go to “Chrome”, click on the tag “” at the top right of the screen, then on “Site settings” and finally on “Cookies”. You can now choose to accept or block all Cookies.

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