Privacy policy

At THINKEO, protecting your personal data is our priority.

When you use the website https://thinkeo.io (hereinafter the "Website"),we are required to collect personal data about you.

The purpose of this policy is to inform you on how we process your personal data in compliance withRegulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data(hereinafter the "GDPR").

1.     Who is the data controller?

 The data controller is THINKEO, French simplified joint stock company, registered with the Registry of Trade and Companies of Bordeaux under the number 883 208 142 and whose head office is located at 7 rue du Chai des Farines – 33000 Bordeaux (hereinafter “Us” or “We”).

 

2.     What personal data we collect?

 The term ‘personal data’ means data enable to identify a natural person 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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We may collect the following personal data:

·      Identification and contact data (e.g. full name, email and postal addresses, telephone number, your photo);

·      Login data (e.g. logs, IP address);

 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 our services.

 

3.     On what legal basis, for what purposes andfor how long do we keep your personal data?

 

Purposes

To compile a database of customers and prospects

 Legal basis

Our legitimate interest in developing andpromoting our business

 Data retention period

For our  clients: their personal data are retained for the duration of the business  relationship plus a period of 1 year from the termination of this  relationship.

For our  prospects: their personal data are retained for a period of 1 years starting  from the last contact with us (e.g., communication, action).

In  addition, personal data may be archived for probationary purposes for a  period of 3 years

Purposes

To send newsletters, requests and direct marketingmailings

Legal basis

For our clients: ourlegitimate interest in developing and promoting our business

For our prospects BtoB: our legitimate interestin developing and promoting our business

Data retention period

Personal data are retained for a period of 1year starting from the last contact with us (e.g., communication, action).

Purposes

To send  newsletters, requests and direct marketing mailings

Legal basis

For our  clients: our legitimate interest in developing and promoting our business

For our  prospects BtoB: our legitimate interest in developing and promoting our  business

Data retention period

Personal  data are retained for a period of 1 year starting from the last contact with  us (e.g., communication, action).

Purposes

To answer  to your information request and other inquiries

Legal basis

Our  legitime interest in responding to your inquiries

Data retention period

Personal  data are retained for the necessary time to process of your request and are  deleted once the request has been processed.

Purposes

To process  data subjects’ requests to exercise their rights

Legal basis

Legal  and regulatory obligations

Data retention period

If we  ask you a proof of identity: we only retain it for the necessary time to  verify your identity. Once the verification has been carried out, the proof  is deleted.

If you  exercise your right to object to stop your data being used for direct  marketing: we keep this information for 3 years.

 

4.     Who are the recipients of your personal data?

Will have access to your personal data:

(i)             The staff of our company.

(ii)            Our processors: hosting provider (OVHCloud), CRM tool (Hubspot), mailing provider (Gmail), audience measurement and analysis provider(Google Analytics) ;

(iii)           If applicable: public and private organisations, exclusively to comply with our legal obligations.

 

5.     Are your personal data likely to be transferred outside the European Union?

Your personal data is hosted for the duration of the processing on the servers of the company OVH, located in the European Union.

 As part of the tools, we use (see article 4 on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

·      Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of theEuropean Commission;

·      Or specific contracts have been executed with our processors for the transfer of your personal data outside the European Union, based on the StandardContractual Clauses between a controller and a processor approved by theEuropean Commission;

·      Or appropriate safeguards as defined by the GDPR have been undertaken.

 

6.     What rights do you have regarding your personal data?

 

You have the following rights with regard to your personal data:

 

-       Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.

 

-       Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.

 

-       Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.

 

-       Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.

 

-       Right to erasure (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.

 

-       Right to file a complaint to a competent supervisory authority (in France, the CNIL), under GDPR article77, if you consider that the processing of your personal data constitutes a breach of applicable regulations.

 

-       Right to define instructions related to the retention, deletion and communication of your personal data after your death (article 40-1 of French law “informatique et libertés”).

-       Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.

-       Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.

7.     Contact information for data privacymatters

Contact email : contact@thinkeo.io

Contact address: 7 rue du Chai des Farines – 33000 Bordeaux

 

8.     Modifications

We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

 

Entry into force: March, 29th 2021

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