Sole trader, (“Entrepreneur Individuel”, “EI”), Delphine Cophy, SIRET 93141255500019 ( French business identification number), in her capacity as data controller for Emosupport, attaches great importance to the protection and respect of your privacy. This privacy policy is intended to inform you, in accordance with European Regulation No. 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 “Regulation” or “GDPR”), of our practices regarding the collection, use and sharing of the information that you may provide to us in the course of our activities.
This policy aims to inform you of the categories of personal data that we may collect or hold about you, how we use them, with whom we share them, how we protect them, and the rights you have over your personal data.
What is personal data?
The term “personal data” refers to any information that allows you to be identified as an individual. When you use our website (the “Site”), when we meet (in person or remotely), or when we perform our services for you, we may ask you to provide us with certain personal data concerning you.
What personal data do we collect?
By using our Site, during our meetings and in the course of the services we carry out on your behalf, you may provide us with information, some of which is of a nature to identify you and therefore constitutes personal data (hereinafter the “Data”). This Data includes in particular: (i) identification data (surname, first name, postal address, email address, telephone number), (ii) transaction data (bank details for payment), (iii) technical data (where necessary for the operation of the Site), (iv) data relating to the support services we provide (which may include special categories of data), and (v) data relating to your browsing on our Site.
How do we use the data we collect and on what legal basis?
Simple browsing on the Site does not require prior registration or identification. It can be done without you providing any personal data about yourself.
However, when you decide to subscribe to information from our Site, contact us directly via the Site, respond to surveys, or send us comments, we collect this information strictly as necessary for the performance of our mission.
We may also collect this information when you contact us by means other than our Site (in particular by telephone, email or postal mail), during our meetings (in person or remotely) or in the course of performing our services for you.
This data is used to:
- Carry out commercial prospecting activities. This processing is based on our legitimate interest.
- Manage accounting and comply with our tax obligations. This processing is based on a legal obligation.
- Respond to your requests for information and contact submitted via our Site. This processing is based on your consent.
- Help us maintain a safe and secure environment on our Site. This processing is (i) based on our legitimate interest (ensuring the security of the Site), (ii) necessary for compliance with our legal obligations and/or (iii) necessary for the establishment, exercise or defence of legal claims.
- Manage our Site and carry out internal technical operations for the purposes of troubleshooting, data analysis, testing, research, analysis, studies and surveys. This processing is based on our legitimate interest (ensuring the security of our Site and improving its features).
When Data is collected, you will be informed whether certain items of Data are mandatory or optional. If you do not provide mandatory Data, we may be unable to fulfil your request in whole or in part.
Who is the data controller?
Data controller: Delphine Cophy, sole trader, creator of Emosupport, located in Paris, France.
Email address: hello@emosupport.com
Who are the recipients of the data we collect and why do we share this data with them?
1. Data transferred to public authorities and/or bodies
In accordance with applicable regulations, Data may be transmitted to the competent authorities upon request, in particular to public bodies, judicial auxiliaries, court officers, debt collection bodies, solely in order to comply with legal obligations, as well as in the context of identifying the perpetrators of offences committed on the internet.
2. Data transferred internally
The Data collected and processed is made available to members of the team, interns, and to any internal department of the business.
3. Data transferred to third parties
We may work in collaboration with third-party companies or consultants, self-employed professionals who may have access to your Data, in particular:
- Sub-processors we use to provide IT services (database management, hosting, storage, maintenance, etc.), accounting services or communication services.
We only transmit to these third parties the Data they need to perform their services, and we require them not to use your Data for any other purpose. These third parties act solely in accordance with our instructions and are contractually required to provide a level of security and confidentiality for your Data that is equivalent to ours and to comply with the applicable regulations on the protection of personal data.
Data retention period
Your Data will not be kept for longer than is strictly necessary for the purposes set out in this Policy and in accordance with the Regulation and applicable laws.
In this respect, Data used for the performance of the services you entrust to us is kept for the entire duration of the contractual relationship, then archived in accordance with applicable limitation periods.
Your Data is erased once the applicable retention periods have expired.
Archiving means that your Data will no longer be available online but will be extracted and stored on a separate, secure medium.
Data used for marketing and communication purposes may be kept for a maximum of three (3) years from the end of the business relationship or from the last contact with the prospect concerned.
Your Data is erased once the retention periods have expired. However, your Data may be archived beyond the periods provided for the purposes of research, establishment and prosecution of criminal offences, solely in order to make your Data available to the judicial authorities, where necessary.
Archiving means that your Data will no longer be available online but will be extracted and stored on a separate, secure medium.
How is your data protected?
All appropriate organisational and technical measures have been taken to preserve the security, integrity and confidentiality of your personal data.
Where we use a service provider, we ensure that the provider meets its security obligations before any Data relating to you is communicated.
Where is your data stored?
Your Data is stored and hosted, for the entire duration of its processing, on servers located at Hostinger International Ltd, 61 Lordou Vironos Street, Lumiel Building, 4th floor, 6023 Larnaca, Cyprus.
The IP address may also be collected in order to determine the city from which you are connecting.
What are your rights over your data and how can you exercise them?
In accordance with applicable data protection laws and regulations, you have a number of rights in relation to your Data, namely:
Right to information: you have the right to be informed about the processing of your personal data and, if you wish more details, you can contact us at: hello@emosupport.com.
Right of access: you have the right to access all of your personal data at any time.
Right to rectification: you have the right to rectify at any time any inaccurate, incomplete or outdated personal data.
Right to erasure: in certain cases, you have the right to obtain the erasure of your Data. However, this is not an absolute right and we may, for legal or legitimate reasons, retain such Data.
Right to restriction: you have the right to obtain restriction of the processing of your personal data in certain cases defined in Article 18 of the GDPR.
Right to data portability: you have the right to receive your personal data in a structured, commonly used and machine-readable format and to have it transmitted to a third party of your choice.
Right to be forgotten: you have the right to require that your personal data be erased and to prohibit any future collection of such data.
Right to lodge a complaint: you have the right to lodge a complaint with the CNIL in France if you consider that the processing of your personal data constitutes a breach of the applicable provisions.
Right to object: you have the right to object to the processing of your personal data.
Please note, however, that we may continue processing despite this objection, for legitimate reasons or for the establishment, exercise or defence of legal claims.
Right to withdraw your consent at any time: you may withdraw your consent to the processing of your Data where the processing is based on your consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to give instructions regarding the fate of your data after your death: you have the right to provide us with instructions regarding the use of your Data after your death.
You may exercise the above rights by writing to us at the following address: hello@emosupport.com.
Changes to and application of this privacy policy
We reserve the right, at our sole discretion, to modify this policy at any time, in whole or in part. Such changes will take effect upon publication of the new policy. We will inform you in advance of any changes by any appropriate means.
Contact
For any questions relating to this Policy or for any request concerning your Data, you can contact us by sending an email to: hello@emosupport.com