Privacy policy

This Privacy Policy (the “Privacy Policy”)Charter»)aims to formalize our commitment to respecting the privacy of users of the website www.deepqual.com (the “Site»)operated by Deepqual SAS. The Charter and the General Conditions of the Site form a contractual whole. All capitalized terms not defined in this Charter are defined in the General Conditions available here:[[Terms and Conditions URL]. As part of the provision of our Site, we process your personal data in compliance with the General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”) and under the conditions set out below.  Personal data means any information relating to an identified or identifiable natural person. We collect and process personal data in the context of providing our Services or communication about these Services exclusively, in strict compliance with the GDPR.

 We only collect personal data that is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. Thus, you will never be asked to provide personal data considered “sensitive”, such as your racial or ethnic origins, your political, philosophical or religious opinions.

 By registering on the Site, you authorize us to process your personal data in accordance with the Charter.If you do not accept the terms of this Charter, please refrain from using the Site and the Services.

1. In which cases do we collect your personal data and what data is collected ?

We may collect and store your personal data, in particular when you:

•       browse the Site 

•       [Actions on the Site or Services resulting in the collection of personal data. Examples: account creation, online payment, etc.]

•       contact us.

We use your personal data to enable the implementation and management of the Site Services and to respond to your specific requests. We also use your personal data to operate and improve our Services, our Site and our approach. This information is used only by us and allows us to better adapt our Services to your expectations.

If you opted to receive emails and messages from us when you created your Account, you will then receive electronic and alphanumeric messages about our products and promotions. We will then use the personal data you provided when you registered. You can unsubscribe from these mailings at any time.

1.1 Navigation on the Site

Login details.Each time you connect to our Site, we collect personal data such as, in particular, your IP address and the MAC address of your computer, the date and time of connection, as well as information on the browser you use.

Navigation data.We also collect information that identifies how you access the Site, which pages you view and for how long. In this context, we may use Cookies as specified in paragraph 6 below.

[If account creation is required]

1.2 Creation of an Account

Access to some of our Services requires the prior creation of an Account. In accordance with the General Conditions, you will be asked to provide a certain amount of personal data when creating your Account,including your first and last name, your postal address, your email address and your telephone number.

[If any Services on the Site are chargeable] 

1.3 Payment

Some of the Services available are subject to payment. For this purpose, you agree that we may use external service providers who may collect personal data in order to enable the proper functioning of credit card payment processing services or any other means of payment and, where applicable, delivery of products or services.  To pay for your purchase, you must provide your billing details as well as your payment details, including your bank card number, expiry date, security code and the name of the cardholder if paying by bank card. You may also be asked to provide your carrier name, mobile phone model and a valid mobile number so that we can provide purchase instructions directly to your mobile phone..  We retain details of your payments, as well as details of purchases you make. Transaction details are retained either in our systems or with the external service provider. This retention is carried out for internal purposes, including accounting, compliance and legal purposes, in accordance with paragraph 5 of this Charter.

 [If sending a newsletter]

 1.4 Subscription to our Newsletter

When creating your Account, you may give your prior consent to receiving our newsletters regarding news, new products, services and promotions, within the framework of the Services.  You can also directly consent to receiving our newsletters by entering your email address in the spaces provided for this purpose on the Site. In any event, you have the right to withdraw your consent to receiving such newsletters at any time and free of charge under the conditions set out in paragraph 6 of the Charter. 

1.5 Contacts

 In order to follow up on requests that you may make to our Customer Service and to confirm information concerning you, we may use your first name, last name, email address and telephone number.

 2. How do we protect your personal data ?

 We have implemented technical and organizational security measures to ensure the security, integrity and confidentiality of all your personal data, to prevent them from being distorted, damaged or accessed by unauthorized third parties. We ensure an appropriate level of security, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risks and their likelihood. However, it is specified that no security measure is infallible, we are not able to guarantee absolute security of your personal data. [If account creation is required]

Furthermore, it is your responsibility to ensure the confidentiality of the password that allows you to access your Account. Do not communicate this information to person. If you share your computer, remember to log out before leaving a Service.

3. In which cases do we share your personal data? 

 3.1 Sharing your personal data with third-party companies 

When you browse the Site, your personal data may be transmitted to external service providers. These third parties provide a service on our behalf and in our name in order to enable the proper functioning of credit card payments and other Services.

 {Note: If you use tools such as cloud storage software (e.g. Google Drive), a CRM (e.g. Zendesk, Salesforce) or any other tool that involves a transfer of data, and this tool locates its servers outside the European Union, you are most likely transferring data to a country outside the European Union. If in doubt, do not hesitate to consult your usual counsel or one of our partner lawyers} 

[If no transfer of personal data is made outside the EU]   

No transfer of personal data is made outside the European Union.   

[If there are transfers of personal data to a country outside the EU] 

Personal data may be transferred to countries located outside the European Union (such as[Name of countries receiving transfers of personal data]) for the purpose of[Purpose of the transfers made].   In accordance with the GDPR, all transfers of personal data to a country located outside the European Union and/or not offering a level of protection considered sufficient by the European Commission have been the subject of cross-border flow agreements in accordance with the standard contractual clauses issued by the European Commission.

 [If there are transfers to the United States]  

Other transfers of personal data to the United States are governed by the EU – US PRIVACY SHIELD:Click here for more information.   Except in the case where a third party asks you to accept a confidentiality charter and conditions of use specific to it, the third-party companies having received communication of your personal data have undertaken to process your personal data only for the implementation of our Services. We will never share, without having obtained your prior consent, your personal data with third-party companies for marketing and/or commercial purposes. 

3.2 Sharing with authorities 

We may be required to disclose your personal data to administrative or judicial authorities when their disclosure is necessary for the identification, arrest or prosecution of any individual likely to harm our rights, any other user or a third party. Finally, we may be legally required to disclose your personal data and cannot object in this case. 

4. How long do we keep your personal data? 

We will only keep your personal data for the duration of your registration on the Site in order to ensure your identification when you log in to your Account and to enable the provision of the Services. Therefore, if you unsubscribe from the Site, your personal data will be deleted and only kept in archive form for the purpose of establishing proof of a right or contract. In any event, we will keep your personal data for a period not exceeding that necessary for the purposes for which they are processed in accordance with the uses set out in this Charter and in compliance with laws and regulations.

 5. Cookies: how do we use them?

5.1 What is a cookie? 

A cookie is a text file that may be placed on a terminal when consulting an online service with browser software. A cookie file allows its issuer, during its period of validity, to recognize the terminal concerned each time that this terminal accesses digital content containing cookies from the same issuer.  In any event, cookies placed on your browser terminal with your consent are destroyed 13 months after they are placed on your terminal. 

5.2 What are the cookies issued on our Site used for? 

The cookies we issue allow us to: 

 • To establish statistics and volumes of traffic and use of the various elements making up our Site (sections and content visited, paths taken), allowing us to improve the interest and ergonomics of the Site and, where applicable, of our products and services.

• To adapt the presentation of our Site to the display preferences of your terminal (language used, display resolution, operating system used, etc.) during your visits to our Site, according to the hardware and viewing or reading software that your terminal has.

 • To memorize information relating to a form that you have completed on our Site (registration or access to your account) or to products, services or information that you have chosen on our Site (subscribed service, contents of an order basket, etc.)

• To allow you to access reserved and personal areas of our Site, such as your Account, using identifiers or data that you may have previously provided to us and to implement security measures, for example when you are asked to reconnect to content or a service after a certain period of time.

  [If there is a sharing gateway to social networks]

 When you browse the Site, social media cookies may be generated, in particular via the sharing buttons which collect personal data.  When you first visit the Site, a cookie banner will appear on the home page. A clickable link allows you to learn more about the purpose and operation of cookies and refers to this Charter. Continuing to browse another page of the site or selecting an element of the Site (in particular: image, text, link, etc.) materializes your acceptance of the deposit of the cookies concerned on your computer. 

5.3 How can you control the cookies used? 

You can configure your browser software at any time so that cookies are stored on your device or, on the contrary, that they are rejected (either systematically or according to their issuer). You can also configure your browser software so that the acceptance or rejection of cookies is offered to you punctually, before a cookie can be stored on your device. 

 Attention :any setting may modify your Internet browsing and your conditions of access to certain services requiring the use of cookies. We decline all responsibility for the consequences related to the degraded functioning of our services resulting from the impossibility of recording or consulting the cookies necessary for their functioning and that you have refused or deleted. This would be the case if you tried to access our content or services that require you to identify yourself. This would also be the case when we (or our service providers) could not recognize, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings or the country from which your terminal appears to be connected to the Internet. 

5.4 How to configure your navigation software?

 For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which you will allow you to know how to modify your cookie preferences. Below you will find information regarding the main browsers.

 Internet Explorer / Edge In Internet Explorer,

click the Tools button, and then click Internet Options. On the General tab, under Browsing History, click Settings. Click the View Files button.

 Firefox 

 • Go to the Tools tab of the browser and then select the Options menu 

• In the window that appears, choose Privacy and click on Show cookies    

Safari 

• Access Settings via the browser menu (Safari > Preferences)

 • Click on Privacy. 

Google Chrome

 • Access Settings via the button to the right of the URL bar or via the browser menu (Chrome > Preferences).

 • Select Advanced Settings 

• Click on Content settings then on Cookies. 

For more information about cookies, you can consult the CNIL website.   

 6. What are your rights?

 You are the only ones who have communicated to us the data in our possession, via the Site. You have rights over your personal data. In accordance with the regulations on the protection of personal data, in particular articles 15 to 22 of the GDPR, and after having proven your identity, you have the right to ask us for access to the personal data concerning you, the rectification or erasure of such data.    Furthermore, within the limits set by law, you also have the right to object to the processing, to limit it, to decide on the post-mortem fate of your data, to withdraw your consent at any time and the right to the portability of the personal data provided. You can contact our Services to exercise your rights at the following email address:[ e-mail address]or to the following postal address:[mailing address],by attaching a copy of an identity document to your request. [If sending newsletter] In addition, you can unsubscribe from our newsletter at any time by clicking on the unsubscribe link at the bottom of each email. You can also unsubscribe by sending a message to the following address:[e-mail address].

 7. Can we modify the Charter? 

 We reserve the right to modify the Charter at any time. You are therefore advised to consult it regularly. In the event of a modification, we will publish these changes on this page and in the places that we deem appropriate depending on the subject and the importance of the changes made. 

Your use of the Site after any changes means that you accept those changes. If you do not accept any material changes to this Charter, you must stop using the Site.

 8. Data Protection Officer and contact

 {Note: The appointment of a Data Protection Officer (DPO) is mandatory if you are "a company whose core business requires you to regularly and systematically monitor people on a large scale, or to process on a large scale so-called "sensitive" data or data relating to criminal convictions and offences." If this is not your case, the appointment of a DPO is still strongly recommended by the CNIL}

 [If designation of a DPO]

We have appointed a Data Protection Officer (DPO) with the CNIL (Designation No.[[DPO designation number with the CNIL]). The contact details of our Data Protection Officer are as follows:

[DPO Name and Firm] 

[DPO Postal Address]

[DPO Phone]

[DPO email address]

For any questions regarding your personal data or if you wish to delete your Account, please contact us at the following postal address:[Mailing address]( indicating "Privacy - Data Protection"), or by email to[E-mail address].

9. The National Commission for Information Technology and Civil Liberties ("CNIL") 

[In the event of declarations to the CNIL made prior to the entry into force of the [GDPR]

We have carried out the preliminary formalities required by the Data Protection Act with the CNIL. The collection and computer processing of personal data has been the subject of a simplified declaration no.[ [CNIL declaration number].

 We remind you that you can contact the CNIL directly on theCNIL website or by mail to the following address: National Commission for Information Technology and Civil Liberties (CNIL), 3 Place de Fontenoy - TSA 80715, 75334 PARIS CEDEX 07.