PRIVACY POLICY

Last updated: January 9, 2023

UNTIE NOTS is very committed to protecting the privacy of visitors and users (hereinafter the “User” or “You“) of its website https://www.untienots.com/ (hereinafter the “Website“).

In accordance with applicable regulations, and especially the General Data Protection Regulation n°2016/679 of 27 April 2016 (hereinafter the “Regulations”), the purpose of this privacy policy (hereinafter the “Policy“) is to inform Users of the Website about the categories of personal data collected, how such data is processed, for what purpose, for who and for how long it is stored.

The Policy also informs Users of their rights and how they can exercise them.

For any question relating to the Policy, You may contact the UNTIE NOTS Data Protection Officer (“DPO“): Ubiquity Avocats (contact@ubiquityavocats.com +33 (0)1.53.70.10.40).

1. The data controller

The data controller which processes Users’ personal data is UNTIE NOTS, a French “société par actions simplifiée” (SAS) with a share capital of €13 746, registered at the Nanterre Trade Register under number 812 492 767, whose registered office is located at 1 allée Santos Dumont, 92150 Suresnes, France (hereinafter “UNTIE NOTS“).

When Users visit the Website, UNTIE NOTS may process personal data in order to allow Users to access the services offered through the Website, such as, for example: obtaining a demonstration of UNTIE NOTS Platform, contacting UNTIE NOTS through the contact form or subscribing to the Newsletter (hereinafter the “Services“).

Personal data is defined as data or information relating to a natural person and which allow to identify or make this natural person identifiable, such as surname, first name, email or postal address, or telephone number (hereinafter the “Data“).

Through each Data collection form, UNTIE NOTS undertakes to collect only strictly necessary Data to comply with minimization principle.

2. Data collected by UNTIE NOTS

UNTIE NOTS may collect Users’ Data when providing the Services.

The Data we may collect are:

  • Contact Data: refers to the mandatory Data that the User provides (i) by filling in the contact form: name, business email address, business location, (ii) by requesting a demonstration of Untie Nots Platform: name, business email address, business location, or (iii) by subscribing to UNTIE NOTS Newsletter: email address.
  • Data voluntarily communicated by the User: refers to the Data that the User intentionally communicates to UNTIE NOTS, in particular via the free text areas when requesting a demo or filling in the contact form.

UNTIE NOTS strongly recommends that the User avoids communicating Personal Data via these free text areas or in any case to limit such communication to what is strictly necessary to process the User’s request. However, if UNTIE NOTS were to collect Data this way, UNTIE NOTS will use only Data strictly necessary to process the User’s request.

When providing the Data, the User will be informed whether Data is mandatory or optional. Where Data is mandatory but not provided by the User, access to the Services will be limited.

3. Purposes and legal basis of Data processing

Data collected when using the Website are subject to several processing operations responding to the following purposes:

  • To provide the “Services” as described above.
  • To respond to the User requesting a demonstration of the Platform.
  • To respond to any request made by the User via the “Contact” form.
  • To send UNTIE NOTS Newsletter to the User.

The processing of Data is based on the following legal basis:

  • Performance of pre-contractual measures taken at the User’s request, when the User request a demonstration of the Platform.
  • User’s consent when filling in the “Contact” form. Consent is formalized by sending the message to UNTIE NOTS.

User’s consent when subscribing to the Newsletter. Consent is formalized by clicking the related box and submitting the request. 

4. Recipients of Data

UNTIE NOTS may communicate Data to different internal recipients depending on the purpose of the processing. UNTIE NOTS may also collaborate with subcontractors who will carry out Data processing in the name and on behalf of UNTIE NOTS based on its instructions. Finally, UNTIE NOTS may communicate Data to external recipients such as accountants, external auditors, lawyers.

The recipients of the Data may be:

  • Internal recipients (within UNTIE NOTS): As the case may be, UNTIE NOTS’s personnel in charge of (i) processing Users’ requests, or (ii) carrying out demonstrations of the Platform, or (iii) sending the Newsletter.
  • External recipients:

– Data communicated to public authorities and/or public bodies: In accordance with the Regulations, Data may be transferred to the competent authorities upon request and in particular to public bodies, exclusively to meet legal obligations, court officials, judicial officers and bodies in charge of debt collection, as well as for the research of perpetrators of offences committed on the Internet.

– Data communicated to subcontractors: Data may be communicated by UNTIE NOTS to its service providers (in particular IT service providers for purposes such as database management, hosting, storage, maintenance, etc.), its auditors or statutory auditors, accountants, lawyers, or business partners under the conditions described above.

UNTIE NOTS shall in any event ensure that recipients of the Data, whether internal or external, are bound by an obligation of confidentiality or by secrecy and are subject to the same obligations than the ones provided in this Privacy Policy. 

5. Data transfer outside the EU or EEA

UNTIE NOTS does not transfer User’s Data to countries outside the European Union. If UNTIE NOTS were to carry out such a transfer, the User would be informed beforehand and the transfer would be carried out in an appropriate legal framework and in a secure manner in accordance with the Regulations. 

6. Users’ rights

In accordance with the Regulations and as a data subject concerned by the Data processing, the Users have the following rights:

  • The right of access allows You to access (and obtain a copy of) Data we process about You in an intelligible and easily accessible manner. You also have the right to obtain confirmation that your Data is being processed.
  • The right to rectification allows You to obtain the correction of any error, inaccuracy, obsolescence or insufficiency of your Data.
  • The right to erasure of your Data in certain cases. This right is not absolute and has limits, such as legal obligations or legitimate reasons to keep the Data.
  • The right to restrict the Data processing in certain cases.
  • The right to Data portability in a structured and commonly used format, for your personal use or to transmit them to a third party of your choice. This right applies only where the processing of your Data is carried out by automated means and based on your consent or on the performance of a contract.
  • The right to object to the processing: You have the right to object at any time to a Data processing based on our legitimate interest or related to commercial prospecting purposes. This right is not absolute and can be refused for legal or legitimate reasons.
  • The right to withdraw a given consent at any time.
  • The right to give instructions concerning the fate of your Data after your death.

The User may exercise these rights at any time by contacting UNTIE NOTS at contact@untienots.com. 

You are informed that when You exercise your rights, You may be asked to prove your identity, in particular by sending an identity document or any other document allowing verification of the truthfulness of your request, in order to protect UNTIE NOTS and the User against any fraudulent request.

Finally, the User has the right to lodge a complaint with the supervisory authority of his/her country of residence, for France, the CNIL: https://www.cnil.fr/.

7. Data storage and archiving

User’s Data will be kept for no longer than is necessary for the purposes stated herein and in accordance with the Regulations.

Data collected to respond to a request for a demonstration of the Platform or those sent via the “Contact” form is kept no longer than the time required to process the request.

Data collected via the Website for Newsletter subscription is kept for three (3) years from the date of the User’s last contact. 

These storage periods do not prevent You from exercising your rights, as detailed in Article 6 above. User’s Data are in principle erased when the storage periods expire or stored in intermediate archiving under secure conditions in accordance with the Regulations for the purposes of researching, establishing or pursuing criminal offences for the sole purpose of allowing, as necessary, the availability of such Data to the judicial authority.

In addition, UNTIE NOTS may store Data definitively anonymized for the purpose of producing statistical studies.

8. Use of cookies

Through the website, UNTIE NOTS only places cookies that are necessary for the use of the Website. 

Cookies are small text files of letters and numbers that can be used by websites to facilitate the user’s experience.

Necessary cookies are technical cookies that are essential to the functioning of the Website. They allow the User to use the main features of the Website and do not allow any behavioral or identification tracking.

Such cookies are activated by default and cannot be deactivated by the User. Browser settings may allow the User to block these cookies, with potentially negative effects on the operation of the Website. 

9. Security

The databases created in the context of the Data processing described in this Policy are strictly confidential. UNTIE NOTS undertakes to take all useful precautions and appropriate organizational and technical measures to preserve the security, integrity and confidentiality of the Data and specially to prevent it from being compromised, damaged or accessed by unauthorized third parties.

UNTIE NOTS shall take adequate technical and organizational measures to prohibit unauthorized access or disclosure of Users’ Data. However, UNTIE NOTS cannot guarantee the absence of any risk of Data misuse.

10. Data collection by third party websites

The Website contains links to third party websites whose information and data collection practices may differ from those of UNTIE NOTS. Users are encouraged to review the privacy policies of such third party websites, since UNTIE NOTS has no control over the information submitted to and/or collected by such third party websites.

11. Updating of the Policy

The Policy may be modified at any time by UNTIE NOTS, in particular in order to comply with any regulatory, jurisprudential, editorial or technical developments.

The User should refer to the latest version of the Policy before browsing the Website.