PRIVACY POLICY

Last updated: April 22, 2021

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 “Site”).
In accordance with the Regulations, the purpose of this privacy policy (hereinafter the “Policy”) is to inform Users of the Site of the category of personal data collected, how such data is processed, for what purpose, to whom it is intended to 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 Data Protection Officer (“DPO”) of UNTIE NOTS: Ubiquity Avocats (contact@ubiquityavocats.com +33 (0)1.53.70.10.43).

1. The data controller

The data controller responsible for processing Users’ personal data is UNTIE NOTS, a French “société par actions simplifiée”(SAS) with a share capital of €13 702, 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 the “Publisher” or “UNTIE NOTS”).
When Users use the Site, the Publisher may process personal data in order to allow Users to access the services offered by the Site, such as, for example: obtaining a demonstration of the Loyalty Challenge solution; contacting UNTIE NOTS or applying for a position via the “Join Us” tab (hereinafter the “Services”).
Personal data is defined as data or information relating to a natural person that makes it possible to identify him or her or to make him or her identifiable, such as his or her surname, first name, email or postal address, or telephone number (hereinafter the “Data”).
For each Data collection form, the Publisher undertakes to limit the collection of Data to what is strictly necessary to respect the principle of Data minimization.

2. Data we collect

UNTIE NOTS may collect Users’ Data in the context of the provision of the Services, including when simply visiting the Site.
The Data we collect are:
Contact Data: refers to the mandatory Data that the User provides by filling in the contact form: name, email address by requesting a demonstration of the Loyalty Challenge solution: name, email address.

Data published/communicated voluntarily by the User: refers to the Data that the User intentionally communicates to the Publisher, in particular via the free text areas in the context of a request for a demonstration of the “Loyalty Challenge” solution or when filling out the contact form or in the context of an application posted on the Site.

UNTIE NOTS strongly recommends that the User avoids communicating 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 in this way, UNTIE NOTS will use only Data strictly necessary to process the User’s request.

Data collected during an application on the Site: when You apply spontaneously or when You respond to an advertisement published on the Site: refers to the name, email address, Data from the CV and cover letter as You upload them on the Site, as well as any Data voluntarily communicated in the free text area. In this respect, the Data that we may be led to process are:
surname, first name,
age,
personal status,
postal and email address,
phone number,
professional experience,
diplomas
position for which the application is being made, and
more generally, any other information provided by the User in the context of the application.

3. Purposes and legal basis of Data processing

Data collected during the use of the Site are subject to several processing operations in order to meet the following purposes:
To provide the “Services” as described above.
To respond to the User’s request to obtain a demonstration of the Loyalty Challenge solution.
To respond to any request made by the User via the “Contact” form.
To personalize Users’ browsing on the Site according to their interests and needs.
To manage the security of the Site.
To compile statistics on the knowledge of UNTIE NOTS’ Services and on the Site’s frequentation measurements.
With the aim of recruiting, to manage Users’ applications of Users filed on the Site https://www.untienots.com/. In this respect, UNTIE NOTS may: analyze the applications (skills, qualifications, diplomas, suitability of the position to the application), verify the content and, if necessary, take references after informing the candidate, or interact with the candidate.
Verify Your identity.

At the time of Data collection, the User will be informed whether Data is mandatory or optional. Otherwise, access to the Services and their use by the User may be restricted.
The processing of Data is based on the following legal basis:
The performance of a contract to which the User is a party or the performance of pre-contractual measures taken at the User’s request, when the User wishes to obtain a demonstration of the Loyalty Challenge solution.

The User’s consent to the processing of Data freely communicated when the User contacts UNTIE NOTS via the “Contact” form. Consent is formalized by sending the message by email to UNTIE NOTS.

The legitimate interest of UNTIE NOTS without disproportionately affecting the rights of the User: to know its clientele and to adapt its Site and its offers according to the information completed by the User and/or the browsing of the User on the Site.

The legitimate interest of UNTIE NOTS which doesn’t disproportionately affect the rights of the User, and/or as the case may be, the respect of the legal obligations of the Publisher, in the context of the management of the security and maintenance of its Site

The legitimate interest of UNTIE NOTS, where it doesn’t disproportionately affect the rights of the User, to analyze the applications submitted to it by the User via the Site https://www.untienots.com/.

4. Recipients of Data

UNTIE NOTS may communicate Data to different internal recipients depending on the purpose of the processing (HR department; marketing department; technical department). UNTIE NOTS may also collaborate with subcontractors who will carry out Data processing in the name and on behalf of UNTIE NOTS and on its instructions (such as, for example, IT service providers, software or hardware suppliers). Finally, UNTIE NOTS may communicate Data to external recipients such as accountants, external auditors, lawyers.
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.
The recipients of the Data may be:
Internal recipients (within UNIT NOTS):
As the case may be, the persons in charge of processing Users’ requests, or carrying out demonstrations of the Loyalty Challenge solution, or managing the security or maintenance of the Site, or (iv) managing Users’ applications (Human Resources department).
Subject to the User’s consent, UNTIE NOTS may also transfer User Data to its commercial partners.

External recipients:
Data transferred 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 in the case of searching for the perpetrators of offences committed on the Internet.
Data transferred to third parties: Data may be communicated by the Publisher to its subcontractors (in particular IT service providers such as database management, hosting, storage, maintenance, etc.), its auditors or statutory auditors, accountants, lawyers, or business partners under the conditions described above.

5. Data transfer outside the EU

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, You, as a data subject concerned by the Data processing, 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: You have the right to obtain the rectification or to complete them.

The right to erasure of your Data in certain cases. This right is not absolute and has limits. We may indeed be led for legal or legitimate reasons to keep these 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 when the processing of your Data is based on your consent, on a contract or is carried out by automated means.

The right to object to the processing: You have the right to object at any time to the processing of your Data based on our legitimate interest, and for commercial prospecting purposes. This right is not absolute. We can indeed, for legal or legitimate reasons, refuse your request to object.

The right to give instructions concerning the fate of your Data after your death.

The User may exercise his/her rights at any time by contacting UNTIE NOTS contact@untienots.com.
When the User has given his/her express consent to the collection of his/her Data on the Site by means of a checkbox or by any other means, he/she is informed that he/she may, at any time, withdraw his/her consent.
The User is informed that in the event that he/she exercises his/her rights, he/she may be asked to prove his/her identity, in particular by sending an identity document or any other document allowing verification of the truthfulness of his 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 Loyalty Challenge solution or those sent via the “Contact” form are kept no longer than the time required to process the request.
Data collected via the Site for the management of applications will be kept for a maximum of two (2) years from the User’s last contact unless the User has objected to this or if the User is actually recruited by UNTIE NOTS.
These storage periods do not prevent You from exercising Your rights, as detailed in Article 5 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 research, the establishment, exercise or defence of criminal offences for the sole purpose of allowing, as necessary, the availability of such Data to the judicial authority.
In addition, the Publisher may store Data definitively anonymized for the purpose of producing statistical studies.

8. Security

The databases created in the context of the Data processing described in this Policy are strictly confidential. The Publisher 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 them from being distorted, damaged or accessed by unauthorized third parties.
The Publisher shall take adequate technical and organizational measures to prohibit unauthorized access or disclosure of User Data. However, the Publisher cannot guarantee the elimination of any risk of misuse of the Data.

9. Data collection by third party websites

The Site 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 sites, as UNTIE NOTS has no control over the information submitted to and/or collected by such third party websites.

10. Updating of the Policy

The Policy may be modified at any time by the Publisher, in particular in order to comply with any regulatory, jurisprudential, editorial or technical developments.
The User must refer to the latest version of the Policy before any browsing on the Site.