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Privacy Policy

POLITIQUE DE CONFIDENTIALITE DU GROUPE KOGNITIF

Please read this privacy policy (the “Privacy Policy”) carefully as it describes how we collect, use, disclose, store and protect your personal data.

This Privacy Policy applies to any website, application or service that references this Privacy Policy. When you provide us or we collect personal data as described in Paragraph 2 below, you authorize us to collect, store and use data such as:

  1. To fulfill our contractual obligations to you,
  2. As part of our legitimate interest in processing your personal data (e.g. for internal administrative purposes, data analysis and benchmarking (see paragraph 3 below for more information), direct marketing, maintaining automatic back-up systems or detecting or preventing criminal activity), or
  3. Based on your consent, which you have the right to withdraw at any time, as described in this Privacy Policy.

This privacy statement may apply to you even if you are not one of our customers and even if you have never used one of our websites, applications or services. Some of your personal information may be in our possession because it was provided to us by a user of one of our websites, applications or services.

Brexit: in this Privacy Statement, references made to “GDPR” also include any type of UK “GDPR” created by the UK Data Protection Act 2018 upon the UK’s exit from the European Union.

  1. Who Are We?

This Privacy Policy applies to all products, applications and services offered by KOGNITIF SAS, registered in the Trade and Companies Register of Caen under number 852421387 and whose registered office is located at the following address: 26, Avenue de Thiès, 14000 Caen, France and by its subsidiaries, with the exception of any other product, application or service governed by separate privacy policies that do not incorporate the provisions of this Privacy Policy.

  1. How Do We Collect Information?

Subject to applicable law, we collect information about you or any third party whose information you provide to us when you:

– Register to use our websites, applications or services (including during free trials); this may include your name (or company name, if applicable), address, email address and telephone number. We may also ask you to provide additional information about your business and preferences;

– Place an order using our websites, apps or services; this may include your name (or company name), address and contact information (including phone number and email address) and payment information; use of our apps, which may include the collection of metadata ;

– Fill out online forms (including callback requests), take part in surveys, post messages on our discussion forums, post blogs, enter contests or sweepstakes, download information such as white papers or other publications, or participate in any of the activities offered on the various interactive areas of our website or on our application or service;

– Interact with us using social networks;

– Provide us with your contact information when you register or access any website, application or service we provide or when you update that information; and

– Contact us offline, for example, by phone, fax, SMS, email or mail.

We will also collect your data when you complete only part of the fields on our site and/or on other online forms and/or when you abandon your entry in the process. We may use this data to contact you to remind you to enter missing information and/or for marketing purposes.

We may also collect information from your electronic devices (including cell phones) and applications used by you or your users to access and use any of our websites, applications or services (for example, we may collect the identification number and type of device used, geolocation and connection information, such as statistics on pages visited, traffic to and from the sites, referring URL, advertising data, your IP address, browsing history and web log information). We may use cookies or other similar means (as described in Paragraph 11 below) for this purpose.

Subject to applicable law, we may supplement the personal data we collect with information obtained from third parties who are authorized to share it; for example, information from credit institutions, information providers or public sources (e.g., for due diligence purposes).

Providing Us With Third Party Data
If you provide us with personal data concerning a third party, it is your responsibility to ensure that you comply with the applicable regulations on the protection of personal data and in particular your obligations to obtain the prior consent of the persons whose personal data you provide to us. As such, in accordance with applicable data protection regulations, you must have notified the subject and obtained his or her express consent, or that you have a legal basis to provide us with his or her personal data, and informed him or her of the manner in which we collect, use, disclose and retain his or her personal data or invited him or her to read our Privacy Policy.

  1. How Do We Use Your Data?

Subject to applicable laws, we collect and process your data for the following purposes:

– To provide any information and services you have requested and any applications or services you have ordered;

-To compare information for the purpose of verifying its accuracy and corroborating it with third parties;

-To provide, maintain, protect and improve the applications, products, services and information you have requested from us;

-To manage and administer your use of the applications, products and services you have requested us to provide;

-Manage our business relationship (e.g., customer services and support activities);

-To monitor, measure, improve and protect our content, websites, applications and services and to provide you with a personalized and quality user experience;

-Conduct internal reviews of our websites, applications, systems and services to test and improve their security, delivery and performance. Where appropriate, we will use a pseudonymised form of any information used for such purposes, and we will ensure that such information is presented in aggregate and is not linked to you or any other individual;

-Provide you with any information we are required to provide to you in order to comply with our regulatory or legal obligations;

-To comply with any other regulatory or legal obligation;

-To detect, prevent, investigate or deter criminal, illegal or prohibited activities or to protect our rights (including liaising with regulatory and law enforcement agencies for these purposes);

-Contact you to find out if you would like to participate in our customer surveys (for example, feedback on your use of our applications, products and services)

-To conduct joint statistical and comparative analysis and tracking to prevent you or any other individual from being identified, except as required by law;

-Provide you with advertisements, marketing messages (which may include pop-up banners) or targeted information that may be of value to you based on your use of our applications and services

-Deliver content and services in conjunction with third parties with whom you have a separate relationship (for example, social network providers);

-To provide you with various location-based services (for example, advertising or other personalized content), where we collect geolocation data.

To the extent permitted by applicable law, we will retain information about you after your konnexion.io account is closed, if your application for a konnexion.io account is denied, or if you decide not to proceed with your application. This information will be retained and used for legal, regulatory, anti-fraud and legitimate business purposes for as long as legally permitted.

Our websites, applications (including mobile applications) and services may contain technologies that allow us to:

-Check specific information from your device or systems necessary for your use of the Websites, Applications or Services against our records to ensure that the Websites, Applications or Services are being used in accordance with our Terms and Conditions and end-user agreements and for the purpose of resolving any problems ;

-To obtain information about technical errors or other problems with our websites, applications and services

-To comply with our regulatory or legal obligations;

-To collect information about how you and other users use the features of our websites, applications and services; and

-Collect statistical information about the operating system and environment from which you access our applications or services.

You can manage your privacy settings in your browser or on our applications or services (if applicable).

In addition to the ways described in Paragraph 3 above, we may also use the information we collect to deliver advertisements, marketing messages (including pop-up banners) or information that may be useful to you based on your use of the websites, applications or services, or any other information we have about you (depending on the website, application or service, you will have the option to configure these features to suit your preferences). Paragraphs 5 and 6 of this Privacy Policy provide additional information on how we do this.

We reserve the right to retain and record communications between us, including e-mails and telephone conversations. The information we collect may then be used for training, quality assurance, recording statistics about the use of the websites and applications and the services you order from us or request information about, and to generally meet our legal and regulatory obligations.

Mobile Data

We may obtain information through mobile applications that you or your users install on their mobile devices for the purpose of accessing and using our websites, applications or services, or for the purpose of providing other services related to such mobile applications (for example, for the purpose of synchronizing information from our application or service with such mobile applications). These mobile applications may be our own mobile applications or those of third parties. In the case of a third party mobile applications, you should read the third party’s Privacy Policy as it will apply to your use of the third party application. We are not responsible for third party mobile applications and their use of your personal information.

Mobile applications may provide us with information about the user’s use of the mobile application and the use of our applications and services accessed by the user through the mobile application. We may use this information to provide and improve the mobile application or our own services or applications. For example, you may record activity with a mobile application.

You may configure the privacy settings of our mobile application on your device, which may affect the performance of the mobile application and the way it interacts with our applications and services.

Data Analysis and Benchmarking

We may use the information generated and stored when you have used our services for our legitimate business interest to be able to provide you with the best service and/or solutions and the best experience. These purposes may be to:

-Send you advertising or marketing messages (including in-product messages) or information that may be useful to you, based on your use of our services;

-Conduct research and development to improve our services, products and applications;

-Develop and provide new and existing functionality (including statistical analysis, benchmarking, insight, receipt recognition and cash flow forecasting); and

-Provide you with services that are tailored to your geographic location (e.g., content that is relevant to your location) for which we collect geolocation data in order to provide you with a relevant experience.

Please be aware that our use may include the personal information of your customers, suppliers, employees and others whose information you enter on our websites, applications or services.

You have the right to object to your data being processed for our legitimate interest. In such a case you are invited to contact us at globalprivacy@konnexion.io.

  1. Sharing Of Your Information
    We may share your personal data with :

– any company within the Kognitif Group, for the purposes set out in this Privacy Policy (for example: for global information management and customer relationship management; for accounting and software and service improvement purposes; and for the purpose of providing you with information, applications, products or services that you have requested);

-Our service providers and agents (including their subcontractors) or third parties who process information on our behalf (e.g., Internet platforms or service providers, payment processors, and companies we use to help us send communications to you) so that they can help us provide you with applications, products, services, and information that you have requested or that we believe may be of interest to you;

-Partners, including system implementers, resellers, distributors, software vendors and developers, who help us provide you with applications, products, services and information that you have requested or that we believe may be of interest to you;

-Third parties that we have used to carry out payment transactions, such as clearing companies, clearing systems, financial institutions and payees;

-Third parties, where you have a relationship with such third party and have consented to us passing on information (for example, social networking sites or other third party application providers);

-Third parties for marketing purposes (for example: our partners and other third parties with whom we work whose products we believe may be of interest to you in the course of conducting your business. For example: financial service providers (such as banks, insurers and financial service providers), payment solution providers, software providers and service providers that provide business solutions);

-Credit reference and fraud prevention agencies;

-Government agencies, regulators and any other third parties necessary to meet Kognitif Group’s legal and regulatory obligations;

-Law enforcement authorities, so that they may detect or prevent crimes or prosecute offenders;

-Any third party, in connection with existing or threatened legal proceedings, provided we are legally authorized to do so (for example, in response to a court order);

-Any third party, in order to comply with our legal and regulatory obligations, including legal or regulatory reporting and the detection or prevention of unlawful acts;

-Our own and the Kognitif Group’s auditors and consultants, in order to fulfill our audit responsibilities;

-Another company, if we sell or buy a business or assets (or negotiate the sale or purchase of a business or assets);

-Any other company to which we may assign the contract between us; and

-Public bodies required to be informed by applicable law.

We may share, publicly or with third parties, information about our websites, applications, products or services that does not include any information that could identify you.

We are required by law to provide metadata to HM Revenue & Customs (HMRC) when you use a Making Tax Digital-enabled software package or application to help you complete, file or update tax returns. To learn more about the data sent to HMRC, click here. To view HMRC’s transaction monitoring privacy statement, click here.

  1. Marketing

We may use your information from time to time to contact you with information about our applications, products and services that may be of interest to you. We may also share your information with our group companies and carefully selected third parties so that they (or we) may contact you with information about their products or services that may be of interest to you. For this purpose, you may be contacted by telephone, mail, SMS or e-mail. You have the right to ask us to stop contacting you for marketing purposes at any time. You may also, at any time, ask us not to share your information with the third parties mentioned in this paragraph. If you wish, you may exercise these rights by selecting your contact preferences at the point where you provide us with your personal data on our websites, applications or services, by using any preference center to which we give you access, or by sending us an email at globalprivacy@konnexion.io.

You may also unsubscribe from any marketing campaign and/or e-mail advertisement by clicking on the link included in the e-mails we send you.

Advertising on a Third-Party Platform
When you respond to communications posted on third-party platforms (e.g., LinkedIn, Instagram, Facebook, Google, or Twitter) we may potentially share your data with these third parties in order to send you targeted advertising content through the third-party platform and based on your profile and interests. Your data is used by the third party platform provider to identify your account and display ads on your screen. You can control which ads you receive on the privacy settings of the third party platform provider, and you can also visit the third party’s help center to learn more.

Your Data and Your Rights

If you reside in the EEA or another region governed by comparable data protection laws, in some cases you will have the following rights:

-The right to know how we use your data and the right to access your data;

-The right to request the modification or deletion of your data and to restrict the processing of your data;

-The right to object to the processing of your data, for example for marketing purposes or when their use is based on our legitimate interest;

-The right to receive the data about you that you have provided automatically in a structured, commonly used and machine-readable format, or to have it sent directly to another company, if this is technically feasible (“data portability”);

-Where you have consented to the processing of your data yourself, the right to withdraw your consent in accordance with legal or contractual limitations;

-The right to refuse any decision based on the automated processing of your personal data, including profiling; and

-The right to lodge a complaint with the supervisory authority responsible for data protection issues (e.g., Commission Nationale de l’Informatique et des Libertés).

If we have incorrect information about you or if your contact information has changed, please let us know so that we can correct it and update our records.

If you withdraw your consent to the use of your personal data for the purposes set out in our Privacy Policy, we may, as a result, no longer be able to provide you with access to all or part of our websites, applications and services.

We will retain your personal data for the duration of our business relationship and after the end of the relationship for as long as is necessary for the legitimate conduct of our business in accordance with the Group Data Retention, Marking and Destruction Policy, or to comply with applicable laws and regulations. In the event that we no longer need your personal data, we will destroy it in a secure manner (without further notice).

  1. Changes to this Privacy Policy
    This Privacy Policy may change from time to time. However, such changes will not affect your rights under this Privacy Policy. We will always update this Privacy Policy on our website. Therefore, when you visit our website, we encourage you to review this Privacy Policy to ensure that you are aware of the most current version (the “last updated” notice informs you of the date of the last update).
  2. Security and Storage of Personal Data
    We ensure the security of your data by taking the necessary technical and structural measures to prevent unlawful or unauthorized processing or accidental loss, destruction and/or damage. We strive to protect your personal data to the best of our ability. However, we cannot guarantee the security of your data transmitted to our websites, applications or services or to other websites, applications and services via an Internet connection or any other connection. If we have given you (or if you have chosen) a password to access certain areas of our websites, applications or services, please keep your password confidential; we will not share your password with anyone.

If you believe your account has been hacked, please contact us at globalprivacy@konnexion.io.

  1. Transfers outside the European Economic Area and the United Kingdom
    Within the European Union and the United Kingdom, personal data is protected by data protection laws. However, other countries may not protect your personal data in the same way.

Our website, and some of our services or applications, or parts thereof, may also be hosted in the United States or outside the United Kingdom or outside the EEA (which consists of all countries in the European Union plus Norway, Iceland and Liechtenstein). This means that we may transfer any data transmitted to us through the Website, Application or Service outside the European Economic Area (“EEA”) to the United States or other territories outside the EEA. When you send us an email, it will also be stored on our email servers which are hosted in the United States of America.

We may use the services of service providers located outside the EEA to help us provide our websites, applications and services to you (such as, for example, platform or payment service providers who help us deliver our services and applications or execute your payments). This means that we may pass your data to service providers located outside the EEA for the purpose of providing our apps and services to you.

We take care to ensure that when our hosting and service providers transfer your data outside the EEA, appropriate measures and controls are in place in accordance with applicable laws and regulations to protect it. For example, we may share such data with our group companies or affiliates located outside the EEA for the purposes set forth in this Privacy Policy. All Kognitif Group companies are subject to Kognitif Group’s data protection policies, which are designed to protect data in accordance with EU data protection laws. In each case, such transfers are made in accordance with the requirements of Regulation (EU) 2016/679 (General Data Protection Regulation) and may be based on the use of the European Commission’s Standard Clauses on Transfers of Personal Data Outside the EEA.

By using our websites, products and services or by interacting with us as described in this Privacy Policy, you consent to the transfer of your data outside the EEA in the circumstances set out in this Privacy Policy. If you do not consent to the transfer of your data outside the EEA, you will not be able to use our websites, applications or services.

  1. Other Sites and Social Networks

If you follow a link from our websites, applications or services to another site or service, this Privacy Policy no longer applies. We are not responsible for the privacy practices of third party sites or services and we encourage you to read the privacy policies posted on those sites or services.

Our websites, applications or services may allow you to share data with social networking sites or to use social networking sites to create your account or log into your social networking accounts. These social networking sites may automatically provide us with access to certain personal data about you that is maintained by these sites (for example, any content you have viewed). It is up to you to manage your privacy settings from your own third party social network account(s) so that you can choose what personal data you allow us to access from those third party accounts.