PRIVACY POLICY
(hereinafter, the « Site »)
This privacy policy is intended to help you understand how your personal data is collected, processed, and stored by TWOO WAY through the Site.
TWOO WAY understands that data protection and privacy are issues for all users visiting the Site.
TWOO WAY is committed, in accordance with the GDPR regulations defined below, to respecting your privacy and protecting your personal data—meaning any information likely to identify you directly or indirectly as an individual.
The objective of this privacy policy is to present TWOO WAY's commitments in this matter.
1. DEFINITION
During your use of our Site and your request to be put in contact with other users, we may ask you to provide us with personal data concerning you.
The term "personal data" refers to all data that allows for the identification of an individual, which corresponds notably to your name, first names, pseudonym, photograph, postal and email address, job title, phone numbers, date of birth, data relating to your transactions on the Site, details of your purchases, bank card numbers, IP address, as well as any other information you choose to communicate to us about yourself.
2. OBJECT
This policy (hereinafter the "Policy") aims to inform you about the means we implement to collect your personal data, in the strictest respect of your rights.
In this regard, we inform you that we comply, in the collection and management of your personal data, with Law No. 78-17 of January 6, 1978, relating to information technology, files, and liberties, in its current version (hereinafter the "Data Protection Act"), as well as Regulation (EU) 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter: "GDPR").
3. IDENTITY OF THE DATA CONTROLLER
The controller of your personal data is TWOO WAY, a simplified joint-stock company with a capital of 1,000 euros, whose registered office is located at 29 rue Tronchet - 75008 Paris and registered in the Paris Trade and Companies Register under number 100 492 511 (hereinafter referred to as "We").
4. PURPOSES AND LEGAL BASES OF PROCESSING
The legal basis for our collection of your personal data is as follows:
- This collection is necessary to execute the contract concluded when you use our services on our Site, whether they are paid or free;
- Legitimate interest when you voluntarily provide us with personal data during your visit to our Site, the data then being collected to allow us to better respond to your requests for information about our services.
Your personal data is collected to meet one or more of the following purposes:
- Manage your access to certain services accessible on the Site and their use,
- Perform operations relating to customer management concerning contracts, invoices, and follow-up of the relationship with customers,
- Build a file of users, customers, and prospects,
- Send newsletters, solicitations, and promotional messages. In the event that you do not wish this, we give you the opportunity to express your refusal in this regard during the collection of your data,
- Develop commercial and traffic statistics for our services,
- Manage the management of reviews of persons on products, services, or content,
- Manage unpaid debts and potential litigation regarding the use of our products and services,
- Personalize responses to your requests for information,
- Comply with our legal and regulatory obligations.
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Why do we collect your personal data? |
Which categories of personal data do we collect for this purpose? |
What is the legal basis authorizing us to collect your personal data for such a purpose? |
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We collect your personal data to identify you when using our Site and to send you communications related to the proper administration of our Site (e.g., registration confirmation, updates to the Site or terms of use, etc.). |
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The legal basis for this processing is the performance of the contract between us, resulting from your acceptance of our general terms and conditions at the time of account creation |
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We collect your personal data to deliver your order/service. |
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The legal basis for this processing is the performance of the contract between us, resulting from your acceptance of our general terms and conditions at the time of account creation |
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We collect your personal data to improve and optimize our Site, for instance by analyzing your behavior during your visit to implement changes regarding ergonomics and user experience. |
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The legal basis for this processing is our legitimate interest in providing and improving the user experience for our visitors and members of our Site. |
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We collect your personal data to understand your preferences and to provide you with commercial offers for products or services similar to those already ordered. |
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The legal basis for this processing is our legitimate interest in providing and improving the user experience for our visitors and members of our Site. |
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At the time of collection of your personal data, we will inform you whether certain data must be provided or if they are optional.
5. RECIPIENTS OF PERSONAL DATA
The following will have access to your personal data:
- Our company personnel;
- Services in charge of control (notably lawyers and accountants);
- Our processors (communication providers, productivity software providers, data hosting providers, payment service providers, billing providers, analysis and audience measurement providers, customer relationship management providers);
- Public bodies may also be recipients of your personal data, exclusively to meet our legal obligations, as well as legal assistants, ministerial officers, and bodies in charge of debt collection.
6. PERSONAL DATA RETENTION PERIOD
6.1 Regarding data relating to the management of customers and prospects:
Your personal data will not be kept beyond the period strictly necessary for the management of our commercial relationship with you.
However, data required to establish proof of a right or a contract, which must be kept to comply with a legal obligation, will be stored for the period provided by the law in force.
Regarding potential prospecting operations aimed at customers, their data may be kept for a period of three (3) years from the end of the commercial relationship.
Personal data relating to a prospect (non-customer) may be kept for a period of three (3) years from their collection or the last contact from the prospect.
At the end of this three (3) year period, we may contact you again to find out if you wish to continue receiving commercial solicitations.
In the event of the exercise of the right of access or rectification, data relating to identity documents may be kept for the period provided for in Article 9 of the Code of Criminal Procedure, i.e., one (1) year. In the event of the exercise of the right to object, this data may be archived for the limitation period provided for in Article 8 of the Code of Criminal Procedure, i.e., six (6) years.
Financial transactions relating to the payment of purchases and fees via the Site are entrusted to a payment service provider who ensures their smooth operation and security.
For the needs of the services, this payment service provider may receive your personal data relating to your bank card numbers, which it collects and keeps in our name and on our behalf. We do not have access to this data.
To allow you to make regular purchases or pay the related fees on the Site, your bank card data is kept for the duration of your registration on the Site and, at the very least, until the moment you carry out your last transaction.
Data relating to the visual cryptogram or CVV2, inscribed on your bank card, is not stored.
If you refuse to have your bank card numbers kept under the conditions specified above, we will not keep this data beyond the time necessary to allow the completion of the transaction.
In any event, data relating to these may be kept for evidence purposes in the event of a potential dispute over the transaction, in intermediate archives, for the period provided for by Article L 133-24 of the Monetary and Financial Code, in this case thirteen (13) months following the debit date. This period may be extended to fifteen (15) months to take into account the possibility of using deferred debit payment cards.
6.2 Regarding the management of lists of objections to receiving prospecting:
Information allowing your right to object to be taken into account is kept for a minimum of three (3) years from the exercise of the right to object.
6.3 Regarding audience measurement statistics:
Information stored in users' terminals or any other element used to identify users and allowing their traceability or frequency of visits will not be kept beyond thirteen (13) months.
7. SECURITY
We inform you that we take all useful precautions, appropriate organizational and technical measures to preserve the security, integrity, and confidentiality of your personal data and, in particular, to prevent it from being distorted, damaged, or accessed by unauthorized third parties. We also use secure payment systems that comply with the state of the art and applicable regulations.
8. HOSTING
We inform you that your data is kept and stored, for the entire duration of its retention, on the servers of Twoo Way company.
9. TRANSFER OUTSIDE THE EUROPEAN UNION
Your data may be transferred outside the European Union as part of the tools we use and our relationships with our processors.
This transfer is secured by means of the following tools:
- Either the data is transferred to a country that has been deemed to offer an adequate level of protection by a decision of the European Commission;
- Or we have concluded a specific contract with our processors governing the transfer of your data outside the European Union, based on standard contractual clauses between a data controller and a processor approved by the European Commission.
10. ACCESS, RECTIFICATION, LIMITATION AND ERASURE OF YOUR PERSONAL DATA
In accordance with European regulations on the protection of personal data, you benefit from the following rights:
- A right of access allowing you at any time to know if your personal data is being processed by our services and, when it is, to have access to said personal data and to the information required by law concerning the methods of processing this data;
- A right to rectification allowing you to request that any inaccuracy concerning your personal data be corrected as soon as possible;
- A right to erasure, allowing you to request that your personal data be erased as soon as possible, provided that this erasure request complies with the conditions required by applicable law;
- A right to limitation of the processing of your personal data, provided that this limitation request complies with the conditions required by applicable law;
- A right to portability allowing you to receive your personal data in a structured, commonly used, and machine-readable format, or to request that this personal data be transmitted to another data controller, provided that this portability request complies with the conditions required by applicable law;
- A right to object to the processing of your personal data for reasons relating to your particular situation, provided that this objection complies with the conditions required by applicable law;
- The right to withdraw at any time the specific consent given for the collection of your personal data, particularly when the processing of your personal data is used for commercial prospecting purposes;
- The right to define directives relating to the retention, erasure, and communication of your personal data after your death.
You have the right to obtain the limitation of the processing of your personal data in the cases defined in Article 18 of the GDPR:
- During the verification period we implement, when you contest the accuracy of your personal data;
- When the processing of this data is unlawful, and you wish to limit this processing rather than delete your data;
- When we no longer need your personal data, but you wish to keep it to exercise your rights;
- During the verification period of legitimate grounds, when you have objected to the processing of your personal data.
Persons whose data is collected on the basis of our legitimate interest are reminded that they may object to the processing of data concerning them at any time. However, we may be required to continue processing if there are legitimate grounds for the processing that prevail over your rights and freedoms or if the processing is necessary to establish, exercise, or defend our legal rights.
You can unsubscribe from our promotional emails via the link provided in the emails. Even if you choose not to receive promotional messages from us, you will continue to receive our administrative messages.
Your rights can be exercised at any time by sending an email to contact@twoo-way.com or a letter to the following address: TWOO WAY, 29 rue Tronchet, Paris 8.
If you have complaints regarding the way we process your personal data, you can contact us using the contact details provided above.
11. PORTABILITY OF YOUR PERSONAL DATA
You have a right to the portability of the personal data you have provided to us, understood as the data you have actively and consciously declared as part of the access and use of the services, as well as data generated by your activity as part of the use of the services.
We remind you that this right does not apply to data collected and processed on a legal basis other than consent or the performance of the contract between us.
This right can be exercised free of charge, at any time, and notably when closing your account on the Site, in order to recover and keep your personal data.
In this context, we will send you your personal data, by any means deemed useful, in a standard open format commonly used and machine-readable, in accordance with the state of the art.
12. FILING A COMPLAINT BEFORE A CONTROL AUTHORITY
You are also informed that you have the right to lodge a complaint with a competent supervisory authority (the Commission Nationale Informatique et Libertés for France) in the Member State in which your habitual residence, your place of work, or the place where the violation of your rights is alleged to have occurred, if you consider that the processing of your personal data subject to this charter constitutes a violation of the applicable texts.
This remedy may be exercised without prejudice to any other remedy before an administrative or judicial authority. Indeed, you also have the right to an effective administrative or judicial remedy if you consider that the processing of your personal data subject to this charter constitutes a violation of the applicable texts.
13. MODIFICATIONS
We reserve the right, at our sole discretion, to modify this Policy at any time, in whole or in part.
These modifications will take effect from the publication of the new policy.