PRIVACY POLICY  

  1. Definition

Personal data :              Any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”)   ; is deemed to be an “identifiable natural person” a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to its physical, physiological, genetic, psychic, economic, cultural or social identity.

 

Processing :                  Any transaction or set of transactions performed or not using automated processes and applied to data or sets of personal data, such as collection, registration, organization, structuring, retention , adaptation or modification, extraction, consultation, use, transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, deletion or destruction.

 

 

File :                                 Any structured set of personal data accessible according to certain criteria, whether that set is centralized, decentralized or functionally or geographically distributed.

 

 

Processing Manager:   The natural or legal person, the public authority, the service or any other body which, alone or jointly with others, determines the purposes and means of the processing.

 

Subcontractor :             The natural or legal person, public authority, service or other body that processes personal data on behalf of the controller.

 

 

Recipient :                     The natural or legal person, the public authority, the service or any other body that receives personal data, whether or not it is from a third party.

 

 

 

  1. The data collected by LINKAVIE

 

2.1.               Which data is collected

 

2.1.1. The TIMEKO App

When subscribing to the TIMEKO Application, it is necessary to indicate an interlocutor within the company, association or other legal person. In addition, as part of the execution of the contract, it is possible that LINKAVIE collects the personal data of several interlocutors within the entity.

To register online on the TIMEKO platform, you must fill out a form. Required fields are indicated by the presence of an asterisk.

 

In the case of a registration of the Client administrator and the creation of the associated community by the LINKAVIE administrator in the TIMEKO back office, you must also provide a certain amount of information (Surname, first name, email, phone, photography) allowing the creation of your account.

 

LINKAVIE collects the administrator’s email address for sending LINKAVIE information mails and the TIMEKO solution (News, new features etc.)

 

LIN KAVIE collects your Client ID, the latter receives an email allowing him to define his personal password, for his authentication.

 

In order to ensure the payment of access to the TIMEKO solution, the banking data relating to your means of payment are collected by LINKAVIE.   : BIC / IBAN in the case of payments by SEPA mandate.

 

The following bank details are collected by the LINKAVIE banking provider : BIC / IBAN , your name in case of payments by SEPA mandate.

 

An authentication cookie is installed on your terminal (token). LINKAVIE collects the data when :

–           You conclude a contract with LINKAVIE

–           You create your account online

–           You contact us

–           You browse our application

–           You exercise one of the rights relating to your personal data

2.1.2. The showcase website www.timeko.fr

LINKAVIE collects the following personal data when you wish to contact LINKAVIE the contact form z carries a demonstration also request via the contact form   :

–           Name

–           First name

–           Mail address

–           Phone number

 

A cookie is installed by a partner to measure the audience of the site and to know the navigation to optimize the ergonomics and navigation of the website.

2.1.3. The processing manager

The processing manager is the company LINKAVIE n ° RCS 804   953 958 whose registered office is 455, rue de la Grande Tousque – 13100 Aix en Provence represented by Mr Thomas LUQUET.

 

2.2.               What is the legal basis for processing your personal data

 

–           Data processing based on the law

Pursuant to Decree No. 3022-219 of 25 February 2011, LINKAVIE must retain data for identifying any person who contributed to the creation of online content.

As a professional, LINKAVIE has the ability to send you information or promotional emails without the Client’s consent. On the other hand, it has the option to unsubscribe at any time by clicking on the link “unsubscribe” available in each information or promotional email sent by LINKAVIE. LINKAVIE collects only the email addresses of the Client Administrator.

 

–           Data processing needed for the contract execution

In order to allow you to access the various services offered by LINKAVIE, you have accepted general conditions of sale.

It is these documents that formalize the contractual relationship between LINKAVIE and you and which constitute the legal basis for the processing of personal data by LINKAVIE.

The data collected is therefore necessary for the execution of this contract.

 

–           Data processing based on the consent and the legitimate interest of LINKAVIE

LINKAVIE has a legitimate interest in processing personal data to ensure, for example, your authentication or measure the audience TIMEKO application.

Although the law allows LINKAVIE to send you promotional emails (or newsletters) as a professional, LINKAVIE has decided to send you these emails only with your consent. Thus, no information or promotional mail is sent to the users and external Users of the community by LINKAVIE, unless active registration by the latter to the LINKAVIE newsletter.

You have the possibility to oppose certain processing such as regarding the sending of promotional mails or cookies of audience measurements (about the website).

 

However, you are notified that the authentication cookie (token) is required and always installed when you authenticate on TIMEKO application.

 

LINKAVIE makes sure not to disregard your interest and that this does not come to affect your private life.

2.3.               What are the purposes ?

 

2.3.1. TIMEKO application

 

The aims pursued are :

 

  • Registration and creation of the online account
  • Payment
  • Execution of the contract
  • Business development
  • Reply to your correspondence
  • Management of requests for the exercise of rights relating to personal data
  • Management of unpaid bills

 

The objectives pursued during cookie (token) installation in connection with the use of the TIMEKO application are the following :

 

  • Improveyour experience (Maintaining authenticated connections, saving preferences)
  • Ensure secure access to your online account to authenticate you

 

2.3.2. The showcase website www.timeko.fr

 

The purposes are as follows :

  • Reply to your contact request
  • Respond to your demo request
  • Sending you promotional emails
  • Management ofrequests for exercise of rights relating to personal data

The purposes pursued concerning the installation of the audience measurement cookie are :

  • To establish statistics and volumes of visitsto our public site fr in order to optimize the website and its ergonomics.

 

2.4.               What is the retention period of your personal data ?

Data concerning the sending of information or promotional emails is kept for a period of 3 years from the last activity on the TIMEKO solution, including the sending of an email.

The audience measurement statistics and attendance data are kept for a period of 13 months according to the law.

In the event of legal proceedings, the personal data concerning you will be kept in order to allow LINKAVIE to ensure its defense or to allow him to establish facts if LINKAVIE is in demand.

The data relating to the performance of the contract are kept for the duration of the contractual relationship and will then be archived in order to comply with the tax and accounting requirements (Article L. 123-22 paragraph 2 of the Trade Code – 10 years) or with legal requirements such as the 5 years period which is the limitation period applicable to personal or movable shares (article 2224 of the civil code) applicable to LINKAVIE.

2.5.               What information is shared with third parties  ?

Some of your personal data is communicated to our subcontractors :

–           Chartered accountant (France)

–           Business Contributors

–           CRM Software Editor and Online Billing (The Netherlands)

–           AWS Europe whose data center is in Paris and concerns the hosting of the TIMEKO solution. The data concerned are the vital statistics data that allowed the creation of your account and all the data entered thanks to the TIMEKO application. Data may in some cases be transferred to the USA as part of the patriot act.

–           Outsourcing Company (France) : Outsourcing the TIMEKO Datacenter infrastructure. The facilities manager, expert in Devops solutions and outsourcing cloud infrastructure, is responsible for the operational maintenance of TIMEKO platform monitors the services and backup systems. It provides secure access to servers and databases for system maintenance and monitoring.

–        OOO CODE TIBURON (Ukraine)   : development and maintenance of the TIMEKO Cloud solution. The subcontractor accesses systems managed by the outsourcer to deploy source code updates, perform maintenance operations, and access the database punctually when solving critical problems. These accesses are authorized on an ad hoc basis, for the facilities manager, under the control of LINKAVIE and after application to LINKAVIE by OOO CODE TIBURON. These accesses are limited in time and have the sole purpose of ensuring a high level of service. Finally, each request is traced in a ticket management tool managed by the outsourcer.

–        Bank provider for the payment of the subscription.

–        Publisher of email software Marketing (France) LINKAVIE uses an email marketing software developed by a French publisher and whose hosting of data is carried out in France and in Europe. Vital registration data is stored whenever a user subscribes to the LINKAVIE or TIMEKO newsletter. A user can unsubscribe at any time. Likewise, a Another email marketing solution is also used via the APIs of the editor (French) for the sending of TIMEKO messages by the email channel. Each customer then has a dedicated sub-account.

–        Telecom Operator (France) : For sending SMS, LINKAVIE relies on a French Telecom operator whose hosting centers are in France. Only the mobile numbers transit through the Telecom operator, to ensure the good deliverability of the messages through the SMS channel.

–        Facebook® (US) : For sending messages via the Facebook Messenger® channel, activated on the initiative of message recipients. The personal data of the recipients are already present on Facebook® by the subscription of the recipient of the messages TIMEKO via Facebook messenger®. No personal data of TIMEKO, which is not already present on Facebook®, is transferred to Facebook®, the user simply authorizes the TIMEKO application to access his Facebook account so that the TIMEKO application can retrieve his ID Facebook messenger® to allow sending TIMEKO messages via this channel.

Naturally, LINKAVIE takes appropriate measures to maintain an appropriate level of confidentiality and security of personal data. LINKAVIE requires all its subcontractors to implement all appropriate technical and organizational measures, on an ongoing basis, to secure personal data and provide them with the same level of protection as that required by the personal data European and French regulations.

For these subcontractors, LINKAVIE has put in place standard contractual clauses adopted by the European Commission between the controller and the subcontractor.

LINKAVIE communicates banking data to its banking provider located in France.

 

  1. What are your rights ?

3.1.               Your right of access

You have the right to obtain from LINKAVIE confirmation that your personal data is or is not processed. Assuming that the data is processed, you have the right to access this data and the following information :

  1. a) the purposes of the processing

(b) the categories of personal data concerned

(c) the recipients or categories of recipients to whom the data has been communicated or will be communicated

(d) where possible, the intended retention period of the data or, where this is not possible, the criteria used to determine the duration

  1. e) the existence of the right to askLINKAVIEfor rectification or deletion of the data, or a limitation of the processing or the right to oppose the processing
  2. f) the right to lodge a claim with the CNIL
  3. g) When personal data are not collected from you directly, any information available at source
  4. h) the existence of automated decision-making, including profiling and, at least in such cases, useful information about the underlying logic, as well as the significance and expected consequences of this processing for you

In addition, when the personal data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate guarantees regarding the transfer.

LINKAVIE will provide you with a copy of the data being processed.

LINKAVIE may charge you a reasonable fee based on administrative costs for any additional copies you request.

If you request a copy of the data electronically, LINKAVIE will provide it in a commonly used electronic form unless you request otherwise.

Finally, the right to obtain a copy of the personal data must not infringe the rights and freedoms of others.

3.2.               Your right of rectification

You have the option to ask LINKAVIE to rectify your inaccurate data as soon as possible. You also have the option of obtaining incomplete personal data concerning you, including providing an additional declaration.

3.3.               Your right to erasure

You have the right to the erasure of your personal data as soon as possible when one of the following reasons applies :

  1. a)Personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  2. b)You withdraw yourconsent on which the processing is based and there is no other legal basis for the processing concerned. The withdrawal of consent is for the future.
  3. c)You exercise your right to object and there is no compelling legitimate reason for the processing
  4. d) Personal data has been subject to unlawful processing
  5. e) Personal data must be erased to fulfill a legal obligation.

You are hereby informed that the right to cancellation may not apply if the processing is necessary to fulfill a legal obligation or to the finding, exercise or defense of rights in court.

3.4.               Your right to limit processing

You have the option to request the limitation of the processing of your personal data when one of the following applies :

  1. a) Verification of your data after a dispute on your part about the accuracy of your personal data
  2. b) The processing is illegal and you oppose the erasure of your personal data and require the limitation of their use
  3. c)LINKAVIEno longer needs personal data about you for processing but the data is necessary for you for the finding, exercise or defense of rights in court
  4. d) You opposed the processing andLINKAVIEchecks whether LINKAVIE’s legitimate grounds prevail over your legitimate reasons.

3.5.               Your right to data portability

You have the option to receive your personal data provided to LINKAVIE in a structured, commonly used and machine readable format when :

  1. a) Processing is based on consentor a contract
  2. b)andthe processing is performed using automated methods .

In the exercise of this right, you have the right to obtain from LINKAVIE that your personal data are transmitted directly from LINKAVIE to another controller when technically possible.

The right to portability must not infringe the rights and freedoms of others.

3.6.               Your right to oppose

In application of the right of opposition, you have the right to oppose at any time, for reasons relating to your particular situation, a processing of personal data based on the legitimate interests of LINKAVIE .

LINKAVIE will no longer process personal data unless LINKAVIE demonstrates that there are legitimate and compelling reasons for the processing to exist and prevail over your interests and your rights and freedoms or the finding, exercise or defense of rights in court.

In addition, for personal data that is processed for prospecting purposes, you have the right to object to it at any time. To do this, you must click on the link in each mail sent by LINKAVIE and totally free or by sending an email to LINKAVIE to the following email address : contact@timeko.fr

3.7.               Spend personal data after death

In application of the law, you have the faculty to define your directives relating to the conservation, the erasure and the communication of your personal data in the event of death.

You can send us your instructions or register them with a certified digital trusted third party. You can therefore designate the person of your choice who will be responsible for executing your instructions. Otherwise, it will be your heirs.

3.8 .               How to exercise them ?

You can exercise your rights by sending your request :

–           By mail to the following address : contact@timeko.fr

–           By mail to the following address : LINKAVIE Company – 455, rue de la Grande Tousque – 13100 Aix en Provence

Your request must be accompanied by a copy of an identity document.

3.9 .               Response time to your request

LINKAVIE has a period of one (1) month to respond to you from the reception of your request. This period can be extended by two months given the complexity and the number of requests. LINKAVIE will inform the person in the month of his request.

Your request must be accompanied by a copy of your identity document.

In the event of the exercise of your right of cancellation or of your right to erasure, you are informed that LINKAVIE may be required to keep your personal data in the form of archiving before deletion for the duration necessary to meet legal, accounting and tax obligations.

Regarding newsletters, promotional offers, you have the ability to unsubscribe at any time by clicking on the hyperlink available in each email sent by LINKAVIE .

You also have the right to lodge a complaint with the CNIL, the supervisory authority ( www.cnil.fr ).

4 .               Where are your data hosted?   ?

Your personal data are hosted in France on secure servers and in the European Union.

In order to provide you with certain services, LINKAVIE is required to transfer certain data outside the European Union. LINKAVIE takes all measures of security and confidentiality to secure the transfers of these data and the reception thereof. LINKAVIE requires by contract that the subcontractors concerned in the USA take appropriate technical and organizational measures, in particular by providing clauses that comply with the GDPR and the recommendations of the European Commission (see article 2.5 of this privacy policy).

 

5 .               Cookies

When browsing the site timeko.fr and / or during your connection to the Timeko application, cookies may be installed and stored in cookie files installed on your device, namely :

–           An authentication cookie (TIMEKO application)

–           An audience measurement cookie (website www.timeko.fr )

 

 

Your choice regarding cookies

LINKAVIE informs you of the installation of cookies, their purpose and your consent by means of a banner on its website.

The audience measurement cookie is installed subject to your expressed choices relating to this cookie and that you can modify at any time.

The cookies installed on your terminal are for the purposes indicated in article 2.3. of this Privacy Policy.

The audience measurement cookie has a maximum life of 13 months as stated in article 2.4. of this Privacy Policy.

As the processing of data regarding audience measurement is based on your consent, you have the right to withdraw it at any time by removing it from your browser, as explained below.

If you withdraw your consent, know that a cookie will be installed to disable the deposit of the cookie of audience measurements on the site www.timeko.fr.

You have the ability to configure your browser software to :

–           To accept all cookies

–           To refuse all cookies

–           To refuse certain cookies according to the issuers

Only the authentication cookie is required for the TIMEKO application. You can request that the authentication cookie be uninstalled by sending an email to the following address : contact@timeko.fr . However, you are informed that when the authentication cookie is uninstalled, you will no longer be able to access and use the TIMEKO application without this cookie being installed again.

 

In order to configure your browser, you need to refer to the help menu of your browser.

 

 

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