I. Objectives and Scope of the Policy
I.1. Objectives of this Policy
The goal of this Policy is to provide clear, precise and complete information to website visitors, prospective customers, users, and Clients of WeProov services ("you") on :
• the conditions of Processing of personal data ;
• data subjects’ rights with regard to the Processing of their personal data, and the conditions for the exercise of those rights ;
• the measures taken to ensure the security of your personal data.
I.2. Scope of this Policy
It is aimed at all visitors to the website, prospects, Clients and Users of WeProov services.
In this Policy, "we", "us" and "our" refer to: PROOV GROUP S.A.S, a company incorporated under the laws of France, with a capital of €480,000, having its registered office at 20 B rue Louis-Philippe 92200 Neuilly-sur-Seine, registered at the Registry of Trade and Companies of Nanterre under number 811989581.
II. General principles of personal data protection implemented byPROOV GROUP
Transparency : PROOV GROUP informs you of the data processing implemented, of your rights and how to exercise them by providing you a clear, precise and complete information available on its website weproov.com, and in all mobile applications published and operated by PROOV GROUP.
Lawfulness of Processing : PROOV GROUP bases its Processing of personal data on valid legal bases provided by Article 6 of the GDPR. Our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it. Most of our information collection and processing activities are typically based on :
(i) contractual necessity or as part of pre-contractual procedures. The data collected and stored is strictly limited to the performance of the contract ;
(ii) one or more legitimate interests pursued by PROOV GROUP ;
(iii) your consent. PROOV GROUP obtain your consent in a free, specific, informed and unambiguous manner when the processing of personal data is based on it.
We may also be required by law to collect your information (iv) or we may need your personal data to protect your vital interests or those of another natural person (v). Purpose limitation: PROOV GROUP strictly limits the processing of personal data to the purposes set out below (III.2.).
Data minimisation : PROOV GROUP ensures the protection of personal data from the design of its products and throughout the life of the process. Only personal data that are necessary foreach specific purpose of processing (III.) are processed by PROOV GROUP.Accuracy of data : PROOV GROUP ensures the accuracy of the data and facilitates the exercise of the right to rectification to the data subject in order to rectify any inaccuracies.
Storage limitation : PROOV GROUP applies the retention periods necessary to achieve its purposes, in compliance with the legislation and regulations. It relies in particular on the CNIL's guidelines. In the absence of recommendations, PROOV GROUP applies by default a duration strictly limited to the purpose for which they are processed.
Security : PROOV GROUP ensures that personal data is protected against loss, theft, or unauthorized modification, and ensures that only authorized persons access it. The measures implemented by the Company are presented in IV and detailed in a separate document entitled"technical and organisational security measures implemented by PROOV GROUP".
III. Methods of collecting and processing personal data
III.1. Data collected by PROOV GROUP
Data that you provide us :
i. Account signup: When you sign up for an account to access one or more of our services, we ask for information like your name, contact number, email address, company name and country to complete the account signup process. You'll also be required to choose a unique username and a password for accessing the created account. You may also provide us with more information such as your photo and language, but we don't require that information to sign up for an account.
ii. Event registrations and other form submissions: We record information that you submit when you (i) register for any event, including webinars (ii) give us your business cards at trade fairs (iii) subscribe to our newsletter (iv) submit a form in order to download the white paper or other materials and access to testimonials (iv), request a demo or a personalized quote or (v)submit a form to request customer support or to contact PROOV GROUP for any other purpose.
iii. Testimonials : When you authorize us to post testimonials about our products and services on websites, we may include your name and other personal information in the testimonial.
iv. Interactions with PROOV GROUP : We may record, analyze and use your interactions with us, including email, telephone, and chat conversations with our sales and customer support professionals, for improving our interactions with you and other customers.
Data that we collect automatically
i. Data from browsers, devices and servers : When you visit our websites, we collect information that web browsers, mobile devices and servers make available, such as the internet protocol address, browser type, language preference, time zone, referring URL, date and time of access, operating system, mobile device manufacturer and mobile network information. We include these in our log files to understand more about our website visitors.
ii. Data from first party cookies and tracking technologies : We use temporary and permanent cookies to identify users of our services and to enhance user experience. For more information about cookies used on our website, please see section VI.
iii. Data from application logs and mobile analytics : We collect information about your use of our services and mobile applications from application logs and in-house usage analytics tools, and use it to understand how your business use and needs can improve our services. This information includes clicks, scrolls, features accessed, access time and frequency, errorsgenerated, performance data, storage used , user settings and configurations, and characteristicsof the devices used to access to our services, and their locations.
Data that we collect from third parties
i. Referrals: If you provide us information about another person, or if another person gives us your information, we will only use that information for the specific reason for which it was provided to us
ii. Information from social media sites and other publicly available sources: We may collect such publicly accessible information, including business profile information, to allow us to connect with you, improve our products, or better understand user reactions and issues.
III.2. Purposes for using information
Prospecting and Marketing
The information we collect for our prospecting and marketing activities is stored in an automated file and processed exclusively for this purpose.
It is used to :
• communicate with you (e.g. via email) about products that you have downloaded and services you have sign up for ;
• provide you with services relevant to your business ;
• keep you informed about new products and services, upcoming events, and other information that we think will be of interest to you ;
• monitor and improve marketing campaigns and make suggestions relevant to the user.
Customer Relationship Management
This information allows us to:
(i) manage your WeProov solution deployment projects;
(ii) send you quotes and invoices;
(iii) create accounts (customer, user, administrator);
(iv) identify/authenticate you when you access WeProov Services.
Support and Assistance
When you encounter difficulties in using WeProov Services and request our support/assistance team by email or by phone, Proov Group employees authorized for this purpose may have access to your WeProov account details and to the content of your WeProov reports, in order to provide you with any appropriate information/solution.
Improving our services
We collect data on your interactions with our solutions to (i) understand how users use our services so that we can better assist them; (ii) monitor and prevent problems; and (iii) improve our services.
III.3. Retention of information
The processing of your personal data will end :
• at the end of the contractual term and after a short retention period determined in the contract to allow for the restoration of the data at the Customer's request ;
• when we no longer have a legitimate interest in processing your data ;
• when you withdraw your consent.
We will then destroy your personal data from our active databases or anonymize it once the purposes described in this Policy have been achieved.
Retention period applied by PROOV GROUP :
- Backup data : 7 days
- Data from WeProov report : 3 months from end of the contract at latest
- Connection data : 1 year
- Data collected for the management of data subjects' rights : 1 year from Proov Group's answer
- Cookies and other trackers : 6 months from the date of consent
- Prospect data : 3 years from the last contact
- Data contained in contracts : 5 years from the termination of the contract for evidential purposes
- Accounting data : 10 years
III.4. International transfers
Your data may be transferred outside the European Union, and more specifically to the UnitedStates, by subcontractors that PROOV GROUP uses to provide WeProov services.
In this case, we ensure that this transfer is based on appropriate guarantees provided by the regulations in force (model contractual clauses approved by the European Commission).
III.5. Communication to third party
We may communicate your personal data:
(i) to partners/suppliers in connection with the provision of the Services such as web analytics providers, payment processors, hosting providers, platform providers for sending notifications to our Customers and users. These service providers are permitted to use your data only for the purpose of providing these services to us ;
(ii) to comply with a legal obligation, request or court order ;
(iii) in the case of an emergency situation, to ensure or preserve the safety of individuals, protect the public or the vital interests of the Company.
Outside of this framework, we will not transfer or disclose your information to third parties for any purpose, including commercial and advertising purposes, without your express prior consent. We share your personal data only as described in this Policy and only with those parties who adopt appropriate security and confidentiality measures.
IV. Security of your personal data
At PROOV GROUP, safety is a fundamental element that is reflected in our processes and our services. Below are some of the technical and organisational measures implemented by the Company:
• Hosting in secure and certified data centers ;
• Network security;
• Encryption of data in transit;
• Strong password policy;
• Regular staff awareness of security and confidentiality;
• Access control;
• Security incident management procedures;
For more information, please contact firstname.lastname@example.org.
V. Your rights respect to data we hold about you
Your rights in information use
Right to access: You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared.
Right to rectification: You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
Right to erasure: You have the right to request that we delete your personal information incertain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.Right to restriction of processing: You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
Right to object: You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing.
Right to complain: You have the right to complain to the Information Commissioner's Office if you have any grievance against the way we collect, use or share your information.
Your choice in information use
Opt out of non-essential electronic communications: You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe' function included in all such messages.
Disable cookies: You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly (for more details see section VI).
Optional information: You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our website.
VII. Management of cookies and other trackers
What is a cookie?
A cookie is a small text file that is stored on your computer or other internet-connected device by web browser when you visit a website. Your web browser will store it for a period of time, and send it back to the web server each time you log in again.
There are different types of cookies and trackers:
• Those that require the prior consent of the user: cookies related to personalised advertising operations: cookies from social networks.
• Those that do not require consent: tracers used to record the user’s choices; tracers used for authentication purposes; tracers used to personalise the user interface; tracers used for audience measurement.
Purpose of our cookies
Several types of cookies are used by PROOV GROUP for its website weproov.com:
(i) Internal cookies necessary for the proper functioning of the website. These cookies are mandatory and do not require consent in accordance with Article 82 of theFrench Data Protection Act.
(ii) Third-party cookies for audience measurement (Google Analytics). Audience measurement services allow us to generate statistics on the number of visitors tot he website, which can be used to improve the website.
(iii) Third-party cookies intended to improve the interactivity of the website. The Website https://www.weproov.com relies on third party services of :
PROOV GROUP leaves you the choice to authorise or refuse the deposit of cookies at anytime. PROOV GROUP declines all responsibility for the management of cookies from third party websites linked to the weproov.com website.
What happens if I do not allow cookies?
Cookies are used to improve the services provided by the website. You can reject and delete them using your browser settings, however your user experience may be degraded.
How to disable/activate our cookies?
When you first visit the website, a banner informs you of the presence of these cookies andrequires you to indicate your choice. They are only deposited if you accept them. You canrefuse the deposit of all or part of the cookies. Whatever your choice, you can revise it at anytime while you are visiting the website.
VIII. Contact information
We have appointed a Data Protection Officer to ensure that the management of your personal data is done in accordance with this Policy and the GDPR. If you have any questions or concerns about our privacy practices with respect to your personal data, you may contact our Data Protection Officer :
- by e-mail at email@example.com
- by post at DPO Proov Group 20 B rue Louis-Philippe 92200 Neuilly-sur-Seine.
- by telephone on 0184808081.