This Privacy Policy is intended for Users of the COSMOS suite (hereinafter the “Suite”), published by DELOS INTELLIGENCE. The purpose of this document is to inform you about how we collect and process your personal information.Respect for privacy and personal data is a priority for DELOS INTELLIGENCE, which is why we are committed to treating them in the strictest compliance with the Data Protection Act of January 6, 1978 (hereinafter “Liberties Act”) of January 6, 1978 (hereinafter “ILE Law”) as amended and with the General Data Protection Regulation (EU) of April 27, 2016 (hereinafter “GDPR”). In any event, we are committed to respecting the following two (2) essential principles:
- Each User remains in control of their personal data;
- Data is processed in a transparent, confidential and secure manner.
For the purposes of this Policy, terms, both singular and plural, will have the following meaning:
•” Beneficiary ”: refers to any person who, with the Customer's authorization, uses the Suite to benefit from the Services, in particular through an Account. The Customer is fully responsible for the use of the Platform by the Beneficiaries.
•” Customer ”: refers to any person who guarantees to be a professional, as defined by French law and case law and subscribing to one of the paid subscriptions offered by DELOS INTELLIGENCE as part of the Contract, in order to benefit from the Suite or to give access to it to Beneficiaries.
•” General conditions of use ”: refers to the conditions intended to govern the use of the Suite by Users.
•” contract ”: refers to all the contractual conditions governing the relationship between the Customer and DELOS INTELLIGENCE.
•” Account ”: refers to the interface hosted on the Suite in which all the data provided by the User and allowing him to access the Services are grouped together. Access to the Account is made using Identifiers. There are two types of Accounts on the Suite:
O The” Main account ”: this account is individual and can only be linked to a single natural person representing the Customer, deemed to have all the authorizations required for this purpose. Each Customer is only able to create one and only one Main Account; and
O The” Associate account ”: this account is individual and can only be linked to one natural person authorized by the Customer. Each User has the possibility to create only one and only one Associated Account. The number of “Associate Accounts” that can benefit from the Services may be limited if necessary.
•” Personal data ” or” Personal data ”: refers to any information relating to an identified or identifiable natural person, 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 elements specific to his physical, physiological, genetic, psychological, economic, cultural or social identity, or to one or more specific elements specific to his physical, physiological, genetic, genetic, psychological, economic, cultural or social identity.
•” Identifiers ”: refers to the identifiers allowing Beneficiaries to access their Account, i.e. the combination of their email address used for professional purposes and the password. Each Customer has custody of their Identifiers.
•” Delos Platform ”: refers to the online Suite accessible at the following address: https://app.delos.so/. The Suite includes all the web pages, Services and functionalities offered to Users.
•” Service ”: refers to any service offered by DELOS INTELLIGENCE as part of the provision of the Suite and the provision of the Solutions.
•” Solutions ”: refers to the various applications of the Delos platform: Delos Chat, Delos Chat, Delos Docs and Delos Trad published and operated by DELOS INTELLIGENCE as well as all its graphic, sound, visual, visual, software, software, software, database and textual components. The Solutions are accessible in SaaS mode (i.e.” Software as a Service ”, i.e. accessible via a compatible internet browser) and bring together a set of functionalities intended for the Customer.
•” User ”: refers to any person who accesses and navigates the Suite, whether Customer, Beneficiary or simple Internet user.
As part of the provision of the various Services, DELOS INTELLIGENCE will play the role of “Data Controller” for you within the meaning of the RGPD
DELOS INTELLIGENCE
149 Avenue du Maine 75014 Paris
contact@delosintelligence.fr
https://app.delos.so/
Legal reminder: The data controller is, within the meaning of the Data Protection Act and the RGPD, the person who determines the means and purposes of the processing. When two or more data controllers jointly determine the purposes and means of the processing, they are the joint controllers (or co-controllers). The subcontractor is a person processing personal data on behalf of the data controller, he acts under the authority of the data controller and on the instructions of the data controller.
Our Data Protection Officer (hereinafter” DPO ”) is there to respond to all requests, including the exercise of rights, relating to your personal data.
You can reach him:
- By Mail : Maximilien de Dinechin, DELOS INTELLIGENCE - Data Protection Officer, email: maximiliendedinechin@delosintelligence.fr
Learn more
The mission of the Data Protection Officer is to inform, advise and monitor the compliance of DELOS INTELLIGENCE in carrying out the processing operations carried out. In accordance with data protection regulations, the DPO acts as a contact point:
- With respect to the persons concerned for any subject relating to the processing of data carried out by DELOS INTELLIGENCE or the exercise of your rights;
- With respect to the CNIL as part of its cooperation mission. The DPO may also contact this authority to seek prior advice or consultation on all matters concerning the protection of personal data;
- With respect to other DPOs appointed by the participating subcontracting organizations or data controllers.
By principle, all personal data concerning you is collected directly from you.
For example when creating an Associate Account on the Suite or during exchanges with DELOS INTELLIGENCE (contact request, letters, etc.).
By exception, we may collect your personal data from the Customer in order to give you access to the Suite as a Beneficiary.
We only collect personal data that is necessary for the purposes that are explicit and determined below:
PURPOSES
DETAILS OF THE PURPOSES PURSUED
LEGAL BASES
Platform and Solution Administration
- General administration of the Suite and associated Solutions;
- Carrying out corrective maintenance operations;
- General management of the security of the Suite and Solutions;
- Deposit of cookies and other tracers necessary for the proper functioning of the Suite and Solutions;
- Control and monitoring of the operation of the APIs;
- Monitoring of programs and carrying out analyses on your use as part of our research and development actions; and
- Production of statistics on the use of the Suite and Solutions.
Our legitimate interest to provide a functional suite.
Evolving maintenance of the Platform and Solutions
- Monitoring of programs and carrying out analyses on your use as part of our research and development actions; and
- Production of statistics on the use of the Suite and Solutions.
Our legitimate interest to ensure users the best possible experience on the Suite, and the best quality of the Services offered.
Provision of Services
- Management of requests to create, modify and delete Main and Associate Accounts;
- Provision and delivery of Services to Users;
- Monitoring and control of the proper use of the Services; and
- Sending non-commercial information relating to the provision of Services.
Execution of the contract, the Processing is necessary for the execution of a contract or pre-contractual measures.
Customizing the user experience
- Deposit of cookies and other tracers in order to analyze your use of the Suite;
- Statistical analyses of your use.
Your consent.
Partnership monitoring
- Monitoring and coordination of partnerships.
Our legitimate interest to maintain our network of partners.
Customer relationship monitoring
- Handling requests for information;
- Management of pre-litigation and litigation;
- Follow-up of requests.
Our legitimate interest to respond to your requests and to defend the interests of DELOS INTELLIGENCE.
Electronic commercial prospecting actions (B2C)
- Direct prospecting: sending email, SMS, automated electronic communication system without human intervention.
Your consent.
Commercial prospecting actions (B2C or B2B)
- Prospecting with users by post or call system with human intervention (B2C);
- Prospecting for professionals;
- Management of the Suite and social networks (community management);
- Organization of events;
- Elaboration of statistics on marketing operations.
Our legitimate interest to offer you offers as part of our commercial development. You can object to these mailings at any time via the dedicated unsubscribe links.
Billing management
- Monitoring of payment for Services and billing
- Management of unpaid bills
Execution of the contract, the Treatment is necessary for the execution of a contract.
Your consent.
- Keeping accounting records and legal supporting documents
Our legal obligations for the preservation of accounting and fiscal data
Sending the Newsletter
- Management of newsletter subscriptions;
- Production of statistics on the use of the Services
Your consent.
Management of requests to exercise rights
- Monitoring the processing of requests;
- Carrying out operations on your data in the context of requests sent
Our legal obligations arising from articles 15 and following of the RGPD and the Data Protection Act.
Establishment of evidence for pre-litigation and litigation management purposes
- Retention of elements for evidentiary purposes in the event of pre-litigation or litigation.
Our legitimate interest
When the legal basis used is the pursuit of a legitimate interest, you have the possibility, on simple request, to obtain additional information relating to the balancing of interests. Customer data is in no way used to train artificial intelligence models (fine-tuning).
The mandatory or optional nature of the Personal Data collected and the possible consequences of a lack of response are indicated during the various contacts with Users.
You can consult the details of the Personal Data that we are likely to collect below:
TREATMENTS
TYPES OF PERSONAL DATA COLLECTED
Suite and Solutions Administration
- Information associated with the Main and Associate Account (title, surname, first name, email address);
- Connection logs, hardware identification data, Service and API usage data, and history of actions on the Suite and Solutions;
- Data collected via cookies and other “technical” trackers;
- Statistics.
Evolving maintenance of the Suite and Solutions
- Connection logs, hardware identification data, Service and API usage data, and history of actions on the Suite and Solutions;
- Data collected via cookies and other “technical” trackers;
- Statistics.
Provision of Services
- Information associated with the Main and Associate Account (name, first name, title, email address);
- Contractual information related to the use of the Services;
- Connection logs;
- Data relating to the use of the Services;
- Statistics;
Customizing the user experience
- Connection logs;
- Data relating to the use of the Services.
Partnership monitoring
- Data relating to the identity of our partners: title, surname, first name, address, telephone number, email;
- Contractual data resulting from agreements with our partners;
- Statistics.
Customer relationship monitoring
- Information associated with the interested party (title, surname, first name, email, postal address);
- Information relating to the request;
- Statistics.
Electronic commercial prospecting actions (B2C)
- Data relating to the identity of the user (title, surname, first name);
- Electronic contact details (email, contact information...);
- Data relating to interactions with our services on blogs, forums and social networks; (B2C)
- Statistics.
Commercial prospecting actions (B2C or B2B)
- Data relating to the identity of the User;
- Postal details of the User;
- Information relating to the organization of events;
- Statistics.
Billing management
- Financial information related to the consumption of Services.
- Payment data, namely data relating to the means of payment used in case of subscription (RIP or RIB, information on transfers, information on payments by bank card...) In the case of punctual payment by bank card, the cryptogram is deleted as soon as the transaction is carried out.
- Data relating to discounts, receipts, balances, etc.
- Data relating to the establishment and payment of invoices: payment methods, discounts granted, receipts, balances and unpaid invoices.
Bookkeeping
- Accounting information and legal supporting documents.
Sending the Newsletter
- Electronic contact details
- Statistics
Management of requests to exercise rights
- Data relating to the identity of the user: title, surname, first names, first names, address, telephone number, email addresses, membership number, date of birth. A proof of identity may be kept for the purposes of proof of the exercise of a right of access, to exercise correction or opposition or to meet a legal obligation
- Data relating to your request to exercise your rights
The detail on the information provided below is not intended to be exhaustive and aims above all to inform you about the categories of Personal Data that DELOS INTELLIGENCE is likely to process.
In any event, DELOS INTELLIGENCE is committed to Processing all Data collected in a manner that complies with the RGPD and the Data Protection Act.
When the collection of this information is regulatory, contractual, if it is a condition for the conclusion of a contract or if there is an obligation to provide information, we will indicate this to you by a mention of the type “*” at the time of collection.
Failure to provide this information could lead DELOS INTELLIGENCE to terminate or deny you access to the Services, and if necessary, engage your responsibility.
Within the limits of their respective responsibilities and for the purposes mentioned above, the main persons who will be likely to have access to your Data are the following:
• The authorized personnel of DELOS INTELLIGENCE;
• Where applicable, the authorized personnel of DELOS INTELLIGENCE subcontractors: hosting provider of the Suite...;
• Where applicable, third parties involved in billing transactions: Banks, Payment Service Providers...
• Where applicable, the courts concerned, mediators, accountants, accountants, auditors, lawyers, bailiffs, debt collection companies, police or gendarmerie authorities in the event of theft or judicial requisition;
• Where applicable, third parties likely to place “commercial” cookies on your terminals (computers, tablets, smartphones, etc.) when you consent.
Your Personal Data is not communicated, exchanged, sold or rented to any person other than those mentioned above without your express, prior consent and in accordance with applicable legal and regulatory provisions.
We keep your Personal Data only for the time necessary for the purposes pursued, as summarized in the table below:
TREATMENTS
PRESERVATION PERIOD
Suite and Solutions Administration
For the duration of the contractual relationship then storage in intermediate archiving for the period of limitation in force, i.e. five (5) years for evidence purposes. Retention of connection logs and history of actions for a period not exceeding twelve (12) months.
Evolving maintenance of the Suite and Solutions
For the duration of the contractual relationship then storage in intermediate archiving for the period of limitation in force, i.e. five (5) years for evidence purposes. Retention of connection logs and history of actions for a period not exceeding twelve (12) months.
Provision of Services
Throughout the duration of the contractual relationship.
Customizing the user experience
Throughout the duration of the contractual relationship.
Partnership monitoring
For the duration of the contractual relationship then storage in intermediate archiving for the period of limitation in force (five (5) years for proof purposes).
Customer relationship monitoring
For claims, during the contractual term or in the event of a break in relationships, the length of time required to close the claim.
Direct commercial prospecting actions by electronic means (B2C)
Until the withdrawal of consent or for a period not exceeding three (3) years from the last contact you made with DELOS INTELLIGENCE.
Commercial prospecting actions (B2C or B2B)
Until the withdrawal of consent or for a period not exceeding three (3) years from the last contact you made with DELOS INTELLIGENCE.
Billing management
Deleting payment information after the transaction is complete. Retention of payment information (payment, subscription, etc.) for the duration of the contractual relationship.
Bookkeeping
In the form of an intermediate archive: legal retention period (e.g. 10-year accounting obligation). The identity document is kept for the time necessary to verify the identity of the person concerned. A copy of an identity document can be kept for a period of 6 years if this is necessary for evidentiary purposes or to meet a legal obligation
Sending the Newsletter
Until the withdrawal of consent or for a period not exceeding three (3) years from the last contact you made with DELOS INTELLIGENCE.
Management of requests to exercise rights
Personal Data relating to the management of legal requests is kept for the duration necessary to Process the request and then stored in intermediate archiving for the applicable period of criminal limitation, namely six years, in intermediate archiving (Article 8 of the Code of Criminal Procedure).
Establishment of evidence for pre-litigation and litigation management purposes
The data processed to manage a pre-litigation case must be deleted as soon as the dispute is settled amicably or, failing that, as soon as the corresponding legal action is prescribed. Data processed to manage a dispute must be deleted when appeals are no longer possible against the decision rendered to have it enforced.
In accordance with the IEL law and the RGPD, you have several rights relating to your Personal Data:
▪ Right to withdraw your consent at any time : for purposes based on consent, Article 7 of the RGPD states that you can withdraw your consent at any time. This withdrawal will not call into question the legality of the Processing carried out before the withdrawal (Article 13-2c RGPD);
▪ Right to define the fate of your Personal Data after your death and to choose whether we communicate (or not) your Personal Data to a third party that you have previously designated (Article 85 LIL).
▪ Right of access : you have the right to access all of your Personal Data at any time, under Article 15 RGPD ;
▪ Right to rectification : you have the right to rectify your inaccurate, incomplete or outdated Personal Data at any time in accordance with Article 16 of the RGPD ;
▪ Right to erasure : you have the right to demand that your Personal Data be erased and to prohibit any future collection of your Personal Data for the reasons set out in Article 17 of the RGPD, namely when they are inaccurate, incomplete, equivocal, outdated, or whose collection, use, communication or storage is prohibited (find out more);
▪ Right to limitation of treatment : you have the right to ask us to temporarily freeze the use of some of your data, under the provided conditions (Article 18 of the RGPD);
▪ Right to object : under Article 21 RGPD, you have the right to object. Note, however, that we may maintain their Processing despite this opposition, for legitimate reasons or the defense of legal rights.
▪ Right to portability : under certain conditions specified in Article 20 of the RGPD, you have the right to receive the Personal Data you have provided to us in a standard, machine-readable format and to require its transfer to the recipient of your choice.
These rights can be exercised by contacting our DPO:
- Email to the address: maximiliendedinechin@delosintelligence.fr;
- Postal address: DELOS INTELLIGENCE - 83 boulevard du Montparnasse - 75014 Paris.
You also have the option of filing a complaint with a competent supervisory authority.
To date, DELOS INTELLIGENCE does not carry out automated decision-making that could have legal effects on you, or significantly affect you.
On its Suite, DELOS INTELLIGENCE uses Connection Data (date, time, Internet address, Internet address, protocol of the visitor's computer, page viewed) and cookies (small files stored on your computer) to identify you, to remember your consultations, and to benefit from the Suite's audience measurements and statistics, and in particular relating to the pages viewed.
Depending on the purposes, Users may consent, refuse or choose to place certain types of cookies on their terminals.
In principle, we process your Personal Data within the European Union. The data will be stored at Scaleway, a sovereign hosting provider located in France. Artificial intelligence models will be deployed within the European Union. In view of the evolution of our activity, we may be required to transfer your Data outside the European Economic Area. In this case, we will keep you informed of this evolution.
We implement all the technical and organizational measures necessary to ensure the security of our processing of personal data and the confidentiality of the data we collect. As such, we take all necessary precautions, with regard to the nature of the data and the risks presented by the treatments, to preserve its security and, in particular, to prevent the data from being deformed, damaged, or that unauthorized third parties have access to it (physical protection of the premises, procedures for authenticating persons accessing the data, procedures for authenticating persons accessing the data with personal and secure access via confidential identifiers and passwords, etc.).
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