[COMPANY] PRIVACY NOTICE & COOKIE POLICY
[Company Name and Designation], is a [Type of Company & Details],
Ex to follow : : XXXXX SAS, a simplified joint-stock company with capital of €XXXXXX, registered with the Paris Trade and Companies Registry under no. XXX XXX XXX, having its registered office at [address] ("Company Name," “we” or “us”).
Reference in this notice to “personal data” means any information that identifies, or could reasonably be used to identify a living individual, either on its own or together with other information. In addition to this Privacy Notice, please also refer to our Terms and Conditions, as well as our Cookies Notice which explains the use of cookies and other web tracking devices used on our website. Together these documents set out the basis on which any personal data will be processed by us.
Please read this notice carefully to understand our practices with respect to personal data.
HOW WE COLLECT YOUR PERSONAL DATA
As a website-based open innovation platform, we regularly receive personal data as part of our services. The personal data that we collect and process may include:
Personal data that you give us, including:
- Registration. We collect the mandatory information required to create your user account and to register for the services we provide on our website, meaning your name, email address, and password [to be completed depending on your registration fields].
- Profile. You have choices about the information in your profile, such as, whether to provide your date of birth, title, photograph, country, education, professional skills, and employment preferences. You don’t have to provide additional information in your profile; but profile information helps you to get more from our services, like being identified by teams to participate in a challenge. If applicable, your profile will also show membership in a team(s).
- Messages, postings and uploads. We collect personal data from you when you provide, post or upload it to our website, such as when you register for a challenge, when you upload deliverables (e.g., documents, presentations, audio/video files) submitted as part of your participation in a challenge, when you chat or message with other members of the community, post announcements, or use public message boards.
- Technical information. We keep a record of any correspondence between you and us, such as information that you send when you report a problem with our website or service.
- Any other information relating to you which you may provide to us.
Information that we collect automatically from a third-party source, including:
Social Media Authentication Information [If applicable]. If you register on our website using social media authentication (such as Facebook, LinkedIn, Twitter, etc.), we will access certain personal data (e.g., name, email) from your social media profile according to the terms and conditions of those platforms.
Technical Information. When you visit our website we collect information relating to the devices you use and the networks to which you are connected. This technical information, includes your IP address, log-in information, bandwidth used, time of visit, browser type and version, browser plug-ins types and versions, operating system, information about your visit including the URL clickstream, download/upload errors, pages visited, page interactions, and other connection data held in our logs. We collect this information using different technologies, like cookies (see our Cookies Notice).
HOW LONG WE RETAIN YOUR PERSONAL DATA
We retain your personal data so long as you have an account with us. If you close your account, your personal data will be immediately deleted.
Information you have shared with others (e.g., through messages, chats or on message boards/walls) will remain visible after you close your account, but will be anonymized. Your profile may continue to be displayed in the services of others (e.g., search engine results) until the user refreshes their cache.
If your account is suspended or blocked, we will keep your data for a period of between 2 and 5 years to prevent you from circumventing the terms and conditions of our website.
We may also retain your personal data for an additional period to the extent necessary to assert or defend against legal claims.
HOW WE USE YOUR PERSONAL DATA
We use your personal date to provide, support and develop our innovation platform service. We use your personal data to:
- allow you to take part in the innovation challenges on our website;
- enable you to personalize your user profile/account;
- send you service-related information (e.g., confirmation of your registration in a challenge) by email and/or any other communication means;
- enable you to communicate and interact with other community members, such as team members, mentors, jury members and/or the organizers of a challenge (e.g., team member messages or invitations to join a team);
- publish an announcement that you are a finalist or winner of a challenge;
- give you access to our support services to enable you to communicate with us;
- keep our website secure and safe;
- measure or understand the effectiveness of advertising and to deliver relevant advertising to you;
- target you for ads on social media platforms (like Facebook);
- send you, in accordance with applicable laws and where required, with your consent, marketing materials and suggestions of our services (e.g., up-coming challenges) that may interest you;
- notify you about changes to our services;
- administer our website, including for troubleshooting, access, data analysis, testing, research, analytic and survey purposes;
- improve our website to ensure that content is presented in the most effective manner; and
- comply with our legal obligations, including court orders and other legal or regulatory requirements.
HOW WE SHARE YOUR PERSONAL DATA
We may share your personal data with [Company Name] affiliates, for the purposes outlined in this Privacy Notice.
Profile. When you use our services, your profile is fully visible to all members of our community, such as challenge participants, mentors, jury members, and the company or organization that sponsors a challenge. Certain profile information (e.g., name, photo, community, etc.) can also be visible to others on or off our website (e.g., visitors to our website or users of third-party search engines).
Wall posts, messages and deliverables. When you post on a message board/wall, it can be viewed by all members of the community. You can send messages to team members, individual participants, challenge administrators or mentors. Deliverables pertaining to the challenge, can be viewed by other members of your team (if applicable), challenge administrators, jury members and team mentors.
Public challenges. Certain of our challenges are public, which allows the public to vote on the winning deliverables. In these cases, the public can view wall posts related to the challenge, individual and team profiles and deliverables pertaining to the challenge (presentations, audio/video files, etc.). Before participating in a public challenge, you will be asked to consent to this information being made public. Please don’t participate in a public challenge, if you do not want to make this information public.
We also work with third parties who are recipients of your personal data, such as:
- Agorize SAS which is the company hosting and maintaining the platform
- the company that has sponsored a challenge, its administrators, mentors and jury members, or other persons to whom it has granted access to your personal data for the sole purpose of administering the challenge. We have entered data sharing arrangements with the companies with whom we co-organize a challenge to ensure compliance with data protection laws;
- social media platforms that may provide you with connecting services to use our website;
- our sub-contractors, who are technical (e.g., cloud computing platforms, data and content management and transmission systems, search engine providers, etc.) or analytics providers; and
- social media platforms who may advertise our services on their websites.
We only share your personal data with third parties in the following cases:
- where it is necessary to perform our services (e.g., providing your personal data to a partner company with whom we co-organize a challenge);
- to assist us in the improvement and optimization of our website by using analytics and search engines;
- it is explicitly requested by you (e.g., when registering through social media authentication);
- it is based on your consent and/or our legitimate interest (i.e. providing you with meaningful advertising);
- if we are required to do so by law or in a good faith belief that disclosure is reasonably necessary to respond to claims asserted against us, to comply with legal proceedings, in the framework of an investigation, or protect the rights, property or personal safety of [Company Name] or its members;
- if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer; and
- if all or part of our assets are acquired by a third party, your personal data may be included as transferred assets.
If you decide to share your personal data with us by using social media authentication, the latter’s privacy policies will apply to you. We do not control the collection or processing of your information by such platforms.
THE LEGAL BASIS FOR DATA PROCESSING
We collect, use and share the data that we have in the ways described above:
- as necessary to provide the services on our website and fulfill the Terms and Conditions;
- consistent with your consent, which you may revoke at any time through your profile page;
- as necessary to comply with our legal obligations;
- as necessary for our legitimate interests, including our interests in providing an innovative, personalized, and effective service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
DIRECT MARKETING E-MAILS AND TARGETTED ADS ON SOCIAL MEDIA PLATFORMS
In accordance with applicable laws and where required with your consent, we may use the information you give us on our website for electronic direct marketing (e.g. receiving our newsletters, invitations to upcoming challenges or events and other communications that we think may interest you). You can withdraw your consent at any time by unticking the relevant box in your member account clicking on the unsubscribe link in each email, or contacting us at the details provided below.
Regarding targeted ads and content, you can object at any time by configuring your settings regarding advertisement on your social media account (e.g., Facebook).
TRANSFERRING YOUR PERSONAL DATA
We store your personal data in the European Economic Area. If you use our website, your personal data may be shared among [Company Name] affiliates (both inside and outside the European Economic Area). Our global policy requires all affiliated entities to ensure a level of data protection at least as protective as those mandated by the European Economic Area.
We may also transfer personal data to third parties, including those based outside the European Economic Area, for example (but not limited to) sub-contractors and third parties involved in providing services. When we transfer your personal data, we will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure its integrity and protection.
HOW WE KEEP YOUR PERSONAL DATA SECURE
We will take appropriate technical and organizational measures against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data in accordance with our internal security procedures covering its storage, access and destruction.
YOUR RIGHTS REGARDING PERSONAL DATA
In addition to your rights under applicable data protection legislation and where we are permitted or required by applicable law and regulation, we will provide you, upon request, with a copy of your personal data and we will correct any errors identified by you. You also have the right to receive and/or have us transfer to another data controller a subset of your personal data. You have the right to object to and restrict our processing of your personal data as well as the right to lodge a complaint with supervisory authorities regarding the processing of your personal data. All such requests, or any questions or comments regarding this policy or our handling of your personal data, should be addressed to [contact email address].
LINKS
Our website contains links to other websites, including to partner companies. Those websites have their own privacy practices, for which we do not accept responsibility or liability. Please review those policies before submitting any personal data.
UPDATES
This Privacy Notice was updated in [insert date]. We reserve the right to amend this Privacy Notice from time to time to reflect changing legal requirements or our processing practices. Any such changes will be posted on this website and will be effective upon posting.
COOKIE POLICY
A cookie is a file that records information relating to your navigation on our website [insert your platform link] (date and time the pages were loaded; browser used and language; pages viewed, frequency and duration of visits to the site, number of visits, sources of the visit, location) and can facilitate your visits to the site.
During the first visit on the website, a consent window pops up to ask for your cookies preferences regarding the following cookie categories:
- Audience monitoring (i.e. Google Analytics,..)
- Social media (i.e. Facebook, Linkedin,...)
- Marketing (i.e. Sumo,...)
The 3 categories are disabled by default. You may either accept all, refuse all or only accept selected categories of cookies.
Until you make a choice, the consent window will be displayed on any visited page and no cookies will be installed, except technical cookies required to operate the platform.
Once a choice is made, the cookies related to the selected categories will be installed on the next visited page or upon page refresh.
At any time, you can delete cookies, refuse installation of new cookies or be notified before a new cookie is installed by configuring your browser following the instructions below.
Please note that if you uninstall a cookie or refuse the installation of cookies, you may not be able to use some of our services on our website.
Types of cookies
We use the following types of cookies:
- Technical session cookies for site management: when you access the site, a session cookie and a cookie “token” with unique encrypted session id code is passed to your computer. The session cookie then controls your access to the site for that session, and is deleted once you close your browser or log off from the site. The token cookie controls your access to the website as an authenticated user, and is kept until you logout or for a maximum of 7 days. These cookies also allow us to identify your device and preferences when you return to our website, such as customized features, language and regional preferences. These cookies are an essential part of the site delivery system, and you will not be able to fully use our site without these cookies enabled. The information gathered by these cookies is anonymous, and is used only to improve your experience on our website.
- Technical persistent cookies for site management: if you register on the site and select the "Remember me" option, a persistent cookie is passed to your computer. This cookie is not deleted when you leave the site or close your browser, but is saved on your computer. This cookie contains an encrypted user id code that identifies your computer upon future visits and automatically logs you into the site. This cookie is functional, and is designed to remember your preferences, to make your experience on our site better. It does not contain any personal information that could be used to identify you.
- Third-party cookies for audience monitoring: We may use Google Analytics, Google Tag Manager, Hotjar or other tools to monitor traffic on our site. When you visit our site, these programs set certain cookies that record statistical information about your visits to the site. We measure the number of visits, the number of pages viewed as well as visitors' activity on the site and their frequency of return. This helps us improve our website and its functionality, for example, by ensuring that users can navigate it intuitively. These cookies do not store any personal information that could be used to identify you.
- Third-party cookies for social media: If the platform allows you to register using social media Single Sign On connectivity, we will use the information stored in these cookies to authenticate you.
- Third-party cookies for marketing: If marketing tools are configured on the platform, these cookies will be used to send you communications. (deactivated by default)
- What cookies are installed?
Cookies installed by Agorize:
Cookie |
Description |
Opting out |
Duration |
_agorize_session
|
Contains information about the navigation session and allows the user to access the site |
N/A |
Expires at the end of the session. |
cookies_policy_accepted |
Saves a user's choice regarding cookies |
N/A |
13 months |
jwt_token |
Contains a key specific to the user after successful login. This is a mandatory cookie to navigate as a logged in user. |
N/A |
7 days |
jwt_payload |
Contains user information specific to the user after successful login. This is a mandatory cookie to navigate as a logged in user. |
N/A |
7 days |
remember_user_token |
Keeps the user logged in if the remember me option is selected upon login |
N/A |
14 days |
hide_profile_incomplete |
Helps users filling their information on the website |
N/A |
13 months |
Third-party cookies for audience monitoring:
Cookie |
Description |
Opting out |
Duration |
Google analytics: |
|
|
|
_gid
|
Used to distinguish users. |
|
24 hours |
_gat
|
Used to throttle request rate. |
1 minute
|
|
_ga |
Used to distinguish users. |
13 months |
|
Hotjar |
|
|
|
_hjIncludedInSample |
Session cookie to let Hotjar know whether a user is included in the sample which is used to generate funnels. |
365 days |
How to delete, be notified when cookies are installed or configure your browser?
Clearing cookies already installed on your computer.
You can clear the cookies already installed on your computer by clearing your browser’s cache. For instructions on how to remove cookies on the Chrome, Firefox, Safari, Opera, and Internet Explorer browsers, click here.
Configuring your browser to refuse cookies, or to be notified when cookies are installed.
All web browsers enable you to set your cookies preferences before you navigate the internet. For instructions on how to configure your web browser to refuse cookies or to notify you when cookies are installed, click here.
If you have questions about our Cookies Policy, please email us at [insert your contact email address].