Politique de confidentialité Solution Golem.ai

Idéquanet respects the right to privacy and recognizes the importance of protecting personal data.

In this respect, Idéquanet undertakes to process personal data transmitted by its Clients, as well as by the persons browsing its website, in accordance with the provisions of Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the " GDPR ). "), of the law N° 78-17 of 6 January 1978 relating to data processing, files and freedoms (hereinafter the " Law N° 78-17 ") as well as this Privacy Policy of Idéquanet (hereinafter the " Privacy Policy ").

The purpose of the Privacy Policy is to detail the origin and use of personal data collected and processed by Idéquanet as well as the measures it implements to best protect said data.

 
Article 1 - Scope of this policy

Idéquanet, whose registered office is located at 49 rue Notre-Dame de Nazareth 75003 Paris, registered with the Paris Trade and Companies Register under number 821 352 317, collects and processes personal data transmitted to it:

  1.  by the companies using the Golem.ai solution (hereinafter the " Client(s) ") and their agents (hereinafter the " Authorized Users "), in the context of the performance of the contract relating to the Golem.AI solution (hereinafter referred to as " Golem.ai ») ;
  2. by people browsing the website published by Idéquanet accessible at the following address https://www.golem.ai (hereinafter the« Visitor(s) »)
 
Article 2 - Treatments operated by Idéquanet
2.1 - Legal basis for processing

In order to use the Solution, Clients have entered into a contract, with which Authorized Users are required to comply. These documents formalize a contractual relationship between the Client, the Authorized Users and Idéquanet and serve as a legal basis for the collection and processing of personal data. Idéquanet is authorized to process, on behalf of its Clients, personal data necessary to provide access to Golem.ai.

As part of the browsing by Visitors, it is in the legitimate interest of Idéquanet to be able to process certain data relating to the use of the said website in order to improve its operation.

2.2 - Description of Processing
Processing Operations:
Collecting; access; use; matching; transmission; organization
Purpose(s) of the Processing(s):
Providing and managing the Golem.ai solution; the creation and use of the personal account; the categorization of electronic messages received by the Client; identification of relevant information; commercial prospecting.  
Category(ies) of Data Subjects:
Golem Solution Clients, Authorized Users and Visitors.
Category(ies) of Personal Data processed:
Identification data, contact data, economic information, login data.
Categories of Data Recipients: 
Clients and partners.
Categories of personnel with access to Personal Data (e.g. security, operational, legal personnel):
Security, marketing and operational staff.

Unless the consent of the persons concerned is obtained under the conditions provided for in accordance with the provisions in force, these operations must not lead to the establishment of profiles likely to reveal sensitive data (racial or ethnic origins, philosophical, political, trade union, religious opinions, sexual life or health of individuals).

In any event, the Customer is required to inform Idéquanet in advance of any other processing planned and to ensure compliance with the regulations in force. In particular, the Client is required to carry out, if necessary, an impact assessment of the envisaged processing on data protection under the conditions provided for in Article 35 of the European Regulation on the protection of personal data.

 
Article 3 - Data retention period 
3.1 - Retention period of data communicated by Customers and Authorized Users

The personal data communicated by the Client and the Authorized Users will be kept for the duration of the Contract between the Client and Idéquanet.

3.2 - Retention period of data communicated by Visitors

Visitors’ personal data are kept by Idéquanet for a period of three (3) years from the date of their collection.

Audience measurement statistics are not kept for a period exceeding six (6) months.

Certain data may be archived beyond the periods provided for (i) in the event of litigation in order to establish the reality of the disputed facts; and/or (ii) for the purposes of investigating, detecting and prosecuting criminal offences for the sole purpose of allowing, as necessary, the communication of such data to the judicial authority.

Archiving implies that this data is no longer available online but is extracted and stored on an autonomous and secure medium.

After the deadlines set out in the Privacy Policy, the personal data of the Visitors are deleted.

Idéquanet keeps Visitors’ data only for the periods specified above and will delete them at the expiry of the aforementioned periods.

 
Article 4 - Idequanet’s commitments

In accordance with Articles 28 and 32 of the GDPR, Idéquanet undertakes to:

  1. take and maintain all necessary measures, including appropriate technical and organizational measures, to preserve the security and confidentiality of the personal data entrusted to it for the supply of access to Golem.ai, in order to prevent them from being distorted, altered, damaged, disseminated or accessed by unauthorized persons;
  2. ensure that people authorized to process personal data on its behalf, in addition to having received the necessary training in the protection of personal data, respect confidentiality or are subject to an appropriate legal obligation of confidentiality;
  3. comply with the applicable legal provisions relating to the conditions of processing and/or the destination of the data communicated to him or to which he will have access in the context of providing access to Golem.ai;
  4. act only on the Client’s documented instruction for the processing of the personal data concerned;
  5. exploit the personal information collected or to which it may have had access for the sole purpose of providing Golem.ai to Clients, Authorized Users and Visitors;
  6. not to exploit for purposes contrary to the Contract the personal information collected or to which he may have had access in the context of the execution of the Contract in accordance with the applicable legal provisions, and to transfer them only to a third party indicated or authorized by the Client;
  7. not to resell or transfer data that is strictly confidential;
  8. to assist Clients, Authorized Users and Visitors, as far as possible, by implementing appropriate technical and organisational measures, as well as to fulfil its obligation to respond to requests from data subjects in order to exercise their rights of access, rectification, erasure, opposition, limitation and data portability;
  9. assist the Client, to the extent possible and taking into account the information provided by the Customer, to comply with its obligation to: (a) notify the Supervisory Authority of a personal data breach; (b) communicate to the data subject a personal data breach; (c) carry out a data protection impact assessment.

In the context of the processing of personal data, Idéquanet may involve subcontractors.

In this case, Idéquanet ensures that the subcontractor complies with its obligations under the GDPR and that it provides sufficient guarantees as to the implementation of appropriate technical and organizational security measures.

Idéquanet undertakes to sign, with all its subcontractors, a written contract imposing on them obligations equivalent to its own in terms of the protection of personal data in accordance with the provisions of Article 28 of the GDPR.

The list of second-tier subcontractors to date is as follows: 

  1. Scaleway;
  2. PostHog;
  3. Google suite (email, stockage).
 
Article 5 - Rights of Authorized Users and Visitors

Authorized Users have the following rights:

  1. A right of access : this right allows Authorized Users and Visitors to obtain information regarding the processing of their personal data as well as a copy of such data;
  2. A right to rectification : this right allows Authorized Users and Visitors to request that personal datathey consider inaccurate or incomplete be amended accordingly;
  3. A right to object : it allows Authorized Users and Visitors to object to the processing of their personal data for reasons related to their particular situation. The right to object is absolute with regard to the processing implemented for commercial prospecting purposes;
  4. A right to restrict processing : it allows Authorized Users and Visitors to suspend the processing of personal data to which they are subject while retaining the processed data;
  5. A right to data portability : it allows Authorized Users and Visitors to obtain that the personal data they have provided be retainedor, where technically possible, transferred to a third party. The information requested by Authorized Users will be provided to them in electronic form, unless expressly requested otherwise; 
  6. The right to define guidelines relating to the fate of their data after their death; ;
  7. A right to erasure : it allows Authorized Users and Visitors to obtain the deletion of their personal data. With regard to the right to delete personal dataof Authorized Users, this will not be applicable in cases where the processing is implemented to meet a legal obligation.

Authorized Users and Visitors are informed that they have the right to lodge, at any time, a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), if they consider that the processing subject to the Privacy Policy constitutes a violation of the applicable legislation on the protection of personal data. 

 

Article 6 - Personal Data Protection Officer

In order to ensure at all times the protection of the personal data that it collectsand processes in the course of its activities, Idéquanet has appointed a Data Protection Officer whose contact details are as follows: Marie-Justine Chassagne - marie-justine.chassagne@golem.ai.

 
Article 7 - Changes to the Privacy Policy

Idéquanet reserves the right to make, at any time, any changes to the Privacy Policy that it considers necessary and useful.

In the event of a change to the Privacy Policy, Idéquanet undertakes to make the Client and Authorized Users and Visitors accept the new Privacy Policy again when they access Golem.ai again.  Golem.ai.

They will also be accessible on Golem.ai and, if applicable, in the User account on Golem.ai.

 
Article 8 – Cookies

Idéquanet collects information about the use of Golem.ai by Authorized Users and Visitors using cookies. Cookies are text files that may be deposited by Idéquanet on the hard drive of the computer of Authorized Users and Visitors or any other access device they use, when consulting Golem.ai. Cookies help Idéquanet remember Authorized Users and Visitors when accessing Golem.ai as well as various information about previous visits.

Here is a list of these cookies:

Functional cookies : These cookies allow Authorized Users and Visitors to browse Idéquanet’s services and use functions such as connecting to secure areas.

Non-functional cookies : These cookies make it possible to obtain attendance statistics useful for optimizing its ergonomics and content. They also allow the user to view multimedia content of third-party services directly on the site.

Cookies used:

  • Google
  • YouTube
  • Google Analytics
  • Crazy Egg
  • Doubleclick
  • Hubspot