Empowill Privacy Policy
This privacy policy describes the conditions under which your data is stored and used when you use our website (our "Site") as a visitor or before you connect to the Empowill application (the "Solution").
If you are part of a company that uses the Empowill Solution, any information relating to the processing of your personal data must be requested directly from your employer, with Empowill acting in this case as a subcontractor.
Do you have a question? Don't hesitate to contact us via the " Contact " page.
Charter for the protection of users' personal data
EFFECTIVE JANUARY 1, 2020
1. Definition and nature of personal data
When you use the empowill.com website, we may ask you to provide us with personal data.
The term "personal data" refers to any data that directly or indirectly identifies an individual.
2. Purpose of this charter
The purpose of this charter is to inform you about the means we use to collect personal data, in strict compliance with European law.
In this regard, we inform you that we comply, in the collection and management of personal data, with Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms, in its current version, known as "Informatique et Libertés", and Regulation (EU) 2016/679 of April 27, 2016, as soon as it comes into force (hereinafter: the "RGPD").
3. Identity of person responsible for data collection
The company responsible for collecting your personal data is EMPOWILL, SAS, registered in the Paris Trade and Companies Register under number 851 769 315, having its registered office at 2 avenue Taillade 75020 Paris France (hereinafter referred to as "We").
4. Data Protection Officer
We have appointed a Data Protection Officer, in the person of Mr MALAREWICZ, whose contact details are as follows:
Mr Alexandre MALAREWICZ
EMPOWILL
2 avenue Taillade, 75020 Paris
Email address: dpo@empowill.com
5. Collection of personal data
The legal basis for our collection of personal data is as follows:
(i) Legitimate interest when you voluntarily provide us with personal data when using our Site, the data then being collected to enable us to better respond to your requests for information about our services.
(ii) Your consent with regard to the audience analysis cookies referred to in article 11.
Personal data is collected for one or more of the following purposes:
(i) To build up a file of registered members, users, customers and prospects.
(ii) To send newsletters, requests and promotional messages. If you do not wish us to do so, we give you the option of expressing your refusal in this respect at the time of data collection.
(iii) To compile commercial statistics and statistics on the use of our services.
(iv) To manage the opinions of individuals on products, services or content.
(v) To personalize responses to requests for information.
(vi) To comply with our legal and regulatory obligations.
When collecting personal data, we inform you whether certain information is mandatory or optional. Mandatory data is necessary for the operation of our services. For optional data, you are entirely free to choose whether or not to provide it. We will also inform you of the possible consequences of failing to do so.
6. Recipients of collected data
Access to your personal data will be granted to our company's staff and to auditing bodies (in particular the statutory auditor).
Your personal data may also be used by public bodies, exclusively to meet our legal obligations, by law enforcement officers, judicial officers and debt collection agencies.
7. Transfer of personal data
Your personal data will not be transferred, rented or exchanged for the benefit of third parties.
8. Retention period of personal data
(i) Concerning data relating to the management of customers and prospects: personal data will not be kept beyond the period strictly necessary for the management of our commercial relationship with you. However, data required to establish proof of a right or contract, or to comply with a legal obligation, will be kept for the period stipulated by the law in force.
With regard to any prospecting operations aimed at customers, their data may be kept for a period of three years from the end of the commercial relationship.
Personal data relating to non-customer prospects may be kept for a period of three years from the date of collection or last contact with the prospect.
At the end of this three-year period, we may contact you again to find out whether you wish to continue receiving commercial solicitations.
(ii) Concerning the management of lists of objections to receiving canvassing: The information used to take account of your right to object is kept for a minimum of three years from the date on which you exercise your right to object.
(iii) Concerning cookies: The retention period for the cookies referred to in Article 11 is 13 months.
9. Security
We inform you that we take all necessary precautions and appropriate organizational and technical measures to preserve the security, integrity and confidentiality of your personal data and, in particular, to prevent it from being distorted, damaged or accessed by unauthorized third parties.
10. Hosting
We inform you that your data is kept and stored on the servers of OVH SAS for as long as it is required.
11. Cookies
Cookies are text files, often encrypted, stored in your browser. They are created when a user's browser loads a given website: the site sends information to the browser, which then creates a text file. Each time the user returns to the same site, the browser retrieves this file and sends it to the website's server.
Different types of cookies are used for different purposes:
- Technical cookies are used throughout your browsing experience, to facilitate navigation and execute certain functions. A technical cookie may, for example, be used to memorize the answers entered in a form, or the user's preferences regarding the language or layout of a website, where such options are available.
We use technical cookies.
- Social network cookies may be created by social platforms to enable web designers to share their site's content on these platforms. In particular, these cookies may be used by social platforms to track users' browsing habits on the website concerned, whether or not they use these cookies.
We do not use cookies from social networks. If we decide to do so at a later date, we will ask for your consent before depositing them. You will also have the opportunity to inform yourself about the nature of these cookies and to accept or refuse them.
We also invite you to consult the privacy policies of the social platforms that set these cookies, to find out how they use the browsing information they may collect thanks to these cookies, and how you can exercise your rights with these platforms.
- Advertising cookies may be created not only by the website on which the user is browsing, but also by other websites displaying ads, widgets or other elements on the page displayed. In particular, these cookies can be used to carry out targeted advertising, i.e. advertising determined according to the user's browsing habits.
We do not use advertising cookies. If we decide to do so at a later date, we will ask for your consent before depositing them. You will also have the opportunity to inform yourself about the nature of these cookies and to accept or refuse them.
- We use Google Analytics, a statistical audience analysis tool that generates a cookie to measure the number of visits to our site, the number of pages viewed and visitor activity. Your IP address is also collected to determine the city from which you are connecting.
We remind you that you can refuse to accept cookies by configuring your browser. However, such a refusal could prevent our site from functioning properly.
12. Access to your personal data
In accordance with the "Informatique et Libertés" law and the RGPD, you have the right to obtain communication and, where appropriate, rectification or deletion of data concerning you, through online access to your file. You can also contact :
- e-mail address: dpo@empowill.com
- postal address: 2 avenue Taillade 75020 Paris France
Persons whose data is collected on the basis of our legitimate interest, as mentioned in article 4, are reminded that they may object to the processing of their data at any time. We may, however, continue to process data if there are legitimate grounds for the processing which override your rights and freedoms, or if the processing is necessary to establish, exercise or defend our legal rights.
13. Right to define directives concerning the processing of data after your death
You have the right to define directives concerning the conservation, deletion and communication of your personal data after your death.
These directives can be general, meaning that they apply to all personal data concerning you. In this case, they must be registered with a trusted digital third party certified by the CNIL.
Instructions may also be specific to the data processed by our company. In this case, please send them to the following address:
- e-mail address: dpo@empowill.com
- postal address: 2 avenue Taillade, 75020 Paris France
By sending us such instructions, you expressly give your consent for these instructions to be stored, transmitted and executed in accordance with the terms and conditions set out herein.
In your instructions, you may designate a person to carry out your wishes. This person will then be entitled, when you die, to take cognizance of your directives and ask us to implement them. If you do not designate a person, your heirs will be entitled to take cognizance of your instructions on your death and ask us to implement them.
You can change or revoke your instructions at any time by writing to us using the contact details above.
14. Portability of your personal data
You have a right to the portability of the personal data you have provided to us, understood as the data you have actively and consciously declared in the course of accessing and using the services, as well as the data generated by your activity in the course of using the services. We remind you that this right does not apply to data collected and processed on a legal basis other than consent or the performance of the contract binding us.
This right may be exercised free of charge, at any time, and in particular when closing your account on the Platform, in order to recover and store this personal data.
Within this framework, we will send you your personal data, by any means deemed useful, in a standard open format commonly used and machine-readable, in accordance with the state of the art.
15. Making a complaint to a supervisory authority
You are also informed that you have the right to lodge a complaint with a competent supervisory authority, (the Commission Nationale Informatique et Libertés for France), in the Member State in which your habitual residence, your place of work or the place where the violation of your rights would have been committed is located, if you consider that the processing of your personal data subject to the present Charter constitutes a violation of the applicable texts.
This recourse may be exercised without prejudice to any other recourse before an administrative or legal jurisdiction. Indeed, you also have the right to an effective administrative or judicial remedy if you consider that the processing of your personal data as described in the present Charter constitutes a violation of the applicable laws.
16. Limitation of processing
You have the right to limit the processing of your personal data in the following cases:
- During the period of verification that we implement, when you dispute the accuracy of your personal data,
- When the processing of such data is unlawful, and you wish to limit such processing rather than delete your data,
- When we no longer need your personal data, but you wish to retain them to exercise your rights,
- During the period of verification of legitimate grounds, when you have objected to the processing of your personal data.
17. Modifications
We reserve the right, at our sole discretion, to modify this charter, in whole or in part, at any time.
You agree to be notified of updates to these terms and conditions by posting them on the Site. Any modification will take effect as of its publication.
By continuing to use our Site, or by accessing it after the effective date of any updates, you declare that you have read the updates and accept all modifications made to them.
18. Entry into force
This charter comes into force on 01/01/2020.
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