This policy (together with our terms of service and any other documents referred to in it) sets out:
- Data processed on behalf of our Customers
- Information collected
- Use of the Collected Information
- Data retention
- Protection of your information
- Information sharing
- Customers Consent
- Children and Privacy
- Tracking technologies
- Data transferts
- Your rights
- Changes to this policy
- Contact information
*includes Services Provider such as Account Servicing Payment Service Providers or Third Party Providers (TPP) which can be Account Information Service (AIS) or Payment Initiation Service (PIS)
Data processed on behalf of our Customers
We may collect and receive Customer Data and other information and data (Other Information) in a variety of ways:
- Customer Data. Customers or individuals granted access to our Services by a Customer (Authorized Users) routinely submit Customer Data to us when using the Services.
- Other Information. We also collect, generate and/or receive Other Information:
- Account Information. To create, or update a Service or Customer account, you or your Customer supply us with name ,firstname, phone number, entity ( domain or organisation to which customer belongs)
- Usage Information.
- Services Metadata. When an Authorized User interacts with the Services, metadata may be generated that provides additional context about the way Authorized Users work.
- Log data. As with technology services delivered over the Internet, our servers automatically collect information when you access or use our Services and record it in log files. This log data may include the Internet Protocol (IP) address, the date and time the Services were used.
- Device information. We collect information about devices accessing the Services, including unique device identifiers. Whether we collect some or all of this Other Information often depends on the type of device used and its settings and the Services being used.
- Additional Information Provided to Us. We receive Other Information when you request support, interact with our social media accounts or otherwise communicate with us.
Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, Information). However, certain Information is collected automatically and, if some Information, such as account setup details, is not provided, we may be unable to provide the Services.
Use of the Collected Information
Customer Data will be used by us in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. We are a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to an account, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
We use Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, we use Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide search, learning and productivity tools and additional features.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about our company. These are marketing messages, so you can control whether you receive them.
- For billing, account management and other administrative matters. We may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
Protection of your information
We follow industry standards and implement proven security technology to protect our Customer Data, and access to Customer information is restricted to authorized personnel only. We are very sensitive to the privacy concerns of our Customers and visitors to our Website.
Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Service; any transmission is at your own risk given the transmission of information via the internet can’t be not completely secure.
We do not sell your information to third parties.
We may share the information you provide with our technical partners acting on our behalf to support our processing of personal data under this policy.
We will disclose your personal information to third parties in the event that APTORIEL or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Please note that we do not allow our Customers to opt out of contact that is required for the functionality of our Services or to maintain Customer accounts.
Children and Privacy
We do not knowingly target or solicit personal information from children or send them requests for personal information. If you are under the age of 18, you confirm you have received permission from your parent or guardian before using our Services or sending us personal information.
We may transfer your Personal Data to countries other than the one in which you live.
We do not transfer your Personal Data to countries that are not under the European General Data Protection Regulation.
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information.
To the extent that our processing of your Personal Data is subject to the General Data Protection Regulation, we rely on our legitimate interests, described above, to process your data.
EU Citizen rights under GDPR, you have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing;
- to request that your provided personal data be moved to a third party.
Your right to withdraw consent: Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time. You can exercise the rights listed above at any time by contacting us at firstname.lastname@example.org.
Please contact us at email@example.com for any GDPR issues you may have. You do, however, have the right to approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html for data protection authorities in the EU).
This policy was last updated on January 20, 2021.
You may email us at firstname.lastname@example.org or use our mailing address:
117 rue de Charenton