This is a courtesy translation prepared by us and not reviewed by a certified and sworn professional established for convenience purposes only. In case of discrepancy of interpretation between the English and the French version, the French version shall prevail.
Updated to January 28th, 2022
ARTCLE 1. PRESENTATION
The company TWINSYS (hereinafter “We") is a simplified joint-stock company, registered with the Trade and Companies Register of Saint-Brieuc under number 900 857 566, with a share capital of 25,000 euros, whose registered office is located at 4, rue André-Marie Ampère in Lannion represented by Mr. Olivier Le Fol.
TWINSYS offers companies a SaaS software solution for managing their workspaces (the “Solution"). The Solution is presented on the website accessible at the address https://www.twinsys.io/ (the “Site"). The Site allows any visitor (the “Visitors"), to use the following services, (i) the presentation of the Solution allowing her/him to consult the offers and prices of the Solution and to access a description of the services offered by TWINSYS as part of the Solution; (ii) the booking service of a demonstration, allowing her/him to book a time slot in order to benefit from a free demonstration of the Solution, (iii) the contact service allowing her/him to send inquiries about the Solution, by contacting a member of THE TWINSYS staff or to reserve a time slot for a first discussion by videoconference, via the contact form made available to the Visitor, and (iv) the instant messaging support service allowing her/him to interact live with a TWINSYS staff member (the “Services").
We have adopted this data protection policy (the “Policy") to explain how We collect, process, store, use and share the personal data (the “Data") that you provide to us ("You") and that we collect when you access, browse and use the Site and Services.
We act as the controller of Your Data for the processing carried out in connection with your use of the Site and the Services within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR") and the a law n ° 78-17 of January 6, 1978 amended by the law of August 6, 2004 then by the law of June 20, 2018 relating to data processing, files and freedoms (the “LIL") and any other French or European regulations applicable in the matter (the “Applicable Legislation on the Protection of Personal Data").
TWINSYS reserves the right to freely evolve the functionalities of the Site and the Services, in particular for legal or technological reasons at its sole discretion, in order to create new features or improve the existing functionalities of the Site and Services. Any modification of the Site and/or the Services is enforceable against the Visitor without notice from its production and the update of the General Conditions of Use (the “GCU") and the Policy. As such, the Visitor is invited to read the GCU and the Policy regularly.
ARTCLE 2. WHAT DATA DOES TWINSYS PROCESS?
Data is information that directly or indirectly identifies You. We process the following Data in connection with your use of the Site and Services:
- Your identification data such as name and/or surname and/or email address and/or mobile phone number and/or any information provided by You when You access and use the Site and Services;
- Your exchanges and correspondence with the instant messaging assistance service.
ARTCLE 3. FOR WHAT PURPOSES AND ON WHAT BASIS IS YOUR DATA PROCESSED?
We process your Data where this is necessary for the purposes of the legitimate interests we pursue, namely the following purposes:
- Allow your navigation on the Site;
- Improve your user experience on the Site.
We process your Data with your consent, in particular for the following purposes:
- Allow you to contact Us or book a demo, or benefit from the instant messaging support service.
ARTCLE 4. COOKIES
We may use cookies to collect your Data. Cookies are small text files that help your browser navigate our Site. The Cookie is generated by our Site and is accepted and processed by your browser software. The Cookie is stored in the folder or subfolder of your browser and this allows it to access the Cookie again when You revisit our Site. Thus, your browser uses the information stored in the Cookie to simplify your navigation on our Site by remembering the settings You have selected during your previous visits to our Site.
We use Cookies to allow You to browse and/or use our Site and its current features, to inform us about your origin and measure our audience, to maintain the relationship with You, to offer You quality content.
The Cookies we use are as follows:
| Cookie name | Usefulness | Description |
|---|---|---|
| Tawk.to | Essential | it allows us to provide instant messaging support to visitors |
These Cookies intended exclusively to carry out or facilitate navigation on the Site and necessary for the provision of a Service do not require your consent.
You also have the choice to accept or refuse to keep all or part of the Cookies in your browser or to disable all or part of the Cookies by configuring your settings. For more information on Cookies, please refer to the following website: http://www.allaboutcookies.org.
ARTCLE 5. WHO ARE THE RECIPIENTS OF YOUR DATA?
We share your Data with employees of our internal services such as IT and support, in particular in connection with your use of the Site.
We also share your Data with our subcontractors responsible for hosting your Data, sending communications about our services, compiling statistics and collecting your consent. In this case, We ensure that our subcontractors adhere to our Data Processing Policy and comply with the same Data Protection obligations that We are imposed. We also ensure that they provide sufficient guarantees to implement the appropriate technical and organisational measures so that the processing meets the requirements of our Data Processing Policy and, more broadly, the Applicable Legislation on the Protection of Personal Data.
We may also disclose your Data to the competent authorities to exercise our rights conferred by law or to comply with the law or a court order. Except as required by law or jurisdiction, we are not obligated to notify You of such data disclosures.
ARTCLE 6. IS YOUR DATA TRANSFERRED OUTSIDE THE TERRITORY OF THE EUROPEAN UNION?
We guarantee that We do not transfer any of your Data outside the territory of the European Union.
ARTCLE 7. HOW IS YOUR DATA STORED?
We (through our service providers) store your Data in storage facilities located within the territory of the European Union for a period not exceeding what is necessary for the purposes for which your Data was collected and processed by Us and, in any event, in accordance with legal requirements.
Your Data will be stored in our active database for the time necessary to browse and use our Site and will be irreversibly deleted or anonymized by Us or archived in an intermediate database with limited access at the end of your browsing session on the Site, with the exception of your contact Data which will be kept in our active database for a period of 3 years from the end of your browsing session on the Site in order to send You promotional communications about our Solution.
Your Data will be archived in a limited-access intermediary database in case We are legally required to retain it for a longer period of time, for example to comply with the law, to establish proof of our rights or our contract with You or for tax, accounting or audit purposes. In these cases, the duration of the storage processing will depend on the respective statutory limitation or retention periods and the Data will be erased after the expiry of the relevant retention periods.
ARTCLE 8. HOW IS YOUR DATA SECURED?
We seek to ensure the security of your Data and have implemented security measures consistent with accepted industry practices to protect your Data and limit access to it.
In particular, We have put in place appropriate technical and organizational measures to minimize the risks associated with the loss of your Data, misuse, unauthorized access and unauthorized disclosure such as: secure access to the Data through the implementation of identifiers and passwords; Data safeguards; security controls carried out by our engineers at each new production of a new development; contractual clauses necessary to guarantee the security of the Data at the level of the subcontractors, in particular to guarantee the effectiveness of the guarantees provided and the conditions for the return and destruction of the Data, as well as restrictions on physical access to our data centers and authorization controls for access to the Data.
However, despite our efforts to protect your Data, there is always a risk that an unauthorized third party may find a way to circumvent our security systems or that transmissions of your Data over the internet will be intercepted. We cannot guarantee the absolute security of your Data, nor the fact that the Data You provide will not be intercepted during transmission to Us over the internet. Therefore, We invites You to take all necessary precautions to protect your Data when You are on the Internet or when You use the Site.
In any case, when We become aware of a breach of your Data likely to create a high risk to your rights and freedoms, We notify You of this breach as soon as possible to allow You to take the necessary measures to protect You, in addition to having previously informed the National Commission for Informatics and Freedoms (the “CNIL"). If You have any questions regarding the protection of Data in our Services, You can write to the following address: contact@twinsys.io.
ARTCLE 9. WHAT ARE YOUR RIGHTS AS A PERSON CONCERNED BY THE DATA PROCESSING?
You have the following rights over your Data and the processing of your Data:
- right of access to your Data;
- right to rectify your inaccurate Data;
- right to erase your Data, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of a right;
- right to request the limitation of the processing of your Data to the extent that the accuracy of your Data is disputed by You, the processing is unlawful, but You object to the erasure of the Data and request the limitation instead, We no longer need the Data, but You need it to assert, exercise or defend legal claims or You have objected to the processing;
- refrain from receiving a copy of your Data in a structured electronic format or requesting the transfer of your Data to another controller, where technically feasible;
- right to object to the processing of your Data for reasons related to your particular situation, including your profile, or for marketing purposes;
- may withdraw your consent at any time where the processing is based on consent. You can also file a complaint with the CNIL at the following address: CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.
You can exercise your rights by sending us a clear and precise request by email to the following address: contact@twinsys.io. In this case, your Data will be erased, unless its processing is necessary to comply with our legal obligations, to comply with our contractual obligations or to pursue our overriding legitimate interests. Your request will be processed by our team within a reasonable time from the date of its receipt and will be accepted or refused subject to our legal obligations and within the limits of your rights.
ARTCLE 10. LINKS TO THIRD PARTY SITES
The Site may contain links that redirect You to other websites. The presence of a link to a third-party site on the Site does not in any way constitute an endorsement, authorization or affiliation with this website. If You click on a link that redirects You to a third party’s website, including an ad, You will leave the Site and the Services You were using to go to the selected website. Since We have no influence on the activities of third parties, We disclaims any responsibility for the use of your Data by such third parties and We cannot guarantee compliance with the same Data protection practices as those of TWINSYS. If You visit the website of a third party from a link from our Site, You must consult the Data Protection Policy of this website before transmitting your Data to it.
ARTCLE 11. TERMS OF USE OF THE SITE
The content of this Policy is linked to that of the General Conditions of Use of the Site (“GCU”) and all capitalized terms found in this Policy have the meaning given to them in these Terms that You can consult at the following email address: GCU.
ARTCLE 12. HOW TO CONTACT US?
If You have any questions or concerns about this Policy, please contact Us by email at the following address: contact@twinsys.io or by mail at the following address: TWINSYS, 4 rue André-Marie Ampère - 22300 Lannion.
