Protection of personal data

FOREWORD

1. COOT SOLUTIONS takes great care in the management and protection of personal data.

2. COOT SOLUTIONS has designed and published a mobile application called "SHARE(D)" (the "Application"), offering any user or natural person, services dedicated to the management and organisation of their daily family life.

3. COOT SOLUTIONS collects, via its website www.share-d.com (the "Site") and its Blog (https://share-d.com/blog) and in the course of carrying out its activities, personal data about individuals using the Application's Features (the "Users").

PURPOSE

4. The purpose of this document is to inform all Users on how COOT SOLUTIONS collects, uses, processes and transmits personal data.

5. The definitions set out in Article 2 of the General Conditions of Sale and Use shall apply here.

PERSONAL DATA CONTROLER

6. The data controller is COOT SOLUTIONS, a simplified joint stock company with a capital of €9,626.50, registered with the Paris Trade and Companies Register under number 830 800 868, whose registered office is at 4 Bis rue Lafayette, 38000 Grenoble, France, and whose EU VAT number is FR32 830 800 868.

7. The Data Protection Officer is Mr. Anthony Amouyal, domiciled at the COOT SOLUTIONS headquarters.

8. COOT SOLUTIONS undertakes to comply with all legislative and regulatory provisions relating to the protection of personal data (in particular EU Regulation No. 2016/679 of 27 April 2016).

DATA COLLECTED

9. Personal data collected by COOT SOLUTIONS may be directly transmitted by a User when registering and using the Application, browsing the Site or in the context of the formation and execution of a subscription to the Application.

10. This information includes: surnames, first names, postal address, e-mail address, telephone number, home address or login details of any User.

11. COOT SOLUTIONS may collect personal data directly transmitted by the User in the context of the execution of a commercial relationship and relating to the history of your orders of products or services via the Application and your successive subscriptions.

12. COOT SOLUTIONS also collects data via Cookies. A cookie does not personally identify a User but allows its issuer to recognise the User's device and to collect a certain amount of information relating to the navigation carried out from this device. The User is invited to consult the section below on Cookies.

13. COOT SOLUTIONS may also collect data through standard Internet technologies such as scripts, pixels and redirects. These technologies can collect information on the use of the Site or Application, the presence of cookies on the device of the User, whether or not emails sent by COOT SOLUTIONS have been read and any links contained in these emails that have been clicked on to improve the user experience on the Site and Application published by COOT SOLUTIONS.

14. COOT SOLUTIONS may also collect personal data from mobile devices used by a User. Depending on the device features activated by a User when downloading and using the Application, the mobile device sends information relating to the model of the device used, its operating system version, its type of connectivity and its geolocation. This data, processed by our servers, allows us to improve the use of our Site and Application and to measure the audience of our Application.

15. The Application is intended for natural persons of legal age, but a minor may create a Personal Account provided that he or she has obtained the express authorisation of an adult who is the holder of a Personal Account and is related to the minor such as a family relation.

PURPOSES OF THE COLLECTION OF PERSONAL DATA

16. COOT SOLUTIONS collects and processes personal data in accordance with the legal grounds provided by the laws and regulations in force, in particular:

a) Execution of a contract: for example, COOT SOLUTIONS collects personal data during the performance of its activities for the benefit of Users;

b) Fulfilment of a legal obligation such as keeping invoices;

c) Legitimate interests pursued by COOT SOLUTIONS such as processing for the purpose of optimising its services offered to Users or for the purpose of fraud prevention and, in any event, in compliance with the fundamental rights and freedoms of the User which prevail over the legitimate interests of COOT SOLUTIONS;

d) User consent: the consent of the User is required in particular for the collection of information not covered by the purposes mentioned above.

B/ Purposes of COOT SOLUTIONS

17. COOT SOLUTIONS may collect and store personal data from Users for the following purposes:

ProcessingLegal basis
Creation and management of a COOT SOLUTIONS personal user accountFormation and execution of the contract
Review of a subscription application; Processing and execution of a subscription;Formation and execution of the contract and legitimate interest of COOT SOLUTIONS
Customer satisfaction managementLegitimate interest of COOT SOLUTIONS: improvement of the quality of the services offered
Fight against fraud and usurpation; Detection and correction of anomaliesExecution of the contract and legitimate interest of COOT SOLUTIONS
Statistics, analysis, selection and segmentation of Users and their responsesConsent of the User Execution of the contract and legitimate interest of COOT SOLUTIONS
Sending targeted commercial offers by email, on social networks, on other websites or any other mediumUser consent
Personalisation of the Site and Application according to the User's preferencesUser consent
Measuring the amount of visits made to the Site and the ApplicationUser consent
Provision of sharing tools on social networksUser consent
Sharing information with business partnersExecution of the contract and consent of the User for operations for market research purposes

18. For the processing of data requiring the User's consent, the User has the option of withdrawing his or her consent by making a request here contact@share-d.com.

19. In the event that the User's consent has not been previously obtained, COOT SOLUTIONS does not proceed with the processing mentioned.

DATA TRANSMISSION

A/ General Information

20. The personal data collected and processed by COOT SOLUTIONS may be consulted by an employee of the Company in the context of the execution of its contractual commitments.

21. Personal data collected and processed by COOT SOLUTIONS may be transmitted to:

- COOT SOLUTIONS partners who may process them on their behalf ("recipients")

- partners of COOT SOLUTIONS who may process them on behalf of and under instructions from COOT SOLUTIONS ("subcontractors").

22. In any case, the personal data collected by COOT SOLUTIONS are not subject to any transfer forconsideration.

23. Recipients may include:

-  COOT SOLUTIONS industrial and financial partners who contribute to the provision of the services offered by the Publisher for the benefit of the User;

-  the police authorities in the context of judicial requests concerning the fight against fraud;

-  possible commercial partners such as marketing and advertising agencies, subject to the reservationsstipulated in this document.

24. COOT SOLUTIONS may use subcontractors for the following operations:

- secure payment on the Site or the Application;

- provision of the full Features of the Application;

- the fight against fraud and the recovery of unpaid bills;

- the management of e-mails, telephone calls, their possible recording and the sending of postal mail;

- the execution of after-sales service operations with a third-party service provider mandated by COOT SOLUTIONS;

- the personalisation of the contents of the Site and the Application;

- the performance of maintenance operations and technical developments of the Site, the Applicationand the COOT SOLUTIONS information system;

- the collection of user opinions;

- the sending of commercial market research emails.

25. COOT SOLUTIONS may also share personal data in the event of a subsequent change in the structure of the company COOT SOLUTIONS, including the sale, transfer or merger of the company or part thereof. COOT SOLUTIONS will then ensure that the other party complies with the laws and regulations on the protection of personal data.

B/ Transmission outside the EU

26. The data collected by COOT SOLUTIONS is stored in the European Union.

27. However, for the purposes set out above, personal data may, exceptionally, be transmitted to companies located in countries outside the European Union. As it stands, COOT SOLUTIONS does not transmit such data to recipients located in countries outside the European Union.

28. In this case, COOT SOLUTIONS ensures that personal data is only transferred outside the European Union to third countries ensuring an adequate level of protection and recognised as such by the European Commission, companies certified under the Privacy Shield or companies ensuring an adequate level of protection by the existence of binding corporate rules.

29. For example, the use of personal data in connection with social networks may result in a transfer to the United States.

30. Users are invited to consult the pages of the social networks relating to the protection of personal data.

USER RIGHTS

31. In order to ensure that Users have the necessary control and visibility over the processing of their personal data, COOT SOLUTIONS guarantees the proper exercise of the rights they have.

32. Thus, every natural person is entitled to exercise the following rights:

- right of access to processing

- right to object to processing

- right of rectification of processing

- right of limitation of processing

- right to object to profiling

- right to data portability

- right to deletion

33. By the processing of personal data, the data subject can exercise their rights with the company COOT SOLUTIONS:

- by post: 4 Bis Rue Lafayette, 38000 Grenoble

- electronically: contact@share-d.com

34. The application must be accompanied by proof of identity.

35. COOT SOLUTIONS has a period of one month to respond from the date of receipt of the request. An extension of the 2-month period is possible in view of the complexity and number of requests, provided that the data subject has been informed within the initial one-month period.

36. In case of exercising a right to oppose marketing profiling, the User is informed that he/she will continue to receive commercial requests but these will be less relevant and will no longer be targeted according to his/her centres of interest.

37. In the event of no response or an unsatisfactory response, the data subject has the right to refer the matter to the supervisory authority in his/her country of residence (CNIL.FR)

DIGITAL DEATH

38. The User has the right to define instructions concerning the conservation, deletion and communication of his/her data after his/her death. These instructions can be general (concerning all personal data processing) or specific (concerning only specific data processing).

39. The User may send any advance instructions that he or she may have formulated to the following address: contact@share-d.com

DATA RETENTION PERIOD

40. The processed data are kept for no longer than is necessary for the purposes for which they are processed.

41. The length of time that personal data is retained varies depending on how long a User has used the Site and Application:

User typeDuration of conservation
Subscribed userThe entire duration of the subscription. Upon de-registration, all documents in their space, e-mail, date of birth and name are deleted. For the duration of the subscription, the first name and all documents related to the proper execution of the contract are kept for the other users of the family unit using in the Application. This information will be permanently deleted when the last user in the unit configured in the Application is unsubscribes.
User without subscriptionDeletion of all their information during description. The first name and all documents relating to the correct use of the service for any other User of the same Family Space are kept for the entire duration of use of the Application. This information will be permanently deleted when the last User linked to the shared Family Space unsubscribes.
Other Internet userThe data generated by the cookies is kept for 13 months.

42. Some types of processing are subject to a specific retention period. For example, invoices are kept for 10 years; data relating to the execution of a transaction carried out via the Site or the Application are kept for up to 5 years after the end of the execution of the obligations; logs generated by the Use of the Service are kept for up to 1 year after their recording.

SECURITY OF THE DATA COLLECTED

43. As the data controller, COOT SOLUTIONS takes great care to ensure the security and confidentialityof the data collected and processed.

44. COOT SOLUTIONS has appropriate security measures in place to ensure the physical security of the buildings housing our systems, the security of the computer system to prevent external access to personal data, and having secure copies of User data.

45. COOT SOLUTIONS takes care to select subcontractors on the basis of their ability to ensure the security of the processing by appropriate measures.

DATA COLLECTED BY SOCIAL NETWORKS

46. COOT SOLUTIONS may propose to use social networks to improve the commercial relationship andto offer you targeted advertising on these networks.

47. The use of social networks to interact with COOT SOLUTIONS is likely to result in data exchange between COOT SOLUTIONS and these social networks.

48. COOT SOLUTIONS invites all Users to consult the personal data management policies of the various social networks to learn about the personal data that may be transmitted by them.

COMMERCIAL MARKET RESEARCH

49. Subject to obtaining your express consent, COOT SOLUTIONS may use your details to send youtargeted advertising, in particular by email and SMS.

A/ Market Research by email and SMS

50. The prior and express consent of the User is required for any commercial market research to be sent by electronic means.

51. With the exception of the following, COOT SOLUTIONS will not send you personalised requests via email or text message if you have not consented to them.

52. In any case, the User has the possibility to oppose the receipt of these requests, at any time, by carrying out the following actions:

- for email requests, by clicking on the unsubscribe link inserted in each email;

- for SMS requests, by sending a message containing only the words "Stop SMS" to the numberindicated in the message.

B/ Advertising retargeting

53. COOT SOLUTIONS may use the services of companies whose role is to identify Internet users who have already visited the Site or used the Application and to send them personalised emails.

54. These companies may use cookies to distinguish between Users and then customise the advertisements that those Users receive based on their browsing history.

55. This mechanism explains why a User who has browsed the Site or the Application may receive an advertising email without having given his/her email address to COOT SOLUTIONS.

56. This processing involves partners who have already collected your e-mail address and your consent to allow advertising to be sent. You can object to this type of processing by contacting contact@share-d.com

USE OF COOKIES

A/ General Information

57. Cookies are trackers deposited on your device (computer, tablet, smartphone, etc.), in particular when consulting a website or reading an e-mail, and which make it possible to monitor browsing or analyse the behaviour of the Internet user in order to facilitate browsing and activate certain features.

58. There are two types of cookies:

a. first party cookies deposited by COOT SOLUTIONS for the purposes of navigation and operation of the Site or the Application;

b. third party cookies placed by third party partner companies in order to identify your interests and to send you personalised offers on our Site or Application. These trackers are directly managed by the companies that publish them and that must also respect the regulations on data protection.

B/ Purposes of the use of cookies, tags and trackers

59. COOT SOLUTIONS may use first party cookies or third party cookies for the following purposes:

- to enable the use of the main Features (COOT SOLUTIONS cookies essential to use the Site or the Application);

- adapt the presentation of our Site or Application according to the device used and/or according to the preferences of each User;

- store information relating to a form you have filled in on our Site or Application;

- allow Users to access reserved and personal areas on the Site or the Application;

- implement security measures;

- establish statistics, volumes of visits and use of the elements making up our services (audience measurement cookies);

- share information with advertisers on other websites and propose advertisements that are relevant toyour interests (advertising cookies);

- share information on social networks (social network sharing cookies);

C/ Settings for the deposit of cookies, tags and trackers

60. COOT SOLUTIONS collects your consent prior to any deposit of advertising cookies, audience measurement and sharing with social networks.

61. At any time, the User may modify his/her preferences with regard to cookies in the following ways:

a. settings for browsers:

- Safari™ : https://support.apple.com/fr-lu/guide/safari/sfri11471/mac,

- Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647 ,

- Firefox™: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies ,

- For Opera™ : http://help.opera.com/Windows/10.20/fr/cookies.html

b. operating system settings of your smartphone:

- iOS: https://support.apple.com/fr-fr/HT201265

- Android: https://support.google.com/chrome/topic/3434352

c. cookies settings with a tool proposed by COOT SOLUTIONS

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