{brand} by Braineet SAS

Privacy policy

{brand} builds strong, lasting relationships with its customers, partners, consumers and associates, based on mutual trust: making sure that their personal data are safe and remain confidential is an absolute priority for {brand}.

{brand} complies with all French and European regulatory and legal provisions on the protection of personal data.

{brand} enforces a very strict privacy policy to guarantee protection of the personal data of those who use its platforms and other applications:

Users remain in control of their own data. The data are processed in a transparent, confidential and secure manner.

{brand} is committed to a continuing quest to protect its users’ personal data in accordance with the General (EU) Data Protection Regulation of April 27, 2016 (hereinafter the “GDPR”).

{brand} has a dedicated personal data protection team comprising a Group Data Protection Officer registered with the CNIL (Commission Nationale de l’Informatique et des Libertés [French Data Protection Agency]) and a network of contact persons dedicated to personal data protection.

PURPOSE OF THIS POLICY

{brand} takes the protection of your personal data very seriously.

We developed this policy to inform you of the conditions under which we collect, process, use and protect your personal data. Please read it carefully to familiarize yourself with the categories of personal data that are subject to collection and processing, how we use these data and with whom we are likely to share it. This policy also describes your rights and how you can get in touch with us to exercise these rights or to ask us any questions you might have concerning the protection of your personal data.

This policy may be amended, supplemented or updated, in particular to comply with any legal, regulatory, case law or technical developments that may arise. However, your personal data will always be processed in accordance with the policy in force at the time of the data collection, unless a compulsory legal prescription determines otherwise and must be enforced retroactively.

This policy forms an integral part of the Terms & Conditions of the Platform.

IDENTITY AND CONTACT DETAILS OF THE CONTROLLER

The personal data controller is: Braineet SAS, a corporation duly organized under the laws of France, located at 255, quai de la Bataille de Stalingrad, 92130 Issy-les-Moulineaux.

DEFINITIONS

“Personal Data” means any information relating to an identified natural person or one that can be directly or indirectly identified by reference to an identification number or to one or more factors specific to this person.

“us” or “our” {brand}. (hereinafter “{brand}”),

“you” any Platform user/visitor.

“Platform” “Innov’Hub”, the innovation and collaboration Platform available at the address: support@braineet.com.

COLLECTION AND SOURCE OF PERSONAL DATA

We will most likely collect your Personal Data directly (in particular via the data collection forms on our Platform) or indirectly (in particular via our service providers and/or technologies on our Platform).

We undertake to obtain your consent and/or to allow you to refuse the use of your data for certain purposes whenever necessary.

You will be informed of the purposes for which your data are collected via the Registration Page.

TYPES OF PERSONAL DATA COLLECTED AND USED BY US

We may specifically collect and process the following types of Personal Data:

the information that you provide when you registered the first time to the Platform;

the information that you provide when filling in the forms on the Platform;

the information that you provide for authentication purposes;

via “posts”, comments or other content that you post on the Platform.

Such Personal Data is collected directly from you when you decide on a voluntary basis to contribute to Innov’Hub. Personal Data identified by an asterisk in the data collection forms are compulsory as these are necessary to fulfill any orders placed. In the absence of this compulsory information, these transactions cannot be processed.

PERSONAL DATA THAT WE AUTOMATICALLY COLLECT

We collect some information automatically when you visit the Platform in order to personalize and enhance your experience. We collect this information using various methods such as:

Cookies

A “cookie” is a small information file sent to your browser when you visit our Platform and stored on your computer. This file contains information such as the domain name, the internet access provider and the operating system as well as the date and time of access by the user. Cookies cannot damage your computer in any way.

Cookies are not used to determine the identity of an individual who visits our Platform. Cookies allow us to identify, in particular, your geographic location and the display language in order to improve your online browsing experience. They also enable us to process information about your visit to our Platform, such as the pages viewed and the searches made, in order to improve our Platform content, to follow your areas of interest and offer you more suitable content.

If you do not want to receive cookies from our Platform, you can adjust your browser settings accordingly. To manage your choices, each browser has a different configuration. These configurations are described in your browser’s help menu, which will explain how to change the settings to your desired cookies configuration.

We recommend, however, that you do not deactivate our cookies. Keep in mind that if you block, turn off or reject our cookies, some of our webpages will not display correctly or you will no longer be able to use some of the services we offer. In this case, we cannot be held liable for any consequences related to the reduced functionality of our services arising from our inability to store or consult the cookies required for its functioning and which you have declined or deactivated.

Lastly, by clicking on the dedicated icons of social networks such as Twitter, Facebook, Linkedin, etc., if these are displayed on our Platform, and if you have agreed that cookies may be downloaded while you are browsing our Platform, the social networks in question may also download cookies to your devices (computer, tablet or mobile phone). These types of cookies are downloaded to your device only on condition that you have given your consent by continuing to browse our Platform. You can, however, at any time revoke your consent to these social networks downloading these types of cookies.

For more information, please consult the Cookie Policy of the Platform.

IP addresses

An IP address is a unique identifier used by some electronic devices to identify and communicate with each other on the internet. When you consult our Platform, we can use the IP address of the device used by you to connect you to the Platform. We use this information to determine the general physical location of the device and to know in which geographical areas visitors are located.

Statistics

The Platform uses Google Analytics to generate statistical reports. These reports tell us, for example, how many users consulted the Platform, which pages were visited and in which geographical areas Platform users are located. The information gathered via the statistics may include, for example, your IP address, the Platform from which you arrived at our site and the type of device that you used. Your IP address is hidden on our systems and will only be used if necessary to resolve a technical problem, for Platform administration and to gain insight into our users’ preferences. Platform traffic information is only accessible to authorized staff. We do not use any of this information to identify visitors and we do not share this information with third parties.

Analytics

Innov’Hub will use Google Analytics to create statistical reports. These reports will tell us, for example, how many users visited Innov’Hub, what pages have been browsed, and from what geographic regions users visited Innov’Hub. The information collected through the use of analytics may include, for example, your IP address, the website from which you visited us and the type of device you used. Your IP address is masked on our systems and will only be used on a need-to-know basis to resolve technical issues, to administer our Innov’Hub and to understand visitor preferences. Traffic information on Innov’Hub is accessed only by authorized personnel. We do not use any of this information to identify visitors and we do not share it with third parties.

PURPOSES FOR WHICH WE USE PERSONAL DATA

We use your personal data specifically for the following purposes:

to manage your registration process to Innov’Hub and support and manage the {brand} Innovation Program implemented throughout {brand} to encourage employees and external business partners to collaborate and contribute to its Innovation strategy;

to identify ideas teams;

to gather statistics

to personalize and enhance your experience on our Platform

any other purpose of which we will inform you, if applicable, when we collect your data.

LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

We process your personal data as part of the performance and management of our contractual relationship with you, in our legitimate interest to improve the quality and operational excellence of the services we offer to you or in compliance with certain regulatory obligations.

Your personal data may also be processed based on your prior consent in the event that under certain circumstances, your consent would be requested.

DISCLOSURE OF PERSONAL DATA

The security and confidentiality of your personal data are of great importance to us. This is why we restrict access to your personal data only to members of our staff who need to have this information in order to process your orders or to provide the requested service.

We will not disclose your personal data to any unauthorized third parties. We may, however, share your personal data with entities within the {brand} group and with authorized service providers (for example: technical service providers [hosting, maintenance], consultants, etc.) whom we may call upon for the purpose of providing our services. We do not authorize our service providers to use or disclose your data, except to the extent necessary to deliver the services on our behalf or to comply with legal obligations. Furthermore, we may share personal data concerning you (i) if the law or a legal procedure requires us to do so, (ii) in response to a request by public authorities or other officials or (iii) if we are of the opinion that transferring these data is necessary or appropriate to prevent any physical harm or financial loss or in respect of an investigation concerning a suspected or proven unlawful activity.

STORAGE PERIOD OF YOUR PERSONAL DATA

We will store your data only for as long as necessary to fulfill the purposes for which it was collected and processed. This period may be extended, if applicable, for any amount of time prescribed by any legal or regulatory provisions that may apply

SENSITIVE PERSONAL DATA

As a general rule, we do not collect sensitive personal data via our Platform. “Sensitive personal data” refers to any information concerning a person’s racial or ethnic origins, political opinions, religious or philosophical beliefs, union membership, health data or data relating to the sexual life or the sexual orientation of a natural person. This definition also includes personal data relating to criminal convictions and offenses.

In the event that it would be strictly necessary to collect such data to achieve the purpose for which the processing is performed, we will do so in accordance with local legal requirements for the protection of personal data and, in particular, with your explicit prior consent and under the conditions described in this Privacy Policy.

PERSONAL INFORMATION AND CHILDREN

The Platform is for use by adult persons who have the capacity to conclude a contract under the legislation of the country in which they are located.

Children users under the age of 16 years or without legal capacity must obtain consent from their legal guardians prior to submitting their data to the Platform.

The 16-year age limit may be reduced to 13 years depending on the local legislation in your usual place of residence.

TRANSFER OF PERSONAL DATA

As {brand} is an international group, your personal data may be transmitted to internal or external recipients that are authorized to perform services on our behalf and that are located in countries outside the European Union or the European Economic Area which do not offer an adequate level of personal data protection. Such access from the different Users of Innov’Hub is in fact necessary for the purpose of allowing an interaction with the content submitted by other users.

To guarantee the security and confidentiality of personal data thus transmitted, we will take all necessary measures to ensure that these data receive adequate protection. When registering on Innov’Hub to participate in the Innovative initiative, by ticking the box to that effect, you consent as a User, that your Personal Data be accessible to the Users willing to interact with You who may be based in country which is not considered by the European Commission or the data protection national authorities as providing an adequate level of protection.

YOUR RIGHTS

{brand} is committed to ensure protection of your rights under applicable laws. You will find below a table summarizing your different rights:

Right of access and rectification	You can request a copy of the Personal Data we hold about you. You may also request rectification of inaccurate Personal Data, or to have incomplete Personal Data completed.
Right to erasure	Your right to be forgotten entitles you to request the erasure of your Personal Data in cases where: (i) the data is no longer necessary for the purpose for which it was collected; (ii) you choose to withdraw your consent; (iii) you object to the processing of your Personal Data; (iv) your Personal Data has been unlawfully processed; (v) there is a legal obligation to erase your Personal Data; (vi) erasure is required to ensure compliance with applicable laws.
Right to restriction of Processing	You may request that processing of your Personal Data be restricted in the cases where: (i) you contest the accuracy of your Personal Data; (ii) {brand} no longer needs your Personal Data for the purposes of the processing; (iii) you have objected to processing for legitimate reasons.
Right to data portability	You can request, where applicable, the portability of your Personal Data that you have provided to {brand}, in a structured, commonly used, and machine-readable format you have the right to transmit this data to another Controller without hindrance from {brand} where: (a) the processing of your Personal Data is based on consent or on a contract; and (b) the processing is carried out by automated means. You can also request that your Personal Data be transmitted to a third party of your choice (where technically feasible).
Right to object to Processing	You may object (i.e. exercise your right to “opt-out”) to the processing of your Personal Data particularly in relation to profiling or to marketing communications. When we process your Personal Data on the basis of your consent, you can withdraw your consent at any time.
Right not to be subject to automated decisions	You have the right not to be subject to a decision based solely on automated processing, including profiling, which has a legal affect upon you or significantly affects you.
Right to lodge a Complaint	You can choose to lodge a Complaint with the Data Protection Supervisory Authority in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages. You have also the right to lodge your Complaint before the courts where the {brand} entity has an establishment or where you have your habitual residence.

To exercise these rights, you can either send your request to support@braineet.com and/or to the Group Data Protection Officer at support@braineet.com.

SECURITY

We implement all possible technical and organizational security measures to ensure security and confidentiality in processing your personal data.

To this end, we take all necessary precautions given the nature of the personal data and the risks related to its processing, in order to maintain data security and in particular to prevent distortion, damage or unauthorized third-party access (physical protection of the premises, authentication procedures with personal, secured access via identifiers and confidential passwords, a connection log, encryption of certain data, etc.).

CUSTOMER RELATIONSHIP MANAGEMENT DATABASE (“CRM DATABASE”)

We use a database to manage and monitor our relationships with existing and potential customers. This database includes the personal data of associates of our customers or other partners with whom we have a business relationship or with whom we want to establish such a relationship. These data, used only for this purpose, notably include: contact details (surname, first name, telephone number, email address, etc.), publicly accessible information, the responses to targeted emails and other information collected and recorded by our associates as part of their interactions with our customers and partners. If you want to be removed from our CRM database, please write to support@braineet.com.

LINKS TO OTHER SITES

Occasionally, we provide links to other Platforms for practical and informative purposes. These Platforms are mostly {brand} Platforms and some of them operate independently from our Platforms and are not under our control. These Platforms are run by third parties with their own confidentiality recommendations or terms of use which we strongly advise you to read. We do not accept any liability with regard to the content on these sites, for the products and services that may be offered there or for any other use thereof.

UPDATES OF OUR CONFIDENTIALITY POLICY

We may update or amend this confidentiality policy as and when needed. In this case, amendments will be available in the Platform. Please consult this page from time to time if you want to be informed of any possible changes.

DATA STORAGE

If you have subscribed to certain services via our Platform and you no longer want to receive emails, please consult the “unsubscribe” page corresponding to the service you are subscribed to. You can close your account via the user profile interface of the Platform or by contacting support@braineet.com. We will dissociate your public posts from your account profile but we may retain information about you for the purposes authorized by this policy and archive your Personal data 5 years after the deactivation of your account for analytics consistency purposes.

When employees leave the company, they shouldn’t have access anymore to this platform but their account and related personal data is kept in the system for 5 years for statistics purposes and also to keep more consistency with their contributions in the Platform.

HOW TO CONTACT US

If you have any questions or comments with regard to this policy, please do not hesitate to contact us at the following address: support@braineet.com or contact our Group Data Protection Officer at the following address: support@braineet.com.

Last updated: January 2021.