Personal Data Protection Policy
Preamble – Scope
By accessing the FOLLOWANALYTICS’ website and using the services offered, the User acknowledges having read and understood this General Policy on the protection of personal data, as well as the practices for collecting consent, collecting and processing data, information described in this document.
In general, you can visit our Website without having to send us any Data. However, in order to be able to provide you with certain services, FOLLOWANALYTICS may ask you to provide certain Data.
Personal Data – hereinafter referred to as “the Data” – means any information relating to an identified or identifiable natural person – hereinafter referred to as “data subject”.
This Policy sets out the principles and guidelines for the protection of your Personal Data and is intended, among other things, to inform you of:
- The Personal Data collected by FOLLOWANALYTICS and the reasons for this collection,
- The way in which these Personal Data are used,
- Your rights in Personal Data concerning you.
Table of Contents
1. Presentation of the company
2. Intellectual Property of our site
3. Contact Information
4. Appointment of a DPO-DPD at the CNIL
5. Collection and Use of Collected Data
6. Data Retention Period
7. Categories of recipient of your data
8. Data Transfer
9. Fair interest of our treatments
10. Information on minors under 15
11. Reminder of your rights defined by the RGPD Regulation
12. Exercise of rights
13. Cookies policy of our web site
14. Measures taken for the protection of personal data
15. Data Breach
16. Applicable law and jurisdiction
17. Modification of this Data Protection Policy
FOLLOWANALYTICS provides an online marketing automation platform for websites and mobile applications. It enables marketing teams to create notification campaigns that reinforce customer engagement, usage, and retention.
The company FOLLOWANALYTICS is committed to comply with all legal obligations regarding the protection of personal data, including publicly committing to compliance with the General Regulations for Data Protection and the Data Protection Act.
Regulation (EU) 2016/679, known as the General Data Protection Regulation (“GDPR”) and Law No. 78-17 of 6 January 1978 relating to data, files and freedoms, as amended by the law of August 6, 2004 (“Data Protection Act and Freedoms”).
In accordance with the Data Protection Act, and the General Data Protection Regulation, FOLLOWANALYTICS undertakes to:
- treat only fair and lawfully collected data;
- treat the collected data only for specified, explicit and legitimate purposes;
- treat only the relevant and relevant data that are not excessive in relation to the purpose of the processing;
- take all necessary precautions to preserve the security of the data, in particular to prevent them from being deformed, altered, damaged;
- do not communicate this data to third parties outside the company without informing the persons.
Conscious of the fact that the provision of information online implies a great mark of trust on the part of the users, we consider this trust with the utmost seriousness and make a major priority of the security and the confidentiality of the personal data that you us provide when you visit our website and use our services.
The content of our site, the general structure, the tree structure, the textual contents, the animated images or not and the logos of which the site is composed are the exclusive property of the company FOLLOWANALYTICS. Any representation, total or partial, of this site or its content, on any medium, for a collective or professional use, even internally in the company, by any process whatsoever, without the express prior written permission the company FOLLOWANALYTICS is prohibited and constitutes an infringement punishable by articles L.335-2 and following of the Code of the Intellectual Property, likewise the violation of these provisions submits the offender and all persons responsible to the penal and civil penalties envisaged by French law.
Site web: https://www.followanalytics.com
Data Controller: M. Pierre VIBERT
Publishing Director: M. Pierre VIBERT
Company: FOLLOW-APPS (FollowAnalytics)
Type: SAS au capital de 70 906 €
RCS: RCS Paris 750 901 258
TVA: FR36750901258 000 38
Headquarters: 5 Third Street, Suite 520, San Francisco, CA 94103
Contact email: firstname.lastname@example.org
HQ Reception: +1-844-236-5569
Paris Reception: +33 (0)1 85 09 95 14
Subcontractor hosting the site and data
Type: SAS au capital de 500 000 euros
RCS: Roubaix – Tourcoing 424 761 419 00011
Headquarters: 2 rue Kellermann – 59100 Roubaix
Web Site: http://www.ovh.com
Tel.: +33 9 72 10 10 07.
Subcontractor in charge of the development and maintenance of the site
Headquarters: 10 rue de Penthièvre, 75008 PARIS
Web Site: www.kaokeb.com
Tel.: +331 86 95 91 69
4. Appointment of a DPO-DPD at the CNIL
The company FOLLOWANALYTICS has appointed a Data Protection Officer at the CNIL under the reference DPO-11646.
Its mission is to monitor in a rigorously independent way, the application of the law regulating the protection of the personal data that it is for our collaborators, our customers, our candidates as well as for all our suppliers and partners intervening in the developing our solutions.
It ensures on an ongoing basis that every precaution has been taken to preserve the physical and logical security of individuals’ data in order to prevent such things from being compromised, distorted or damaged.
Data Protection Officer
Designated Legal Entity:
Avocat Associé – DPO
Data Protection Officer
84 rue Jean de la Fontaine – 75016 Paris
Phone: +33 (0) 6 16 09 25 07
Only personal data that is useful for the contact request, demonstration of our products, registration for an event, registration for our newsletter or project processing are collected by the company FollowAnalytics.
Legal Basis of our data processing
We are entitled to process your data only from the moment:
- where you explicitly give us permission by validating the box “I have read and accept the policy of Protection of Personal Data. I consent to send this data form to the FollowAnalytics Company, in order to be contacted again. “On the consent form.
- then thereafter, if we have a contractual relationship, the processing will be legitimate and necessary in the follow-up of it, insofar as you will be party to or associated with the execution of the pre-contractual or contractual measures undertaken with us .
Data Collection Purpose
FOLLOWANALYTICS collects and processes personal data including:
- to send the newsletter in case of express choice in this sense, until your possible opposition / un-subscription,
- to contact you following a request for demonstration of our products, contact or a request to download editorial content FollowAnalytics,
- for the registration and management of an event,
- for the targeting of newsletters,
- to manage the options of your subscription to our various publications,
- to provide the requested contractual services,
- if necessary, to offer additional or optional services until a possible opposition on your part.
Categories of collected data
We refrain, with regard to personal information that you entrust to us, from any indirect collection, from any indirect use, and in a general way, from any act likely to infringe on your private life or your reputation.
FollowAnalytics thus ensures to collect only data strictly necessary for the declared purpose of the various treatments implemented by the company. When requesting a contact, demonstrating our products, registering for an event or registering for our newsletter, the following data is collected for the purposes of the services provided by the company:
Last name and first name
And, if necessary (optional):
Data relating to the file to be processed
Interests (different choices or options of the newsletter to receive)
History of the commercial exchanges (date and report of the telephone calls, RDV, …)
During the exchanges concerning the projects of the company, various Personal Data may be collected with the prior and informed consent of the interested persons, for the sole needs of the treatment of the projects of the company.
The company FOLLOWANALYTICS, in accordance with the legislation in force, will keep the Personal Data only for the duration necessary for the treatment. More specifically :
- Concerning the treatment and the follow-up of the candidatures, the company FOLLOWANALYTICS, in the respect of the legislation in force, will delete the data of the candidates within a maximum delay of one year after the last contact.
- Concerning the communication and management of contact requests, the company FOLLOWANALYTICS, in accordance with the legislation in force, will delete the data of its interlocutors within a maximum of three years after the last contact.
- The personal data of the clients and prospects involved will be kept in active database for a maximum of three years, after the end of the contractual relationship for the clients, or the last incoming contact for the prospects, in accordance with the law.
- For employees, the texts have variable durations for the preservation of certain data. (Employment contracts, URSSAF, pension funds, etc.) without prejudice to the legal obligations of conservation or limitation periods.
Beyond this period, the data may be anonymised and kept for exclusively statistical purposes and will not give rise to any exploitation of any nature whatsoever.
The Data collected is for internal use within FOLLOWANALYTICS and strictly limited to the most appropriate teams to process the request made. However, we may share the Data collected with our technical service providers for the purposes described above.
We strictly require our partners to always act in accordance with applicable data protection laws and to pay special attention to the confidentiality of such Data. In application of the regulations in force, any subcontractor who could process personal data on behalf of FOLLOWANALYTICS undertakes in particular to:
- treat the data only for the one or more purpose (s) that is / are the subject of the subcontracting,
- process the data according to the instructions of FOLLOWANALYTICS,
- guarantee the confidentiality and security of the Data.
The recipients of your data are:
- the management of our company,
- the administrative staff
- the persons in charge of the commercial follow-up through the person in contact with your company
- the subcontractors for hosting the data
° SALESFORCE, 3 Avenue Octave Gréard – 75007 Paris
- external collaborators for invitations to events (subcontractors, collaborators, technical service providers for the organization of this event),
- in the context of the sending of newsletters, the collaborators, technical service providers, for the targeting and the realization of the sendings
° PARDOT, 3 Avenue Octave Gréard – 75007 Paris
- in the context of its commercial relations, with its partners
FOLLOWANALYTICS may also disclose or transfer your personal data to third parties in the following particular circumstances:
- by law, in the context of legal proceedings, litigation and / or a request from public authorities in your country of residence or otherwise;
- disclosure is necessary for national security, law enforcement or other public purpose purposes;
- in the event of restructuring, sale, merger or sale, to the relevant third party.
In the event that your Data is transferred outside the European Union, we make sure that:
- Personal data is transferred to countries recognized as offering an equivalent level of protection.
- Personal data is transferred to entities certified under the Privacy Shield
- For personal data transferred outside the countries recognized by the CNIL as having a sufficient level of protection, one of the mechanisms ensuring appropriate safeguards as provided by the applicable regulations, and in particular the adoption standard contractual clauses.
In some cases, and particularly with respect to our employees, the processing may be necessary for the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject who require protection of personal data, in particular where the data subject is a child. (GDPR art 6.f)
The website https://www.followanalytics.com is primarily intended for companies, administrations, and journalists, to allow them to take up with the company FOLLOWANALYTICS.
FOLLOWANALYTICS does not offer, through its website https://www.followanalytics.com services for minors under 15 years and is therefore not intended to collect personal data. In the event that a 15-year-old child sends personal data to the company FOLLOWANALYTICS, it will make every effort to delete the data transmitted.
Under the provisions of Article 12 of the GDPR you have the right to obtain clear, concise and transparent information from our company. The purpose of this document is primarily to fulfill the obligations referred to in Article 13.
Right to be confirmed treatment
- You thus have the right to obtain from the controller the confirmation that personal data concerning you are or are not processed.
(article 15-1 of the RGPD)
Access rights, purposes, categories, recipients, duration
When they are, you have a right of access to the said personal data and the following information:
(a) the purposes of the treatment; (article 15-1a of the RGPD)
(b) the categories of personal data concerned; (article 15-1b of the RGPD)
(c) the recipients or categories of recipients to whom the personal data have been or will be communicated; (article 15-1c of the RGPD)
(d) where possible, the retention period of the personal data envisaged, or the criteria used to determine that duration; (article 15-1d of the RGPD)
Correction, deletion-forgetting, limitation, opposition, portability
You are entitled to ask the controller:
e1) the correction of your personal data (article 16 of the RGPD)
e2) the erasure of your data or the “right to be forgotten” (article 17 of the RGPD)
You have the right to request the deletion of your data only for the reasons provided by the applicable regulations and in particular when:
- the Data are no longer necessary for the purposes for which they were collected or otherwise processed;
- you withdraw the consent on which the treatment is based, and there is no other legal basis for the treatment;
- you oppose treatment and there is no compelling legitimate reason for the treatment;
- you consider that your data has been subject to unlawful processing;
- your data must be erased to fulfill a legal obligation.
e3) Limiting the processing of personal data (Article 18 of the RGPD)
You have the right to obtain from the data controller the limitation of the use of your data solely for the reasons provided for by the applicable regulations and in particular when:
- you dispute the accuracy of the Data about you;
- you consider that the processing is illegal and you oppose the erasure of your data;
- The data is still necessary for you to find, exercise or defend legal rights even though FOLLOWANALYTICS no longer needs them.
e4) the right to oppose the processing of your data (article 21 of the RGPD) by withdrawing your consent being recalled that this withdrawal will not affect the lawfulness of the treatment based on the consent made before the withdrawal thereof
e5) the right to recover your data in a format easily readable by a machine to ensure its portability; (article 20 of the RGPD)
Complaint to the CNIL, origin of the data, automated decision
You also have the right:
f) to lodge a complaint with a supervisory authority; (article 15-1f of the RGPD)
g) when personal data are not collected from you, any information available as to their source; (art 15-1g of the RGPD)
(h) to verify the existence of automated decision-making, including profiling, and in such cases, useful information regarding the underlying logic, as well as the significance and expected consequences of such processing. (article 22 of the RGPD) (article 15-1h of the RGPD)
Right to know if your data is subject to cross-border flows
- You have the right to be informed of the appropriate safeguards provided if your data is transferred to a third country outside the European Union. (article 15-2 of the RGPD)
Right to obtain a copy of your data
- You have the right, by proof of your identity, to obtain from the data controller an electronic or paper copy of the personal data concerning you, processed in our company or at any other location. of our subcontractors. (provided that this application does not affect the rights and freedoms of others.)
You can send any request to this effect to the Data Protection Officer who has been emptied above. (articles 15-3 & 4 of the RGPD)
Right to give instructions in case of death
- You also have the right to give us instructions on the fate of your data after your death.
(Law No. 2016-1321 of October 7, 2016 for a Digital Republic)
Right to revoke a previously issued authorization to collect
You have the right to withdraw your consent at any time. The withdrawal of this consent does not compromise the lawfulness of consent-based treatment prior to such withdrawal.
You must be informed of this right before giving your consent. It must be as simple for you to withdraw your consent as it is to give it to us.
(article 7-3 of the RGPD)
Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority if you find a violation of your data or if you believe that the processing of your personal data constitutes any violation of the rules.
We suggest, however, that you first contact the DPO-DPD designated in B above to request clarification.
You will find under this link for information the procedure provided by the CNIL. https://www.cnil.fr/fr/agir
Right to know the consequences of a refusal to provide information
You are informed that in accordance with Article 32 of the Data Protection Act, the information you provide us with the forms on the site are necessary to respond to its request and are intended for services in charge of responding to your request to follow-up purposes.
You have the right to refuse to send us this information, but you are informed that in this case, the company FOLLOWANALYTICS may in turn refuse to respond to an incomplete request from you.
Right not to be the subject of an automated decision
You have the right not to be the subject of a decision based exclusively on automated processing, including profiling, producing legal effects concerning you. (art 22-1)
FOLLOWANALYTICS does not carry out such data processing.
Right to require that your data be kept safe
The company FOLLOWANALYTICS ensures the security and durability of your Personal Data by implementing a series of physical and logical protections in the preservation and safeguarding of your data, to prevent them from being destroyed, corrupted, modified, diverted, or altered.
In accordance with the “Loi Informatique et Libertés” of January 6, 1978 modified, justifying your identity, you have the right to access and rectify or delete information about you. You may also, for legitimate reasons, oppose the processing of this data or request portability.
To exercise your different rights defined in § G of this, you will have to prove your identity and optionally:
- tell us why you want to exercise them
- to precisely define the perimeter of the data of which you wish to copy
- specify the data format you want back
For this purpose, you will contact the correspondent of the CNIL responsible for monitoring our compliance:
Monsieur Jean-Michel Livowsky
Data Protection Officer
11 rue Théodule Ribot ~ 75017 Paris
Telephone: 01 4227 7349
The partial opposition (or simple request for un-subscription) is a right that you can exercise at any time during shipments, through a link on each email you receive from us, it is useless to enter a DPO for that.
Comprehensive information of all your rights
For more information about your rights, log on to the CNIL website at: https://www.cnil.fr
You also have the right to go directly to the Commission if you believe that your rights have been violated, or that our company is not respecting its data protection commitments.
When you browse our website, we collect certain information using cookies.
A cookie is a text file saved on your device’s hard drive, such as when you visit a site or read an email. A cookie identifies the device on which it is registered, during the period of validity of the consent, which can not exceed 13 months.
Cookies are managed by your internet browser and only the issuer of a cookie may read or modify the information contained therein.
We use 4 types of cookies:
Operating Cookies (WordPress)
They allow us to ensure a smoother operation of the site. (eg recording your favorite language). They are required to enjoy the best browsing experience.
Audience Measurement Cookies (Google Analytics)
They allow us to know how many visitors come to our website, and understand what use of our website is made.
They also allow us to know which pages are preferred by our visitors.
Social Network Cookies (Linkedin, Twitter)
These allow us to know how many times and by whom are shared our contents on social networks.
We have no control over the processes used by these social networks to collect information relating to your browsing on Our Site. We invite you to consult the privacy policies of these social networks to know for what purposes (including advertising) they use the navigation information they collect through these application buttons. These privacy policies must include information about how to manage your preferences on your social networking account.
Marketing Cookies (Pardot)
They allow us to know the number of people who opened our emailings and clicked on its links.
For customers, they allow them to not have to re-enter their personal data in marketing forms.
You can at any time choose to enable or disable these cookies by going to the “Cookies” page located in the footer menu You can also disable and / or delete cookies from your computer, tablet or mobile phone by managing your browser settings.
A very effective CNIL tutorial can help you if you wish to better control your navigation traces, we encourage you to consult it.
14. Measures taken for the protection of personal data
FOLLOWANALYTICS has taken steps to prevent any personal data breach, including:
- Appointment of a Data Protection Officer at FOLLOWANALYTICS
- Awareness of the teams on the protection of personal data
- Audit and mapping of the processing of personal data carried out within the company and its subcontractors
- Security audit of the information system
- Implementation of a general data protection policy
In the event that we become aware of an illegal access to your personal data corresponding to a treatment for which we are responsible, we undertake to notify you of the incident as soon as possible if it meets a legal requirement.
16. Applicable law and jurisdiction
Our website and our activity are governed by French law. In the event of litigation resulting from your use of our websites or its activity, the French courts will be exclusively competent.
17. Modification of this Data Protection Policy