PRIVACY POLICY

TERMS AND CONDITIONS

Last updated: November 5th, 2019

1. Preamble

1.1 This privacy policy describes the privacy practices of INVYO, a SAS company duly incorporated and existing under French Law, registered under number 835 292 368 located at 10 Penthièvre street, 75008 PARIS (hereinafter referred to as “INVYO” and/or “We”).

The terms of this policy apply to INVYO’s website, accessible at the following URL address : https://invyo.io/ (hereinafter referred to as “Site” and defined at article 2.1)and inform you about the use, the collection and the processing of your personal data.

1.2 INVYO acts as a data controller within the meaning of European Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as "GDPR").

1.3 This privacy policy may occasionally be updated. Any changes will be indicated by a link to the privacy policy, as integrated to the Site. In case of material changes to this policy, We will provide notice or obtain your consent regarding such changes, as may be required by Law.

2. Definitions

2.1 "Site": means the https://invyo.io/ website (the main one) and any corresponding mobile apps and all derived sites as may be published by INVYO.

2.2 "User(s)" and/or “You”: means any visitor of the Site and any user who has entered Personal Data on the Site registration form(s) in order to benefit from all or part of the services, as provided on the Site and who has accepted our Terms of Service and the current privacy policy.

2.3 “Data Controller”: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State Law, the controller or the specific criteria for its nomination may be provided for by Union or Member State Law.

2.4 "Cookies": generally means tracers used alternatively or in combination notably in order to facilitate the User’s browsing, to propose services tailored to the User’s areas of interest (Advertising Cookies), to allow the development of statistics (Audience Cookies) and to allow Users to access personalised products and services on the Site.

2.5 "GDPR": means the General Data Protection Regulation No. 2016/679 of April 27, 2016 applicable as of May 25, 2018 or, instead, any Law that may be adopted for the transposition of said Regulation.

2.6 "Personal Data": means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal Data include banking data.

3. What information does INVYO collect about You?

3.1 We collect Personal Data You provide to us when You create an account on the Site, subscribe to INVYO’s newsletters or when You contact us for information about our offers or send us a message (in particular from the URL addresses : https://invyo.io/ and https://insights.invyo.io/europe/ by clicking on the footer “Insight Europe” at the bottom of the home page of the Site); the Personal Data We directly collect from You notably include :

  • First name / last name
  • password
  • e-mail

3.2 You must also be informed of the collect of your Personal and banking data by our partner “STRIPE”, from the URL address https://fintech-insights.com/, which is in charge of online payments (when purchasing research reports).

We specify that in the context of contractual relations between INVYO and STRIPE, the parties respect your privacy and guarantee that the use of your Personal (banking included) Data is compliant with applicable law.

For more information on STRIPE's features and how STRIPE collects your Personal (banking included) Data, you can click on the following link https://stripe.com/fr/privacy.

In any case, your Personal (banking included) Data collected from URL address https://fintech-insights.com/, by both INVYO and STRIPE are only used for the processing of your order and will never be shared to external parties.

3.3 When You subscribe to our newsletters, You expressly agree to receive, regularly, news about INVYO’s activity. You can unsubscribe at any time by clicking on the unsubscribe link at the bottom of the page of our newsletters.

3.4 The forms available on the Site for collecting Your Personal Data indicate whether or not data collection is mandatory. In the event You fail to provide any mandatory data, INVYO will not be able to provide its services.

3.5 We may also automatically collect information, such as Your IP address, browser type, access time, navigational information or any other information by the intermediary of our analytics tracking system, including cookies or other technology as described in our Cookies Policy.

4. Purposes for which We may process Your Personal Data

4.1 We may process Your Personal Data for the purposes described in this privacy policy, and notably with a view to:

(a) provide services as available on the Site, including but not limited, to the “free demo access” which allows Users to try INVYO’s services and evaluate the opportunity to subscribe a license. This processing is necessary to take steps, at Your request, prior to entering into a contract (section 6.1 b) of GDPR);

(b) perform operations relating to our commercial relationship (if any) and to safely conduct online payment transactions (also in the context of INVYO’s relations with STRIPE, in accordance with the description of this partnership at article3.2), including invoice, accounting, performance of license; this processing is necessary for the performance of a contract to which the data subject is party (section 6.1 b) of GDPR);

(c) communicate with You and send document or information You may require from us on the Site (newsletters, message etc.); the legal basis for this processing is consent (section 6.1 a) of GDPR);

(d) monitor and improve our Site, including internal operations, such as maintenance of Users’ accounts and security systems; this processing is based on our legitimate interest (section 6.1 f) of GDPR) or, when required, on your consent according to our Cookies Policy [link to be integrated].

4.2 We may also use Your Personal Data for any processing that could be necessary for compliance with a legal obligation to which We are subject.

5. Sharing of Your Personal Data

5.1 We may disclose Your Personal data to third party as may be strictly necessary for the purposes of administrating our Site and more generally providing services We offer to You.

In this respect, Your personal Data may be shared with our authorized staff and subcontractors. Any sharing of Your Personal Data with our business partners or other third parties is subject to Your consent.

We specify that your Personal Data may be transferred to EU countries, only for the purposes duly mentioned at article 4, in particular to INVYO’s hosting services provider listed at article 5.4 hereinafter.

5.2 Our subcontractors are involved in the following areas:

  • Hosting, maintenance of the Site and other technical operations relating thereto;
  • elivery and performance of the services provided on the Site and any technical operations relating thereto.

5.3 Your Personal Data held in our database will be stored on the servers of our hosting services provider Microsoft Azure, notably in the following countries : France, Ireland and Netherlands [identified at [https://products.office.com/fr-fr/where-is-your-data-located]].

5.4 In addition to the specific disclosures of Personal Data set out in this section, We may disclose Your Personal Data where such disclosure is necessary for compliance with a legal obligation to which We are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.5 In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.

6. How long does INVYO retain Your information?

6.1 We retain Your Personal Data for as long as necessary to deliver the services, provided on the Site, and to perform our commercial relationship (if any) or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

When you register on the Site for an account creation, We process and keep Your Personal information for as long as You maintain Your account and use our services or products. When You close your account, We delete any Personal Data that We no longer have a business reason to retain; We however retain any Personal Data related to our commercial relationship (if any) in order to commit with our legal obligations.

6.2 Indeed, in the event of a request to delete Your Personal Data and/or if you exercise your right to request the deletion of Your Personal Data, We may however retain it in the form of intermediate archiving, for the duration necessary to meet our legal, accounting and tax obligations.

Actual retention periods of Personal Data may then vary, in consideration of our legal or contractual obligations, and of the type of data concerned, which Users acknowledge and agree.

7. Cookies

We use Cookies to improve the operation of the Site and your browsing experience.

The Cookies used from the Site are listed on the following link .

Some Cookies allow You to use the main features of the Site. By disabling their use, you will no longer be able to access its features. In addition and depending on the settings for the use of Cookies, some tracking devices may be issued or read by third parties.

Cookies do not typically contain any information that personally identifies a user, but Personal Data that we store about You may be linked to the information stored in and obtained from Cookies. You can, at any time, change the settings of your Cookies and thus block and/or refuse their use. More information can be found at the following link < Cookies Policy>.

8. Security

We take appropriate and reasonable steps designed to help protect Your Personal Data from unauthorised access, use, disclosure, alteration, and destruction. We then ensure the security of Your Personal Data and implement the necessary technical and organisational measures, with regard to the nature, scope and context of the Personal Data that You communicate to us and the risks presented by their processing, to preserve the security of your Personal Data and, in particular, to prevent any accidental or unlawful destruction, loss, alteration, disclosure, intrusion or unauthorised access to this data.

If a password is used to protect your account and Personal Data, it is your responsibility to keep your password confidential.

9. Your rights

9.1 In this Section 9, we have listed the rights that you have under data protection law.

9.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your Personal Data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete / incomplete Personal Data;

(c) the right to erasure - you can ask us to erase your Personal Data;

(d) the right to restrict processing - you can ask us to restrict the processing of your Personal Data;

(e) the right to object to processing - you can object to the processing of your Personal Data;

(f) the right to data portability - you can ask that we transfer your Personal Data to another organization or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your Personal Data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your Personal Data is consent, you can withdraw that consent.

9.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

9.4 You may exercise any of your rights in relation to your Personal Data by written notice to us, using the contact details set out below.

10. Contact Information

If You have a privacy concern or if You want to exercise Your rights, You can contact our data protection officer at <laurent.rak@invyo.io> or send us a letter at the following address: < 58 Victoire street, 75009 PARIS>.

ou will receive a reply within a maximum period of one (1) month from the date of receipt of your request. If necessary, this period may be extended by two (2) months by INVYO, which will be notified to you, depending on the complexity and/or number of requests.

You may, at any time, make a claim to the competent supervisory authority (in France, the CNIL: www.cnil.fr).

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