This privacy policy (the “Privacy Policy”) applies to any person (hereinafter, the “User”) who browses www.qwertize.com (hereinafter, the “Website”) and/or interacts with QWERTIZE in connection with the use of the Website and/or any website publisher who subscribes to the services offered by QWERTIZE (hereinafter, the “Services”) through the acceptance of the Terms and Conditions on the Website. This Privacy Policy does not apply to the processing of personal data that could take place due to a contractual relationship between QWERTIZE and an advertiser.

QWERTIZE, as a controller, is committed to protecting the privacy of Users in accordance with legal requirements, including in particular Act No. 78-17 of 6 January 1978, as amended (known as the “Data Protection Act”) any supplementing or superseding law, order or directive, and European Regulation 2016/679 on the protection of personal data (“GDPR”). In particular, the purpose of the Privacy Policy is to provide Users with the best information on how QWERTIZE protects the personal data it collects in relation to the Website and more generally as a result of the performance of the Services.

By providing personal data in connection with the use of the Website, as well as during the performance of the Services, the User acknowledges having read the terms of this Privacy Policy.

1. Data collected by QWERTIZE

As part of the contact form, QWERTIZE may collect and process the following User data:

• Identity: full name; telephone number; email address;
• Any other information directly and voluntarily provided by the User, in particular the messages the User sends through the contact form (sent messages), through emails or that the User provides when it contacts customer service.

As part of the creation of the Client Account, QWERTIZE may collect and process the following User data:

• Identity and contact information: full name; address; telephone number; email address;
• Professional life: company name; SIRET; website URL;
• Technical data: the User’s username and password to log in to the Client Account.

As part of the performance of the Services related to the General Terms and Conditions, QWERTIZE may collect and process the following User data:

• Identity and contact information of the Client’s employees, managers, representatives in the context of the creation and management of the Client Account in QWERTIZE’s databases;
• Data relating to the Services performed, namely details of the Services performed, technical data related to the calculation of the Billable Earnings, financial data, banking data, billing and accounting data;
• Data relating to the monitoring of the contractual relationship;
• Data necessary for the realization of loyalty, prospecting, study, survey and promotion activities;

The mandatory nature of the information the User must provide on the Website is indicated at the time of data collection and on the corresponding forms with an asterisk. The failure to provide this information or a response that is deemed to be irregular by QWERTIZE is likely to lead QWERTIZE to refuse to take into account the User’s request.

QWERTIZE may use some of the User’s personal data for prospecting/marketing purposes (sending newsletters, invitations to events, etc.). The User may explicitly object to the collection and processing of its personal data for these purposes by ticking the relevant box.

2. Why QWERTIZW processes personal data

As a data controller, QWERTIZE collects the User’s personal data lawfully and fairly and in compliance with the User’s rights.

QWERTIZE collects information, including personal data, for the following purposes:

• To manage the creation of the Client Account;
• To manage the contractual relationship in the context of the performance of the Services;
• To send newsletters and other prospecting messages (with the User’s consent);
• To develop statistics and improve the Website and the Services provided;
• To communicate with Users and answer their questions;
• To comply with the applicable legislation and regulations.

3. The legal basis of the processing of personal data

When QWERTIZE processes Users’ data to provide them with the Services requested, i.e. to manage the Client Account and more generally the contractual relationship, the legal basis of this processing is the performance of the contract and for certain specific cases, compliance with legal obligations (e.g. for accounting treatments and the establishment and preservation of associated documents).

When QWERTIZE processes Users’ data to develop commercial statistics and to improve the Website, the legal basis of this processing is QWERTIZE’s legitimate interests, and more specifically, its economic interests in the ongoing improvement of its Website and Services and to understand Users’ needs and meet their expectations.

When QWERTIZE processes Users’ data to send them newsletters and other marketing messages, the legal basis of this processing is QWERTIZE’s legitimate interests, and more specifically, its economic interests. Notwithstanding the foregoing, no information concerning the activities of QWERTIZE will be sent to them for marketing purposes if they have expressed their objection to the use of their data for commercial prospecting purposes.

When QWERTIZE processes Users’ data to communicate with them and respond to their questions, the legal basis of this processing is, in certain cases, the performance of the contract (when the communication/question is linked to the Website and/or the Services) and, in other cases, QWERTIZE’s legitimate interests and more specifically, its economic interests in the ongoing improvement of its Website and its Services and to understand Users’ needs and meet their expectations.

When QWERTIZE processes Users’ data to comply with applicable laws and regulations, the legal basis of this processing is the compliance with the legal obligations to which QWERTIZE is subject.

4. Data collected through cookies

The Website may use cookies. Cookies are small text files that are stored on the User’s device when the User visits the Website. These files allow the exchange of status information between the Website and the User’s browser. This data may reveal the type of browser used, the date and time of the visit, the IP address and the activities carried out on the Website. Cookies act as a memory for a website, allowing that website to remember the User’s device on the User’s return visits and:

• to retain login information;
• to improve the security, quality of services and browsing of the Website;
• to allow the User to interact with QWERTIZE using social networks;
• for performance/analytics purposes.

Cookies used by QWERTIZE:

• Strictly necessary cookies:
  These cookies are essential in order to allow the User to browse the Website and use its features. Without these cookies, the services that the User has requested, such as the storage of login data and access to the Client Account, cannot be provided. These cookies also remember the User’s preferences, such as the country from which the User visits the Website. These cookies can therefore be used to offer the User a more tailored experience and improve the user experience. These cookies do not gather information about the User that could be used for commercial prospecting or targeted advertising.
  
  These include session cookies and persistent cookies.
  
  Session cookies exist until the User closes the browser. Persistent cookies are stored on the User’s device until deleted or until a specified period of time is reached.



• Social network cookies
  The Website uses various social plug-ins provided by major social networks (e.g. Facebook, LinkedIn and Twitter).
  
  When browsing the Website, browsing data may be transferred directly to the social networks concerned, even without the User’s direct interaction. These cookies are not controlled by QWERTIZE. The User must visit the relevant third-party website for information on how these cookies work.



• Performance/Analytics cookies
  Google Analytics :
  
  The Website uses Google Analytics cookies to improve the Website’s performance and to optimize the User’s online experience. These cookies collect information about how visitors use the website, for instance which pages visitors go to most often, the pages visited and other websites visited before visiting the Website. The information obtained through Google Analytics is used for the sole purpose of improving the Website. If the User does not want Google Analytics to monitor the User’s activities on other websites, the User can visit: http://tools.google.com/dlpage/gaoptout

The User’s prior consent is required before reading or placing cookies that are not strictly necessary for the operation of the Website and/or the provision of the Services.

The User’s consent is collected by means of a banner that appears on the User’s initial visit to the Website, in accordance with the CNIL Recommendation on the matter.
Cookies that are not necessary for the operation of the Website and/or the Services are placed for a maximum period of 13 months. Beyond this period, the User is required to consent anew before any new cookies can be placed on the User’s device.

The User can change the web browser’s settings to refuse cookies. However, the refusal to accept cookies may limit or even prevent the use of certain Website features.

Here are some examples on how to delete and/or manage browser cookies:

Microsoft Internet Explorer version 11 :

• Tools
• Options
• History
• Select
• Select block cookies

Chrome :

• Tools
• Advanced
• Privacy
• Cookies
• Select block cookies

Firefox :

• Tools
• Options
• Privacy
• Select block cookies

Safari :

• Preferences
• Privacy
• Select block cookies

Opera :

• Preferences
• Advanced
• Cookies
• Select block cookies

Note that this paragraph is only intended to inform the User about cookies placed on the User’s device when browsing the Website. The issue of cookies placed as part of the advertising network Services governed by the Terms and Conditions and the Client’s and QWERTIZE’s respective obligations in this respect is clearly and exclusively defined in the General Terms and Conditions.

5. How long data is kept

QWERTIZE keeps personal data collected through the Website and as part of the performance of the Services governed by the Terms and Conditions as follows:

• Data collected using the Website contact form:
  Data is kept for a period of three years from the date of their collection by QWERTIZE or for three years following the User’s last connection. This retention period only applies to data concerning Users who do not subsequently become QWERTIZE Clients. Where Users do become QWERTIZE Clients, the applicable retention period is that given below.



• The creation of the Client Account and generally the management of the contractual relationship with the User who is also a QWERTIZE Client:
  Data are kept for the duration of the contractual relationship and are retained at the end of this contractual relationship for the duration of the applicable limitation period.

6. The rights of Users regarding their personal data

Pursuant to applicable regulations, the User has the following rights:

RIGHTS	DESCRIPTION
The right to be informed	The User has the right to be informed in a concise, transparent, comprehensible and easily accessible manner as to how the User’s personal data is processed.
The right of access	The User has the right to obtain (i) confirmation that its personal data are or are not being processed and (ii) access to said personal data and a copy of same.
The right of erasure	In some cases, the User has the right to erase its personal data. This right is not absolute and QWERTIZE may have legal or legitimate reasons for retaining such data.
The right of erasure	In some cases, the User has the right to erase its personal data. This right is not absolute and QWERTIZE may have legal or legitimate reasons for retaining such data.
The right to limit the processing of personal data	In some cases, the User has the right to limit the processing of its personal data.
The right to portability	The User has the right to receive its personal data provided to QWERTIZE in a structured, commonly used and machine-readable format, and has the right to transmit this data to another controller without QWERTIZE obstructing this transmission. This right applies only when the processing of the User’s personal data is based on the User’s consent or the performance of a contract and said processing is carried out using automated processes.
The right to object	The User has the right to object, at any time and for reasons related to its particular situation, to the processing of its personal data if said processing is based on QWERTIZE’s legitimate interests. QWERTIZE may, however, cite legitimate and compelling reasons to continue the processing. When the User’s personal data are processed for prospecting purposes, the User has the right to object at any time to the processing of its personal data for these prospecting purposes. The User can exercise this right by clicking on the “unsubscribe” link available at the bottom of the messages sent by QWERTIZE or by changing the settings of its Client Account on the Website.
The right to withdraw consent at any time for consent-based processing	The User may withdraw its consent to the processing of personal data when this processing is based on the User’s consent. The withdrawal of consent does not compromise the lawfulness of consent-based processing that occurred prior to the withdrawal.
The right to lodge a complaint with a supervisory authority	The User has the right to contact the CNIL to file a complaint concerning the practices relating to the protection of its personal data by QWERTIZE. QWERTIZE nevertheless invites the User to inform them in advance of any question or complaint the User may have concerning the protection of personal data.
The right to give instructions regarding the use of data after death	The User has the right to give QWERTIZE instructions concerning the use of its personal data after the User’s death.

To exercise these rights, the User may send a request to the following address: dpo-en @ qwertize.com

QWERTIZE may ask the User to provide proof of identity before responding to its request.

7. Accuracy of personal data

The User must ensure that personal data provided through the Website and during the performance of the Services is up-to-date, accurate, complete and unambiguous.

8. Provision of Users’ personal data

QWERTIZE will keep the personal data collected though the Website and will only share this data under certain circumstances and in accordance with the provisions of the applicable regulations.

QWERTIZE may share Users’ personal data with companies in its group to perform the Services that are governed by the Terms and Conditions.

QWERTIZE may in particular allow third-party service providers, in their capacity as subcontractors, to access Users’ personal data to perform services relating to the Website, including in particular hosting, storage and analysis services, data processing, database management or computer maintenance services. These service providers will only act on the instructions of QWERTIZE and will have access to Users’ personal data solely to perform these services and will be held to the same security and confidentiality obligations as QWERTIZE.

In addition, Users’ personal data may be shared with third parties for the following reasons:

• As part of a merger or acquisition by a third party of QWERTIZE, in whole or in part, which the User accepts;
• In response to judicial or administrative proceedings of any kind or to enforcement actions requested by the competent authorities;

To comply with legal obligations, to protect the rights and/or security of an individual, to protect the rights and property of QWERTIZE, including the need to comply with this Privacy Policy, and to prevent fraud, security or technical issues.

9. Transfer of Users’ personal data

Personal data collected by QWERTIZE is either stored on QWERTIZE servers or on the servers of a service provider located in the European Economic Area.

In addition, the service providers or other third parties listed above with which QWERTIZE may share Users’ personal data may be domiciled abroad, including outside the European Economic Area. QWERTIZE will then require that they take, in accordance with the regulations in force, all organizational and technical measures to ensure an adequate level of protection of Users’ personal data (in particular by signing Standard Contractual Clauses approved by the European Commission).

10. Security and protection of Users’ personal data

QWERTIZE prioritizes the security of personal data. QWERTIZE undertakes to take all administratively and technically reasonable measures to prevent any disclosure, use, alteration or destruction of personal data provided by a User (access control, password security, access according to specific authorizations, etc.).

11. Amendment of Privacy Policy

The Privacy Policy is available for consultation on the Website. QWERTIZE reserves the right to amend the Privacy Policy at any time. The amended Privacy Policy will take effect on the date it is published on the Website.

12. Contacting QWERTIZE

For any questions or comments concerning this Privacy Policy, the User may contact QWERTIZE at the following email address dpo-en @ qwertize.com.

QWERTIZE Data Protection Officer's Contacts: Hutin Geoffroy