Confidentiality policy

SUMMARY OF KEY POINTS

This summary provides the key points of our privacy notice, but you can find more details on any of these topics by clicking on the link that follows each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our services, we may process personal information based on how you interact with 'octopize.io' and the services, the choices you make, and the products and features you use.

Do we process sensitive personal information? We do not process sensitive personal information.

Do we receive information from third parties? We do not receive information from third parties.

How do we handle your information? We process your information to provide, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We only process your information when we have a valid legal reason for doing so: in the case of subscribing to the newsletter only.

In what situations and with what parties do we share personal information? We do not share information in specific situations and with specific third parties.

‍How do we keep your information secure? We have implemented organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to outsmart our security and collect, access, steal, or modify your information in an inappropriate manner.

‍What are your rights? Depending on where you are located geographically, applicable privacy law may mean that you have certain rights with respect to your personal information. See below for more.

‍How can you exercise your rights? The easiest way to exercise your rights is to contact us here: contact@octopize.io. We will review and respond to any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?‍
‍Personal information provided by you.
‍The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following: - email addresses - names

‍Sensitive information.
‍We do not process sensitive information. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to that personal information.

Hubspot.
We also collect information through cookies and similar tracking technologies, including, but not limited to, information about user interactions with our website, such as pages visited, length of visit, and form information submitted by users. This data may be collected using third party tools such as HubSpot.

‍2. HOW DO WE HANDLE YOUR INFORMATION?‍
‍In short: We process your information to provide, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.‍

‍We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

‍- To send you marketing and promotional communications. We may process personal information that you send to us for marketing purposes, if this is in accordance with your marketing preferences. You can choose not to receive our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?”
- To safeguard or protect the vital interests of a person. We may process your information when it is necessary to safeguard or protect an individual's vital interests, for example to prevent harm.

Hubspot.
The information collected by HubSpot is used to analyze user behavior on our website, improve the user experience, and optimize our services and content.

‍3. WHAT LEGAL BASES DO WE USE TO PROCESS YOUR INFORMATION?‍
‍In short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide services to you in order to enter into or fulfill our contractual obligations, to protect your rights, or to satisfy our legitimate business interests.

Hubspot.
For data collected by analytics cookies like HubSpot, we rely on user consent, which is obtained when you visit our site and accept our cookie banner.

If you are located in the EU or the UK, this section applies to you.
‍The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click hither to find out more.
- Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not override your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to: - Send users information about special offers and discounts on our products and services.
- Legal obligations. We may process your information when we believe it is necessary to comply with our legal obligations, for example to cooperate with a law enforcement agency or regulatory body, to exercise or defend our legal rights, or to disclose your information as evidence in a dispute in which we are involved.
- Vital interests. We may process your information when we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
‍We may process your information if you have given us specific permission (i.e. explicit consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally authorized by applicable law to process your information without your consent, including, for example:
- If the collection is clearly in the interests of an individual and consent cannot be obtained in a timely manner.
- For investigations and the detection and prevention of fraud
- For commercial transactions if certain conditions are met
- If the information is contained in a witness statement and the collection is necessary to assess, process, or settle a claim for compensation.
- For the identification of injured, sick or dead people and the communication with their loved ones.
- if we have reasonable grounds to believe that a person has been, is, or could be a victim of financial abuse
- Whether it is reasonable to expect that the collection and use with consent will compromise the availability or accuracy of the information and that the collection is reasonable for purposes related to an investigation into a violation of an agreement or the violation of the laws of Canada or a province.
- if disclosure is necessary to comply with a subpoena, warrant, court order, or court rules concerning the production of documents
- if the information was produced by an individual in the course of employment, business or profession and the collection is consistent with the purposes for which the information was produced
- if the collection is carried out solely for journalistic, artistic or literary purposes
- If the information is available to the public and is specified by the regulations.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?‍

‍In short: We may share information in specific situations described in this section and/or with the following third parties. We may need to share your personal information in the following situations:
- Business transfers. We may share or transfer your information as part of or during negotiations for a merger, sale of company assets, financing, or the acquisition of all or a portion of our business by another company.
- Hubspot. We share some information with third party partners like HubSpot, who process it on our behalf to provide analytics and marketing services. HubSpot may also share this information with other third parties when required by law or as part of subcontracting with our service providers.

- Focus on the cookie policy
Our website uses cookies to improve your user experience and for analytics, marketing and performance purposes. This includes third party cookies such as those used by HubSpot. You can manage your cookie preferences at any time by using our cookie management center or by following the cookie deactivation instructions available in your browser.

‍5. HOW LONG DO WE KEEP YOUR INFORMATION FOR?‍
‍In short : We keep your information for as long as necessary to fulfill the purposes described in this privacy notice, unless otherwise required by law.

We will only keep your personal information for as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). None of the purposes of this notice will require us to keep your personal information for more than 3 years.

When we no longer have a legitimate business need to process your personal information, we delete or anonymize that information, or, if this is not possible (for example, because your personal information has been stored in backup archives), we store your personal information securely and isolate it from further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SECURE?
In short: we aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of all personal information that we process. However, despite our protective measures and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be 100% guaranteed, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to outsmart our security and collect, access, steal, or otherwise modify your information in an inappropriate manner. While we do our best to protect your personal information, the transmission of personal information to and from our services is at your own risk. You should only access the services in a secure environment.

7. DO WE COLLECT INFORMATION ABOUT MINORS?‍
‍In short : We do not knowingly collect or market data from children under the age of 18.

We do not knowingly solicit or market data from children under the age of 18. By using the Services, you represent that you are at least 18 years of age or that you are the parent or guardian of such a minor and that you consent to the use of the Services by such dependent minor. If we learn that personal information from users under the age of 18 has been collected, we will deactivate the account and take reasonable steps to promptly remove that data from our records. If you are aware of any data we may have collected from children under the age of 18, please contact us at contact@octopize.io.

8. WHAT ARE YOUR PRIVACY RIGHTS?‍
‍In short: In some regions, such as the European Economic Area (EEA), the United Kingdom (UK), and Canada, you have rights that make it easier for you to access and control your personal information. You can review, change, or delete your information at any time.

In some regions (such as the EEA, United Kingdom, and Canada), you have certain rights under applicable data protection laws. This may include the right (i) to request access and to obtain a copy of your personal information, (ii) to request correction or deletion, (iii) to restrict the processing of your personal information and (iv) where appropriate, data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You may make such a request by contacting us using the contact information provided in the section “HOW TO CONTACT US ABOUT THIS NOTICE?” “below.

We will review and respond to any request in accordance with applicable data protection laws.

If you are located in the EEA or the United Kingdom and you believe that we are unlawfully processing your personal information, you also have the right to complain to the data protection supervisory authority in your country. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details of the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we rely on your consent to process your personal information, which may be express and/or implied consent under applicable law, you have the right to withdraw your consent at any time. You may withdraw your consent at any time by contacting us using the contact details provided in the “HOW TO CONTACT US ABOUT THIS NOTICE” section below. However, please note that this will not affect the lawfulness of the processing prior to its withdrawal or, where permitted by applicable law, the processing of your personal information carried out based on legal processing grounds other than consent.

‍Unsubscribe from marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in emails we send, or by contacting us using the contact details provided in the section “HOW TO CONTACT US ABOUT THIS NOTICE?” “below. You will then be removed from the marketing lists. However, we may still communicate with you, for example, to send you messages relating to services required to administer and use your account, to respond to service requests, or for other non-commercial purposes.

If you have questions or comments about your privacy rights, you can email us at contact@octopize.io or dpo@octopize.io.

9. DO-NOT-TRACK FUNCTION CONTROLS
‍Most web browsers and some operating systems and mobile applications have a “Do-Not-Track” (“DNT”) function or setting that you can enable to indicate your privacy preference so that data about your online browsing activities is not monitored and collected. At this stage, a uniform technological standard for recognizing and implementing DNT signals has not been finalized. As a result, we do not currently respond to browser DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If an online tracking standard is adopted and we need to meet it in the future, we will inform you of this practice in a revised version of this Privacy Notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?‍
‍In short : Yes, if you are a California resident, you have specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, allows our users who are California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) that we have disclosed to third parties for direct marketing purposes, as well as the names and addresses of any third parties with whom we have shared personal information during the previous calendar year. If you are a California resident and would like to make such a request, please submit it to us in writing using the contact information provided below.

If you are under the age of 18, a California resident, and have a registered account with the Services, you have the right to request the removal of unwanted data that you post on the Services. To request removal of this data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you are a California resident. We will ensure that data is not displayed publicly on the Services, but please be aware that data may not be completely or completely removed from all of our systems (for example, backups, etc.).

ACCP Privacy Notice
‍The California regulatory code defines a “resident” as follows:
(1) any person who is in the State of California for purposes other than temporary or transitory purposes and
(2) any person who is a resident of the State of California who is outside of the State of California for temporary or transitional purposes.

All other persons are defined as “non-residents.”

If this definition of “resident” applies to you, we must respect certain rights and obligations regarding your personal information.

What categories of personal information do we collect?
‍We collected the following categories of personal information over the past twelve (12) months:
‍

We may also collect other personal information outside of these categories in cases where you interact with us in person, online, by telephone, or by mail in connection with:
- Receive support through our customer support channels;
- participation in surveys or competitions intended for customers; and
- to facilitate the provision of our services and the response to your requests for information.

How do we use and share your personal information?

You can find more information about our data collection and sharing practices in this privacy notice. You can contact us by email at contact@octopize.io, or by referring to the contact information at the bottom of this document.If you use an authorized agent to exercise your right to opt out, we may refuse a request if the authorized agent does not provide evidence that they have been validly authorized to act on your behalf.

Will your information be shared with others?

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes information on our behalf.

We may use your personal information for our own business purposes, for example to undertake internal research to develop and demonstrate technologies. This is not considered to be a “sale” of your personal information.

Octopize has not disclosed or sold personal information to third parties for business or commercial purposes in the last twelve (12) months. Octopize will not sell personal information belonging to website visitors, users, and other consumers in the future.

Your rights with respect to your personal data:

Right to request the deletion of data - Request for deletion

You can request that your personal information be deleted. If you ask us to delete your personal information, we will comply with your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of their right to freedom of expression, our compliance requirements resulting from a legal obligation, or any processing that may be necessary to protect against illegal activities.

Right to be informed - Information request

Depending on the circumstances, you have the right to know
- if we collect and use your personal information;
- the categories of personal information we collect
- the purposes for which the personal information collected is used;
- if we sell your personal information to third parties;
- the categories of personal information that we sold or disclosed for a business purpose;
- the categories of third parties to whom the personal information was sold or disclosed for commercial purposes; and
- In accordance with applicable law, we are not required to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to non-discrimination for the exercise of a consumer's privacy rights

We will not discriminate against you if you exercise your privacy rights.

Verification process
‍
Upon receiving your request, we will need to verify your identity to determine if you are the same person we have information about in our system. These verification efforts require us to ask you to provide information so that we can compare it to the information you have previously provided to us. For example, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with information we already have on file, or we may contact you through a communication method (for example, telephone or email) that you previously provided to us. We may also use other verification methods if circumstances require it.

We will only use the personal information provided in your request to verify your identity or authority to make the request. Wherever possible, we will avoid asking you for additional information for verification purposes. However, if we cannot verify your identity based on information that we already have, we may ask you to provide additional information in order to verify your identity and for security or fraud prevention purposes. We will remove this additional information as soon as we have finished verifying your identity.

Other privacy rights
‍
- You can object to the processing of your personal information.
- You can request the correction of your personal data if it is incorrect or no longer relevant, or request to restrict the processing of the information.
- You can designate an authorized agent to make a request under the CCPA on your behalf. We may refuse a request from an authorized agent who does not provide evidence that they have been validly authorized to act on your behalf in accordance with the CCPA.
- You can ask to be excluded from the future sale of your personal information to third parties. Upon receipt of a withdrawal request, we will respond to it as soon as possible, but no later than fifteen (15) days following the date the request was submitted.

To exercise these rights, you can contact us by email at contact@octopize.io, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

11. ARE WE UPDATING THIS NOTICE?‍
‍In short: Yes, we will update this notice as required to remain in compliance with applicable laws.

‍We may update this privacy notice from time to time. The updated version will be indicated by a “Revised” update date and the updated version will be effective as soon as it is available. If we make material changes to this privacy notice, we may notify you by either prominently posting a notice of the changes or by sending you a notification directly. We encourage you to review this privacy notice frequently to be informed about how we are protecting your information.

Hubspot. We will update this privacy policy if we change our use of third party services like HubSpot or if new cookie regulations come into effect.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
‍If you have any questions or comments about this notice, you may contact our Data Protection Officer (DPO), Morgan Guillaudeux, by email at dpo@octopize.io, contact@octopize.io, or by post to the following address: 103 Route de Vannes,44800, Saint-Herblain, France

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
‍Depending on the laws applicable in your country, you may have the right to request access to, change, or delete the personal information we collect about you. To request that your personal information be reviewed, updated, or deleted, please contact: Morgan Guillaudeux at contact@octopize.io .