Introduction
Welcome to ACTIYON's privacy policy, as established in compliance with Law n°78-17 date January 6th, 1978 and the General Data Protection Regulation (« GDPR ») n°2016/679.
ACTIYON respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please use the Glossary hereunder to understand the meaning of some of the terms used in this privacy policy.
Purpose of this privacy policy
This privacy policy aims to give you information on how ACTIYON collects and processes your personal data through your use of this website, including, as a tester, or when you purchase our services, including any data you may provide through this website when you sign up to our newsletter or purchase a product or service or take part in a competition or send us an email through the website or create an account or subscribe to one of our training session, conference, webinar or meeting.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
ACTIYON is the controller of, and responsible for your personal data (collectively referred to as "ACTIYON", "we", "us" or "our" in this privacy policy).
LEE Sangmin is responsible for overseeing questions in relation to this privacy policy]. If you have any questions about this privacy policy, including any requests to exercise your legal right, please contact LEE Sangmin, President, using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact LEE Sangmin, President, 16 Boulevard Maréchal Lyautey 38000 Grenoble, admin@actiyon.com.
ACTIYON is a French “Société par Actions Simplifiée”, with a share capital of 54 000,00 Euros, whose head office is located at French Tech in the Alps, 16 Boulevard Maréchal Lyautey 38000 Grenoble, and registered in France, at Grenoble’s Trade Registry with number : 811 691 179.
You have the right to make a complaint at any time to the Commission Nationale Informatique et Libertés (CNIL), the French regulator for data protection issues (www.cnil.fr). We would, however, appreciate the chance to deal with your concerns before you approach the CNIL so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on February 20th 2022.
Future historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Taking into account the wide range of services we can provide and the different uses of the website you can make, we may have to collect, use, store and transfer different kinds of personal data about you, whether confidential or sensitive, or not, which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services) nor use this website. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We may also receive Technical Data about you if you visit other websites employing our cookies.
Please see our cookie policy hereunder in 10, for further details.
Technical Data from the following parties:
analytics providers such as Google ;
advertising networks and
search information providers.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly available sources [such as Companies Register based in France or similar entities in Europe].
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Please refer to Glossary, lawful basis, to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing and communications to you via email or text message. You have the right to withdraw consent to marketing and communication at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new client
(a) Identity
(b) Contact
Performance of a services contract with you
To process and deliver your services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Communication
(a) Performance of a services contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which may include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing & Communication
(a) Performance of a services contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how clients use our services
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing & Communication
(a) Performance of a services contract with you
(b) Necessary for our legitimate interests (to study how clients use our services, to adapt and develop them and grow our business)
To administer and protect our activity and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, offer, marketing, client relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to improve our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, product/service experience or other transactions or previous services.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy in 10 hereunder.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We do not transfer your personal data outside European Union.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for ten years after they cease being clients, especially for tax purposes.
In some circumstances you can ask us to delete your data: see “your legal rights” below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please refer to the Glossary hereunder to find out more about these rights.
If you wish to exercise any of the rights set out above, please contact LEE Sangmin.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
What are cookies?
The ACTIYON website uses cookies.
A cookie is a small text file which is stored on your computer, tablet or phone when you visit a website. These cookies allow us to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.
There are two main types of cookies:
Cookies can be set by the website you have browsed, i.e. the website displayed in the uniform resource locator (URL) window. These are called first party cookies. Third party cookies are set by a website other than the one you are browsing.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit https://www.allaboutcookies.org.
Consent : On your first visit to the ACTIYON website, you will be asked if you consent to or refuse the installation of all non-essential cookies. Your choice will be recorded and applied on your successive visits to our site.
Queries
If you have any questions or comments regarding this Cookies policy, please email : admin@actiyon.com.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES : by ordering our services or entering into our website, you expressly agree and give your consent to the possible transfer of your data to the following third parties, especially our IT sub-contractors, to which your data may be transferred in compliance with GDPR Article 46.
Other companies in the ACTIYON Group acting as joint controllers or processors and who are based in the EU and provide IT and system administration services and undertake reporting.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. This also enables you to issue instructions in advance relating to your personal date in case of death. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
