Holaspirit (the “Platform”), is a web platform that is accessible at www.holaspirit.com, and is operated by Holaspirit, a French Joint Stock Company; share capital: 40,000 euros; registered address: 72, rue du Faubourg Saint-Honoré 75008 Paris, France; registered in Paris, France under number 818 592 511 (the “Company”).
The users of the Platform (the “ User(s) ”) can access a number of functionalities to manage governance issues and other related services (the “Service(s) »). Cet accès leur est ouvert sous la responsabilité d’un client de la Société ayant conclu un contrat de service spécifique avec cette dernière (l’« Organisation ”). They are given access to the Platform by a client of the Company that has signed a specific contract for services with the latter (the “Organisation”), for the entire duration of this contract, save in case of restrictions imposed by the Organisation itself.
1. The collected data
This data is gathered at various points in time using various methods :
- The collected data
- In order to become a User, you must provide some personal data, such as your first name, family name, e-mail address, password. Without this minimum of information, it is not possible to create an account. Unless you decide to share your governance in public and except the email and password, this data is only accessible to the other Users who are registered with the Platform of the Organisation using their personal email and password.
- Using the Platform
- When you use the Platform, the Company’s servers automatically record the information that is created and exchanged while using our Services. For instance, the Company is aware of all of your session data.
- Log files, Internet Protocol (IP) address and information concerning your computer
- When you connect to the Platform, the Company receives the link of the web site from which you reached the Platform, and it also receives the link that you follow upon leaving the Platform.
The Company also receives your IP address and information concerning the operating system of your computer and its web browser.
- Internet tags
- We may occasionally use Internet tags (also known as "tags", or action tags, one-pixel GIFs) and deploy them through a specialized partner. These tags are placed both in online advertisements allowing you to access the website. This helps to evaluate the visitors' responses to the site and the effectiveness of its actions (for example, the number of times a page is opened and the information accessed). The external service provider may collect information about visitors to the site, compile reports on the site's activity.
2. Retention of the collected data
Once collected, data are stored on the servers of the Company or of a subcontractor of the Company with a view to processing it in connection with the use of the Services. It is kept for as long as necessary for the provision of the Services and functions offered by the Platform to the Organisation and for a period of seven (7) days following the termination of the contract between the Company and the Organisation, whatever the reason for this.
You shall at all times retain ownership over all personal data concerning you that you transmit over the Platform. In accordance with France’s data protection law no. 78-17 of 6 January 1978, as subsequently modified by law no. 2004-801 of 6 August 2004 , Regulation EU 2016/679 of 27 April 2016 and GDPR (General Data Protection Regulation), you shall therefore have a right to access, rectify, limit the processing and/or request the erasure of your personal data, as well as the right to oppose said processing and a right to request the portability of your personal data. To exercise your rights, please write to the Organisation at its address, which is shown in the page entitled “about” of the Platform, once connected using your personal access identifiers.
The processing of your personal data by computer has been declared to France’s CNIL under no. 1909920. You have the right to file a complaint for violation of your data protection rights with this regulating body.
3. Use of the collected data
- with your express or implied consent;
- afin de se conformer à la loi, la règlementation en vigueur, à toute procédure judiciaire, aux décisions de justice ou à tout autre cas de divulgation obligatoire ;
- in order to comply with the law, the prevailing rules and regulations, any legal proceedings, court rulings, or in any other case where disclosure is mandatory;
- in order to protect the rights, the property or the security of the Platform, of its members or of the public;
- as part of the provision of the various Services and functionalities proposed on the Platform, but only when this is necessary for the performance of its operations and the provision of these Services and functionalities.
4. The role played by the Company
When it comes to the processing of personal data, the Company shall merely act as a data processor of the Organisation, as per the definition of this term in Regulation EU 2016/679 of 27 April 2016.
Therefore, the Organisation alone shall determine the purposes and the means of the processing the Users’ personal data. The personal data shall only be processed by the Service Provider based on the written instructions of the Organisation, including with regards to any transfers of personal data to a third country or to an international organisation, unless the Service Provider has an obligation to process the data under EU law or the applicable national law; in that case, the Service Provider shall inform the Organisation about this legal obligation before starting the processing, unless the obligation involved prohibits any disclosure for important public interest reasons.
5. Your obligations
The Company moreover calls upon you to act responsibly, bearing in mind that the Users are alone responsible for the information and content that they disclose, including information concerning racial origins, ethnic background, sexual orientation, political opinions, religious or philosophical beliefs, affiliation to a trade union or any health-related information.
6. Protection of minors
In order to protect minors, the User must be aged 18 or over and must have full legal capacity.
In order to protect your personal data, the access to your account is protected by a password that you must keep confidential. You should immediately inform the Company in case of unauthorised use of your account or any breach of the confidentiality and security of your identifiers.
The Company shall take all reasonable measures to protect your data against any loss or misuse, and unauthorised access, disclosure, modification and destruction. Various hardware and software processes have been implemented in order to ensure the protection of your personal data.
9. Contact details
Should you have any questions, comments, suggestions or complaints, please contact holaspirit SAS.