RGPD AND PRIVACY NOTICE WIIN
At WIIN, protecting and respecting your privacy is a primary concern. The purpose of this document is to inform you about our practices regarding the treatment of information that you may provide to us when using our services, visiting our website
www.wiin.io or when using our software (hereinafter the "Platform(s)").
This document, presents the way we treat the personal data we collect and that you provide to us.
("WIIN") represents the company DAVESE SAS, a simplified joint stock company with a share capital of €18,000, registered in the Paris Register of Companies under number 825 055 528.
The ("Customer(s)") represents all persons who use WIIN services after having subscribed to a paid or free offer giving access to the administrator interface of WIIN Platforms.
The ("User(s)") represents all the candidates, respondents, participants who answer online forms made by a Customer in order to collect and process information.
WIIN will never collect or process personal data concerning, directly or indirectly, racial or ethnic origin, health, sexual orientation, political, philosophical and religious views. Customers shall not request such information from their Users and store such personal data on our Platforms. WIIN will not be liable if a Customer chooses to collect information that does not comply with WIIN's privacy policy. Only the Customer may be held responsible for such collection and no User may make any claim against WIIN. In other words, it is the Customer's responsibility to define what information it collects from Users via WIIN's Platforms and the User's responsibility to agree or not to provide the information requested by the Customer.
1. Ethics, transparency and use of data collected by WIINAt WIIN, transparency in data collection and use is a top priority. We are committed to providing you with the best possible service in this area, and to always answering your questions clearly and in a timely manner.
- WIIN undertakes never to pass on, sell, give away or exchange your data.
- WIIN is committed to comply, regardless of the circumstances, with the General Data Protection Regulation (GDPR) in accordance with the European regulations on data processing and use. Specifically to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)."
- WIIN will never store your data outside the European Union. The data is usually stored in France.
- WIIN is committed to transparency and respect.
- WIIN is committed to ensuring that all data collected by customers is their sole and exclusive property. WIIN has no right to use or claim the data. The customer is the owner and responsible for the user and his data.
The data collected is used solely and exclusively for the purpose of improving the user experience on the Platforms and to enable optimal access to the various services offered.
We would like to point out to the customers and users of the WIIN platforms that WIIN is the only company that collects and analyzes data via online forms and that offers full transparency and a strong ethic of data protection.
2. The information collected by WIIN
WIIN may collect and process the following data:
2.1. The information that Customers or Users transmit directly to WIIN
When using the WIIN Platforms, the Customer and the User may be required to transmit information, some of which may identify them ("Personal Data").
This information includes in particular the following data:
- The data required to register for the services provided by WIIN on its Platforms or to access any other service provided by WIIN. This data includes the first and last name, e-mail address and password of the Customer and/or User. This information is mandatory. Otherwise, WIIN will not be able to provide its services and the Customer and/or User will not be allowed to create an account on our Platforms;
- A photograph or avatar if the Customer and/or User registers via social networks;
- A copy of all exchanges between the Customer, the User and WIIN;
- The storage of responses collected by the Customer, for which the Customer is the sole owner and responsible.
- Details of financial or accounting operations carried out on WIIN's Platforms or by any other means, including information relating to payment cards and secure bank details
- Details of visits to WIIN Platforms and content accessed by the Customer and/or User; - responses to WIIN surveys and questionnaires and opinions left to evaluate WIIN Platforms, which may be used for research and behavioral analysis;
- Data that WIIN may request to provide when the Customer and/or User reports a problem with its Platforms or services, such as the subject of a support request;
- Location-related data where the Customer and/or User has agreed that WIIN may collect and process such data
process such data;
2.2. The data that WIIN collects automatically
In the event that the Customer and/or User connects to the Platforms using the social network features provided, WIIN will have access to some of the data (in particular, an identifier generated for the occasion, your first name, last name, photograph, e-mail address) of the account on the said social network in accordance with the general terms of use of the social network concerned.
During each of your visits, WIIN is likely to collect, in accordance with the applicable legislation and with your consent, where appropriate, information relating to :
- The devices on which you use our services ;
- Or the networks from which you access the Platforms, such as your IP addresses, connection data, types and versions of Internet browsers used, types and versions of plugins in your browser, operating systems and platforms, data concerning your browsing on the Platforms, including your browsing on the various URL pages of the Platforms, the content you access or consult, etc.
Among the technologies used to collect this information, WIIN uses cookies (for more information on this subject, please refer to Article 8 of this Document).
2.3. How long we keep your dataWIIn retains Customer and/or User information for a reasonable period of time after account closure, or as required by law (e.g., financial data is retained for as long as required by applicable tax and accounting laws).
If your account has been suspended or blocked, WIIN will retain your data for a period of between 2 and 10 years after the account has been suspended in order to prevent you from circumventing the rules in force on our Platforms.
You can contact WIIN at the address described in the article "Contact" for any request for early deletion of your information. Your retained data is stored in a secure environment and is not exchanged, resold or used in any form whatsoever.
2.4. Legal basis of the processingIn accordance with European regulations, WIIN must have a legal basis for processing the personal data of its Customers and/or Users.
You have particular rights depending on the legal basis that WIIN uses. These rights are explained later in this Policy.
Regardless of the legal basis used, you always have the right to request :
- Access to your data,
- Their rectification,
- And their removal.
To exercise your rights, contact WIIN as described in the "Contact" section.
For all persons legally entitled to enter into a contract, WIIN will process the data in the manner necessary for the performance of the contracts between WIIN and its Customers. In cases where the data collected is not strictly necessary for the performance of a contract between the Customer and WIIN, WIIN processes the data on the basis of your consent (e.g., we rely on your consent to contact you by e-mail in order to provide you with offers that may be of interest to you, which you can withdraw at any time, e.g., by clicking on the link at the bottom of the e-mail).
This also applies to responses to customer questionnaires that Users may be asked to complete. Users are completely free not to respond to this. However, WIIN only acts as a subcontractor of the customer in the sense of the applicable legislation, the customer being the data controller. The collection of this data is therefore subject to the User's consent, which is based on the User's affirmative action and thus on the User's express willingness to answer the Customer's questions.
3. How does WIIN use the data collected?
WIIN uses the collected data in order to :
- Execute contracts between the Customer and WIIN or between the Customer and a User and provide the requested information and services;
- Send information about WIIN services (e.g. new features of the Platforms) by e-mail or any other means of communication
- Collect payments from Customers or transmit money collected from a User on behalf of a Customer;
- To enable the Customer and/or User profile on the Platforms to be personalised;
- To allow the Customer to communicate and exchange with the Users of its Platform, by means of mailing list and e-mail;
- Ensure compliance with applicable law, WIIN's general terms and conditions, WIIN's privacy policy. In the event of non-compliance by the Customer and/or the User, WIIN may suspend the account of the Customer and/or the User in question on the Platforms;
- To send, in accordance with the applicable legal provisions and with the consent of the Customer and/or User, where required by law, marketing, advertising and promotional messages and information relating to the use of the services and the various ways of using the Platforms
- To inform about changes to the Platforms;
- To manage the Platforms and to carry out internal technical operations in the context of problem solving, data analysis, testing, research, analysis, studies and surveys;
- To improve and optimize the Platforms, in particular to ensure that the display of the contents is adapted to the device of the Customers and/or Users;
- To enable Customers and Users to use the interactive features of the Platforms;
- Assist WIIN in maintaining a safe and secure environment on the Platforms;
4. Who are the recipients of the information collected by WIIN and why do we give them this information?
When using the Platforms, the information transmitted by the Users to the Customers in response to the forms generated by the Customer is automatically communicated to the Customer. WIIN has no rights to this data and only the Customer has the rights to use and exploit it in accordance with the rules it establishes with the User.
WIIN also works with third party companies that may have access to the Personal Data of Customers and Users, and in particular with:
- Subcontractors used by WIIN for technical services, payment services (Stripe and Paypal), email management (Mailjet, Mailchimp), CRM (Zoho, Hubspot) or providers of analytical solutions, such as Google Analytics.
As such, if a Customer or User does not want Google Analytics to be able to analyze his or her activity on the Platforms he or she visits, a Google Analytics disabling browser add-on can be installed. This prevents the Google Analytics JavaScript code (ga.js, analytics.js and dc.js) inserted on websites from sharing information about a person's visit with Google Analytics.
It is also possible, by accessing the settings of each web browser, to simply prohibit tracking during browsing.
WIIN only shares data with the above-mentioned third parties in the context of the performance of contracts to enable Customers and Users to use its Platforms in the best possible way, or where WIIN has the consent of its Customers to do so, or where our legitimate interest so warrants.
WIIN reserves the right to transmit the Personal Data of its Customers in order to comply with any judicial request, in the context of inquiries and investigations, or in order to guarantee the rights, property and safety of WIIN, its Users and more generally any third party.
5. Where and how is the data transferred?
WIIN stores your Personal Data primarily in the European Union. Through the hosting service provider, Amazon Web Services (AWS), which is located in the Paris area of France.
6. Communications sent by WIIN
In accordance with applicable law and with your consent where required, WIIN may use the data provided on the Platforms for commercial prospecting purposes, for example to inform its Customers, send newsletters, or send notifications and communications that may be of interest to Customers and Users.
With respect to promotional emails: recipients may withdraw their consent at any time by clicking on the unsubscribe link provided in each communication or by contacting WIIN as described in "Contact" below.
7. What are your rights regarding your personal data?
When provided by applicable law, you have the right to obtain a copy of the personal data we hold about you. Before responding to your request, WIIN may verify your identity and ask you to provide further information in order to fulfill your request.
WIIn will endeavour to respond to your request within a reasonable time and, in any event, within the time limits recommended by the CNIL, namely one month. If you wish to exercise this right, contact us according to the methods indicated in the article "Contact".
As a User and/or Customer of our Platforms, you also have the possibility to access part of the Personal Data we hold through your account, in the Profile section, to rectify any incorrect information. You may also correct or delete such information by contacting us directly (see "Contact" below).
You can also ask WIIN, by direct contact, to close your online account at any time and you have the right to object to or limit the processing of your Personal Data. In the case of a paid subscription that has not expired or been renewed, the request to delete your account will not result in a full or partial refund.
Please note that WIIn is likely to preserve certain information concerning you when the law imposes it or when there is a legitimate reason to do it. For example, if WIIN believes that fraud has been committed or that a breach of the Terms and Conditions has occurred.
Customers have:
- Tright to lodge a complaint with the competent supervisory authority or to obtain redress from the competent courts if you consider that WIIN has not respected your rights.
- The right to the portability of your data, i.e. the right to receive the Personal Data you have provided in a structured, commonly used and machine-readable format and the right to transmit this data to another controller.
- The right to define directives concerning the fate of your Personal Data after your death.
Users must enforce their rights in accordance with the provisions of the Customer. WIIN reminds you that it does not own the data collected by the Customer from the Users through the Forms issued with the WIIN Platforms. Thus, the Customer is the only one who can respond to the Users' requests. Users cannot turn to WIIN to request a right to delete or correct their data.
8. Cookies and similar technologiesCookies are small files that the administrator of a server installs on your computer and that make it possible to memorize data relating to the Net surfer when it connects to the site. WIIN only uses cookies to store information that is intended to facilitate the navigation of customers and users. You may refuse the installation of cookies at any time or delete them. If you choose to decline cookies, some areas of the WIIN Platforms may not function as intended or at all. When you browse the WIIN Platforms, a cookie is placed on your computer's hard drive. This allows WIIN to personalize its Platforms.
Unless otherwise stated, WIIN's Privacy Policy shall apply to the processing of data collected by means of cookies.
WIIN uses cookies for the following purposes:
- Authentication: use of cookies to verify your account and to determine when you are logged in, so as to facilitate your access to the Services and to provide you with an experience and functionality tailored to your use. In particular, WIIN uses cookies for authentication via social networks, or to allow you to log in to the Platforms using your social network accounts.
- Personalization of the user experience: use of cookies to provide you with personalized content and experiences.
- Navigation tracking - analysis: use of cookies to allow you to fully navigate the Platforms, to change pages without having to log in again, to proceed with the payment of an order, or to use one of the many free or paid features of the Platforms.
For example, to enable WIIN to better understand how the Platforms are used, WIIN works with various analytics partners, including Google Analytics. To prevent Google Analytics from using your information for analytics purposes, you can install the Google Analytics Opt-out Browser Add-on.
Most browsers automatically accept cookies, but you can change your browser settings to decline cookies by going to the Help section of your browser's toolbar.
You may be able to control cookies through the "Settings" function of your mobile device. Please refer to your device manufacturer's instructions for more information.
For more information on cookies:
http://www.cnil.fr/vos-droits/vos-traces/les-cookies/9. Confidentiality of your passwordYou are responsible for maintaining the confidentiality of the password you choose to access your accounts on the Platforms.
As your passwords are stored in encrypted form, WIIN cannot disclose them to you if you forget them. However, WIIN gives you the possibility to choose a new one at any time.
You undertake to keep your password secret and not to disclose it to anyone, and no WIIN employee will ever ask you for your password.
10. Links to other websites and social networksThe Platforms may contain links to third party websites. Please note that these websites have their own privacy policies and that WIIN is not responsible for the use made by these sites of the information collected when you click on these links. WIIN encourages you to review the privacy policies of these sites before submitting your Personal Information to them.
11. Changes to our Privacy PolicyWIIN may change this policy from time to time. When necessary, WIIN will notify you and/or seek your consent. Please check this page regularly for any changes or updates to this document.
12. ContactIf you have any questions about this policy or if you have any requests regarding your personal data, you can contact us by sending an email to our Data Protection Officer at:
office@wiin.ioLast update: January 21, 2021 at 16:56 (GMT)