ARTICLE 1. DEFINITIONS
Capitalized terms used in the singular or plural in the body of this Privacy Policy shall have the meanings given to them in the Terms of Use, or defined below:
Personal Data: means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an "identifiable natural person" is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity;
Processing: means any operation or set of operations, whether or not carried out using automated processes, applied to Personal Data or sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, deletion or destruction.
Data Controller: means the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of the Processing. The Controller of the Personal Data is NUDGE.
Processor: means the natural or legal person, public authority, department or other body that processes Personal Data on behalf of the Controller.
ARTICLE 3. PERSONAL DATA PROCESSED AND PURPOSE OF PROCESSING
Personal Data is collected for specific, explicit and legitimate purposes. NUDGE ensures that personal data is processed in an adequate, relevant and limited manner in relation to the purposes for which it is processed.
In general, NUDGE processes Data in order to provide the User with access to the features of the Application and to ensure the best possible experience, but also for security purposes and to comply with legal and contractual obligations, and in particular:
- To meet the demands and requirements of applicable laws, and administrative and judicial authorities;
- Identify and prevent fraudulent activities and threats to the security of the Site and the Application;
- To enforce or defend its rights, including our rights under its Terms of Use and this Privacy Policy;
- To counter fraud, and to combat any use of the Services that is illegal or contrary to its Terms.
1. The Data collected via the contact form on the Site
- Email address
- Last name, first name
The processing of this Data enables NUDGE to respond to requests from Users or visitors to the Site who fill in the contact form.
The processing of such Data is based on the User's consent.
2. The Data collected during the registration on the Application
When registering on the Application, the User notably provides the following Personal Data:
- Last name, first name
- Email address
- Phone number
- City and country of residence
- Status (student, graduate)
- Education
- Employment information
This Data allows the User to create an account on the Application. This Data is mandatory to access the Services.
The User can also complete his/her profile with other information about him/herself, such as a photo, gender, family situation, biography, etc.
All the Data provided by the User (mandatory or optional) is subject to automated processing by a matching algorithm, which connects the Users of the Application.
NUDGE can also use these Data to reach out to the User in the context of asking for feedback about its services. The legal basis of this use is linked to NUDGE commercial legitimate interest.The processing of this Data is based on the execution of the Terms of Use.
3. The data collected during the User's navigation on the Application
- Information about Users' interactions with the Application
NUDGE collects information about who the User interacts with and what groups the User has joined.
NUDGE also collects information about the groups created by User and the members of those groups.
This processing is based on the execution of the Terms of Use, and on NUDGE's legitimate business interest in conducting audience measurement and analysis, and in providing Users with personalized content to enhance their experience on the Application.
- Information about the User's phone or other connecting device
NUDGE collects information about the devices and equipment the User uses to access the Site and Application, including:
- Device attributes: operating system, hardware and software versions, application and file names and types.
- Device Settings Data: Information that the User authorizes NUDGE to receive through the settings of the device that the User activates, including access to the User's photos.
- Cookie Data: Data from cookies stored on the User's device, including cookie identifiers and settings.
-Sensitive data collected on the Application
The User may choose to provide so-called "sensitive" information on his/her Personal Space or on groups, in particular about his/her religious beliefs or political opinions. This information is subject to special protections in accordance with European legislation.
The User is under no obligation to provide such Data. By providing it through the Application, the User expressly consents to its processing by NUDGE in accordance with this Privacy Policy.
ARTICLE 4. RETENTION PERIOD OF PERSONAL DATA
NUDGE retains Data only as long as necessary to fulfill the purposes for which it was collected.
In general, the User's Profile Data and the Data on his/her interactions on the Application are kept until the User's Personal Space is closed. After this period, the Data is permanently deleted by NUDGE.
The Data collected when sending the contact form available on the Site are kept for 3 years from the last contact from the User.
The Data from the cookies are kept for a maximum of 25 months.
ARTCLE 5. RECIPIENTS OF PERSONAL DATA
1. Other users of the Application
The Data related to identity, school/university background or career that the User shares via the Application is visible to other users of the Application.
However, Data related to contact information or family status are not shared with other Users.
2. NUDGE employees and internal collaborators
Authorized NUDGE employees and collaborators may access and process User Data as necessary to provide the Services.
All these people are bound by a contractual obligation of confidentiality.
3. NUDGE's service providers
NUDGE may share Personal Data with its service providers for the purpose of performing the Services.
For example, to host Personal Data, NUDGE uses and shares Data with AWS (Amazon Web Services, Inc.), whose servers are located in Frankfurt, European Union.
NUDGE also shares Personal Data with Mixpanel, a provider of a data analysis tool.
4. NUDGE's partner schools, universities and associations
NUDGE may share Data with partner schools, universities and associations that wish to connect their alumni database to the Application.
This sharing is also subject to the terms and conditions and privacy policies of the partner schools, universities and associations.
NUDGE does not share Data with partner schools, universities and associations for marketing purposes.
When partners use Netanswer's website manager for their alumni database, NUDGE may share the Data with Netanswer to ensure that the Data is kept up to date.
This sharing is also subject to the terms and conditions and privacy policy of Netanswer and its partners.
In addition, pursuant to any law, decree, regulation or order of a competent regulatory or judicial authority, Data may be disclosed, if necessary, to protect the interests of NUDGE. NUDGE shall not be liable for such disclosure.
7. Transfer outside the European Union
For the purposes mentioned above, NUDGE may transfer Data outside of the European Union to countries whose laws on the protection of personal data differ from those of the European Union.
Transfers made outside the European Union are governed by standard contractual clauses within the meaning of Article 46 of the GDPR, concluded with partners as appropriate guarantees.
The User can send a request to NUDGE to be communicated the list of partners whose headquarters are domiciled outside the European Union, as well as the standard contractual clauses these transfers are based on, by email, at the following email address:
jlanderoin@withanudge.com.
ARTICLE 6. DATA PROTECTION OFFICER
The role of the Data Protection Officer is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.
NUDGE's Data Protection Officer can be contacted by email at
withanudge@gmail.com.
In accordance with the regulations concerning the processing of personal data, the User has the following rights:
1. Right of access, rectification and deletion
The User may view, update, modify or request the deletion of his/her data.
If he/she has one, the User has the right to request the deletion of his/her account.
2. Right to data portability
The User has the right to request the portability of his/her data held by NUDGE to another operator.
3. Right to limit and object to the processing of data
The User has the right to request the limitation of or to object to the processing of his/her data by NUDGE, without NUDGE being able to refuse, unless it can be shown that there are legitimate and compelling reasons for doing so which may override the interests and rights and freedoms of the User.
The User may exercise his/her rights by contacting NUDGE by email at
withanudge@gmail.com, or by writing to NUDGE, 6 rue d'Armaille, 75017 Paris.
NUDGE shall respond to the User within 30 days.
If the User believes, after contacting NUDGE, that his/her rights have not been respected, he/she may submit a complaint to a supervisory authority. The supervisory authority in charge of the processing carried out by NUDGE is the Commission Nationale de l'Informatique et des Libertés (CNIL).
NUDGE uses various cookies and trackers on the Site and the Application to enable access to the Services, measure audience size and improve the interactivity of the Site and the Application.
A "cookie" is a piece of information, usually small and identified by a name, that may be transmitted to the User's browser by a web site to which the User connects. The web browser will keep it for a certain period of time, and will send it back to the web server each time the User reconnects. Cookies have multiple uses: they can be used to memorize the User's identifier with a merchant site, the current contents of the shopping cart, an identifier allowing the User's navigation to be traced for statistical or advertising purposes, etc.
1. Types of cookies used on the Site and the Application
Strictly necessary cookies: These are cookies that are strictly necessary for the functioning of the Application. They allow the use of the main features of the Site.
These cookies cannot be set because without them the User will not be able to use the Application normally.
The Application uses strictly necessary cookies (in particular to keep the session open during use).
Analytics cookies: These cookies allow NUDGE to collect information about the use and performance of the Site in order to improve its operation, attractiveness and content.
The Site uses Hotjar analytics cookies to better understand the needs of its users and to optimize the Site. The data collected by Hotjar through cookies are related to the behavior of users on the Site.
For more details, it is advisable to consult the list of data collected by Hotjar on the Site via the following link:
https://help.hotjar.com/hc/en-us/articles/1500000187901-Categories-of-Personal-Data 2. Configuration of cookies on the Site
