ARGOflow Privacy Policy

Preamble

ARGO, a simplified joint stock company with a capital of 37,312.70 euros whose head office is located at 1 place Francis Ponge 34000 Montpellier (France), registered in the Montpellier Trade Register under number 804 465 276 (“ARGO” ), publishes and operates the www.ar-go.co website (the “Site“), and the ARGOflow application (the “Application”).

ARGOflow is the platform made available to the Customer and Users under an ARGO license to transform PDF documents into interactive HTML applications.

In this context, ARGO, as a Subcontractor, is required to collect data relating to Users and their behaviour when using ARGOflow services on behalf of its Clients, the Processing Manager. ARGO’s use of the Data is governed by the General Conditions of Services concluded between ARGO and its Client. ARGO, acting on the instructions of its Clients, refrains from carrying out any processing not expressly required by the Client in the context of the operation of the Services nor expressly consented to by the User. ARGO shall not, therefore, be responsible for the Privacy Policy or the privacy practices implemented by its Client.

The protection of personal data and respect for the privacy of our Clients and users is of great importance to us. The purpose of this privacy policy is to inform you of the Treatments implemented in the context of the use of the Services offered and this, in accordance with the regulations in force in France as issued from the French law n°78-17 of January 6, 1978 relating to data processing, files and liberties as amended (“LIL”) and the EU Regulation 2016/679 of April 27, 2016 on the protection of personal data (“GDPR”). In particular, its purpose is to inform people browsing the Site or the Application or using the Services offered on them:

• the way Your Data is collected, used and shared in the context of the provision of these services as well as Your rights (I) ;
• information, which may include personal data, collected in the context of your browsing, thanks to “cookies” (II).

Any changes or updates to this Privacy Policy will be duly brought to the attention of Clients.

I/ PROCESSING OF PERSONAL DATA

1.Definitions

“Clients” means the company with which ARGO has entered into the Terms and Conditions of Service for the ARGO Products available.

“Cookie” means the files, often encrypted, stored by your computer’s browser or on your mobile device and used to record Personal and Non-Personal Data about Your browsing on the Platforms. These cookies allow the sites you visit to access information such as connection data, browsing behavior, parameters used (language and territory) and actions taken (such as “shopping carts” in online stores).

“Data” means any information transmitted by the User to ARGO in connection with the Use of the Site and/or the Application, including Personal Data.

“Personal Data” means any information relating to a natural person identified or identifiable, directly or indirectly, by reference to an identification number or to one or more elements specific to that person;

“Sensitive Personal Data” means any information concerning racial or ethnic origin, political, philosophical or religious opinions, trade union membership, health or sex life as well as genetic or biometric data. In principle, the processing of Sensitive Data is prohibited unless, in particular, the data subject has given his or her express consent.

“User” means any person designated by Client using the Services provided on the Site and/or the Application;

“Platforms” means the aggregation of applications, websites and all digital platforms offered by ARGO in connection with the operation of the Services (to be completed) including the Site and the Application.

“Data Controller” means the natural or legal person who determines the purposes and means of a Data Processing, that is to say, the objective and the way of carrying it out and who is a Subcontractor when processing Personal Data on behalf of its Clients, data controllers.  ARGO’s Client is responsible for the processing of Your Personal Data.

“Subcontractor” means the natural or legal person who processes Data on behalf of a third party data controller. ARGO is a Subcontractor of Your Data.

“Services” means the services provided by ARGO through the Site and the Application as described in our Terms and conditions;

“Processing of Personal Data” means any operation, or set of operations, relating to personal data, regardless of the process used (collection, recording, organization, storage, adaptation, modification, extraction, consultation, use, communication by transmission or distribution or any other form of provision, reconciliation) carried out by ARGO in the context of the use of the Services.

2.Categories of Personal Data Collected

You are informed that the Personal Data collected and processed depends on Your use of the Services and the functionalities that You decide to activate according to the options chosen.

• • Civil Status: Last name, first name
  • Identification data: e-mail address, telephone number of the Client’s internal contacts, SIRET number, Intracommunity VAT number

You agree to provide current and valid Personal Data and warrant that you will not make any false statements or provide any erroneous information.

2.1. Nature of collected Data

2.1.1. Data collected from Clients

• Customer identification data: Name, first name, company name, e-mail and postal address, telephone number

2.1.2. Data collected from Users

• Identifying information such as Name, First Name, Image, E-mail Address, Login and Password, IP Address
• Reading profile data: Pages read, IP address, name of the document read, time spent on each page read; pages/topics searched, date and time of page consultation

You agree to provide current and valid Personal Data and warrant that you will not make any false statements or provide any erroneous information.

3.Mandatory and optional nature of the Personal Data collected

When you register and create your Profile on our Site and/or Application, you are asked to provide the following information: Last Name, First Name, E-mail, Name of the organization. This personal data must be provided to us insofar as it is strictly necessary for your registration and the use of the ARGOflow service. The mandatory nature of the information requested is indicated to you at the time of collection. Failure to provide the said Data will prevent you from accessing and/or using the Services.

The other Personal Data collected is optional. You are therefore free to provide them or not. However, they allow us to personalize the Services that we offer you and to improve your browsing experience on the Site and/or the Application.

4 Purposes of the collection of Personal Data

ARGO, as Data Controller, collects Your Personal Data for the following purposes:

• Provide Services to the Clients and enable them to function optimally (management of registration on the Application, etc.),
• Adapt the products and Services to the Client’s requirements
• Operations relating to the commercial management of Clients
• Operations relating to commercial prospecting
• Establish statistics and audience measurements
• Fighting fraud and ensuring the security of the Platforms
• Execution of the legal, regulatory and administrative provisions in force

Depending on the data processing involved, ARGO processes Your Personal Data on the basis of one of these legal grounds :

• Your prior consent when you have expressed your agreement to the processing of Your Data
• The execution of a contract between you and us
• Legal obligations
• A “legitimate interest” of ARGO within the meaning of the applicable Personal Data Protection legislation. In this case ARGO will take into account your interests and fundamental rights to determine whether the processing is legitimate and lawful.

5 Who has access to Your Personal Data?

5.1. ARGO staff

The Personal Data collected are processed by duly authorized persons within ARGO, namely, and depending on the nature of the processing and the category of Personal Data concerned, ARGO’s legal representatives and its employees in charge of marketing, IT and customer service.

5.2. ARGO’s subcontractors

In the course of carrying out its activities and providing its Services, ARGO uses subcontractors who process Personal Data on its behalf and under its instructions. In accordance with the GDPR, ARGO requires its subcontractors to provide sufficient guarantees that they implement appropriate technical and organizational measures to ensure the security and confidentiality of your data.

ARGO uses subcontractors located in countries offering an adequate level of protection either because they are subject to the provisions of the GDPR or, in accordance with Article 45 of the GDPR, because they have been granted an adequacy decision by the European Commission. Failing this, ARGO undertakes to implement any appropriate mechanism to ensure an adequate level of data protection, including standard contractual clauses established by the European Commission.

More information on the warranties offered by ARGO’s subcontractors is available upon request at [email protected].

5.3. Other possible addressees

ARGO, if necessary, may transmit Your Personal Data to organizations, third parties, administrative or judicial authorities in the following cases:

• • To carry out our legal and regulatory obligations,
  • Identify, prevent or address fraudulent activities, security breaches or other technical problems relating to the Services;
  • To assert a legal claim

ARGO, and only after obtaining your prior consent, may be required to transmit Your Personal Data to Partners in order to carry out joint commercial operations.

6.how long is Your Personal Data kept?

ARGO keeps your personal data, in a form that allows you to be identified, on an active basis for the time strictly necessary for the fulfillment of the purposes for which they are collected and processed, namely :

• For the purpose of providing the Services :
  • Identity and contact: 5 years after the end of the contractual obligations ;
  • Commercial relations: 5 years after the end of the contractual obligations;
  • Connection data: 12 months after collection ;
  • Terms of payment: 13 months after debit ;
• For commercial prospecting and direct marketing purposes:
  • Identity and contact : 3 years from the last contact ;
  • Login data: 12 months from collection

Your Personal Data may also be archived with limited and justified supervised access for the time necessary

(i) to comply with ARGO’s legal and regulatory obligations (accounting, taxation: 10 years)
(ii) to allow ARGO to assert a legal claim, before being definitively deleted.

7 How does ARGO ensure the security and privacy of your Personal Data?

ARGO undertakes to process your Personal Data in a lawful, fair, transparent, proportionate, relevant manner, within the strict framework of the purposes pursued and announced, for the duration necessary for the processing implemented and in a secure manner.

ARGO implements and maintains appropriate technical and organizational measures to ensure the security and confidentiality of your Personal Data by preventing it from being distorted, damaged or communicated to unauthorized third parties. To this end, ARGO provides Users with a Data Management Platform that allows you to access in real time the Personal Data entrusted to you.

ARGO ensures the protection and security of the Personal Data collected in order to ensure its confidentiality and to prevent it from being damaged, misused, destroyed or disclosed to unauthorized third parties.

As such, ARGO has taken physical, electronic and organizational safeguards to prevent any loss, misuse, unauthorized access or distribution, alteration or destruction of Personal Data. Among these protective measures, the SSL protocol incorporates technologies specially developed to protect Personal Data during transfer. All Personal Data is confidential and access is limited to ARGO employees, service providers and subcontractors with a strict need-to-know basis for the purposes of their work. All persons having access to Your Personal Data are bound by an obligation of confidentiality and may be subject to disciplinary action and/or sanctions for failure to comply with these obligations.

However, it is important that you take care to prevent unauthorized access to your Personal Data. You are responsible for maintaining the confidentiality of your password and account information. Therefore, the User is invited to ensure that each session is closed in case of shared use of the same computer.

8 What are your rights regarding your Personal Data?

For treatments carried out by ARGO as Data Controller, it is possible for you, by simple written request sent to the following address: [email protected] to access your Personal Data, to request their correction or limitation, deletion or portability, or to request that they no longer appear in ARGO’s database.

Under the right of access, you are authorized, in accordance with article 15 of the GDPR, to question ARGO in order to obtain confirmation that your Personal Data are or are no longer being processed, as well as to obtain information relating to the processing (in particular its purposes, the categories of Personal Data processed and the recipients to whom the Personal Data are communicated, the length of time the Data are kept or the criteria used to determine this length of time, your rights regarding the Personal Data and the right to lodge a complaint with a supervisory authority).

In accordance with article 16 of the GDPR, the right of rectification gives you the right to require ARGO to rectify, complete or update the Personal Data concerning you when they are inaccurate, incomplete, equivocal or out of date.

Under the conditions provided for in Article 17 of the RGPD, you may also request the deletion of your Personal Data.

In addition, you may request that the processing of your personal data be limited under the conditions of Article 18 of the GDPR, i.e. that your personal data be kept only for the purposes of :

• verify the accuracy of the Personal Data that is being challenged,
• serve you in the context of the establishment, exercise or defense of your rights in court, even though ARGO no longer has any use for it,
• to verify whether the legitimate reasons pursued by ARGO prevail over yours should you object to treatment based on ARGO’s legitimate interest,
• satisfy your request to limit the use of your data – rather than to erase it – in the event that the processing of your data is unlawful.

By virtue of your right to portability and in the circumstances provided for in article 20 of the GDPR, you may recover from ARGO the Personal Data you have provided, in a structured, commonly used and machine-readable format, for the purpose of forwarding it to another data controller.

In accordance with article 21 of the GDPR, you have the possibility to object, at any time, to the processing of your Personal Data for commercial prospecting purposes.

To exercise your rights of access, rectification, deletion, limitation, portability and opposition mentioned above, you just have to send your request, as you wish:

– by e-mail to the following address : [email protected] ;

– by postal mail to the following address

ARGO SAS
Hôtel French Tech
1 Place Francis Ponge, 34000 Montpellier

ARGO will respond to the request within 30 days of receipt.

The exercise of these rights is free of charge. However, in the event of a request that is manifestly unfounded or excessive, particularly in view of its repetitive nature, ARGO reserves the right (i) to demand payment of a fee taking into account administrative costs, or (ii) to refuse to act on the request.

In case of persistent disagreement concerning your personal data you have the right to seize the CNIL at the following address:

Commission Nationale de l’Informatique et des Libertés
3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07

9 What happens if your Personal Information is compromised?

In the event of a violation of Personal Data, and for processing carried out in ARGO’s capacity as Data Controller, ARGO shall notify the CNIL of the violation as soon as possible, and if possible seventy-two (72) hours at the latest after becoming aware of it, unless the violation in question is not likely to create a risk for the rights and freedoms of Users.

When a violation of Personal Data is likely to create a high risk for the Client’s rights and freedoms, ARGO will inform the Client, in clear and precise terms, as soon as possible, subject to the exceptions provided for in Article 34 of the GDPR.

Without prejudice to any other administrative or jurisdictional recourse, the Client who considers that the processing of its Personal Data constitutes a violation of the provisions of the legislation in force may file a complaint with a competent supervisory authority such as the CNIL.

10 Who to ask your questions to?

You may at any time contact the ARGO Personal Data Referrer, regarding all matters relating to the processing of your Personal Data and the exercise of their rights as described below, at the following address: [email protected].

II/ PROCESSING OF PERSONAL DATA COLLECTED THROUGH COOKIES

1 What are “Cookies”?

The purpose of our Cookies is first of all to improve your navigation on our Site or our Application.

2 What Cookies does ARGO use?

2.1. Technical Cookies

These Cookies allow us to provide you with services tailored to your browsing experience, such as the ability to log in through your Facebook, Twitter or Google account. These Cookies allow us to improve your User experience. ARGO may use the following Cookies:

2.2. Analytical cookies/audience measurement

These Cookies allow us to obtain information about the use of our Site, our Application and ARGOflow and to analyze traffic data. These traffic statistics allow us to detect navigation problems and thus optimize your browsing and reading experience. ARGO may use the following Analytical Cookies:

2.3. Tracking Cookies

Cookies are used to track and “trace” your behavior and your navigation. In particular, they are deposited and read when you consult the Site or the Application, but also when you read an e-mail, install or use a software or mobile application, regardless of the type of device used, such as a computer or a smartphone. ARGO may use the following tracking cookies:

3) How long are Cookies used?

The use of Cookies may be limited to the duration of your browsing on the Site/Application with automatic deletion when you leave the Site and may not, in any event, exceed a period of use of six (6) months with the exception of Audience Measurement Cookies which may be kept for up to 13 (thirteen) months.

4 How do I accept and disable Cookies?

Your prior consent is required before installing certain Cookies.

Thus, during your first visit to the Site, a “cookie banner” appears on the access page that allows you to accept all families of cookies, to refuse them, or to personalize your choices. Clicking on “Personalize my choices” will allow you to make your choices.

You will be free to modify your choices at any time by clicking here.

It is also possible for you to oppose by default to the deposit of Cookies by configuring your browser. Indeed, your browser can be configured to automatically accept or refuse Cookies. You also have the possibility to deactivate the storage of Cookies, to be alerted when a Cookie is issued and to see its content and validity period.

Uninstalling a Cookie or objecting to the installation of Cookies on your devices may alter your browsing experience and prevent you from benefiting from certain services on the Site.

Cookie instructions for the most commonly used browsers are available via the following links:

Mozilla Firefox :

https://support.mozilla.org/fr/kb/activer-desactiver-cookies or https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Google Chrome:

https://support.google.com/chrome/answer/95647?hl=fr or https://policies.google.com/technologies/managing

Apple :

http://support.apple.com/kb/HT1677?viewlocale=fr_FR&locale=fr_FR

Microsoft Edge :

https://support.microsoft.com/fr-fr/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy

Opera :

https://help.opera.com/en/latest/web-preferences/

If you would like more information on Cookie control tools, please visit the following link:

www.cnil.fr/vos-droits/vos-traces/les-cookies

We remind you that it is not necessary to obtain your prior consent to the installation of “technical” Cookies, i.e. Cookies that are strictly necessary for the delivery of the Services.