Padam Mobility Personal Data Processing Policy
Customers and Prospects

The subject of the Policy

This personal data processing policy (hereinafter in the “Policy The purpose of the company Optiways, a simplified share company with a capital of 137,816.69 euros, is based on 19 rue des Feuillantines – 75016 Paris, registered in the Paris Register of Trade and Companies under the number 802 466 177 (hereafter ” Padam Mobility “us”).

Used in the Policy, the terms “personal data,” “persons concerned,” “processing manager,” “processing,” “international transfer” and “subcontractors” have the meaning attributed to them in Regulation 2016/679 of 27 April 2016 relating to the protection of individuals with respect to the processing of personal data and the free movement of that data.

Description of treatments implemented by Padam Mobility

Building a base of customers and prospects

As part of the creation and maintenance of its customer and lead base, Padam Mobility staff are likely to collect the following personal data:

name
given name
Professional email address,
Professional phone number,
company
Busy position,
Various information you can provide during your exchanges with Padam Mobility staff,

This personal data will be collected directly from you, especially as part of a business relationship established between Padam Mobility and your company or work events. This personal data will be used to enable Padam Mobility to manage and maintain its relationships with its customers and prospects, to send newsletters and other direct communications, and, where appropriate, for the purpose of billing for services.

Padam Mobility processes this personal data in order to develop its business. The legal basis of the treatment is therefore the legitimate interest pursued by Padam Mobility.

This data is kept for two (2) years from the end of the business relationship with your company and for two (2) years from collection if no business relationship is established.

Sending and consulting newsletters

Padam Mobility may use your email address to send you newsletters and other direct communications via email. You can object to these mailings at any time by sending an email to data-privacy@padam.io address or using the opt-out link in the emails sent by Padam Mobility. Please note that your email address may be retained after you opt out if a business relationship is still in progress between Padam Mobility and your company.

When sending these emails, Padam Mobility will collect the following personal data:

IP address
Location
Email openings
Browse Padam Mobility’s website and blog
Padam Mobility documents downloaded

This personal data will be collected through tracers or cookies and is only used for audience measurement and service enhancement by Padam Mobility. By continuing to browse Padam Mobility’s sites, you agree to use them. You can object to the use of these tracers by changing your browser settings.

The legal basis for the treatment is Padam Mobility’s legitimate interest in communicating about the development of its business.

Audience measurement data is kept for thirteen (13) months from collection. The tracers will be deleted after thirteen (13) months from the opening of the first email.

[Warning: The tracers used by the majority of service providers sending e-mails for audience measurement are like cookies within the meaning of the Computer and Freedoms Act. Section 32 of the Computer and Freedoms Act requires the processing officer to obtain the prior consent of the person concerned before depositing this type of file on his terminal except for cookies of pure measure of hearing provided that:
The site’s editor provides clear and complete information;
An anti-cookie mechanism is simply accessible and usable on all browsers, and all types of devices (including smartphones and tablets).
The data collected is not cross-referenced with other treatments.
The deposited cookie must only be used to produce anonymous statistics;
The cookie should not be used to track the user’s browsing on other sites.
The IP address to geolocate the user should not be more accurate than the city scale.
Cookies and gross attendance data are not kept for more than 13 months.]

Recipients of personal data and international transfers

Padam Mobility uses computer tools to manage its customer base and prospects (CRM), send direct communications and generally store its data. These IT tools are made available to it by third-party providers with whom Padam Mobility has contracts including provisions relating to the protection of personal data. These providers, who will have access to certain personal data, are listed below:

Salesforce
Pardot
Sendinblue,
Google
Freshdesk
Twitter
Linkedin

These providers are likely to transfer your personal data outside the European Union to host or perform maintenance operations. Mechanisms have been put in place to supervise these appropriate transfers by Padam Mobility. You are informed that Salesforce and Google have adhered to the principles of the Privacy Shield agreement (you can get more information about this mechanism by visiting the site https://www.privacyshield.gov/welcome).

[Warning: As stated in my email, the data protection guarantees provided by Pipedrive and Sendinblue are far from sufficient. With regard to data transfers, if Pipedrive specifies that it benefits from privacy shield accreditation – information verified on the Privacy Shield website – Sendinblue only indicates that such transfers are possible without offering any framing mechanism. I advise you to get closer to these entities to get more guarantees. Regarding Google, please let me know if your G Suite account includes standard contractual clauses.]

Your rights

You have the following rights, regarding your personal data that we collect and process.

When you ask us to correct or delete your personal data or limit its processing, we will do our best to inform each recipient to whom this data has been shared (unless this proves impossible or involves disproportionate effort).

Right of access

You can ask us to view the personal data about you processed by Padam Mobility. If you request it, we will also provide you with a copy of all personal data about you in our possession.

You can also ask us for the information we are legally required to give you, including:

The purpose of the treatment
The categories of personal data involved;
Recipients to whom personal data has been or will be shared;
The shelf life of personal data And
additional information about your personal data rights.

Right to data portability

You have the right to portability of your personal data. This right is separate from your right of access, since it only applies to the personal data you have provided to us (excluding automatically generated statistical data). This right allows you to receive your data in a structured electronic format, commonly used, so that you can transfer it to another processing manager or subcontractor.

Right to rectification

You may, at any time, request that we correct inaccurate or incomplete personal data about you, and we will proceed promptly and accordingly.

Right to erasure (“right to be forgotten”)

You can request the removal of your personal data, provided that one of the following conditions is met:

Your personal data is no longer necessary for the purposes for which it was collected or processed;
You assert your right to object to the processing of your personal data;
Your personal data has been treated illegally where
your personal data must be deleted, because we are legally obliged to do so.

Right of opposition

When your personal circumstances warrant, you may object to us processing your personal data when it is done in our legitimate interest.

You may also object at any time to us processing your personal data when it is done for marketing purposes.

Right to limit treatment

You can request a restriction on the processing of your personal data when one of the following conditions is met:

When you challenge the accuracy of your personal data, you can request a restriction on its processing, during the time required to verify your request;
When processing is illegal, you can request a restriction on the use of your personal data rather than deleting it.
If we no longer need your personal data for processing purposes, but you need that data to establish, enforce or challenge a right in court; where
When you have objected to the processing of your personal data as part of our legitimate interests, you may request a restriction of that processing while we investigate your request.

Complaint to the supervisory authority

You have the right to file a claim with the competent supervisory authority (in France, this authority is the CNIL, whose website is accessible at the following address: https://www.cnil.fr/).

Contact Us

In order to exercise your rights described above or to ask us any questions you may have about the processing of your personal data, you can contact us at data-privacy@padam.io.

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