General Policy for the Protection of Personal Information Data

BYPATH SAS, a company under French law registered with the Register of Business and Companies of NANTERRE under the number 794 713 503, headquartered at 6/10 rue TROYON 92310 SEVRES, France (hereinafter referred to as “BYPATH”) carries out the processing of personal information data (as defined below) within the framework of its business activity, which includes the personal information data of individuals using the BYPATH sales intelligence solution and who navigate the Internet site https://www.bypath.com/ (the “Sites”).

This “Policy for the Protection of Personal Information Data” (the “Policy”) has as its purpose to inform any physical person concerned (“You” or “Your”) of the way in which BYPATH uses such personal information data and of the ways you have for monitoring this use.

It is indispensable to specify here that BYPATH does not use any datum deemed sensitive, such as personal information data which reveals racial or ethnic origin, philosophical or religious convictions or union membership as well as the use of genetic data, biometric data which have the purpose of identifying a physical person in a unique way, data concerning health or data concerning the sex life or sexual orientation of a physical person or personal information data related to criminal convictions or infractions since they do not relate to the business activity of BYPATH nor fulfill any purpose for the use of the business.

  1. FIELD OF APPLICATION OF THIS POLICY FOR THE PROTECTION OF PERSONAL INFORMATION DATA

The General Regulation on the Protection of Data (“RGPD”), applicable beginning on May 25, 2018, has the specific purpose of being applied to any business that collects, stores or uses personal information data.  BYPATH has put in place a strategy whose aim is to respect this regulation (training of its employees, IT network, reporting procedures, etc.).  It is within this framework that this Policy was written.

This Policy lays out the principles and guidelines for the protection of your personal information data, which includes the personal information data collected on – or via – the Sites.

BYPATH collects personal information data online or offline; this Policy applies no matter what the mode of collection or use might be.

The idea of personal information data (“personal information data”) designates any information connected to an identified or identifiable physical person (hereinafter referred to as the “individual concerned”); is considered to be an “identifiable physical person”, a physical person who can be identified, directly or indirectly, in particular by referring to an identifier, such as a name, an identification number, location data, screen name, or one of several other specific elements uniquely tied to his/her physical, physiological, genetic, psychic, economic, cultural or social identity.

“Non-personal data” corresponds to information that does not permit one to identify a person.

Visitors and users of the Sites, please note:  each Site is subject to specific Conditions of Use available on each of the Sites and are part of this Policy.  Your use of the Sites as well as the personal information data that you choose to communicate on the Sites are subject to the provisions of this Policy and to the applicable Conditions of Use.

  1. COLLECTED DATA

Personal information data can include the following:

  • Current and past professional positions
  • First name and last name
  • Job title
  • Professional email address
  • Telephone number
  • Any other personal data which could be considered pertinent to the purposes laid out below.

In any case, the personal information data collected is limited however to data necessary for the purposes laid out in Article 4 below.

Visitors to and users of the Sites, please note:  certain functions and characteristics of the Site can only be used if you communicate to BYPATH certain personal information data when you visit or use the Site.  You are free to furnish or not all or part of your personal information data.  However, if you choose not to furnish it, such a decision may prevent the fulfillment or the satisfactory fulfillment of the objectives described in Article 4 below; certain services and certain functions of the Sites may not function correctly.

  1. PROTCTION OF THE PERSONAL INFORMATION DATA OF CHILDREN

The products and services of BYPATH are not meant to be sold to children who are younger than 16 years, and BYPATH neither collects nor stores voluntarily the personal information data of children younger than 16 years of age.

BYPATH products and services cannot be used by children.  If parents discover that their child has communicated personal information data to BYPATH, they may request that BYPATH delete these personal information data and to terminate the child’s account by sending an email to technique@bypath.com or by logging onto the following link https://www.bypath.com/desinscription/. If it is brought to the attention of BYPATH that personal information data of children younger than 16 have been nevertheless collected, BYPATH will take necessary measures to delete the said data and to cancel the child’s account.

  1. PURPOSES FOR COLLECTING PERSONAL INFORMATION DATA

As indicated above, you furnish your personal information data on a voluntary basis.

Personal information data are generally collected for the needs of the business activity of BYPATH, such as the improvement of the use experience of our solution by the user, the sending of personalized notifications (business signals), the sending of communication, a better adaption of the BYPATH’s products and services to the needs of the customers or the respect of declarative obligations described in the law, or other similar activities.

BYPATH collects and uses personal information data about you for the needs of its business activity and in particular for the following purposes:

  • To allow you to ask for and obtain information on BYPATH and its products and services
  • To allow you to have interactive and personalized use of the Sites
  • To understand your needs and areas of interest in order to furnish you with the best adapted products and/or services (example:  business signals adapted to your target audience)
  • For purposes of prospection
  • To access all the characteristics and options offered by the Sites
  • To allow BYPATH to manage surveys
  • To allow BYPATH to manage its marketing activities
  • To allow BYPAH to manage its business relationships:  business opportunities, business offers, purchases, contracts, orders, invoices, etc.
  • To offer you commercial and support services
  • To allow you to purchase software licenses, products or services, to download software and/or to record software licenses
  • Process job applications and manage recruitment sources
  • Mange your training and/or certification on BYPATH products and services
  • Any other purpose linked to BYPATH’s business activity

Subject to local applicable law, by furnishing your email address, you are expressly authorizing BYPATH and its affiliates to use, along with other useful personal information data, in order to send you business notifications (business alerts), support proposals from our Customer Service Management team, commercial or marketing messages.

BYPATH is also likely to use your email address for administrative purposes or other objectives not connected to marketing (for example, to notify you of important changes made to the Sites).  For all useful purposes, we state again that the use of personal information data for purposes of prospecting can be considered to have been carried out for a legitimate reason (cf. (47) EU REGULATION 2016/679 FROM THE PARLIAMENT AND FROM THE COUNCIL).

  1. COOKIES

The Sites may use cookies or other technologies likely to collect or store personal information data.  Cookies are stored text files used to record both personal and non-personal information data concerning your navigation on the Sites.  Cookies can be permanent (and remain after you log off the Sites in order to be used on your subsequent visits to the Sites) or temporary (and disappear as soon as you log off the Sites).

BYPATH uses cookies:

  • in order to improve your user experience, in particular by:
    • allowing a service to recognize your device, thus you will not have to furnish the same information several times in order to accomplish the same task.
    • recognizing the screen name and the password that you have already furnished in order for you not to have to supply them again on each page that asks you for them.
  • to analyze the traffic and the data on the Sites in order to:
    • measure the number of users of the services, thus allowing it to make them easier to use and to ensure their capacity is capable of answering your requests rapidly.
    • help BYPATH to understand the way in which the users interact with the services in order to improve them.

Invisible pixels and cookies furnished by BYPATH or by third parties can be used and stores. At the time of the transmission of information generated by these cookies, the cookie parameters make sure that the IP address is rendered anonymous before any geo-tracking and before storage.  This information will be used for the purposes of evaluating your use of the Sites, of creating reports on Site activity for BYPATH, and of offering you better services targeted on your needs.  BYPATH will not connect your IP address to any other datum.

When you navigate on the Sites, the cookies are activated by default and the data can be read or stored locally on your device.  By continuing to use the Sites, you expressly accept the use of such cookies by BYPATH.

You can also configure your browser so as to systematically refuse cookies (including cookies used to purposes of measuring hits).  However, if such is the case, certain functions and characteristics of the Sites may not function correctly and you may not be able to access certain parts or services of the Sites.

  1. CONDITIONS OFPROCESSING AND STORAGE OF PERSONAL INFORMATION DATA

The “processing” of personal information data includes in particular the use, storage, recording, transfer, adaptation, analysis, modification, declaration, sharing and destruction of personal information data as a function of what is necessary in regard to circumstances and legal requirements.

All personal information data collected are stored for a limited period as a function of the purpose of the processing and only for the duration described by the applicable legislation.

  1. LINKS TO WEBSITES NOT CONTROLLED BY BYPATH OR ITS AFFILIATES

The Sites may offer links to third-party Internet sites likely to interest you.

BYPATH has no control over the content of third-party sites nor over the practice of these third parties in the area of the protection of personal information data that they might collect.  Consequently, BYPATH declines any responsibility concerning the processing carried out by these third parties of personal information data.  It is your responsibility to inform yourself on the policies for the protection of personal information data of these third parties.

  1. TRANSFER OF PERSONAL INFORMATION DATA

In the event of access of the Sites from a country that is not a member of the European Union and in which the legislation related to the collection, use and transfer of data differs from that of the European Union, we draw your attention to the fact that by continuing to use the Sites, which are regulated by French law and corresponding conditions of use and this Policy, you are transferring your personal information data to the European Union and you consent to this transfer.

BYPATH may transfer your personal information data outside the European Union on conditions of ensuring, before transferring them, that the entities outside the European Union, which include companies affiliated with and subsidiaries of BYPATH, offer an adequate level of protection, incompliance with European legislation.

If BYPATH learns that a third party to which BYPATH has communicated personal information data for purposes laid out in Article 4 above, uses or divulges the personal information data without observing this Policy or in violation of the applicable legislation, BYPATH will take all reasonable measures to prevent or terminate the said usage or divulgence.

You also have the right to authorize or not authorize BYPATH to use your personal information data for a purpose other than those for which those data were initially collected.

BYPATH may also be led to transfer your personal information data to a third party if BYPATH deems that such a transfer is necessary for technical reasons (for example, for housing services by a third party) or to protect its legal interests (for example, in the event of the sale of assets to a third-party company, change in management or total or partial liquidation of BYPATH).

BYPATH may also share your personal information data with business partners when BYPATH and the business partner cosponsor an event or participate together in a marketing promotion in which you are involved.

BYPATH may communicate your personal information data if the law obliges it to do so or if BYPATH deems in good faith that such a divulgence is reasonably necessary in order to be in compliance with a legal procedure or to protect the rights, the assets or the personal safety of BYPATH, our customers or the public.

If the applicable legislation allows it, BYPATH may also share your personal information data with third parties in order to propose targeted marketing or advertising offers to you.

These transfers may take place on the Internet or by any other method judged appropriate by BYPATH in compliance with the applicable legislation.

  1. RIGHT OF ACCESS AND CORRECTION OF DATA

BYPATH has implemented mechanisms for the protection of personal information data adapted to ensure that personal information data is used in compliance with the purposes above and to ensure their accuracy and that they are up to date.

You have the right to access your personal information data.  In addition, you have the right to request the correction, the updating or the deletion of your personal information data (right of erasure, right of oblivion), the right to limit their processing (Art. 18 of EU Regulation 2016/679).  You also have the right to obtain the record of communication of your personal information data by BYPATH.

If you have an account, you can exercise your rights of access and of correction by accessing your account.  If not, you can exercise your rights of access and of correction by sending an email to the following address: technique@bypath.com

Based on the size of the request, BYPATH reserves the right to charge the requester a reasonable amount to cover the expenses linked to access, correction or deletion transactions.  BYPATH reserves the right to refuse access to personal information data in specific cases described by the applicable laws and regulations.

  1. SECURITY AND RECIPIENTS OF DATA

BYPATH takes steps to protect and secure the personal information data that you have chosen to communicate, in order to ensure their confidentiality and to prevent them from being deformed, damaged, destroyed or divulged to non-authorized third parties.

BYPATH has put in place physical, electronic and organizational measures to prevent any loss, inappropriate use, access or non-authorized publication, alteration or possible destruction of these personal information data.   In addition to these protection measures, BYPATH has integrated technologies specifically designed to protect the personal information data during their transfer.  However, in spite of BYPATH’s efforts to protect your personal information data, BYPATH cannot guarantee the infallibility of this protection because of the inevitable risks that may occur at the time of the transmission of personal information data.

All personal information data being confidential, their access is limited to collaborators, service providers and agents of BYPATH who need them within the framework of the fulfillment of their assignments.  All individuals having access to your personal information data are held to an obligation of confidentiality and expose themselves to disciplinary measures and/or other sanctions if they do not respect these obligations.

However, it is important that you exercise caution in order to prevent any non-authorized access to your personal information data.  You are responsible for the confidentiality of your password and the information appearing on your account.  Consequently, you must be sure to close your session in case of shared use of the same computer.

  1. RESOLUTION OF DISAGREEMENTS

Although BYPATH has taken reasonable measures to protect personal information data, no transmission or storage technology is totally infallible.

However, BYPATH is concerned with guaranteeing the protection of personal information data.  If you have reason to think that the security of your personal information data has been compromised or that they have been the subject of abusive use, you are invited to contact BYPATH at the following address: technique@bypath.com

BYPATH will investigate claims concerning the use and divulgence of personal information data and will attempt to resolve them in compliance with the principles appearing in this Policy.

Non-authorized access to personal information data or their improper use may constitute a crime in terms of local legislation.

  1. CONTACT

For any question concerning this Policy, to no longer receive information from BYPATH or for any request for correction, addition, updating or deleting of your personal information data, you may send an email to the following email address:  : technique@bypath.com

  1. EFFECTIVE DATE AND REVISIONS TO THE POLICY FOR THE PROTECTIONS OF PERSONAL INFORMATION DATA

This Policy can be updated based on the needs of BYPATH and on circumstances or if the law requires it.  We therefore invite you to regularly make yourself aware of updates.