Privacy Policy

Last updated: 09/05/2021

Within the framework of the use of the Trezy platform (hereinafter the "Platform"), Trezy is led to collect and process personal data of the user (hereinafter the "User") who acts on behalf of and under the responsibility of Trezy's customer company (hereinafter the "Customer").There are three types of User on the Platform, which are jointly referred to as "User": The "Owner" User, who creates his or her Owner User Account on the Platform on his or her own initiative;The "Administrator" User, who creates his or her Administrator User Account after receiving an invitation from the Owner User or an Administrator User on the Platform;The "Reader" User, who creates his or her Reader User Account after receiving an invitation from the Owner User or an Administrator User on the Platform.In order to preserve the User's trust, Trezy invites him to take note of its policy on the matter, which describes in particular the data collected, the use made of it and the rights available to the User, in compliance with Law n° 78-17 of 6 January 1978 as amended and EU Regulation 2016/679 of 27 April 2016.

1. WHO COLLECTS YOUR PERSONAL DATA?


The company responsible for processing the User's personal data is: TREZY, [corporate form, share capital, place of registration in the RCS, registration number in the RCS, address of the registered office]  (hereinafter referred to as "Trezy").
Trezy collects and processes a certain amount of personal data relating to the User according to the terms and conditions defined below.

2. WHAT DATA DO WE COLLECT AND WHY DO WE COLLECT IT?


The Platform allows Trezy to implement personal data processing under its own responsibility. The treatments implemented by Trezy are exhaustively listed in the present Privacy Policy.The Platform also allows the Customer, via an Owner User Account or an Administrator User Account, to enter into a direct contractual relationship with a partner of Trezy (hereafter the "Partner"), a third party and independent of the latter. Any processing of personal data of an Owner or Administrator User implemented by the Partner is carried out under the exclusive responsibility of this Partner and does not fall within the scope of the present privacy policy. As such, Trezy, third party to this contractual relationship, does not assume any responsibility for this processing.

Where applicable, the User concerned is invited to take note of the personal data processing carried out by these partners.

2.1 Creating a User Account - Authentication
The creation of at least one User Account (Owner User Account) is necessary for the Customer to benefit from the services offered by the Platform.The data collected are: name, professional email address, professional telephone number and password of the User. The User's password is however encrypted and therefore unreadable by Trezy.The User's name is collected in order to identify the holder of the User's Account.The email address and the password are used to authenticate the User and to connect to his User's Account. The email address and password are used to authenticate the User and to log in to the User's Account.The email address also allows the User to receive an email to reset the password if he/she forgets it.The email address and telephone number are collected to provide support and assistance to the User.

2.2 Monitoring of actions carried out on the Platform
In the context of the use of the Platform, Trezy collects data relating to the monitoring of actions carried out by the Owner User and by the Administrator User on the Platform. This data is collected in order to allow any User acting on behalf of the same Customer to be aware of the actions carried out by any other User acting on behalf of the same Customer.

2.3 Sending notifications to Users
Trezy uses the Users' professional email addresses in order to communicate to them by email: its newsletter; promotional offers; changes in its service offers.

3. WHAT IS THE PURPOSE OF PROCESSING YOUR DATA?

3.1 Creating a User Account and monitoring connections and actions
Trezy processes the personal data of the Users referred to in Articles 2.1 and 2.2 in execution of the contractual relationship between the Customer and Trezy.Indeed, the execution of this contractual relationship and the benefit of the services offered on the Platform requires the use of a User Account. The services offered in application of this contractual relationship also imply that any User of the same Customer can consult the actions carried out on the Platform by the other Users of this same Customer.Any User acts on behalf of, under the authority of and under the responsibility of the Client.

3.2 Sending notifications to Users
Trezy processes the User's personal data referred to in Article 2.3 in order to send notifications to the User insofar as the User does not express opposition. The User may at any time object to this processing, either from the "My account" section, then "Notifications", by deselecting all the notifications or by deselecting the type of notification he/she no longer wishes to receive, or by clicking on the link provided for this purpose in each email he/she receives from Trezy, or by sending a request to this effect to the following address: By email: gdpr@trezy.io Or by post: TREZY, 40 RUE ALEXANDRE DUMAS 75011 PARIS

The User's opposition is only valid for the future and does not call into question the lawfulness of the processing carried out prior to his opposition.

4. WHO DO WE SHARE YOUR DATA WITH?


Trezy is the recipient of all the data collected and processed in its capacity as data controller. Only duly authorised Trezy personnel may be informed of this data.The Users of the same Client are recipients of the identifying data and the follow-up of the actions carried out by the Owner User and the Administrator User of the same Client.Insofar as it is requested by an Owner User or Administrator User, the Partner is the recipient of the User Account data of the Owner User or Administrator concerned. The Partner implements, under its own responsibility, the processing that it considers necessary. The User concerned is invited to contact the Partner to find out more about the personal data processing carried out by the latter.Under no circumstances will Users' personal data be passed on to commercial or advertising actors.

5. WHO ARE OUR SUBCONTRACTORS?
Trezy uses subcontractors solely to ensure the maintenance and hosting of the Platform.The details of these subcontractors may be communicated to the User on request at the following address:

By email: gdpr@trezy.io
Or by post: TREZY, 40 RUE ALEXANDRE DUMAS 75011 PARIS


Trezy guarantees that its subcontractors are established within the European Union and present sufficient guarantees regarding the implementation of appropriate technical and organisational measures so that the processing meets the requirements of the EU Regulation 2016/679 and the Data Protection Act.Processors may themselves be allowed to subcontract all or part of their operations subject to strict compliance with the provisions of Article 28 of EU Regulation 2016/679 and this Privacy Policy.However, as the person in charge of the processing, Trezy remains the sole interlocutor of the User.

6. WHAT ARE YOUR RIGHTS?


The User has rights regarding the content and use of his/her personal data.Requests to exercise rights can only concern data processed under the responsibility of Trezy.
To exercise these rights, the User must write to Trezy, specifying in the subject of his letter or e-mail that it is a request for information or a claim relating to his personal data, and will provide proof of receipt of his request.

Any request in this regard should be sent to the following address: By e-mail: gdpr@trezy.io Or by post: TREZY, 40 RUE ALEXANDRE DUMAS 75011 PARIS


Trezy may require that the request be accompanied by a copy of the identity document of the person concerned in order to avoid any fraud and/or illicit access to his/her data.However, certain personal data may be exempted from such requests in certain circumstances, for example if they infringe the rights and freedoms of third parties. If an exception applies, Trezy will let the User know when responding to his request.Furthermore, if the exercise of the User's rights leads to the deletion of his data, the User is informed that this may result in the deletion of his User Account and that the contractual relationship between the Customer and Trezy may thus be called into question, totally or partially.

6.1 Rights of access, opposition, limitation, deletion and rectification of data

In accordance with the regulations in force, the User has the right:To access any of his personal data held by Trezy;To update any of his personal data that is not up to date or incorrect;To restrict the way in which Trezy processes his personal data;To ask Trezy to provide him with a copy of any of his personal data held by Trezy;To object to the use of his personal data for notification purposes (Article 2.3)

6.2 Right to data portability

The User has a right to the portability of his personal data, which must be returned to him by Trezy in a structured, commonly used and machine-readable format, if he so wishes.The User may only exercise this right to portability in respect of personal data that he or she has actively and consciously declared or that he or she has generated through his or her activity, to the exclusion of any other data that is calculated, derived or inferred from the data he or she has provided. Furthermore, only personal data that are processed automatically and collected on the basis of consent or the performance of a contract are affected by this right.Trezy reserves the right not to satisfy the User's request insofar as the data concerned by his request do not meet the abovementioned conditions.For all data not meeting the above criteria, the User may only exercise the rights mentioned in the previous clause (Article 6.1). The exercise of the right to portability does not preclude the exercise of any other rights the User may have.Trezy will not prevent the transmission of the data concerned by the right to portability to another data controller, either through the intermediary of the User, or directly when this is technically possible. In the event that the direct transmission of data to another data controller is not technically possible, Trezy will inform the User and propose an alternative solution.Trezy is not responsible for the processing that the User carries out on the data resulting from the right to portability once he has recovered them. Trezy is not responsible either for the processing carried out by the new data controller of the User's data following a request that he will have made in this sense.

6.3 Right to formulate advance directives
In accordance with the regulations in force, the User may formulate advance directives on the use of his/her data after his/her death (e.g. retention, deletion, disclosure). The User may modify or withdraw his instructions at any time.

6.4 Right to lodge a complaint with the CNIL
The User is informed of his right to lodge a complaint with the competent control authority (the Cnil in France: www.cnil.fr), in the event of non-compliance with legal and regulatory provisions by Trezy or its subcontractors in the context of the management of his personal data.

7. HOW LONG DO WE KEEP YOUR DATA?

7.1

The data relating to a User Account (Article 2.1) are kept by Trezy for the duration of the contractual relationship between Trezy and the Customer insofar as the User Administrator is deemed to be the representative of the Customer. As the User Owner is deemed to have full power of representation of the Customer, Trezy archives these personal data in a database separate from the operating database for a period of five (5) years from the end of the contractual relationship between Trezy and the Customer, which corresponds to the legal period of prescription in contractual matters.

7.2 The data relating to the creation of an Administrator User Account and a Reader User Account (Article 2.1) are kept by Trezy for the time the Administrator User or Reader User has a User Account.The data relating to an Administrator User Account and a Reader User Account are immediately deleted:At the end of the contractual relationship between the Customer and Trezy; or For an Administrator User Account: in case of a request for deletion of the Administrator User Account by the Owner User or by an Administrator User;For a Reader User Account: in case of a request for deletion of the Reader User Account by the Owner User or by an Administrator User.Furthermore, an Administrator User Account or a Reader User Account that has not been used for a period of one (1) year is considered to be inactive. Any connection to the User Account will start this one (1) year period again. At the end of this period, the data relating to an inactive account is deleted. One (1) month before this deletion, Trezy informs the User concerned by email indicating the modalities allowing him to indicate his contrary will. Trezy shall at the same time inform the Owner User.

7.3 The data relating to the follow-up of actions carried out on the Platform (Article 2.2) are kept for the duration of the contractual relationship between the Customer and Trezy in order to allow the Customer, whoever the User may be, to benefit from a follow-up of these actions throughout the contractual relationship. Consequently, the data of the User concerned is kept throughout this period, regardless of whether the User Account concerned has been deleted during this period.Trezy will be able to keep these data longer for statistical purposes as long as they are totally anonymised, making it impossible to identify the person from whom they originated.

7.4 Personal data used in the context of notifications sent to the User (Article 2.3) are kept for a period of three (3) years from their collection or from the last contact from the User (for example, a request for documentation or a click on a hypertext link contained in an e-mail; however, the opening of an e-mail cannot be considered as a contact from the User) At the end of this period of three (3) years, Trezy may contact the User concerned again to find out whether he wishes to continue to be contacted by Trezy. In the absence of a positive and explicit response from the User, all notifications to the User will cease. However, if the User still has a User Account, the data is kept according to the methods defined in Article 7.1 or 7.2.

7.5 In the event of exercising the right of access or rectification, data relating to identity documents shall be kept for the period provided for in Article 9 of the Code of Criminal Procedure, i.e. one (1) year.If the right to object is exercised, data relating to identity documents may be archived for the limitation period provided for in Article 8 of the Code of Criminal Procedure, i.e. three (3) years.In the event of the exercise of the right to object to being requested by Trezy, the information enabling the right to object to be taken into account is kept for three (3) years as from the exercise of the right to object. This data may not be used for any other purpose than the management of the right of opposition and only the data necessary to take into account the right of opposition are kept (in particular, the e-mail address).

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