What is the purpose of this policy?

We attach great importance to the protection and confidentiality of your personal data, which we consider to be a guarantee of our reliability and trustworthiness.
Our data privacy policy reflects our commitment to complying with applicable data protection regulations, in particular the General Data Protection Regulation (GDPR).
In particular, the privacy policy aims to inform you about how and why we process your data in the context of the services we provide.

Who does this policy apply to?

The policy applies to you regardless of your place of residence, whether you are a customer of Open Modal, a potential customer (‘prospect’) or simply a visitor to the www.openmodal.com website.
If you are under 18 years of age, you are not authorised to use our services without the prior consent of your parents or the person with parental authority. If you believe that we may hold information about one of your children under the age of 18 without your consent, you can request that we delete it by contacting us at contact@openmodal.com.

Why do we process your data and on what basis?

As part of the services we offer, we are required to process your personal data for the following reasons and on the following basis:

• So that you can benefit from our services (e.g. creation of a customer account, organisation of appointments, etc.) and so that we can respond to your requests (e.g. requests for information, complaints, etc.) on the basis of our general terms and conditions of sale, our general terms and conditions of use, and our legitimate interest in providing you with the best possible service.
• So that you can stay informed of our latest promotional offers and events by email and telephone, based on our legitimate interest in retaining our customers and on your consent, if you are not yet one of our customers.
• To enable you to follow us on social media based on the terms and conditions of use of the platform used (e.g. Facebook, LinkedIn, etc.) and our legitimate interest in having a dedicated page on social media.
• To guarantee and enhance the security and quality of our services on a daily basis (e.g. statistics, data security, etc.) based on our legal obligations, our general terms and conditions of sale and our legitimate interest in ensuring the proper functioning of our services.
• Finally, we may also install cookies on your device. For more information on the use of cookies, please see our Cookie Policy.

We undertake to process your data only for the reasons described above. However, when you voluntarily publish content on the pages we edit on social networks, you acknowledge that you are entirely responsible for any personal information you may transmit, regardless of the nature and origin of the information provided.

What data do we process and for how long?

• If you would like more details about retention periods, you can contact us at: contact@openmodal.com.
• Professional identification data and contact details (e.g. surname, first name, professional email address, professional address, etc.) are kept for the entire duration of the service provision, plus the legal limitation periods, which are generally five years.
• When there is confusion between the name of your organisation and your personal name (e.g. self-employed, micro-business, etc.), economic and financial data (e.g. bank account number, verification code, etc.) retained for the duration necessary for the transaction and for the management of invoicing and payments, plus the legal limitation periods, which are generally 5 to 10 years.
• Data for commercial and marketing purposes (e.g. email address, etc.) is kept for a maximum of 3 years from the last contact we had with you.
• Connection data (e.g. logs, IP address, etc.) is kept for a period of 1 year.

Upon expiry of the retention periods summarised above, we delete all your personal data in order to guarantee your privacy for years to come.
The deletion of your personal data is irreversible and we will no longer be able to provide it to you after this period. At most, we can only retain anonymous data for statistical purposes.
Please also note that in the event of a dispute, we are obliged to retain all data concerning you for the entire duration of the case, even after the expiry of the retention periods described above.

What rights do you have to control the use of your data?

The applicable data protection regulations grant you specific rights that you can exercise at any time and free of charge in order to control how we use your data.

• Right to access and copy your personal data, provided that this request does not conflict with business secrecy, confidentiality, or correspondence secrecy.
• Right to rectify personal data that is incorrect, obsolete, or incomplete.
• Right to object to the processing of your personal data for commercial prospecting purposes.
• Right to request the erasure (‘right to be forgotten’) of your personal data that is not essential to the proper functioning of our services.
• Right to restrict your personal data, which allows you to photograph the use of your data in the event of a dispute over the legitimacy of processing.
• Right to data portability, which allows you to retrieve some of your personal data in order to store it or easily transfer it from one information system to another.
• Right to give instructions on what should happen to your data in the event of your death, either through you, a trusted third party or a beneficiary.

For a request to be considered, it must be made directly by you at contact@openmodal.com. Any request not made in this manner cannot be processed.
We will respond to your request as soon as possible, within two months of receipt, in the event that the request is technically complex or if we receive numerous requests at the same time.
Please note that we may refuse to respond to any excessive or unfounded requests, particularly if they are repetitive in nature.

Who can access your data?

We only share your data with persons duly authorised to use it for the purpose of providing our services. These may include our staff responsible for providing the service, accounting, marketing or even the security of our premises.
We may also share your data with public authorities, external advisors and practitioners, and service providers.

How do we protect your data?

We implement all the technical and organisational measures required to guarantee the security of your data on a daily basis and, in particular, to combat any risk of unauthorised destruction, loss, alteration or disclosure of your data.
For example, our teams’ passwords must be complex and changed frequently, and their computers are equipped with the latest antivirus software and firewalls. In addition, your data is regularly backed up and encrypted to enhance its security on a daily basis.

Can your data be transferred outside the European Union?

Unless it is strictly necessary and in exceptional circumstances, we never transfer your data outside the European Union and your data is always hosted on European soil. In addition, we do our utmost to only recruit service providers who host your data within the European Union.
In the event that our service providers are nevertheless required to transfer your personal data outside the European Union, we take great care to ensure that they implement the appropriate safeguards to ensure the confidentiality and protection of your data.

Who can you contact for more information?

Our Data Protection Officer (DPO) is always available to explain in more detail how we process your data and to answer any questions you may have on the subject at contact@openmodal.com.

How can you contact the CNIL?

You can contact the French data protection supervisory authority (the ‘Commission nationale de l’informatique et des libertés’ or ‘CNIL’) at any time at the following address: Service des plaintes de la CNIL, 3 place de Fontenoy – TSA 80751, 75334 Paris Cedex 07 or by telephone on 01.53.73.22.22.

Can the policy be changed?

We may change our privacy policy at any time to adapt it to new legal requirements and to new processing methods that we may implement in the future. You will of course be informed of any changes to this policy.