Cedille, a venture of Coteries Ltd (hereinafter also referred to as "we", "us" or "her") places the protection of the privacy of its Users at the centre of its preoccupations. In this context, we are aware that the increasing use of computer tools and information systems requires the implementation of technical and organisational measures to effectively protect your Personal Data and your private sphere. We want you to feel safe using our service.
The Personal Data that you communicate to us when you use our Site or Services is processed in accordance with the Swiss Federal Data Protection Act of 19 June 1992 (RS 235.1; LPD).
- User Account or Account: the personal account created on the Site by a registered User and allowing access to the Services ;
- General conditions of use: the document allowing to know the conditions of use of Cedille.ai ;
- Content: the software, photos, videos, texts, graphics, music, sounds, creative suggestions, messages, comments, feedback, reactions, ideas, notes, drawings, articles and other documents (non-exhaustive list) that the Site or the Services may contain ;
- Personal Data or Data: all information that relates to an identified or identifiable person ;
- Coteries: the company operating the Site and Services ;
- We: a term also designating Cedille.ai ;
- Partners: companies with which we have a partnership in order to offer our Services and/or propose their Services through our Site and/or advertising partnerships and/or in any other way.
- Stakeholders: Cedille.ai and Users ;
- User profile: the User Account interface allowing a Registered User to add, modify or correct his or her information ;
- Services: all the services and functionalities (tools, applications and features) made available by the Site after registration ;
- Site: the website Cedille.ai and its derivatives : http(s)://(www.)INSERT_WEBSITE_URL, etc. ;
- Partner sites: websites belonging to our Partners ;
- Treatment/processing: any operation relating to personal data – whatever the means and processes used – in particular the collection, conservation, use, modification, communication, archiving or destruction of data ;
- User: any person accessing and browsing the Site ;
- Registered user: any person accessing and browsing the Site and having a personalised User Account enabling him/her to access all of the Services ;
- You: a term referring to any User or Registered User;
- The Site and its Services are not intended for persons under 18 years of age. We do not knowingly collect Personal Data from minors. If we learn that we have collected Personal Information from a minor, we will delete it. If you believe that we may have collected Personal Information from a minor, please contact us using the following email address: firstname.lastname@example.org. This exclusion does not apply to Data transmitted by a person over the age of 18 giving information about a minor of whom he or she is the legal representative as well as any Data transmitted by a person of full age.
3. ACCEPTANCE AND MODIFICATION
The current version can be found on the Site at any time.
4. THE DATA WE COLLECT ABOUT YOU
- Personal Data means any information about a person from which that person can be identified. It does not include data for which the identity has been removed (anonymised data).
- We may therefore collect, use, store and transfer different types of Personal Data about you which we have grouped together as follows :
◦Identity data, including first name, surname, username or similar identifier and date of birth.
◦Contact data, which includes email, telephone numbers and postal address.
◦Technical Data, which includes Internet Protocol (IP) address, cookie ID, device ID, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and any other technology on the devices you use to access the Site.
◦Profile data, which includes the status of your User Profile, the date and time you last logged on and the date and time you registered for the Service.
◦Usage data, which includes information on how you use the Site and/or the Services to offer you personalised solutions.
- We do not collect any category of Sensitive Personal Data about you (including information on your ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information and genetic and biometric data). We also do not collect information on criminal convictions and infractions.
5. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect your Personal Data.
Data collected by Cedille.ai
- Direct interactions. This includes the Personal Data that you provide to us when, in particular, you create a User Account, use our Services, give your opinion, transmit documents or information via our Site.
- Log file information. Log file information is automatically reported by your browser each time you access a web page. When you use our Site and/or Services, our servers automatically record certain log file information. These server logs may collect technical data such as your IP address, browser type and information about the number of clicks and how you interact with links on the Site, Partner Sites, domain names, landing pages, pages viewed and other similar information.
Data collected by third parties
- Automated technologies or interactions. When you interact with us, our Site and/or Services, we may automatically collect technical data about your equipment, browsing actions and habits. We collect this Personal Data using cookies, server logs and other similar technologies described below.
- Third parties or publicly available sources. We may receive Personal Information about you from a variety of third party services, as described below.
- Technical data of the following parts :
◦providers of analytical services with headquarters outside the EU.
◦Identity and contact data from connections or connections of third parties (e.g. Facebook Connect, Google or Twitter by "following", " liking" or linking your account to the Site).
- You can view a list of the external services we use and customise your preferences by clicking on the link at the top of the page.
6. HOW WE USE YOUR PERSONAL DATA (PURPOSES OF PROCESSING)
Data collected by Cedille.ai
We process your Personal Data for the following purposes:
- continue to improve Services ;
- allow the management of the Site and Services and provide the proposed Services ;
- continue to improve the Site ;
- customer relationship management ;
- ensure the security of the Site, detect and prevent abuse ;
- suggesting new Services to you and for marketing purposes ;
- proceed to the deletion or correction of your Personal Data or that which you have transmitted to us ;
- send you automatic email reminders during the process of using the WebApp and/or the Site. These emails include reminders when a task has not been completed, when the Registered User has not logged in to the Site for a number of days. These emails are an integral part of the Services and are not treated as a newsletter. You can, however, unsubscribe from these emails by clicking on the link contained in the email ;
- offer you competitions by email, post or SMS, with the possibility of unsubscribing at any time ;
- send you newsletters and other newsletters, with your consent, for marketing or other purposes, by email or SMS.
In case of legal obligation, we work together with government and judicial representatives to apply and comply with the law in force. In this case, the Personal Data may be transmitted to government or judicial representatives if the controller deems it necessary to comply with its legal obligations to respond to legal actions or lawsuits (including, in particular, summons to appear with a fine), to defend one's rights, to protect public security or the safety of any person, to prevent or impede any activity which may be considered or be likely to be considered unlawful or liable to result in criminal proceedings.
7. COOKIES AND TOOLS USED
Disabling cookies may mean that you cannot use all the functions of our Site. If you decide not to install cookies on your computer while browsing our Site, you understand that your experience may be limited and that you may not have access to all functions and pages.
The cookies we use cannot be used to discover your identity.
The following list describes the cookies we may use and how they are used :
Cookies required for operation
These cookies are strictly necessary to provide you with the services available on a website and to use some of its features, such as access to secure areas. As these cookies are strictly necessary for the proper functioning of a site, they are not subject to consent. You can block or remove them by changing your browser settings, but this will affect your experience of how the site works.
- Remember if you have visited this site before and remember your preferences.
- Remember if you have closed the "pop-ups" (alert messages) for 30 days. This will help us to avoid spamming our users (sending email unintentionally). Without cookies, we would display pop-ups every time a page is reloaded.
- Stay logged on to the site when you leave it and then come back.
Cookies for analysis, performance improvement and targeting
- Facebook and Facebook Pixel : Facebook collects information that helps us understand how you interact with our Site and better understand our audience. We also use it to make our Content and/or Services known to a qualified audience. These cookies (valid for 12 months) collect IP addresses and track your online activities over time, on different sites or other online services, automatically collecting information relating to navigation on the Site. These technologies can "recognise" you on the different devices you use, such as a desktop or mobile computer, your smartphone or tablet. Third parties (advertisers) use this information to provide advertisements about products and services that are relevant to your interests. These ads can appear on other sites or mobile applications from any of your devices. Please note that at no time do we have access to the information collected by these cookies, but we may use it globally, via Facebook's advertising platform, to offer content or services similar and/or complementary to those you have consulted on this site. This process also allows us to manage and monitor the effectiveness of our marketing efforts. Facebook Pixel also allows us to measure the impact of our publications on Facebook as well as for advertising purposes: audience creation and targeting of visitors to the Site (retargeting). To learn more about the use of Facebook cookies, please visit the page https://www.facebook.com/policies/cookies/. By default and in accordance with the law, these cookies are not activated on our Site without your consent.
- Google Ads : Google Ads is Google's advertising platform. We use it to advertise our Content and/or Services to a qualified audience. These cookies (valid for 12 months) collect IP addresses and track your online activities over time, on different sites or other online services, automatically collecting information relating to navigation on the Site. These technologies can "recognise" you on the different devices you use, such as a desktop or mobile computer, your smartphone or tablet. Third parties (advertisers) use this information to provide advertisements about products and services tailored to your interests. These ads may appear on other sites or mobile applications from any of your devices. Please note that we do not at any time have access to the information collected by these cookies, but that we can use this information as a whole, via Google's advertising platform, to offer content or services similar and/or complementary to those you have consulted on this website. This process also allows us to manage and monitor the effectiveness of our marketing efforts. For more information on the use of Google's cookies, please visit the page https://policies.google.com/technologies/types. By default and in accordance with the law, these cookies are not activated on our Site without your consent.
- Google Optimize : Google Optimize is a platform for testing and experimentation. We use it in particular to test page variants. Randomly, 50% of the visitors will see variant A and the other half will see variant B. After a certain number of visits, we could understand which of the pages works best and keep only the best performing one. This allows us to improve our Users' experience on the Site and to learn more about our audience. Google Optimize uses analytics cookies to "identify" visitors of different variants in order to count them and enable us to compare and ensure that a returning visitor will see the same page. For more information on the use of Google's cookies, please visit the page https://policies.google.com/technologies/types. By default and in accordance with the law, these cookies are not activated on our Site without your consent.
8. YOUR CHOICES REGARDING THE COLLECTION OF YOUR PERSONAL INFORMATION
- View and change your Account Information. Each Registered User can consult his or her Personal Identity, Contact and Profile Data. Each Registered User may view, update or correct his or her Personal Identity, Contact and Profile Data by editing his or her User Profile for the Data contained therein, which is located on his or her User Account. For Data that does not appear in the User Profile, in order to update or correct said Data, the Registered User must send us an email to the following address: email@example.com.
- You can also completely delete (deactivate) your User Account, at any time, by sending a request to the following email address: firstname.lastname@example.org.
- Unsubscribe from newsletters and any promotional emails. You may unsubscribe from our newsletters and promotional emails at any time by using the unsubscribe mechanism contained in those emails (also referred to as "unsubscribing"). Please note that unsubscribing from emails will unsubscribe you from the newsletter from Cedille.ai. However, you will always receive the transactional emails necessary for the operation of the Services of Cedille.ai, such as e-mails confirming that you have created a new User Account, e-mails helping you to reset your password, e-mail reminders.
- We will only use your Personal Data for the purposes for which we have collected it, unless we reasonably believe that we need to use it for another reason and that this reason is consistent with the original purpose. If we change the purpose, we will notify you of the new purpose by email. If you would like an explanation of how processing for the new purpose is compatible with the original purpose, please contact us at : email@example.com.
9. DATA CONTROLLER
By "Data controller" means the private person who decides on the purpose and content of a file containing Personal Data.
The data controller is Coteries
10. DATA RETENTION PERIOD
Unless the User requests its deletion, we will keep your Personal Data until 5 years after your last use of the Services, subject to a legal obligation (accounting data, for example) or an overriding interest of Coteries to keep Personal Data (in order to be able to defend our rights in the event of a dispute, for example).
The retention of this Data is also intended to facilitate your future use of the Services (during a new move for example).
In the aforementioned cases allowing us to retain Personal Data for a period longer than 5 years after your last use of the Services, the retention period depends on legal requirements and/or the statute of limitations of possible legal actions.
11. DATA STORAGE
The Personal Data processed by Coteries are stored on a Supabase server in Frankfurt.
We undertake to take adequate technical and organisational measures to prevent undue access, disclosure, modification, leakage or unauthorised destruction of Personal Data collected by the Site and/or the Services. Technologies and security measures, rules and other procedures, firewalls and password protection measures that comply with industry standards are used to protect Personal Data. You are responsible for maintaining the secrecy of your password and account information and for controlling access to your email communications with us. However, please be aware that the use of the Internet is by definition not secure, and that it involves certain risks to Personal Data. When you browse the Internet, it is your responsibility not to compromise the security of Personal Data concerning yourself or third parties, by exercising due diligence to avoid encouraging malicious acts and/or malware such as Trojan horses, computer viruses or worms. Finally, we are not responsible for the functionality or security measures of third parties. In the event that the Personal Data has been improperly consulted by an unauthorised person, or if there is reason to believe that it has been consulted, we undertake to inform you without delay by email.
13. RIGHT TO INFORMATION, RECTIFICATION; DELETION AND LIMITATION OF PROCESSING
You have the possibility, free of charge and at any time, to :
- ask us if we are processing Personal Data about you ;
- access the Personal Data we process about you (i.e. right of access), subject to our overriding interest in restricting access to certain Personal Data ;
- ask us to modify or update erroneous Personal Data, this request for modification has no retroactive effect ;
- request the deletion of your Personal Data processed by us, subject to Personal Data that we are legally obliged to retain (e.g. accounting data) or that we have an overriding interest in retaining (e.g. in order to be able to defend our rights in the event of a dispute). This deletion request has no retroactive effect.
To make use of any of these rights, a written request must be sent to the following e-mail address: firstname.lastname@example.org. In addition, you will be asked to provide proof of your identity; this Data is used for identification purposes only and will not be processed for other purposes. This process is free of charge.
We respond to requests for access or rectification within 30 days at the most from receipt of the written request.
Finally, you can inform us of your instructions (destruction or transfer to a third party, cf. clause 14) concerning your Personal Data that we may hold in the event of your death.
14. ACCESS REQUEST AND DATA PORTABILITY
In the context of an access request, we undertake to deliver the digitised Personal Data to the person concerned in a customary electronic format (i.e. Data portability). If Personal Data is not digitised, we may, at our discretion, deliver the originals, copies or digitised copies (in a customary electronic format). The data subject may request that his or her Personal Data be provided to a third party of his or her choice. We reserve the right to require written consent from the data subject covering the terms and conditions of the surrender (or transfer) of his or her Personal Data, including the name and contact details of the third party to whom we are required to surrender it.
15. AMICABLE CONFLICT RESOLUTION CLAUSE
16. APPLICABLE LAW AND PLACE OF JURISDICTION