Personal data protection policy

Version of 04.05.2022

PREAMBLE

The Bric Resilience Web Platform Application (hereinafter the "  Application  ") allows you to creates communities of resilience in your geographic area. 

The Application is developed and operated by OGOXI, a simplified joint-stock company, registered with the TARBES Trade and Companies Register under number 808 018 048 and whose head office is located at PIC PYRENEES INNOVATION (65150 – SAINT LAURENT DE NESTE) ( hereinafter “  OGOXI  ”).

When browsing the Application, OGOXI will collect and process the Personal Data of its Users.

Particularly concerned about the protection of the privacy of its Users, OGOXI intends to provide them with precise information on all of its Processing. It is in this capacity that it undertakes to respect the following two (2) essential principles:

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What is personal data?

“Personal data” refers to any information concerning and enabling a User to be identified directly or indirectly. The surname and first name or a photo can, for example, allow direct identification; an e-mail address may allow indirect identification.

What is a treatment?

The word "Processing" means any operation, or set of operations, relating to personal data, regardless of the process used (collection, recording, organization, storage, adaptation, modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, reconciliation or interconnection, blocking, erasure or destruction, etc.).

This Privacy Policy is intended for Users of the Application accessible directly online at the address https://platform.bric-network.com (hereinafter the "Site") or, if available, downloadable on mobile phone or tablet, in application of the Data Protection Act of January 6, 1978 (hereinafter "  LIL law  ") as amended and the General Data Protection Regulation (EU) of April 27, 2016 (hereinafter "  GDPR  ").

ARTICLE 1. THE PROCESSING RESPONSIBLE

OGOXI, a simplified joint-stock company, registered with the TARBES Trade and Companies Register under number 808 018 048 and whose head office is located at PIC PYRENEES INNOVATION (65150 – SAINT LAURENT DE NESTE), will have the status of data controller for the treatments detailed below. 

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Legal reminder  :

The data controller is, within the meaning of the Data Protection Act and the GDPR, the person who determines the means and purposes of the processing. Where two or more controllers jointly determine the purposes and means of processing, they are joint controllers (or co-controllers).

The processor is a person processing personal data on behalf of the controller, he acts under the authority of the controller and on his instructions.

ARTICLE 2. CONTACT DETAILS FOR DATA PROTECTION

To respond to all requests, including the exercise of rights, relating to Users' Personal Data, Users are invited to contact OGOXI:

• contact@ogoxe.com
• PIC PYRENEES INNOVATION (65150 – SAINT LAURENT DE NESTE).

ARTICLE 3. SOME DEFINITIONS

• "Application": means the application published by OGOXI accessible directly online or, if available, downloadable on a phone or tablet.

• “Client”: refers to a natural or legal person, public or private actor, having concluded a service contract with OGOXE in order to benefit from specific services dedicated to professionals. 

• “Account”: refers to the interface hosted in the Application in which the data of a Designated User is grouped and allowing him to access the various functionalities of the Application. Access to the Account is done using Identifiers.

• “General Conditions of Use  ”: designates the contractual conditions intended to govern the use of the Application by the User. The General Conditions of Use are accessible within the dedicated tab of the Application.

• “  Personal Data  ”: means the personal data that is the subject of Processing under this Privacy Policy as defined in Article 4 (1) of the GDPR.

• “Functionalities”: refers to all the functionalities accessible on the Application and provided to Users by OGOXI through the Application and in particular access to data on environmental risks.

• “Identifiers  ”: refers to a User's login (e-mail address or pseudonym) and password, necessary to access his Account.

• “  Offer  ”: refers to the category of Users (Basic, Advanced or Professional) to which the User belongs and the Features from which he benefits according to the option chosen.

• “  Parties  ”: in the plural, designates together OGOXI and the User. In the singular, designates only one of the two Parties.

• “  Site  ”: refers to the OGOXI website accessible from the link: https://platform.bric-network.com .

• "  Processing/Processing  ": means any of the operations referred to in Article 4 (2) of the GDPR, carried out on Personal Data in the context of the execution of this Privacy Policy.
•  “  User  ”: refers to any natural person who accesses the Application and benefits from the Services offered. Users can be: 

• “  Basic User  ”: refers to any User who accesses the Application on a non-professional and free basis.
• "  Advanced User  ": refers to any User who accesses the Application on a non-professional basis but as part of a "Family" Subscription (paid). As such, it benefits from Advanced Features. 
• “  Professional User  ”: designates any User using the Application as staff, employee or representative of a Client.

ARTICLE 4. COLLECTION AND ORIGIN OF DATA

As part of the navigation on the Application and for the provision of the Functions, OGOXI collects and processes Personal Data relating to Users.

As part of compliance with the principles of data protection by design and data protection by default, OGOXI ensures that the necessary consents have been obtained when registering Users and using certain Features.

In all cases, all Users are informed of the purposes for which their Personal Data is collected by OGOXI via, in particular, the various online collection forms or, where applicable, via https://www.ogoxe.com/cookies

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The Personal Data of Users collected by OGOXI is Processed in accordance with the purposes provided for during the collection in compliance with the Referential relating to the processing of personal data implemented for the purposes of managing commercial activities published by the CNIL.

When necessary, OGOXI undertakes, depending on the case, to obtain the consent of Users and/or to allow them to oppose the Processing of their Personal Data for certain purposes, such as, for example, to deposit third-party cookies on their devices (mobile phone, computer, tablet) for the purpose of measuring the Application's audience and/or to send information (newsletters, news, etc.) relating to the Application and/or related topics .

ARTICLE 5. THE PURPOSES AND LEGAL BASIS OF THE PROCESSING IMPLEMENTED

When the legal basis used for the Processing operations that OGOXI carries out is based on the pursuit of a legitimate interest, any User has the possibility, as a data subject, on simple request, to obtain additional information relating to the in balance of interest.

In any case, OGOXI only collects the Personal Data necessary for the explicit and determined purposes below:

1.  

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Processing Details  :

- Processing requests for information;

-Answers to requests for information;

- Follow-up of requests;

- Informative tracking

Legal basis  : Execution of the contract or execution of pre-contractual measures

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Processing Details  :

- The registration of Users or Customers;

-Account management;

- Management of contractual relations and contracts.

Legal basis  : Execution of a contract or execution of pre-contractual measures.

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Processing Details  :

• •  : Each User can manage an address book to determine the recipients of notifications via the Application. To add a User to his address book, a User must know the identification number of this User on the Application.

Legal bases  :

- Execution of a contract or execution of pre-contractual measures;

-The User's consent when required.

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Processing Details  :

- Payment;

- Invoicing follow-up;

- Maintaining accounting records and legal documents.

Legal basis  : Legal obligation: article L. 102 B and following of the Book of tax procedures.

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Processing Details  :

- Management of newsletter subscriptions

- Sending commercial offers.  

Legal bases  :

– Legitimate interest of OGOXI;  

– The consent of the User when it is required

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Processing Details  :

Ensure the proper functioning and continuous improvement of the Application and its Functions.

Legal bases  :

– OGOXI's legitimate interest in guaranteeing the best level of operation and quality of the Application, in particular through visit statistics;

– The User's consent when required.

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Processing Details  :

This Processing covers all the operations necessary to follow up on requests for rights sent to OGOXI (qualification of the request, investigations, performance of specific technical operations, etc.). It only concerns cases where OGOXI acts as a data controller.

Legal basis  : Legal obligation arising from the GDPR and the LIL.

ARTICLE 6. CATEGORIES OF DATA COLLECTED

The mandatory or optional nature of the personal data collected and the possible consequences of a lack of response are indicated during the various contacts with the persons concerned.

Any User can consult the details of the Personal Data that OGOXI is likely to have concerning him below.

Details of processed data

NB: the detail of the information provided below is not intended to be exhaustive and is above all intended to inform Users of the categories of data that OGOXI is likely to Process.

For the management of information requests  :

- Last name First Name ;

– Company name if a legal entity;

- E-mail address ;

– Telephone number

For registration on the Application:

- Last name First Name ;

– Connecting customer if Professional User; 

– Pseudonym;

- E-mail address ;

- Password.

For the management and monitoring of accounts and offers :

– Last name, first name of the User or of the contact for Customers;

– Email address and/or pseudonym;

– Mailing / billing address if applicable;

– Current offer.

For the use of the Features and the Application:

– “Contact” functionality  : name, e-mail, telephone, User identification number (specific OGOXI identifier) ​​on the Application and group to which the contact belongs.

For payment management  :

-Credit card number, expiry date, security code;

-Account number, RIB;

-Data necessary for the establishment of invoices.

For sending news and commercial offers  :

-Last name First Name ;

-E-mail address ;

– Current offer.

For the proper functioning and continuous improvement of the Application;

Data collected via cookies and other tracers present on our Site or the Application; for more details, see our cookie management charter https://www.ogoxe.com/cookies;

Technical or scientific data provided by Users or their devices connected to the Application, where applicable and when traceable to a User or Client.

For the management of requests for rights arising from the GDPR and the amended Data Protection Act  :

-Last name First Name ;

-E-mail address ;

– If necessary, a copy of the identity card.

ARTICLE 7. RECIPIENTS OF PERSONAL DATA

Only the authorized and determined persons mentioned below may have access to User data.

Personal Data is not communicated, exchanged, sold or rented to any person other than those mentioned above.

ARTICLE 8. CONSERVATION OF PERSONAL DATA

OGOXI undertakes that the Personal Data collected will be kept in a form allowing the identification of Users for a period that does not exceed the period necessary for the purposes for which this Personal Data is collected and Processed.

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Management of registrations and requests for information:

The data is kept for the time necessary to process the request and then for three (3) years from the last contact with OGOXI.

Management and monitoring of accounts and contracts  (management and monitoring of Offers, provision of the Application):

The data is kept throughout the contractual relationship and then archived. They are then stored for five (5) years for evidentiary purposes in accordance with the legal and regulatory obligations to which OGOXI is subject. The accounting documents are also kept for ten (10) years.

Payment management  :

For payments by credit card, in accordance with Article L.133-24 of the Monetary and Financial Code, this data may be kept for the purpose of proof in the event of any dispute of the transaction or complaint, in intermediate archives, during a period of thirteen (13) months following the debit date (duration extended to fifteen (15) months for deferred debit payment cards).

The data relating to the PAN and visual cryptogram are not stored and the data relating to the expiry date are deleted when its expiry date is reached.

Invoices and accounting data issued are kept for ten (10) years from their issue.

Sending news and commercial offers  :

The data is kept until the User unsubscribes via the link provided for this purpose.

The proper functioning and improvement of the Application

Cookies and other commercial tracers may be placed on the User's terminal for a maximum period of thirteen (13) months. Beyond this period, the raw traffic data associated with an identifier is either deleted or anonymized.

The technical and/or scientific data likely to characterize Personal Data are anonymized before being integrated into the Solution and made accessible to third parties.

For the management of requests for rights arising from the GDPR and the amended Data Protection Act  :

Data relating to the management of rights requests are kept for the duration necessary to process the request. They are then archived for the applicable criminal limitation period in intermediate archiving.

In the event of communication of a copy of an identity document, it is deleted after the processing of the request.  

ARTICLE 9. THE RIGHTS OF PERSONS CONCERNED

In accordance with the Data Protection Act and the GDPR, any User has the following rights   ( find out more ) :

Right of access  ( article 15 GDPR ) , rectification  ( article 16 GDPR ) , update;

Right to erasure of Personal Data  ( article 17 GDPR ) , when they are inaccurate, incomplete, ambiguous, outdated, or whose collection, use, communication or storage is prohibited

Right to withdraw consent at any time ( article 7-3 GDPR )

Right to limit the processing of personal data  ( article 18 GDPR )

Right to the portability of the Personal Data provided, when the data is subject to automated Processing based on consent or a contract  ( article 20 GDPR )

Right to object to the Processing of Personal Data ( Article 21 GDPR )

Right to lodge a complaint with the CNIL ( article 77 of the GDPR )

· Right to define the fate of the data after death and to choose whether or not OGOXI communicates the data to a previously designated third party  ( article 85 LIL ) . In the event of death and in the absence of instructions, OGOXI undertakes to destroy the data, unless their retention proves necessary for probative purposes or to meet a legal obligation.

These rights can be exercised by simple request, by e-mail to contact@ogoxe.com or by post to OGOXI – PIC PYRENEES INNOVATION 65150 – SAINT LAURENT DE NESTE.

For more information on the rights of data subjects, Users are invited to consult the website of the Commission Nationale de l'Informatique et des Libertés, accessible at the following address: http://cnil.fr .

ARTICLE 10. CONNECTION DATA AND COOKIES

OGOXI makes use on its Site and on the Application of connection data (date, time, Internet address, protocol of the visitor's computer or telephone, page consulted) and cookies (small files saved on the computer, the tablet or the User's telephone) allowing him to be identified, to memorize the consultations, and to benefit from measurements and statistics of audience of the Application, in particular relating to the pages consulted and the Functions used.

Any User may consent, refuse or choose the type of cookies which he accepts to be deposited on his computer, tablet and smartphone terminals.

A cookie is a text file deposited and read in particular when browsing a website or an application, regardless of the type of terminal equipment used.

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The cookie allows the recording of certain information on navigation and online behavior, thus allowing OGOXI to facilitate and improve the User's experience as an Internet user.

The deposit of these files on a terminal requires the prior collection of consent when they are not strictly necessary for the proper functioning of the Application.

For more details, click here https://www.ogoxe.com/cookies 

ARTICLE 11. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

As a matter of principle, OGOXI processes Personal Data within the European Union.

Given the nature of its activity, OGOXI may be required to transfer Personal Data outside the European Union. In this case, these transfers are accompanied by appropriate guarantees in accordance with the regulations (conclusion of standard contractual clauses from the European Commission, for example, and taking appropriate security measures). Details of these guarantees are available on request by email to contact@ogoxe.com or by post to OGOXI – PIC PYRENEES INNOVATION 65150 – SAINT LAURENT DE NESTE.

ARTICLE 12. SECURITY

OGOXI and its possible subcontractors undertake to implement all technical and organizational measures to ensure the security of the Processing of personal data and the confidentiality of Personal Data, according to the current technical means and in application of the Data Protection Act and the European Data Protection Regulation (GDPR).

OGOXI takes the necessary precautions, with regard to the nature of the Personal Data and the risks presented by the Processing, to preserve the security of the data and, in particular, to prevent them from being distorted, damaged, or that unauthorized third parties have access to them. (physical protection of premises, Customer authentication process with personal and secure access via confidential Identifiers, logging of connections, etc.).

ARTICLE 13. UPDATE OF OUR PRIVACY POLICY

This Privacy Policy may be modified in particular according to the various legislative and regulatory developments. To this end, the User may consult the update directly on the Application.