1st June 2015

 

Company 40, SAS with a capital of 3,000 €, RCS Paris B 793 196 874, whose registered office is at 8 rue du foin, 75003 Paris, France is committed to safeguarding the Personal Data of Users. This privacy policy (“Privacy Policy”) is part of the T&C. Each word defined in the T&C has the same meaning in the Privacy Policy.

By accessing and using EARLY WORK, Users agree to abide and be bound by this Privacy Policy, which may be modified or updated from time to time without notice. Any modification or update will be displayed on the EARLY WORK Website.

The effective date of this Privacy Policy is June 2015. To the extent any translated version of the Privacy Policy conflicts with the French version, the French version shall prevail.

I. NATURE OF PERSONAL DATA COLLECTED BY COMPANY 40

Company 40 collects and processes data that Users voluntarily provide in order to access or use EARLY WORK, as well as data relating to Users’ preferences and traffic (such as IP addresses).

The purposes of data processing are: to enable Users to create an Account for accessing EARLY WORK and using the services; to improve the services by placing cookies on Users’ terminals; and to send Users commercial offers.

In order to use EARLY WORK, Users need to open an Account and provide Company 40 with at least the following personally identifiable information:

. Name,

. Surname;

. Email address;

. Postal address;

. Phone number.

Users may complete their profile with other Personal Data (other phone numbers, date of birth, etc.).

Company 40 will never collect or process Personal Data pertaining to, directly or indirectly, race, health, sexual orientation, political, philosophical, or religious views. Users shall not store such Personal Data through EARLY WORK.

 

II. NON-PERSONAL IDENTIFIABLE DATA & COOKIES

2.1. Traffic

Traffic data is generated when Users’ terminals connect to the Internet and are not sufficient alone to identify them. Company 40 may collect the following data: origin of the connection, type and version of Users' Internet browser, length of connection, etc.

Such data may be used for statistical purposes to analyze traffic and to improve EARLY WORK. Traffic data is always processed anonymously.

2.2. Cookies

Company 40 places cookies on Users’ terminals. These small files may contain, for instance, traffic data and Users’ preferences.

The purposes of the cookies placed by Company 40 are to:

. Authenticate Users;

. Record Users’ visits and their origin;

. Record Users’ country and language.

Company 40 does not authorize its partners to place cookies on Users’ terminals.

Cookies are mandatory to use EARLY WORK and consequently must be accepted by Users. Users can configure their browser to disable cookies, or alternatively to prompt them, before accepting a cookie from the Websites they visit. If Users disable cookies, however, they may not be able access all of EARLY WORK, the Website, or all functions provided by EARLY WORK.

III. PROCESSING USERS’ PERSONAL DATA

Company 40 collects and processes Users’ Personal Data in a fair and lawful manner and in respect of their rights. Company 40 is the entity responsible for processing Users’ Personal Data.

The processing of Users’ Personal Data made by Company 40 is registered with the French Registrar: “Commission Nationale de l’Informatique et des Libertés” (CNIL).

IV. RETENTION OF USERS’ PERSONAL DATA

 4. 1. Security

The Personal Data communicated by Users are hosted by Company 40.

Company 40 does its upmost to prevent any interference with Users’ Personal Data such as loss, diversion, intrusion, unauthorized divulgation, alteration, or destruction.

4. 2. Duration

Without prejudice to the following paragraph, the Personal Data processed by Company 40 will be deleted at the latest three (3) years after the cancellation of the corresponding User's Account or after three (3) years of inactivity on User's Account.

Company 40 is legally bound to keep the following Personal Data for the duration of one (1) year from the point of creation, change or deletion of the User's Content:

. Identifier of connection;

. Identifier given by the terminal;

. Types of protocols;

. Nature of the operation;

. Date and hour of the operation ;

. Identifier used by the author of the operation.

4.3. Cancellation of Account

Users may request that their Account be cancelled pursuant to the T&C. Their data will be deleted by Company 40 without prejudice to section 4.2 above.

V. TRANSFER OF USERS’ PERSONAL DATA

In order for EARLY WORK to carry out some of its services, Users’ Personal Data (such as names and addresses) may transit through Company 40’s providers. 

Company 40 may provide Users’ Personal Data if required by law or compelled by a court of law.

 

VI. COMMUNICATION FROM COMPANY 40

Company 40 may send emails to Users to the email address associated with their Account for technical or administrative purposes or to inform Users of the evolution of its services. Company 40 may send Users commercial offers unrelated to EARLY WORK but Users may unsubscribe at any time.

 

VII. RIGHT TO ACCESS, MODIFY AND DELETE USERS’ PERSONAL DATA

Pursuant to the French statute dated January 6, 1978, titled “Informatique et Libertés”, Users have the right to access, modify, object to the processing of, and request the deletion of, the Personal Data collected or processed by Company 40 (except as detailed in section IV.).

Users may exercise this right by writing to Company 40.

Users may also modify their Personal Data directly from their Account.

VIII. SOCIAL NETWORK PLUGINS AND GOOGLE ANALYTICS

Facebook

We use plugins corresponding to the social network Facebook on the Website. This is a service offered by the US company Facebook Inc., 1601 South California Avenue, Palo Alto, USA. If you visit one of our pages that contains one of these plugins, your browser automatically establishes a connection with the Facebook servers. The plugin content is transmitted directly to your browser by Facebook and is integrated with the Webpage that is displayed there. An overview of the Facebook plugins is available at the following address: http://developers.facebook.com/docs/plugins/

The integration of the Facebook plugin informs Facebook that the User visited a particular page of the EARLY WORK Website, even if you do not have a Facebook account or you are not logged into Facebook at that time. This information (including your IP address) is sent by your browser to a Facebook server in the US where the information is stored.

If you are logged into Facebook, Facebook can link your visit to the EARLY WORK Website to your personal Facebook account. When you interact with the plugins, for example by clicking "Like" or "Share", the corresponding information is also sent directly to a Facebook server where it is stored. In addition, information is published on Facebook and visible to your Facebook friends.

Facebook may use this information for advertising purposes, for market research and to tailor Facebook pages as desired. For this purpose, Facebook creates profiles corresponding to use, interests and contacts that allow it to assess your use of our Website in connection with advertising on Facebook, inform other Facebook users about your activities on our Website and to provide other services in connection with your use of Facebook. 

If you do not want Facebook to associate the consultation of our Websites with your Facebook User account, please log out of your Facebook profile. 

Twitter

The EARLY WORK Website contains plugins from microblogging network Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. On the Website, you will recognize the Twitter plugins (the Tweet button) and the Twitter logo. The following information seeks to briefly explain the Tweet button: when the User visits a page of our Website which contains this plugin, a direct link is established between your browser and the Twitter server. Twitter is informed that you have visited our page with your IP address. If you click the Twitter button whilst connected to your Twitter account, you can link the content of our pages to your Twitter profile, which allows Twitter to link your visit to the EARLY WORK Website with your User account. We draw your attention to the fact that as a mere supplier of these pages, we do not know how Twitter uses the data collected. For more information, see Twitter's Privacy Policy.

Pinterest

The EARLY WORK Website uses the "Pin it" button associated with the social network Pinterest, registered to Pinterest Inc., 808 Brannan St., San Francisco, CA 94103, USA. The inclusion of the "Pin it" button on the webpage allows for Pinterest to be informed when the User has consulted the corresponding page on a different Website. If the User is connected to Pinterest at that time, Pinterest can link the EARLY WORK Website to the User's Pinterest account. When the User clicks the "Pin it" button, data is transmitted to Pinterest who stores this information. To disable this function, the user must log out of their Pinterest account prior to clicking the "Pin it" button.

To find out more information about how Pinterest collects, processes and uses data, and to understand your related rights and the available settings in place to protect the User's privacy, consult Pinterest's Privacy Policy: http://pinterest.com/about/privacy/

+1 (Google Plus)
The Website uses the browser extension "+1" corresponding to the social network Google Plus, which is operated by Google. The corresponding button is identifiable by the "+1" symbol on a white or colored background.

When you visit a page of our Website that displays this button, your browser automatically establishes a connection to Google's servers. The contents of the "+1" button is transmitted by Google to your browser and is integrated into the Website. This means that we have no control over the amount of data collected by Google with this feature. According to Google, no personal data is collected if the User does not click the button. Only data, including the IP address, of the connected members is collected and processed.

Additional Information

If you do not want Facebook, Google Plus, Twitter or Pinterest to collect your data via the EARLY WORK Website and associate this data with your account or your User data, you must log out of the social network concerned before visiting the EARLY WORK Website.

For detailed information on the purposes for which and the extent to which the different social networks collect, process and use personal data and your related rights and on how to set up your account or your membership profile to protect your privacy, please consult the respective privacy policies of these social networks.

Use of Google Analytics

This Website uses Google Analytics, an Internet audience analysis tool owned by Google Inc. ("Google"). Google Analytics uses "cookies" — text files stored on your computer —, to analyze your use of the Website. The information generated by the cookie pertaining to your use of this Website is usually transmitted and stored on a Google server in the United States. In case IP-anonymisation is activated on this Website, the User's IP address is shortened by Google prior to this event, within the Member States of the European Union or other signatory States to the Agreement on the European Economic Area.

The full IP address is sent to a Google server in the United States to be shortened only in exceptional cases. Google uses this information in order to assess your use of the Website, compiling reports on Website activities for its operators and provide other services related to Website and Internet use. Google is also likely to transfer this information to third parties where required by law or where such third parties process the data on behalf of Google. The IP address transmitted by your browser as part of Google Analytics is not merged with other data by Google.

You can disable the use of cookies by selecting the appropriate settings on your browser. However, we advise you that in this case, it could be that you cannot use all the features of this Website. By using the Website, you consent to the processing of data collected by Google about you in the manner and for the purposes mentioned above.