Privacy Policy

Version from February 14 2023

In order to provide you with its services and during your exchanges with MyBestPro SAS, publisher of the Wengo site (hereinafter "We", "Our" or "MyBestPro company"), we process your data relating to your use of Our services. We undertake (i) to remain transparent in the management of your personal information and (ii) to respect the application to remain within the legal framework for protection of personal data, in particular the European general regulation on the protection of personal data (“GDPR ”) and the French data protection law “Informatique et Libertés”.

This privacy policy (“Privacy Policy”) (i) the procedure by which we collect personal identifiable information pertaining participants and (ii) describes how and under what circumstances, we may use, disclose and transfer this personal data when:

• You use wengo.com website (“website”) or Partners’ website
• You use all available services from the website or from the Partner’s website
• You use the Platform.

This Privacy Policy constitutes a regulation associated with Terms and Conditions.

The terms used in this Privacy Policy have the same meanings as defined into the Terms and Conditions to which this Privacy Policy is attached.

Under the event of opposition, between any of the provisions of this Privacy Policy and the General Terms and Conditions, the terms of the present ones shall prevail.

ARTICLE 1 : DATA COLLECTION

Data Provided by You

• Email address and telephone number
• Login and password
• Account preferences
• Date of Birth
• Credit or debit card or PayPal

For all payment information, we use the services of the Providers, Ogone and Adyen certified to PCI DSS 3.2, the main international security standard whose objectives are to ensure the confidentiality and integrity of cardholders data under the European Payment Services Directive (PSD, 2007/64/CE).

We do not store card information, only the elements necessary to the processing of the transactions and their consequences (payment, guarantee, disputes…) are preserved: the reference of the credit card, the first six and the last 4 digits of the card and the expiry date.

PERSONAL DATA AUTOMATICALLY COLLECTED WHEN USING OUR SERVICE

When using our services, we automatically record information related to (i) your use of our services, (ii) your interaction with our advertising, (iii) information on the software and devices feature you use, (iv) information from your browser.

In addition, our Websites and mobile applications include the ability for you and other Users to post information via online reviews, comments, forums, or blogs. As a result, we will also receive information about you: (i) when you choose to post or otherwise share this information on our Websites or mobile applications, or (ii) when other users post or otherwise share information about you on our Websites or mobile applications.

We collect this information by:

• Log files : when you use our services, some information are automatically registered in our log files such as (i) IP address, (ii) unique identifier, (iii) your operating system and its location, (iv) browser you use, (v) pages viewed.
• Cookies : We may use tracking technologies such as invisible pixel, log file implemented on our Website that we store on your device (called “cookies”). These technologies allow us to recognize your device and to follow your interaction with our services, mails and ads.

In the event that you do not want your Personal Data to be collected through cookies, you can deactivate the support for the latter directly in your cookie banner. However, this operation may reduce the performance and functionality of the platform and its tools. For more information, please see our cookies policy.

ARTICLE 2 : HOW WE USE YOUR DATA (PURPOSES AND LEGAL BASES)

USE OF OUR SITE, CUSTOMER RELATIONSHIP MANAGEMENT

We mainly use your Personal Data in the context of the management of Our customers/prospects for the purposes of providing Our Tools, administering the Platform, connecting Participants and billing them as well as in Our relationship with Participants.

SENDING COMMUNICATIONS AND COMMERCIAL OFFERS

Your data also allow us to offer you promotional offers and to carry out prospecting actions by sending you requests and newsletters as soon as you have consented to them.

REALIZATION OF STATISTICAL STUDIES

We also use your Personal Data to establish statistics of visits and use of the various elements that make up Our Sites.

We only collect the Data necessary for the purpose of the intended processing.

If We plan to use your Personal Data for purposes other than those mentioned above, We undertake to inform you first. You will then have the possibility of not giving your consent or of withdrawing it.

ARTICLE 3 : SHARING AND DISCLOSURE OF YOUR DATA

Your data is intended for Our internal services but also:

DATAS SHARED TO COMPANIES BELONGING TO MYBESTPRO GROUP

We use third parties in the context of the execution of services and orders, in particular: management, execution, processing and payment. We share the necessary information to enable them to carry out their missions.

Our service providers are required to respect Our Charter on the protection of personal data and not to use your Personal Data to serve their own commercial interests.

DATAS SHARED TO SERVICE PROVIDERS

We use service providers for customer management and payment process. We only share with our providers information they need for their mission.

Our service provider must respect our Charter on the Protection of Personal Data and commit not to use your data for their own commercial purposes.

DATAS SHARED WITH THIRD PARTIES

We share information with third parties only with your consent. We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we believe may aid a law enforcement investigation. In addition, we reserve the right to release all types of information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of information about you may protect the rights, property, or safety of us or another person.

PLUG-INS AND SOCIAL MEDIA

We use plug-ins or social media modules on some of our Websites. These include “like”, “share” buttons from third party social networks such as Facebook, Twitter, Youtube, that you can find on our Websites. They allow you to like and share information from our Websites with friends on social networks. When you visit a page of our Websites (web or mobile) containing plug-ins or social media modules, a connection is established with the servers of social networks (Facebook, Twitter, Youtube…) who are then informed that you have accessed the corresponding page of the website consulted, even if you do not have a Facebook, Twitter, Youtube user account, and even if you are not connected to your Facebook, Twitter, Youtube account. If you do not want social networks to publish your actions from plug-ins in your social media accounts, you must disconnect for your social networks before visiting our Websites.

ADS AND CUSTOMIZATION

We use cookies or proprietary identifiers (such as Google Analytics cookie) and cookies or third party identifiers (such as Google Advertising Cookies) to make the advertising more personalized for Users. For more information, please review Google’s Privacy Policy and Terms of Use. We use these technologies for the purpose of target advertising based on the center of interests pertaining to various visits to our Websites and provide internal reports including the company, MyBestPro. Datas collected are anonymized or linked to pseudonym so it is not possible to identify you personally.

You can opt out of these Google Analytics advertising features via Ad Settings or providing a Google Deactivation Ad-Block on your browser.

SALE OR TRANSFER OF ALL OR PART OF OUR ACTIVITIES OR ASSETS:

In the event that all or part of Our activities or assets are transmitted to a third party, in particular by succession, sale, merger, transformation of the fund, Your personal data may be transmitted to said third party, unless You object to it for reasons relating to your particular situation.

ARTICLE 4 : WHERE DO WE STORE YOUR DATA

Your Personal Data is stored in our databases located in France as well as those of Our service providers.

In some cases, for essentially technical reasons, some Data are transferred outside the territory of the European Union. The purpose of this transfer is to provide you with quality customer service. In this case, We undertake to guarantee the protection of your information by setting up protection systems in accordance with the applicable legislation, in particular by means of data processing contracts based on the standard contractual clauses of the European Union. These service providers are required to comply with our security standards and may be audited by Us at any time in order to check their compliance with the legislation.

ARTICLE 5 : HOW LONG WE WILL KEEP YOUR DATA

Your Personal Data is stored by Us and / or any subcontractor of Our choice for the strict performance of Our obligations, and are retained, unless you specify otherwise, for a maximum of 4 (four) years from the date of termination of the commercial relationship for the purposes of commercial prospecting and in order to comply with Our legal obligations, and resolve any disputes that may arise in connection with Our services.

At the end of these 4 (four) years, We commit ourselves to contact you again to determine whether you wish to continue to receive commercial solicitations. Beyond this maximum duration, the data will be archived and anonymized or destroyed.

The archiving of your Personal Data is carried out on a reliable support in accordance with the legislation in force. In the event of a dispute between the Data thus stored and any document provided by you, it is expressly agreed as an evidentiary agreement that the Data collected by Us will take precedence and will only be admitted as evidence. If you do not delete, the data collected via the implementation of cookies are retained for a period of 13 (thirteen) months from the implementation of the cookie on your device.

ARTICLE 6 : YOUR RIGHTS

RIGHTS OF ACCESS, MODIFICATION, LIMITATION, DELETION AND PORTABILITY

You have a general right of access, rectification, limitation and deletion, the right not to be the subject of an automated individual decision as well as a right to portability of the set of Personal Data about you, collected as you use Our services.

You may exercise these rights at any time by going to your Personal Account or by contacting us at the following address: [email protected] enclosing proof of your identity card.

RIGHT OF OPPOSITION

You may at any time object to the processing of your Personal Data or withdraw your consent by contacting us at the following address: [email protected] enclosing proof of your identity card.

ADVERTISING AND COOKIES

If you no longer wish to receive targeted advertising based on your interests or any form of tracking please refer to our cookies policy

ARTICLE 7 : ADVISOR'S OBLIGATIONS

Any Consultant offering its Services on Our Platforms undertakes to comply with its obligations under the applicable regulations for the protection of personal data as it results in particular from the European Regulation on the protection of personal data. 

Except with the express and prior consent of the User, the Consultant agrees not to make any use of the Personal Data relating to the User for purposes other than the strict needs of the execution and billing of its Service or to assert his rights in any dispute with a User. Similarly, the Consultant is informed that it is forbidden to communicate any Personal Data to a third party without the express prior consent of the User.

Any Consultant undertakes to indemnify us against the consequences of any claim by a User resulting from the breach by the Consultant of his obligations under the applicable rules regarding the protection of personal data and / or of the Charter.

ARTICLE 8 : UPDATE Of THIS PRIVACY POLICY

This policy may change at any time, in particular due to the introduction of new services or new technologies, or changes in the legislative and regulatory framework.

We will inform you of substantial changes and invite you to consult this page regularly.

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