DESCRIPTION OF THE TREATMENT OF PERSONAL DATA
1. General information
The present charter describes the conditions for the treatment of information collected by the WIIDII company, simplified joint-stock company with a capital of 586 024.37 euros, registered at the R.C.S. of Bordeaux under the number 803025972, and whose headquarters are based at 3 rue Allée Fabre d’Églantine – 33160 SAINT MÉDARD EN JALLES – FRANCE, as part of its concierge and personal assistance services combining artificial intelligence and human intervention, as described in its Terms & Conditions or T&C.
The WIIDII company (hereafter referred to as “WIIDII” or as “we”) is very attentive to the protection and the respect of the private life of any person of whom it processes personal data as part of the services listed above (hereafter referred to as “you”).
The present charter looks to inform you of our practices regarding the collection, the use and the sharing of information that you have come to supply us via our Application or more generally as part of our relationship.
This policy (as well as our Terms & Conditions) and any document that refers to it present the way in which we deal with the personal data we collect and that you supply us. We invite you to read the present document with care, to know and understand our practices regarding the treatment of your personal data.
You namely benefit from the right to oppose yourself at any moment to certain aspects of the processing of your personal data (see point 6 below for more information). To exercise these rights, you may contact our Delegate for the Protection of Personal Data according to the modalities defined in article 9 below.
Only the version of this document written in French is opposable to the consumers.
2. The information we collect
We are susceptible to process the following data:
Some data is sent to us directly by you (see 2.1), other data is sent to us automatically (see 2.2). You have several rights regarding the processing of this data (2.3).
2.1. The information that you send to us directly
By using our Application, you are required to send us information which is able to identify you and that is necessary for the use of the WIIDII Service of personal assistance.
2.1.1 Personal data sent
Personal data is sent when you fill in forms (like for example the subscription form) or when you ask to create a personal space on the website managed by another company – whether it be by the means of the Application, by phone, email or any other means of communication. This is also the data that you send to us when you bring forward a problem of a claim with a Service Provider.
This information namely contains the data necessary for the subscription to the service we provide on our Application or the access to any other mobile application published by WIIDII, namely for the account of other companies, enabling access to WIIDII’s Service of personal assistance.
This data is namely:
- Your surname and first name,
- Email address,
- Postal address,
- Date of birth,
- Phone number,
- Identification code sent to you by your Member Professional
- And your password.
This information is mandatory as it is necessary for the carrying out of services. If this is not sent to us, you will not be able to access the Application as we will not be able to provide you with the service.
You may also send us other data, such as your bank details, your location, or your personal preferences. If you do not send us this information, you will not be able to benefit from all of the Application’s functionalities, and some of our services will not be accessible to you.
2.1.2 Other information necessary to the use of the Service
This information namely contains the data that you send us directly as part of the use of WIIDII’s Service of personal assistance. This information is inherent to the carrying out of the services.
This data is namely:
- A copy of all of the exchanges that have occurred between you and WIIDII;
- A copy of all of the reservation requests or information requests carried out via our Application;
- The detail of the financial operations carried out for you on our behalf via the Application or by any other means, including phone or email, namely containing the information regarding your reservations and your purchase of goods or services;
- The detail of your visits on our Application and the contents that you have accessed;
- The data that we may ask you to provide when you flag a problem regarding the use of our Service;
- The data linked to your location when you accepted that we collect and treat this data;
- A copy of your passport, your driver’s license, your identity card or any other similar document that you accepted to provide if this information is necessary to reserve or purchase a service;
- Proof (by any means) of your consent to the reservation proposals and the purchase of goods or services carried out via the Application and your acceptance of the terms and conditions and/or sales conditions of a third-party Service Provider;
- A copy of all of the transmission requests of written or vocal messages to your contacts;
- A copy of all the documents that you have asked to save in order to consult them at a later time via the Application (passport, identity card, driver’s license, blood group card, vaccination card, loyalty cards and, more generally, any official or unofficial identification card).
2.2. Data that we collect automatically
Every time you log into the Application, we are susceptible to collect, in accordance with the applicable legislation and if need be, with your agreement, information regarding the devices on which you use our services or the networks from which you access our services, such as your IP addresses namely, connexion data, types and versions of the mobiles used, types and versions of the exploitation systems of your mobile terminal, data regarding your navigation history on our Application, namely your use of the different pages, the content that you access or that you check, the search terms you use, the downloading errors as well as any phone number used to contact us.
We also collect information on your use of our Application, such as:
- The number of requests you make via the Application,
- The nature of the information that you wish to obtain via the Application,
- The number of connexions to the Application, their dates and times.
2.3 Your rights concerning this data
When justifying your identity and if the conditions of exercise of these rights are fulfilled, you can use your access right, rectification right, deletion right, right to the limitation of the treatments, opposition right, portability right, right to introduce a claim with the CNIL and your right to determine the fate of your data after your death. These procedures are detailed in point 6 below.
2.4. Conservation time of your data
Your Personal Data is archived at the end of the following periods:
- ]1 year after the end of your subscription;
- Or for the necessary time for the processing of potential claims that you may have encountered as part of the use of the Service.
These categories of the following Personal Data are susceptible to be kept for different durations:
Financial data (for example payment requests) are kept for the required length of time for the laws applicable in fiscal and accounting matters;
The proof of your consent to the purchase, the reservation or the order of goods or services for the required length of time for the relevant laws applicable.
3. How do we use the data that we collect?
The Application’s goal is to combine machine and human beings in order to propose the best semi-automated service of personal assistance.
The Application looks to create a dialogue with you. For this, the Application must learn and memorise all the information that you give it, to be more relevant.
The more you use the application developed by WIIDII, the more it gets to know you and will answer you in a more personalised manner.
We use the data we collect to:
- Ensure the service of linking you to the Service Providers (that can be WIIDII’s commercial partners) and sending them your request,
- Enable the formalisation of service or delivery of material or immaterial goods’ contracts, between you and the Service Providers, in your name and for your account, as part of the mandate that you have consented to us by accepting our Terms and Conditions;
- Supply you with the information that you require as part of your requests;
- Send you information via the Application, by email or by any other means of communication;
- Receive your payment requests to the attention of the Service Providers, by credit card or any other means, as part of the mandate that you entrusted us with by accepting our Terms and Conditions;
- Enable you to personalise your profile on our Application;
- Ensure that you respect the applicable legislation, our Terms and Conditions and our confidentiality policy. If you fail to do so, we may have to suspend your account;
- Send you, in accordance with the applicable legal provisions and with your agreement when the legislation requires it, marketing, advertising and promotional messages, as well as information relative to the use of our services, our reservation modalities, or to suggest or advise you on goods and services that may interest you;
- Inform you of the modifications that we have brought to our services;
- Verify the information that we have collected on your inscription or when using the Application;
- Manage our Application and carry out internal technical operations as part of the resolution of problems, data analysis, tests, research, analysis, studies and polls, in an anonymous manner;
- Improve and optimise our Application.
Furthermore, we use information in order to propose, personalise and improve our Service of personal assistance. This geographic information may come namely from the precise location of devices (that you authorised us to collect), IP addresses and information concerning your use of our Service.
For example, we use the information at our disposal to develop, test and improve our Service and our Application, namely by carrying out grading and research.
4. Who are the recipients of the information we collect?
4.1. As part of the use of our services, some of your information will be sent to:
– the Member Professionals that authorised you to use the Application by sending you a code;
– the Service Providers (service providers, goods suppliers, search engines, reservation offices, transport companies, train or airplane companies, etc.)
– as part of the reservation, information, detail, purchase of goods and services process;
– the contacts to whom you have asked us to send a message or an information.
We are also susceptible to share information concerning you, namely Personal Data, with the other companies of the WIIDII group that exist or that may be created in the future.
Regarding information relative to your payment details, you may save on the Application the details of your bank card in your personal space. The saving of these details will be done via a secure interface that locally stores information in a secure and compartmentalised part of your mobile terminal. The data is only available via the Application. Neither the user of the mobile terminal (even you), nor any other application will have access to it. The data is encrypted via the AES 256 bits’ algorithm (a standard used by the organisations of the United States government), with a strong, random and unique encryption key for the user, that is stored in a secure space on the WIIDII servers. It is therefore impossible to have access via your mobile terminal or to directly exploit the saved payment card. Once this information has been supplied in your personal space, the details of your payment card are modifiable (reset of all of the publication fields) but not visible (the user of the mobile terminal cannot see the information saved).
In order to guarantee maximum security, no bank information is stored on the WIIDII servers, the mobile terminal contains the encrypted data of your card and the server contains the encryption key. It is therefore impossible to have access to the payment card details without having these two sets of information simultaneously (that are both stored on two independent and different secure platforms).
4.2. We will only share the data with the third parties mentioned above in the following cases:
– When we call upon a Service Provider for the fulfilment of a contract concluded between you and this Service Provider, who is supplying goods or services, in order to send an information, or for the reservation of an event or a service.
– In order to supply or to improve our Service of personal assistance;
– Regarding reservations, we are asked, in order to supply the requested services, to share with the Service Provider some of your Personal Data such as your surname, first name, postal address, mobile phone number and email address, payment references and bank card details for remote payments;
– If we call upon search engine suppliers or analytical solutions to supply the information you request via the Application;
– If you make an express request (for example when you ask us to send a message to a contact, subscribe to a service supplied by a Service Provider by identifying yourself or creating a personal space);
– When we have the legal obligation to do so or if we think that in good faith it is necessary to respond to a claim against WIIDII or the Member Professionals, to conform ourselves to any judicial request, bring proof of your consent for any contract established with Service Providers, such as the Terms and Conditions or Sales Terms and Conditions of the Service Providers and their confidentiality policies, in emergency cases that may be threatening to public health or the physical integrity of a person, as part of enquiries or investigations, or in order to guarantee the rights, goods and security of WIIDII, the Member Professionals or more generally any third party;
– If WIIDII or any part of its assets are bought by a third party, the data in our possession will be transferred to the new owner if required.
We draw your attention to the fact that if you ask us to share some of your information, namely your Personal Data, with the Service Providers, through the connexion services made available by the Service Providers, their confidentiality policies will be opposable to you. We have no control on the collection or the treatment of your data by the Service Providers on their own platform.
We inform you that when WIIDII is required to order something on behalf of the client, WIIDII will refuse to accept consent for the processing of the client’s personal data that is not necessary for the carrying out of the service.
The legitimate interest that we base ourselves on for the treatment of your data is the following:
- To create, supply, take charge and maintain the functionalities of the Application, whose goal is to propose a service of personalised assistance, making daily tasks and the consultation of public information easier;
- To protect our Application, verify the accounts and activities, to fight harmful behaviour, to detect and avoid undesirable content, to ensure that your requests do not contain any harmful content, are not inappropriate or illegal, to investigate suspicious activities or the violation of our conditions or rules of use;
- On an anonymous basis, to supply services of grading and analysis and other commercial services,
- On an anonymous basis, to supply precise and reliable reports to our partners (namely the Member Professionals), developers and other commercial partners, to guarantee a just pricing system and precise statistics on performances, and to demonstrate the value of the Application use;
- On an anonymous basis, in the interest of our partners (namely the Member Professionals), to help them understand the behaviour of their clients, their employees and their members and to improve commercial offers, to validate our subscription pricing systems and to evaluate the efficiency of the use of our Application;
- On an anonymous basis, to carry out research and development tasks in order to improve current knowledge and to develop a dematerialised system of personal assistance that is affordable and efficient for all users.
- To share information with others, namely the authorities, and to answer to legal requests, in order to stop and control fraud, the unauthorised use of WIIDII, the violation of our conditions or rules, or any other dangerous or illegal activity, to protect WIIDII’s intellectual property rights and those of its partners, namely the Member Professionals, our users or any other person namely as part of investigations of regulatory requests.
5. Is your data transferred, how and when?
As a general rule, we keep your Personal Data inside the French territory. However, if for example some Service Providers are located in countries outside of the European Union (“Third Party Country”), we transfer some of your Personal Data to Third Party Countries. This can namely be the case for Third Party Countries for whom the European Commission has not taken a decision of “adequate protection”. In such a case, we will ensure that this transfer be carried out in accordance with the applicable rules and guarantee a sufficient level of protection of private life and the fundamental rights of persons (namely for the typical contractual clauses of the European Commission). In any case, the transfer of your Personal Data is strictly limited to what is necessary to supply the WIIDII Service.
6. What are your rights on your personal data?
6.1. You have the right to obtain confirmation that data with a personal character that concerns you is or is not processed by us and when it is, you have the right to access the said personal data. If you exercise this access right, you will receive a copy of your Personal Data in our possession (“right of access”).
6.2. You may also request the suppression of your Personal Data as well as the rectification of erroneous or obsolete Personal Data (“right of suppression and right of rectification”). Please note that we are susceptible to keep some information that concerns you when the law requires it or when we have a legitimate motive to do so. This is for example the case if you have committed a fraud or violated our Terms and Conditions.
6.3. You have the right to limit the processing of your Personal Data (“right to limitation”). Please note that this right only applies if you contest the exactness of your Personal Data during the period when we are able to verify the exactness of the latter, in case of illicit treatment on our behalf and if you demand a limitation of their use rather than a suppression, we no longer need this data of a personal nature for processing ends but it is still necessary for the observation, the exercise and the defence of rights in justice, in the case of the exercise of your opposition right during the verification period based on knowing if the legitimate motives we are pursuing prevail over yours.
6.4. You have the right to introduce a claim with the competent supervisory authority or to obtain compensation from the competent courts if you consider that we have not respected your rights.
6.5. You also have the right to the portability of your data, that is to say the right to receive the Personal Data that you supplied us with in a structured format, currently in use and machine legible, and the right to forward this data to another processing manager (“right to portability”).
6.6 When the processing of personal data requires your consent, you have the right to withdraw it at any time. The withdrawal of consent does not compromise the legality of the processing based on the consent given before the withdrawal.
6.7 You have the right to oppose yourself at any time to the processing of this data of personal nature that concerns you and whose processing is based on a legitimate interest. In this case, we will cease to process this data, unless we show that there are legitimate or imperious reasons for the processing that prevail over the interests and the rights and freedoms of the person concerned, or for the acknowledgment, the exercise or the defence of rights in court.
When this data of personal nature is processed for market research means, the person concerned has the right to oppose at any moment the processing of this data of personal nature concerning him/her for such market research means. When the person concerned opposes him/herself to this processing for market research means, the data of personal nature is no longer processed for these means.
To exercise these rights, you may contact our Delegate for the Protection of Personal Data according to the modalities listed in article 9 below.
7. Links to other websites
Our Application regularly sends you links to the websites of Service Providers that are third-party companies. Please note that these websites have their own confidentiality policies and the we decline all responsibility in the use made by these sites of the information that is gathered when you click on these links. We invite you to read the confidentiality policies of these websites before sharing your Personal Data.
8. Modification of our confidentiality policy
We may have to occasionally modify the present confidentiality policy. If this is necessary, we will inform you and/or ask you for your agreement. We advise you to regularly check this page to become aware of potential modifications or updates that are made to our confidentiality policy.
For any question pertaining to the present confidentiality policy or for any request relative to your personal data, you may contact us by:
- Sending an email to our Delegate for the Protection of Data at the following address email@example.com
- Sending us a letter to the following address: WIIDII – to the attention of the Delegate for the Protection of Data – 56 rue de Tivoli, 33000 BORDEAUX – FRANCE.
Version updated on 26 July 2018.