In order to manage its commercial activity, NUMWORKS Société par Actions Simplifiée with a share capital of €73,465.00, located at 160 Boulevard Haussmann 75008 Paris, registered with the Paris Trade and Companies Register under number 818 745 945, uses the Personal Data of its customers and prospects as the Data Controller.
This implies that NUMWORKS is responsible for ensuring that such use complies with the applicable regulations on the protection of personal data, which include, in particular:
(Hereinafter referred to as the "Applicable Regulations")
These Regulations aim to ensure a balance between professional activities and the right to privacy.
The present Charter (hereinafter the "Charter") is an information document intended for customers (persons who have made a purchase from NUMWORKS) and prospects (persons interested in NUMWORKS products but who are not yet customers) of NUMWORKS.
This Privacy Policy explains what personal information NUMWORKS collects about you, how and why NUMWORKS uses that information and to whom NUMWORKS discloses it in the course of its business, whether online at www.numworks.com and its extension my.numworks.com (hereinafter the "Site") or offline.
What is Personal Data?
This is any information relating to an identified or identifiable natural person. A person is "identifiable" when he or she can be identified, directly or indirectly, in particular by reference to an identification number or to one or more elements that are specific to him or her.
What is Data Processing?
This refers to any material operation on Personal Data (e.g. collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, erasure or destruction).
What is a Goal?
This is the purpose of carrying out one or more operations ("Processing") on Personal Data.
What is a Data Controller?
This term refers to the natural or legal person, public authority, department or other body which, alone or jointly with others, determines the goals (objective) and means (technical, operational, etc.) of Personal Data Processing.
What is a Sub-Contractor?
This term refers to the natural or legal person, public authority, department or other body that processes Personal Data on behalf of the Data Controller.
NUMWORKS may use several types of Personal Data from its customers and prospects as part of its commercial activity.
In order to make this clearer for you, you will find below examples of the Data that NUMWORKS may legitimately collect and use in this context:
| Type | Data examples |
|---|---|
| Identification data | Surname, first name, title, postal address, telephone and/or mobile number, e-mail address (personal or business), password, date of birth, pseudonym |
| Data relating to personal life |
Family situation
Status (student, parent, beta tester, etc.) Country of residence and language Date of birth, communication preferences |
| Data relating to professional life | Position held, company to which you belong |
| Purchasing and customer relations data |
Order: product type, amount, transaction number, delivery details
Opinions on our brand and products Management of claims and litigation, warranties and product recalls |
| Economic data | Information on the payment method used, transaction number, purchase details |
| Conneion data | Logs, IP address, timestamp |
| Browsg data | Cookie choices, navigation tracking (page viewed, date and time) |
| Sensitive data | Minor status |
NUMWORKS collects and uses the Data of prospects and customers in order to carry out its commercial activity relating to the marketing of its calculator. The persons concerned may be students, their parents or a member of a parents' association, or consumers, or teachers, or professionals.
Customer and/or prospect data are used for the "goals" pursued by NUMWORKS, which are presented in the APPENDIX.
NUMWORKS ensures that the purpose of the processing is lawful, verifying that it is based on one of the following legal bases, as provided for by the GDPR:
The legal basis for each processing operation is specified in the APPENDIX.
The Personal Data of NUMWORKS' customers and/or prospects is kept in a form that allows the identification of the persons concerned:
For exhaustive information on the retention periods, the customer and/or prospect may contact NUMWORKS using the contact details given in ARTICLE 11.
Pursuant to Articles 14 to 22 of the GDPR, the customer and/or prospect has the right to exercise the following rights:
| Right to access | This right allows the customer or prospect to obtain a copy of all their Personal Data held by NUMWORKS, and information on the processing we carry out on this data. |
|---|---|
| Right to rectification | This right allows customers or prospects to update their Personal Data if it is no longer accurate. |
| Right to deletion | This right enables the Customer or prospective Customer to obtain the deletion of all their Data. However, NUMWORKS may archive certain Data in compliance with its legal obligations, or when this is necessary for the management of a claim or dispute. |
| Right to portability |
This right allows the customer or prospect to obtain a copy of their Data only when they meet the following conditions:
(i) They have been provided to NUMWORKS or result from the use of its services, in particular the website, (ii) They have been collected on the basis of consent The copy will be sent to the customer or prospect in a format that allows the Data to be used or entrusted to the service provider of their choice. |
| Right to object to Data processing | This right allows the customer or prospective customer to stop NUMWORKS from processing certain Data in the future if he or she has a legitimate reason to do so. |
| Right to restrict processing |
The exercise of this right allows the customer or prospect to stop, for a limited period of time, any processing other than the conservation of Data on certain Personal Data in the event of:
(i) Dispute the accuracy of such Data or; (ii) Challenge the lawfulness of the processing of such Data by NUMWORKS or; (iii) Establishing, exercising or defending legal rights when the Data is to be deleted. |
| Right to define the fate of post-mortem Data | This right allows NUMWORKS to provide the customer or prospect with instructions on what to do with their personal data after their death (retention, deletion and, where appropriate, communication). |
These rights may be exercised directly with NUMWORKS, whose contact details are given in ARTICLE 11.
Proof of identity may be requested in order to ensure that the information is communicated to the right person in the event of doubt as to the latter's identity (for example if a request comes from an email address that is not known to NUMWORKS even though the Customer has an online account).
NUMWORKS is obliged to reply within one month of receipt of the request. In certain cases, due to the complexity of the request or the number of requests, the Person concerned will be informed that this period may be extended by 2 months (total period of 3 months).
The Data Subject may contact the CNIL in the event of a complaint via the following online complaint form: https://www.cnil.fr/plaintes
Data concerning customers and/or prospects may be transmitted to subcontracting companies acting on behalf of NUMWORKS in order to achieve the processing goals identified in point 5. These are specified in APPENDIX.
Data may also be transmitted to public bodies in order to comply with regulatory obligations (e.g. the French Treasury) or to legal auxiliaries in the event of litigation (lawyers, bailiffs, judges).
NUMWORKS reserves the right to communicate the personal data of its customers and/or prospects to a third party at the request of the judicial authorities or any administrative authority authorized by law.
Customers and/or prospects are informed that their Personal Data may be transmitted for the purposes defined above to companies located in countries outside the European Economic Area. NUMWORKS ensures that this transmission is carried out in compliance with the requirements of the applicable Regulations, and in particular that it is based on one of the guarantees provided for by the GDPR, namely:
For further information on the management of cross-border flows, the customer and/or prospect may contact NUMWORKS using the contact details given in ARTICLE 11.
NUMWORKS implements all appropriate technical and organizational measures, taking into account the nature, scope and context of the Personal Data that customers and/or prospects communicate and the risks presented by their Processing, to preserve the security of Personal Data and, in particular, to prevent any accidental or unlawful destruction, loss, alteration, disclosure, intrusion or unauthorized access to such data.
At any time, customers and/or prospects wishing to know how NUMWORKS uses their Personal Data, to ask for them to be rectified or to object to their processing, may contact NUMWORKS in writing at the following address: Mme Clotilde RAMON, NUWMORKS, 160 boulevard Hausmann 75008 PARIS or by email at the following address: contact@numworks.com
NUMWORKS reserves the right to modify the present Charter from time to time, in particular in order to comply with any changes in legislation or regulations, case law or technical developments. The latest applicable version of the Data Protection Charter is available on the Site and is therefore accessible to all customers and/or prospects, who undertake to check regularly whether any changes have been made to the present policy. Customers and/or prospects undertake to check regularly whether any changes have been made to this policy.
| Goals | Legal basis | Data | Shelf life in Active base | Shelf life in Archive base | Subcontractors |
|---|---|---|---|---|---|
| SITE MANAGEMENT | |||||
| Customer account management | Consent |
|
Duration of account use | 4 years after last connection | Salesforce |
| Processing requests | Processing time | 3 years after processing | Freshdesk | ||
| Site security | Legitimate interest | 1 year | N/A | Sentry, AWS, Scaleway | |
| Site operation |
|
The time required for the operation | |||
| Individualized audience measurement | Consent | 13 months | Salesforce | ||
| COMMERCIAL COMMUNICATION WITH B2C CUSTOMERS | |||||
| Newsletter | Legitimate interest |
|
Exercise of the right of opposition or 3 years from the execution of the last order. | N/A | Brevo |
| Other commercial email communication | Brevo, AWS | ||||
| B2B COMMERCIAL COMMUNICATION | |||||
| Prospects - Email | Legitimate interest |
|
Exercise your right to object
OR For Prospects: 4 years from last contact or collection. For Customers: 4 years from completion of the order. |
N/A | Salesforce, Brevo, AWS |
| Customers - Email | |||||
| Prospects - Mail and call | Salesforce | ||||
| Newsletter (prospects and customers) | Brevo | ||||
| PERFORMANCE OF A CONSUMER CONTRACT | |||||
| Order processing | Contract execution |
|
Order processing time | 5 years from delivery if distance selling or from sale if direct selling (art. 2224 civil code) | Shopify, Amazon seller central, CDiscount, Duhamel, EWarehouse, Ship4you |
| SAV | Duration of the contractual relationship | Amazon seller central, CDiscount | |||
| Claims | Processing time | ||||
| Outstanding payments | Legitimate interest | ||||
| Litigation | 10 years from the date of the disputed deed (arts. L.111-3 and L.111-4 of the Code des Procédures Civiles d'Exécution) | ||||
| EXECUTION OF A CONTRACT WITH A PROFESSIONAL | |||||
| Order processing | Legitimate interest |
|
Order processing time | 5 years from delivery if remote sale or from sale if direct sale (art. 2224 civil code) and 10 years for accounting records | Duhamel |
| SAV | Duration of the contractual relationship | ||||
| Claims | Processing time | ||||
| Outstanding payments | |||||
| Litigation management | 10 years from the date of the disputed deed (arts. L.111-3 and L.111-4 of the Code des Procédures Civiles d'Exécution) | ||||
| SERVICE IMPROVEMENT / PRODUCT TESTING WITH TEACHERS | |||||
| Satisfaction survey | Legitimate interest |
|
Up to the right of opposition within 3 years of active contact | N/A | Salesforce, Brevo, AWS |
| Customer feedback on a product prototype | |||||
| Product requirements questionnaire | Salesforce | ||||