Privacy Policy

PERSONAL DATA

1. Definitions

Customer: means the company that has signed a contract with SIMUNDIA to allow one or more of its employees to register on the Site in order to benefit from a defined number of Sessions.

Personal data: means any information relating to a natural person likely to be identified, directly or indirectly, such as but not limited to a name, a postal address, an e-mail address, a telephone number, an IP address...

Expert(s): means the psychologist, health professional or coach, using the Site to provide Users with psychological and/or coaching services.

Data Subjects: means the natural persons whose Personal Information is collected by SIMUNDIA in connection with the operation of the Site, in accordance with this Agreement.

Sessions: means the support service provided to the User by the Expert on the Site.

Site: means the app.simundia.com platform and the www.simundia.com platform.

Third party employee: means an employee of the Client (HR, manager, colleague) from whom the User requests feedback on his or her training course.

User(s): means the natural person registered on the Site wishing to access the Sessions.

2. Identity of the data controller

The data controller is SIMUNDIA SAS, whose registered office is located at 15, rue Ancelle, 92200 Neuilly-sur-Seine, registered in the Nanterre Trade and Companies Register under the number 827 580 242 (hereinafter referred to as " SIMUNDIA ").

SIMUNDIA operates the www.simundia.com and https://app.simundia.com/ platforms . The Site puts Users who wish to benefit from a training course in contact with Experts.

SIMUNDIA attaches particular importance to respecting the privacy of the persons concerned and the confidentiality of their personal data. SIMUNDIA is thus committed to processing data in compliance with applicable laws and regulations, and in particular Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms as amended by Law 2018-493 of June 20, 2018, and Regulation (EU) 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter collectively referred to as " The Regulations ").

This privacy policy, established by SIMUNDIA, is intended to provide the above-mentioned Data Subjects with summary and global information on the processing of their personal data by SIMUNDIA through the Site.

2. Personal data

The term "personal data" means any information relating to a natural person who can be identified, directly or indirectly, such as, but not limited to, a name, a postal address, an e-mail address, a telephone number, an IP address...

3. Personal Data collected by SIMUNDIA

3.1 The data transmitted by the Customer

When a customer enters into a contract with SIMUNDIA to allow one or more of its employees or agents to benefit from a defined number of sessions, it transmits, under its responsibility, to SIMUNDIA, the email addresses of the employees or agents concerned.

SIMUNDIA will also collect from the customer the email address of employees authorized to access the customer area of the site. The Customer has consented to the use of this Personal Data as part of the contract between them and SIMUNDIA.

3.2 Data transmitted by the User

When the User opens an account on the Site, SIMUNDIA collects on the Site his name, first name, email, phone number, the theme on which he wishes to receive support, the context of the request and its purpose. The User can also choose to send a photo (optional field).

In a second phase, during a telephone conversation between the User and SIMUNDIA, the User may provide additional information in order to define a suitable training path and improve their experience with SIMUNDIA.

At the end of the training course, the User will be able to fill out an optional roadmap including 3 open-ended questions on what has changed for him/her, what he/she is committed to implement as well as tools and readings that he/she will be asked to use later.

SIMUNDIA retains all of the above data relating to the User and his or her training course under the conditions defined below.

SIMUNDIA also keeps a history of the Sessions attended by the User.

On the other hand, SIMUNDIA does not collect any personal data relating to the content of the Sessions attended by the User from the Experts. SIMUNDIA and the Customer have no knowledge of the content of the Sessions and have no right of access to the Sessions provided by the Expert to the User in order to strictly respect the principle of confidentiality.

The only information that SIMUNDIA may request about the Sessions are purely technical (proper functioning of the Site for example), or relating to the conditions of the realization of the Session (number of Sessions attended, method of communication chosen by the parties, possible delay or cancellation of Session for example).

No medical data on the User is collected on the Site.

3.3 Data transmitted by Users on Third Party employees

The User may optionally, when creating an account on the Site, request feedback from a Third Party Employee. The User then transmits to SIMUNDIA the name, first name, email, professional relationship (manager, HR, colleague) of the Third Party Employee concerned and if necessary an additional message.

The feedback request will contain 3 free fields on what the User should continue (asset), stop or start doing (axis of progression) in the context of his professional activity.

SIMUNDIA emails the feedback request to the Third Party employee.

The Third Party employee will be able to:

(i) return the completed feedback request by logging on to the Site and accepting the Site's Privacy Policy or

(ii) request by return mail to SIMUNDIA the deletion of personal data concerning him.

If the Third Party Employee does not return within 15 days of the feedback request, the Third Party Employee's Personal Data will be deleted by SIMUNDIA.

Following the return of the Third Party Employee, SIMUNDIA will retain the Third Party Employee's data and the completed feedback request as defined below.

3.4 Data provided by the Experts

When the Expert registers on the Site and opens his account, SIMUNDIA collects on the Site his name, first name, email, telephone number, diplomas and qualifications, experience and professional background.

3.5 Messaging

SIMUNDIA provides the User and the Expert with a messaging system on the Site that allows them to exchange information on the organization of the Sessions, between themselves or with SIMUNDIA.

This messaging is exclusively intended to improve the organization of the Sessions (postponement, cancellation, ...) or to share resources (sending documentation). As part of the management of the Site, SIMUNDIA will have access to this messaging.

This messaging system is not intended to be used by the User and the Expert to contain individual information on the content of the Sessions.

4. Personal Data of Users managed by third party services

4.1 In the context of the use of the Site, and in order to collect additional information about the User, the User may be invited to answer questionnaires via the Typeform service. The User is not obliged to answer these questionnaires.

The answers provided by the User in the context of these questionnaires are processed by an external Typeform service. The answers to this questionnaire are optional. If the User answers this impact questionnaire, he/she agrees that his/her Personal Data collected in the questionnaire will be processed in accordance with Typeform's terms and conditions.

4.2 The User may ask questions through the Crisp chat service in order to be helped in his navigation. As part of this service, Crisp uses cookies installed on the Site to collect data about the User. By using the Crisp chat service, the User consents to the collection and processing of Personal Data in accordance with Crisp's terms and conditions.

4.3 The User is aware of and consents to the Personal Data collected by the above mentioned third party services being accessible to SIMUNDIA in the context of the management of the User on the Site.

In the context of such data processing, the User will be in direct relation with the third party services concerned. In this case, the User shall refer to the legal notice, the general terms of use and the data protection policies available at https://admin.typeform.com/to/dwk6gt and crisp.chat/en/privacy/. For any problems or questions related to the use of these services and/or the respect of the Regulation by these services, the User can contact the Site at contact@simundia.com.

5. The purposes of the processing carried out by SIMUNDIA

Processing carried out on the legal basis of the performance of SIMUNDIA's contractual obligations and the management of customer relations:

SIMUNDIA collects and processes the Personal Data of the Persons concerned in order to be able to provide, in the best conditions, the services of putting Users in contact with Experts. This data is processed in particular to:

• Select professional and experienced Experts,
• Gather feedback on the User from a Third Party employee to adapt the User's training path,
• To propose to the User an Expert adapted to his need,
• Put the User in contact with the selected Expert,
• To allow the User to book Sessions online on the Site,
• To provide the User and the Expert with a dedicated messaging system,
• Manage the accounts of Users and Experts (follow-up of the commercial relationship with the client, follow-up of the Sessions for invoicing purposes, accounting),
• Track User feedback on the progress of the Sessions,
• To allow the Customer to monitor the training courses selected by its employees, Users.

The User consents to the use of his or her Personal Data when opening an account on the Site and, with respect to the above-mentioned third-party services, when using these services.

The Expert consents to the use of his personal data when he opens an account on the Site.

The Third-Party Employee consents to the use of his/her Personal Data by logging on to the Site in the context of sending the completed feedback request.

The Customer has consented to the use of the Personal Data of its employees authorized to access the Customer Area on the Site in the contract between the Customer and SIMUNDIA.

SIMUNDIA may also process certain Personal Data of Users and Experts for statistical analysis to analyze the Sessions provided and to improve the service offerings.

SIMUNDIA does not use the Personal Data of Data Subjects for commercial prospecting purposes.

6. How long SIMUNDIA keeps the data it collects

Personal Data relating to the User and the Third Party employee will be deleted 5 years after the last connection to the Site of the User.

The personal data relating to the Expert will be deleted 5 years after the last Session he/she provided to a User.

Personal Data relating to the Customer will be deleted 5 years after the last connection to the Site of a User.

The content of the email will be deleted 5 years after the last connection to the Site of the User.

Access to Personal Data relating to the User processed by the third party services referred to in Article 4 above will be removed for SIMUNDIA, under the terms of the privacy policies applied by such third party services, and within a maximum of 5 years after the last use of the third party service concerned.

As an exception, some of this Personal Data may be archived with restricted access to manage ongoing claims and litigation as well as to meet legal and/or regulatory obligations and/or to respond to requests from authorities authorized to make such requests for a maximum period of 10 years. The data is then permanently deleted.

7. Recipients of Personal Data

7.1 Data relating to the User

All the data relating to the User, described in article 3.2 above, are intended for the SIMUNDIA teams and the Expert responsible for providing Sessions to the User.

Within the framework of the follow-up of the training course by its employees, the Customer will have access on its reserved Customer space on the Site:

• to the names of the Users registered on the Site,
• the number of Sessions attended by Users,
• to the themes selected by the Users,
• at the end of the course.

7.2 Data on Third Party Employees

Data related to Third Party Employees (feedback request) will be used by the User, SIMUNDIA teams and the Expert in charge of providing the Sessions to the User.

8. Transfers of Personal Data

8.1 Transfer of User data to the Customer

SIMUNDIA may transmit to the Customer data on the use of the Site by Users.

This data may not, under any circumstances, concern the content of the Sessions followed by the Users.

8.2 Other data transfers

SIMUNDIA does not transfer the Personal Data of Data Subjects to third parties. SIMUNDIA nevertheless reserves the right to use technical subcontractors, for example for hosting and maintenance of personal data.

The Personal Data are hosted by :

• by AWS for object storage, i.e., Users' photos (optional field). The AWS servers used by SIMUNDIA are located in France;
• by the company Clevercloud for the application and the database. The Clevercloud servers used by SIMUNDIA are also located in France.

Technical service providers are required to comply with the Regulations. These service providers may only use Personal Information about Data Subjects on behalf of SIMUNDIA.

The Personal Data of the Data Subjects will only be transmitted :

• if required by current regulations;
• if such transmission is necessary to comply with applicable law or regulation, legal process and/or administrative or judicial order;
• more generally, to act in urgent circumstances to protect the personal safety of the Persons concerned.

SIMUNDIA does not transfer Personal Information outside the European Union.

Personal Data of Data Subjects are not transferred to any SIMUNDIA business partner

9. The rights of the Persons concerned

Data subjects have the following rights:

Right of access: Data subjects have the right to request what data SIMUNDIA holds and to be provided with it.

Right of Correction: Data Subjects have the right to request the correction of inaccurate data held about them by SIMUNDIA.

Right to erasure ("right to be forgotten"): Data Subjects have the right under the conditions provided by the Regulation to obtain from SIMUNDIA the erasure of data concerning them.

Right to restrict processing: Data Subjects have the right to request SIMUNDIA to suspend the processing of their data while an audit can take place (to verify in particular the accuracy and relevance of the Personal Data processed by SIMUNDIA).

Right to Portability: Data Subjects may have their Personal Data transmitted to them in a structured format and have the right to transmit it to another controller.

Right to object: Data subjects have the right to object, at any time, to being included in a file for legitimate reasons.

Right to Set Post-Mortem Personal Data Dispositions: In the absence of directives or statements to the contrary in such directives, the heirs of Data Subjects may exercise their rights to their Personal Data after their death.

Right to lodge a complaint with a supervisory authority

For more information about exercising your rights:

https://www.cnil.fr/fr/comprendre-vos-droits

These rights may be exercised by sending a request to SIMUNDIA at contact@simundia.com. SIMUNDIA will use its best efforts to respond to requests within a reasonable time, and in any event within the time limits set by the Regulations.

10. Security of Personal Data

SIMUNDIA maintains adequate technical and organizational measures to protect Personal Data from accidental or unlawful destruction, loss, alteration, disclosure or unauthorized access.

SIMUNDIA ensures the security of Personal Data against unauthorized access, use or disclosure by implementing enhanced data protection through the use of appropriate physical and logical security measures to ensure data integrity and confidential and secure processing.

Thus, among the measures taken by SIMUNDIA to secure all Personal Information

• Data encryption: The URLs of the Site are encrypted thanks to the use of token ;
• Videoconferencing: Sessions between Users and Experts can be conducted by videoconferencing, thanks to the tool integrated on the Site and developed by Twilio. This tool is based on webrtc technology. For more details on the security of this tool: https: //www.twilio.com/security. No personal data is collected by SIMUNDIA in the context of the Sessions.
• All Experts selected by SIMUNDIA are subject to strict confidentiality commitments: therefore, they may not disclose to SIMUNDIA or any third party the information given by the User in the context of the Sessions. Both the Expert and the User agree not to film or record the Session. He also agrees to isolate himself from any third party likely to hear the conversation during the session.

COOKIES

When consulting the Site, cookies are placed on the User's and/or Expert's computer, cell phone or tablet.

Cookies are text files deposited on the computer during the consultation of a site. Their purpose is to collect information relating to navigation on the sites. Cookies are managed by the Internet browser.

Different types of cookies are used on the Site.

Analytical cookies

These are cookies that allow us to know the use and performance of the Site

Google Analytics, which tracks the number of times the User and/or Expert has visited the Site, which calculates how long the User and/or Expert has stayed on the Site, which tracks which search engine the User and/or Expert has used

Third-party cookies

These are cookies provided by third parties, installed on the Site, which allow a link (exchange of information) with a social network.

Facebook Pixel that tracks the User's and/or Expert's browsing on the Site and links to the SIMUNDIA Facebook page.

This type of cookie may allow the social network concerned to track browsing on the Site, simply because the User's and/or Expert's account with the social network concerned is activated on his/her terminal (open session) during browsing on the Site.

SIMUNDIA has no control over the process used by social networks to collect information about navigation on the Site and associated with personal data they have. SIMUNDIA invites the User and / or Expert to consult the privacy policies of these social networks to learn about the purposes of use, including advertising, browsing information they may collect through these cookies. These protection policies must notably allow the User and/or Expert to exercise their choices with these social networks, notably by configuring their user accounts for each of these networks.

Crisp: which allows the User's questions to be answered on the Site through a chat system. SIMUNDIA invites the User and/or the Expert to consult the privacy policies of the Crisp service in order to become aware of the purposes of use, the conditions of use of the data collected and their retention period.

By continuing to browse the Site, the User and/or Expert accepts the use of these cookies.

The data collected through cookies are kept by SIMUNDIA for a maximum of 13 months.

The User and/or Expert may nevertheless choose at any time to deactivate cookies by setting their Internet browser.

The User and/or Expert can also configure his browser to indicate the cookies that are deposited in his computer and ask to accept them or not.

The User and/or Expert can accept or refuse cookies on a case-by-case basis or systematically refuse them once and for all.

The configuration of the Internet browser is nevertheless likely to modify the conditions of access to the services offered by the Site. Thus, if the browser is configured to refuse all cookies, the User and/or Expert may be blocked from certain essential functions of the Site.

The User and/or Expert may disable cookies by following the instructions as follows:

1/ Internet Explorer browser

In Internet Explorer, click on the Tools button, then Internet Options.

On the General tab, under Browsing History, click Settings.

Click on the View Files button.

Click the Name column heading to sort all files alphabetically, and then scroll down the list until you see files that begin with the prefix "Cookie. (All cookies have this prefix and usually contain the name of the website that created the cookie.)

Select the cookie(s) containing the name "..... "and delete them

Close the window that contains the list of files, then double-click OK to return to Internet Explorer.

2/ Firefox browser

Go to the "Tools" tab of the browser and select the "Options" menu

In the window that appears, choose "Privacy" and click on "Show cookies

Locate the files that contain the name "......". Select them and delete them.

3/ Safari browser

In your browser, choose Edit > Preferences.

Click on Security.

Click on Show Cookies.

Select the cookies that contain the name " ........ "and click Delete or Delete All.

After deleting the cookies, click Done.

4/ Google Chrome browser

Click on the Tools menu icon.

Select Options.

Click on the Advanced Options tab and go to the "Privacy" section.

Click on the Show Cookies button.

Locate the files that contain the name ".... "Select them and delete them.

Click on "Close" to return to your browser

For more information on cookies:

On the CNIL website: http: //www.cnil.fr/vos-droits/vos-traces/les-cookies

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