- all users who visit the Website; and
- the users who have opened a RUMO account (“Account“), whether or not they have subscribed to the Services, either on through a free trial offer, or through a paid offer (altogether the “Subscribers“).
Personal information may be information connected to you specifically, as the individual to whom the information relates. Such information may include name, mailing address, email address, telephone number, or any other information defined as personally identifiable information (or similar term) by the Applicable Regulation (collectively, “Personal Information”). Personal Information does not include your personally identifiable information that has been anonymized (“Anonymous Information”).
The various types of Personal Information that we collect from our users, as well as the purposes and legal bases of the processing we operate are further described below. We are not responsible for the practices of sites linked to from the Services, and you are advised to review their rules and policies before interacting with any of these sites or providing them with any private information.
Information We Collect About You and How We Collect It
We collect several types of information from and about our users:
- Directly from you when you provide it to us:
- For all users:
- information provided when requesting information, or reporting a problem with our Website;
- records and copies of your correspondence (including email addresses), if you contact us;
- your responses to surveys that we might ask you to complete for research purposes.
- For Subscribers: information provided at the time of opening your Account, subscribing to or purchasing the Services, details of transactions you carry out through our Website and of the fulfillment of your orders;
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website or the Services, we may use automatic data collection technologies such as cookies, web beacons, GIF and/or IP address, to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Website, including, but not limited to your search queries, your usage details, traffic data, geolocation data, logs and other communication data and the resources that you access and use on the Website;
- Information about your computer and internet connection, including your IP address, operating system and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service (see article below “How We Use Your Information”).
You may refuse to accept browser cookies by activating the appropriate setting in your browser. However, if you select this setting you may be unable to access certain parts of our Website.
- Cookies (or browser cookies)
- A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer (Internet Explorer, Firefox, Safari or Google Chrome).
- Different types of cookies which have different purposes are used on our Website:
- These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.
- These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enable us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our websites from their site and whether your visit has led to the use or purchase of a product or service from our Website, including the references for the product or service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous. In particular, we use Hubspot to help us understand use of our Website.
- These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.
- Web Beacons. Pages of our the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
- IP Address. Our servers automatically record certain log file information reported from your browser when you access the Services. These server logs may include information such as which pages you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Services. These log files are generally deleted after 30 days.
Social Media Plugins
We integrate social media application program interfaces or plug-ins (“Plug-ins”) from social networks, including LinkedIn, Twitter, and/or possibly other companies, into the Website.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Information:
- As necessary to fulfil our legitimate interests, consisting in answering information requests, informing our users of updates on the Website, or sending newsletters or commercial offers:
- To provide you with information that you request from us;
- To notify you about changes to our Website, our policies, terms or any Services we offer or provide though it, in particular by email;
- To send you newsletters, commercial offers and other information about our products and services.
- As necessary to fulfil our legitimate interests, consisting in ensuring the security of our Website, and to improve your experience on our Website and the performance of our Services:
- Estimate our audience size and usage patterns (e.g. monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns);
- Store information about your preferences, allowing us to customize and improve our Website and the Services;
- Speed up your searches;
- Monitor the effectiveness of our Services;
- Diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses;
- Enhance our Website security;
- Recognize you when you return to our Website (and in particular remember information so that you will not have to re-enter it during your visit or the next time you visit the Website).
- To allow you to participate in interactive features on our Website;
- For analyzing how the Services is used, diagnosing service or technical problems, maintaining security, and personalizing content, and in particular:
- As necessary to perform our contract with our Subscribers:
- To enable you to open your Account, and subscribe to the Services;
- To provide you with notices about your subscription, including expiration and renewal notices;
- To operate, maintain, and provide to you the features and functionality of the Services;
- To implement Services monitoring tools to ensure that you comply with the limits of your subscription;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Retention of Your Information
For all users: If you have not subscribed to the Services yet, but you registered to the newsletter, submitted a request for information, or opened an Account, we may use your Personal Information, including our email exchanges, for up to three (3) years following the end of your last contact with us. We may retain some information in intermediary archives for the applicable limitation durations.
If you are a Subscriber: We will retain your Personal Information as long as you retain your Account on our Website. When you deactivate your Account, we will delete your Personal Information, except those that we need to retain further to our legal obligations (in particular in terms of accounting), or in order to protect and defend our rights in case of dispute, for the duration of applicable limitation periods. In this respect, we will retain your Personal Information in intermediary archives, with rights of access strictly limited on a need-to-know basis. If your account remains inactive for a period of two (2) years, we will contact you to ask you whether you want to keep your account, or whether you would like to delete it. If you do not respond within 48 hours, we will delete your account and your Personal Information.
For purposes of commercial prospection only, we may continue using your Personal Information for up to three (3) years following the end of your subscription.
How We Share Your Information
Anonymous Information: We may share Anonymous Information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All Personal Information you provide to us is stored on our secure servers (or those of our service providers) behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. The information you share in public areas may be viewed by other users.
In accordance with the Applicable Regulation, you have the rights to access and rectify your Personal Information. Under the conditions of the Applicable Regulation, you also benefit from the rights to delete your Personal Information, to request the limitation of their processing, to request their portability, and the right to object to the processing for reasons pertaining to your personal situation when the processing is based on our legitimate interest. You can also communicate instructions about the processing of your Personal Information in case of death.
You are informed that you may, at any time, and without reason, object to the processing of your Personal Information for the purposes of commercial prospection. You can modify the settings you have chosen on the website (https://www.rumo.co/beta/) by email in order to opt out from all or from certain communications.
You can exercise these rights by sending your request accompanied by a copy of an identity document by email to the following email address: email@example.com.
In any case, you may, at any time, submit a claim to the CNIL (French Data Protection Authority) (www.cnil.fr).
SPIDEO SAS – Rumo Services
7bis rue Riquet
75019 Paris – FRANCE