PRIVACY

1. Introduction

We are committed to protecting your privacy and processing your personal data in a transparent, secure and lawful manner.

FINDR (hereinafter, "FINDR" the "Company", "we", "us" or "our") will process your personal data when you visit and use the services provided on https://findr.io/ (hereinafter the "Website") or otherwise interact with us as described herein.

Below you will find information about the type of personal data we process, why we process it, what we use it for and how we may share it, and what your rights are as a Data Subject.

FINDR, which is the publisher of the Website, is a French company based in France at 30/32, Boulevard de Sébastopol - 75004 Paris / RCS: 980 922 454 Paris. FINDR's contact information are mentioned above and you can contact us for any legal matter at support@findr.io. 

The respect of your private life and your personal data is a priority for the Company which commits itself to treat your data in accordance with the French law "Informatique et Libertés" n° 78-17 of January 6, 1978 modified, to the General Data Protection Regulation (EU) 2016/679 of April 27, 2016 (hereinafter "GDPR") and the related standards and recommendations issued by the Commission Nationale de l'Informatique et des Libertés (the "CNIL") or the European Data Protection Committee or other competent authorities whose decisions, guidelines or standards apply on French territory (together, the "Applicable Regulation").

The Company is the data controller for all processing of your personal data, unless otherwise specified in this Privacy Policy (hereinafter "Privacy Policy").

We only use your personal data for the purposes, for the legal reasons and for the retention periods specified below.

The Company acts as data controller for all data collected through the Website, by any other means, or when you enter a contractual relationship with the Company.

If you wish to exercise any of your rights under the Applicable Regulations and as set forth in Section 8 of this Privacy Policy, you may contact the Company by any of the means set forth below, stating your identity and the specific purpose of your request (you may be asked to provide proof of your identity if we are unsure).

If you have any questions about the use of your personal data and your related rights, you may contact the Company by any of the following means:

  • By e-mail at the following address: support@findr.io

  • By mail at the following address: 30/32, Boulevard de Sébastopol 75004 Paris

     

2. Personal data

Personal data are any information that is directly or indirectly linked to a natural person ("Data Subject"), that is, any type of information that can be associated with an individual. This may include, for example, names, e-mail addresses or telephone numbers if they can be associated with a particular living individual, but also, for example, a photograph in which the person can be recognized.

3. Personal data processing

In principle, the term "Processing" includes all types of actions that can be taken with personal data. The definition is very broad and includes all forms of data processing, from collection, recording, retention/storage and adaptation to use, sharing and even deletion of personal data.

4. What personal data do we process, for what purposes and on what legal basis?

We process personal data to perform or conclude an agreement with you in the following circumstances:

  • Purchase of products. If you purchase products from us, we will process your personal data to fulfil our contractual obligations to you. Relevant personal data includes first and last name, shipping/billing address, telephone number, e-mail address, order information, payment information, payment history, credit card information and payment reference number.

  • Use of the dedicated area on the Website. On the one hand, if you have purchased one of our products, you must register them on our Website to enable a person who has found an item with one of your products to find you. The relevant personal data that you must provide are first and last name, address, telephone number, e-mail address, gender and language spoken. As soon as you enter the QR code of your product, you can decide to have (i) an anonymous profile, (ii) a public profile that will require your consent and (iii) to refer to an external link. On the other hand, if you are not a customer of ours but you have found a product with one of our products, you can by flashing the present QR Code get in touch with one of our customers to let them know that you have found their product. To do this, the relevant personal data that you must indicate are possibly your first and last name, your address, your telephone number or your e-mail address.

  • Subscription to our newsletter. If you subscribe to our newsletter, we will process your personal data based on your consent. The relevant personal data is the email address.

The legal basis for our processing of the personal data described above is either your consent or the fact that the processing is necessary to conclude or perform an agreement with you. However, some processing may take place on the basis of our legitimate interests, where your consent is not obtained or where we are not preparing the conclusion or performance of an agreement directly with the Data Subject or where the purpose is not directly related to such preparation or performance of an agreement.

We will process personal data on the basis of our legitimate interests:

  • Customer Service. If you request customer service from us via our support channels, we will process your personal data in order to assist you on the matter in question (i.e. your name, email address and other contact information, order details, purchase amount, purchase history, invoice, payment method, our correspondence with you, technical information about the devices and operating systems used).

  • Questions and complaints. If you have contacted us with questions or complaints about our products (not based on an agreement with you), you may have provided us with personal data such as your name, address, e-mail address and telephone number. We use this data to answer your questions, investigate product-related problems, compensate you if necessary, and prevent fraudulent behaviour, for example, through unfounded complaints and claims.

  • You contact us on your own initiative. If you choose to contact us as a result of our general invitation or on your own initiative via one of our general email addresses, you provide us with personal data which we use to respond to and evaluate the content of your email or if you apply for a job with us.

  • If it is necessary to protect our rights because we have a legitimate interest in establishing, exercising and defending legal claims.

Legal requirements and claims, public interest and consent:

We may need to process your personal data in order to meet legal requirements (e.g., record keeping requirements or as part of our response to a request from you to exercise your individual rights) and by order of the courts or public authorities (e.g., for tax purposes). We may also be required by law or in the public interest to process personal data relating to product issues. We may also process your personal data, such as bank account information or your identity, in order to determine, enforce or defend legal claims

In addition, we may process your personal data on the basis of your consent:

In this case, we will obtain your consent in advance for a specific purpose and ensure that it is provided voluntarily, specifically, knowingly, expressly and unambiguously. You have the right to withdraw your consent at any time; you can contact our department at support@findr.io or refer to the contact information below.

Please note that withdrawal of consent will not apply retroactively to any processing that has already been carried out.

Cookies and Similar Technologies. If you visit the Website and accept our cookies, we may collect personal data, for example: In the form of IP address information, user-generated data from cookies (e.g., clicks, page displayed, page visits, time spent on the page, products displayed and clicked, orders, average order value, how you access and leave the Website, etc.), geographic location (country only), correspondence and comments regarding our products and services, technical data (e.g., device type, browser settings, time zone, operating system, platform). However, with respect to strictly necessary cookies, our processing is necessary for our legitimate interest in providing you with a functional Website when you visit and use the services provided on the Website. 

5. Who are the recipients of personal data?

Only those parties who need to process personal data for the purposes mentioned above will have access to your personal data. We may also work with partners in many countries, both within and outside the EEA, and may therefore also need to share personal data, for example with service providers and legal advisors who are not based in the EEA. This means that your personal data may be transferred outside the EEA. To the extent possible, such transfers will be based on decisions by the European Commission regarding adequate security levels and, if not, primarily on the execution of an agreement between us. In other cases, any transfer of your personal data to third countries will be dependent on adequate safeguards such as standard contractual clauses. In exceptional cases, we may also make such transfers based on your explicit consent, important public interest reasons, the processing of legal claims or to protect your or another person's vital interests.

The Company enters into data processing agreements with third parties who have access to personal data or process it on our behalf, either through their services or through our collaboration. We, therefore, ensure that the third parties we work with process data in the same lawful and secure manner as we do. Specifically, personal data are shared with the following categories of service providers who process such data on our behalf:

  • Depending on the option, your personal data may be passed on to a third party who has found one of your products or to a third party who holds the product with the QR Code;

  • CloudFlare for domain management and as our content delivery network (CDN);

  • Amazon Web Services EMEA SARL for hosting our servers and handling transactional email deliveries (« AWS Europe »);

  • Logistics partners or third party web services such as:

o   Klaviyo Inc. for sending commercial e mail (125 Summer Street, Floor 6, Boston, MA, 02110, United States);

o   Google Cloud And Apple (for authentication);

o   Meta (for commercial prospecting);

  • Payment and e-commerce management services provider:

o   Squarespace Inc. (225 Varick Street, 12th Floor, New York, NY 10014, United States).

We also share your personal data with other data controllers. These Data Controllers may include authorities (police, tax authorities or other authorities) with whom we are required to share data by law or because of suspected criminal activity, payment providers and banks to facilitate transactions, external advisors (lawyers and auditors) and courts to protect our rights, companies that purchase all or part of our operations/assets, and shipping companies to manage and deliver your order.

Where your personal data are shared with other Data Controllers, they will be responsible for your personal data, and we refer to them for more information on how they handle your personal data.

Under no circumstances does FindR Technologies Inc. (US based company) or FindR Technologies SAS (French Based company) sell or rent your personal data to third parties for their own activities.

6. How long is personal data kept?

When we process personal data, it is based on a contract.

  • We retain your personal data for the duration of the contract and delete it when the contract ends. However, the following exceptions apply:

  • If we are required by law to retain or disclose certain of your personal data after the contract ends, we will retain the data for as long and to the extent required by law (for example, up to five years from the end of the contractual relationship under the general statutory limitation regime) or as directed by a court or public authority.

  • If necessary for the establishment, exercise or defence of legal claims, we will retain the relevant personal data until it is no longer required for that purpose.

  • For purchase contracts or use of the service on the Website, we will process your personal data for the contractual duration of our agreement (or for the space on the Website, until your account is deleted) and thereafter for the general statutory limitation period. We will then delete your personal data, provided that no other exceptions described above apply.

We will process personal data on the basis of our legitimate interests:

  • Newsletter: We will retain your personal information for as long as you subscribe or express interest in our newsletters. You can stop receiving our news updates at any time by unsubscribing or opting out of our marketing subscriptions. We will stop processing your data after three (3) years from our last contact.

  • Questions and product complaints: We will process personal data for three (3) years after we receive it, in order to perform statistical analyses of questions and complaints, to investigate, monitor, control and improve our customer service, to pay out compensation and to prevent fraudulent behaviour (e.g., unfounded claims).

  • Website visitors: We will process your personal data for up to 13 months after the collection of cookies on our Website, subject to your prior express consent.

  • Unsolicited application for employment: If you have unsolicitedly applied for a job with us, we will retain your personal data for six (6) months from the date of application in order to contact you if a suitable position becomes available. If you applied for a particular position with us but did not get the job, we will delete your application materials as soon as we inform you that you did not get the job, unless otherwise agreed.

Where we process personal data based on your consent, we will do so until the withdrawal of consent or for as long as is necessary for the purpose of processing the personal data, whichever occurs first, up to a limit of three (3) years after our last contact or the end of our contractual relationship, whichever is earlier.

Note that the above retention periods do not apply to the extent that the Company is required to retain your personal data (in part or in full) in accordance with applicable mandatory law (e.g., accounting legislation) or during the statutory limitation period related to any requirement on your part or applying to you.

7.  What are your rights as a data subject?

Subject to the terms of the applicable regulations, you have the following legal rights:

  • Right of access: At any time, you may request access to your personal data. Upon request, we will provide you with a copy of your personal data in a commonly used electronic format.

  • Right of rectification: You have the right to have incorrect personal data corrected and incomplete personal data completed.

  • Right to erasure: In certain circumstances (including processing based on your consent), you may ask us to erase your personal data. Please note that this is not an unconditional right. Therefore, an attempt to exercise this right may not result in any action by us.

  • Right to object: At any time, subject to the requirements of the GDPR, you may object to any processing by us of your personal data. We will then only process your personal data if it can be demonstrated that there are definitive legitimate grounds for the data to be processed which outweigh your interests, rights and freedoms or if the processing takes place to establish, exercise or defend legal claims. You always have the right to object to your personal data being used for direct marketing purposes, including profiling. This objection can be made at any time.

  • Right to withdraw your consent to the processing of your data (where the processing of your data is based on your consent).

  • Right to restrict processing: In certain circumstances, you may request that we restrict the processing of your personal data. Please note that this is not an unconditional right. Therefore, an attempt to exercise this right may not result in any action by us.

  • Right to Data Portability: You have the right to obtain the personal data you have provided to us (or to have such personal data transferred directly to another controller, if technically possible) in a structured, generally used and machine-readable format, in cases where the processing of your personal data is based on consent or in order to perform an agreement with you.

The right to define the fate of your data after your death and to designate the persons to whom the Company will communicate your data, if you so wish (article 85 of the amended law n° 78-17 of January 6, 1978 relating to data processing, files and freedoms).

If you have any questions or wish to exercise any of your rights, please contact our Company at support@findr.io, stating your identity and the precise purpose of your request (proof of identity may be requested).

 If you have any questions regarding the use of your data and your rights, you can contact the Company by one of the following means

  • By e-mail at the following address: support@findr.io

  • By mail at the following address: 30/32, Boulevard de Sébastopol 75004 Paris France

 For the management of cookies and other tracking tools, the Company invites you to consult article 8 below.

The Company undertakes to respond to you as soon as possible, and in any event within one (1) month of receiving your request. If necessary, this period may be extended by (2) two months, considering the complexity and number of requests sent to the Company. In this case, you will be informed of the extension and the reasons for the delay.

If your request is submitted electronically, the information will also be provided electronically to the extent possible, unless you specifically request otherwise.

 If the company is unable to respond to your request, you will be informed of the reasons for this inability.

You will always have the possibility to file a complaint with a supervisory authority and/or seek legal redress. If after contacting the Company and despite the Company's efforts, you believe that your rights have not been respected, you may file a complaint with the competent supervisory authority. In France, this is the Commission Nationale Informatique et Libertés (the "CNIL"): https://www.cnil.fr/fr/plaintes.

8. Cookies

As part of the way we provide personalised services on our Website, we use cookies to store and sometimes track information about you. A cookie is a small data file that is sent to your browser from a web server, is stored on your hard drive and allows easier access the next time you visit the same page. Their main purpose is to improve the viewing experience of the Website and to enable the delivery of personalised services. We only store and access cookies (which are not necessary on your hard drive) if you have expressly consented.

Some of these browser tracking tools are used only for purposes strictly necessary for the operation of the Website and are therefore exempt from consent, as they are necessary to ensure the access and stable operation of the Website. Others are subject to your express and prior consent.

On the computer, cookies are managed by the Internet browser. These cookies can be session cookies (in which case the cookie will be automatically deleted when the browser is closed) or persistent cookies (in which case the cookie will remain stored in the terminal until its expiration date).

Follow the links below for instructions on how to change your browser settings from some of the more common browser providers (note that these are links to third party websites over which we have no control):

Microsoft Internet Explorer

Safari

Firefox

Google Chrome

By limiting cookies, you may not be able to access all parts of our Website, as some Website functionality is dependent on cookies. In the interest of transparency, we have summarized the cookies used on our Website below. By clicking on the cookie settings, you will find a detailed list of the cookies we use on our Website. We classify cookies into the following categories:

  • Absolutely necessary cookies - These cookies are necessary to help you use the features and services we offer on our Website. These cookies do not collect information about you that can be used to identify you, and they do not monitor or remember where you have been on the Internet. An example of an absolutely necessary cookie is the one that allows our Web Site to keep your items in your shopping cart while you shop online. They are generally set in response to actions you take that are consistent with a request for services, such as setting your privacy preferences.

  • Preference cookies - also known as "feature cookies" - allow the Website to remember choices you have made in the past, your preferred language, or your username and password so that you can log in automatically (if we offer a login feature). They may be installed by us or by a third party vendor whose services we have added to our Website. If you do not allow these cookies, some or all of these services may stop working properly.

  • Statistical cookies - also known as "performance cookies" - collect information about how you use the Website, such as the pages you have visited and the links you have clicked on. This information cannot be used to identify you. All data and information is aggregated and therefore anonymized. The purpose of these cookies is to improve the functionality of the Website and if you disable these cookies, we will not receive information about when you visited our Website and, therefore, we will not be able to verify the performance of the Website.

  • Marketing Cookies - These cookies track your online activity to help us, and our advertisers serve you more relevant ads or to limit the frequency with which you see an ad. These cookies may be set through our Website by our advertising partners. These cookies may be used by these companies to create a profile of your interests to display relevant advertisements on other websites. They do not directly store personal data but are based on the identification of your browser and internet device. If you do not allow these cookies, you will see fewer targeted ads.

If you have consented to all cookies, you can withdraw your consent (except for essential cookies) by going to our cookie settings. Except for essential cookies, blocking the installation of cookies does not prevent you from using the Website effectively. The retention period of the user's choice is six (6) months. The period during which the tracers can collect data in case of user's acceptance is thirteen (13) months maximum.

The cookies used on our Website are the following:

 The other FindR (www.findr.io and http://findr.io) cookies are functional cookies necessary for the operation our website, Apps and Web App.

9. Privacy Policy updates

The Company reserves the right to modify or update the Privacy Policy at any time. Any changes or updates will be effective immediately upon posting on the Website or, in the case of a contractual relationship, by any means, including email, to notify the affected Individual. If such changes are material/impact your obligations, the Company will inform you and seek your consent.

10.  Data Security

We take appropriate technical and organizational measures, including security and integrity measures, to protect your personal data from loss and to prevent unauthorized persons from accessing it. Appropriate security measures we have taken include the implementation of secure private connections, traceability, restoration of lost data and access restrictions. 

11.  Others

 This Privacy Policy is governed by French law, subject to the provisions of the law of any other country in which you may reside. In the event of a dispute and if an amicable agreement cannot be reached, the competent court will be the one determined according to the applicable rules of procedure. We want to have the opportunity to resolve any complaints you may have, but you also have the right to file a complaint with the supervisory body responsible for data protection at any time, as indicated above. To do so, you can contact the French Privacy Authority. You can find more information on its website: https://www.cnil.fr/fr/plaintes

If you have any questions about our processing of your personal data or our use of cookies, or if you wish to exercise any of your rights under applicable privacy laws, please contact our data protection representative at support@findr.io