Episto.uk Chat Privacy Policy

What is the purpose of this policy?

We attach great importance to the protection and confidentiality of your personal data, which for us is a testament to our reliability and trustworthiness.

The data privacy policy specifically demonstrates our commitment to enforcing applicable data protection rules, particularly those of the General Data Protection Regulation ("GDPR").

Specifically, the privacy policy aims to inform you about how and why we process your data in connection with the services we provide.

Who does this policy apply to?

This policy applies to you, regardless of your place of residence, provided you have reached the legal digital age required in your country of residence (e.g., 15 years for France, 16 years for Germany, 13 years for Belgium, etc.) and you respond to a survey via Episto Chat. If you have any doubt about the legal digital age applicable in your country of residence, you can ask us at dpo@episto.fr.

If you are below the legal digital age required in your country of residence, you are not authorized to respond to a survey without the prior and explicit consent of one of your parents, which must be sent in writing to dpo@episto.fr. If you believe that we may hold information concerning one of your children who has not reached the legal digital age required in your country of residence without having consented, you can ask us to delete it by contacting dpo@episto.fr.

Why do we process your data?

As part of the services we offer, we are necessarily required to process your personal data for the following reasons and legal bases:

• To respond to the surveys and polls we offer based on our general terms of use.
• To guarantee and enhance the security and quality of our services on a daily basis (e.g., statistics, data security, etc.), based on our legal obligations, our general terms and conditions of sale, and our legitimate interest in ensuring the proper functioning of our services.

Your data is collected directly from you when you use our platform, and we commit to processing your data only for the reasons previously described. In particular, we commit to never sending commercial solicitations concerning us to individuals responding to surveys and campaigns.

Furthermore, we guarantee that none of your data will ever be sold to a partner or a third party. However, by voluntarily publishing content on the pages we manage on social networks, you acknowledge being entirely responsible for any personal information you may transmit, regardless of the nature and origin of the information provided.

What data do we process and for how long?

We have summarised the categories of personal data we collect and their respective retention periods.

• By default, your data is anonymized except in the express case where you choose to provide identifying information within the questionnaire (e.g., name, surname, and email address). This choice, when available, is always optional. If you provide identifying data, your data will no longer be anonymized and will be retained only for the duration of the survey.

IMPORTANT: Surveys commissioned by our clients may involve the collection of various data (e.g., personal life, hobbies, preferences, etc.) but also the collection of sensitive data (e.g., sexual orientation, political views, sexual preference, etc.). These data, like the aforementioned, remain anonymous unless you decide to provide identifying data in the chat. Your consent will nonetheless always be requested before answering these questions, and the data will only be retained for the duration of the survey.

• Connection data (e.g., logs, IP address, etc.) retained for a period of 1 year.

If you wish to obtain further details on the retention periods applicable to your data, you can contact us at: dpo@episto.fr. In all cases, all your data is deleted when you request the deletion of your account, with a maximum delay of 30 days.

The deletion of your personal data is irreversible, and we will no longer be able to communicate them to you after this period. At most, we can only retain anonymous data for statistical purposes.

Please also note that in the event of litigation, we are obligated to retain all data concerning you for the entire duration of the case processing, even after the expiration of their previously described retention periods.

What rights do you have to control the use of your data?

The applicable data protection regulations grant you specific rights that you can exercise at any time and free of charge to control how we use your data.

• Right of access and copy of your personal data, provided that this request does not conflict with trade secrets, confidentiality, or the secrecy of communications.
• Right to rectification of personal data that is inaccurate, outdated, or incomplete.
• Right to request erasure (“right to be forgotten”) of your personal data that is not essential for the proper functioning of our services.
• Right to restriction of processing of your personal data, which allows for a snapshot of your data's use in case of a dispute regarding the legitimacy of a processing operation.
• Right to data portability, which allows you to retrieve a portion of your personal data to store or easily transmit it from one information system to another.
• Right to provide instructions regarding the fate of your data in the event of death, either directly by you, or through a trusted third party or a legal successor.

For a request to be taken into account, it is imperative that it be made directly by you at dpo@episto.fr. Any request that is not made this way cannot be processed.

Requests can only originate from you. Therefore, we may ask you to provide proof of identity if there is any doubt regarding the applicant's identity.

We will respond to your request as soon as possible, within a maximum of three months from its receipt, should the request be technically complex or if we receive numerous requests simultaneously.

Please note that we may always refuse to respond to any excessive or unfounded request, particularly in consideration of its repetitive nature.

Who can access your data?

We only disclose your data to individuals duly authorized to use it for the implementation of our surveys.

Please note that your personal data may be communicated, only with your explicit consent, to commercial partners to allow you to benefit from their offers and services.

How do we protect your data?

We implement all technical and organizational measures required to ensure the security of your data on a daily basis and, in particular, to combat any risk of unauthorized destruction, loss, alteration, or disclosure of your data (e.g., training, access control, antivirus, etc.).

Can your data be transferred outside the European Union?

Unless strictly necessary and exceptionally, we never transfer your data outside the European Union, and your data is always hosted on European soil. Furthermore, we make every effort to only engage service providers who host your data within the European Union.

Should our service providers nonetheless be required to transfer your personal data outside the European Union, we meticulously ensure that they implement appropriate safeguards to ensure the confidentiality and protection of your data.

Who can you contact for more information?

Our Data Protection Officer (“DPO”) is always available to explain in more detail how we process your data and to answer your questions on the subject at the following address: dpo@episto.fr.

How can you contact the CNIL (the French equivalent of the ICO - Information Commissioner Office)?

You may at any time contact the French data protection supervisory authority (the French equivalent of the ICO - Information Commissioner Office - the "Commission Nationale de l'informatique et des libertés" or "CNIL") at the following address CNIL Complaints Department, 3 place de Fontenoy - TSA 80751, 75334 Paris Cedex 07 or by calling at 00331.53.73.22.22.

Can the policy be modified?

We may modify our privacy policy at any time to adapt it to new legal requirements as well as to new processing activities that we may implement in the future. You will, of course, be informed of any changes to this policy.

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