Last updated: January 5, 2021
AVVINUE (d/b/a Pawtrip) is a simplified joint stock company with a capital of 500 euros, whose registered office is located at 57 rue Président Edouard Herriot - 69 002 LYON, registered in the trade and companies register under number 882 975 998 RCS LYON, and represented by its president, Madame Nicole CABA (hereinafter “ AVVINUE ”), working in the personal services business sector.
As part of its activities, AVVINUE has designed the SaaS solution accessible at the address https://www.avvinue.com/ and / or any suffixes and / or access fields that refer to this address, as well as via any shortcut and other mobile phone, tablet or computer application (the “ Solution ”).
The Solution is intended to be a simple and useful tool for establishing contacts, in the context of a move or relocation, allowing non-professional people concerned to come into contact with local partners involved in the sector of activity of their needs. associates and to manage, via a personal interactive dashboard, the follow-up of its contacts and related procedures (the “ Users ”).
The services that may be offered by the partners present on the Solution, in order to facilitate the relocation and / or relocation of the User, are, without obligation or exhaustiveness, immigration, transport solutions, concierge services, housing, insurance, taxation, banking, language courses, translations, etc.
The whole, in the general conditions of use of the Solution (CGU).
In any case, the Solution can not replace human resources, nor justify any exemption under the laws and regulations in force.
In this context, for AVVINUE, the preservation of Users' personal data is important.
AVVINUE undertakes to implement adequate measures for the protection, confidentiality and security of Users' personal data, in accordance with current European regulations, as issued by Regulation (EU) 2016/679 of the European Parliament and of the Council 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, and repealing Directive 95/46 / EC (general data protection regulation), and French, in particular the rules of national law applicable to the said Regulation.
The purpose of this charter (the " Charter ") is to inform and enlighten Users on the purposes of the collection and processing of their personal data by AVVINUE, as data controller.
Users are invited to read the Charter very carefully and to keep a copy which will be delivered in a durable medium by AVVINUE.
By accepting the Charter, Users accept all the provisions included therein relating to the collection and processing of their data, for the purposes explained below.
Users are required to provide their personal data in digital format when using the Solution.
1. Categories of personal data collected
No sensitive data is collected or processed by AVVINUE.
The User data that AVVINUE can collect and process consists of the following data:
a) identity: title , surname, first names, address, telephone number (landline and / or mobile), fax number, e-mail addresses, date of birth, internal processing code allowing the identification of the customer (this code internal processing can be the registration number in the national identification directory of natural persons (social security number), or the bank card number, or the number of an identity document). A copy of an identity document may be kept for the purposes of proof of the exercise of a right of access, rectification or opposition or to meet a legal obligation;
b) data relating to means of payment: postal or bank identity statement, check number, bank card number, expiry date of the bank card, visual cryptogram (the latter not being kept, in accordance with regulations in force) ;
c) data relating to the transaction such as the transaction number, the details of the purchase, subscription, good or service purchased ;
d) the family, economic and financial situation: married life, number of people making up the household, number and age of the child (ren) at home, profession, field of activity, socio-professional category, place of relocation, relocation, transfer, moving or moving, data related to associated needs;
e) data relating to the monitoring of the commercial relationship: documentation requests, test requests, product purchased, service or subscription taken out, quantity, amount, frequency, delivery address, history of purchases and services, return of products, origin of the sale (seller, representative, partner, affiliate) or of the order, correspondence with the customer and after-sales service, exchanges and comments from customers and prospects, person (s) in charge of the customer relationship ;
f) data relating to the payment of invoices: terms of payment, discounts granted, receipts, balances and unpaid debts not resulting in the exclusion of the person from the benefit of a right, a service or a contract subject to authorization by the Commission as provided for by the provisions of article 25-I-4 ° of the amended law of 6 January 1978;
g) the data necessary for carrying out loyalty, prospecting, study, survey, product testing and promotion actions , the selection of persons only being able to result from the analysis of the data listed above ;
h) data relating to the organization and processing of contests, lotteries and any promotional operation such as the date of participation, the answers given to the contests and the nature of the prizes offered;
i) data relating to the contributions of people who post opinions on products, services or content, in particular their pseudonym ;
j) data collected through electronic communications actions .
Other personal data may be requested in accordance with the need to operate the Solution, following prior notification and agreement to Users.
2. Principles applicable to the collection and processing of personal data
Legal basis for the collection and processing of personal data
The personal data of Users are processed by AVVINUE in the cases authorized by the regulations in force and under the following conditions:
- Obtaining a free, specific, informed and unambiguous consent from the User (or his legal representative in the event of minority or incapacity) to the processing of their personal data ;
- Collection of personal data necessary for the execution of the User's request ;
- Compliance with legal and / or regulatory obligations imposed on AVVINUE (such as the fight against fraud and corruption);
- Protection of the legitimate interests of AVVINUE (such as the protection of the security of its computer network).
User browsing information applicable to the collection and processing of personal data
When using the Solution or certain related services, certain data is collected automatically such as the IP address, the reference of the navigation software used, the navigation data (date, time, content consulted, search terms used, etc.), the references of the operating system.
Among the technologies used to collect Users' personal data, in order to improve the quality of its service and better meet their expectations, AVVINUE may use "php" or equivalent sessions, which store the data, using a unique session identifier. These sessions keep said data in memory for the duration of the Users' browsing.
The data collected during browsing is deleted at the end of the browsing session on the Solution, by the User or, where applicable, within a maximum of 13 months from their collection.
Purposes of the collection and processing of personal data
Users can use the Solution without the need to communicate personal data.
AVVINUE collects and processes User data for the following purposes:
(i) for the needs of use and improvement of the Solution by Users, including putting in contact with the professional partners listed on the Solution,
(ii) for the purposes of improving AVVINUE's commercial offers, in particular in the context of polls, surveys and other solicitations,
(iii) for the purposes of sending and communicating newsletters , various notifications ( electronic emails, sms, social networks such as WhatsApp, Messenger, telephone calls) informative or commercial alerts and / or news from AVVINUE To Desirous Users,
(iv) to respond to inquiries (online contact forms),
(v) to respond to applications for job offers (personal data collected: name (s), first name (s), e-mail, telephone number, CV, cover letters if attached,
(vi) to disseminate via the Solution and / or all social and communication networks and / or all other AVVINUE media and materials, whatever the form or nature, existing or future, the comments and / or opinions of Users on said Solution and / or on AVVINUE,
(vii) for any measure or project falling within an objective of User interest or improvement of the relationship and the customer experience,
(viii) to meet regulatory requirements in force or in the process of being adopted.
Retention period of personal data
The retention period of Users' personal data depends on the purpose concerned.
In this context, Users' personal data is kept for the time necessary to fulfill their request.
In the absence of any achievement, personal data is deleted within the time limits recommended by the Commission Nationale Informatique et Libertés (CNIL), at the end of a period of three years from their collection on the Solution, subject to:
- possibilities and legal obligations in terms of archiving,
- obligations to keep certain data, for probative purposes, and / or to anonymize them.
The User's personal data collected and processed, for the purposes of performing the offers, are kept for the time necessary to manage the contractual relationship, understood as the maintenance, by the User, of his personal account on the Solution.
By way of derogation, the personal data required to establish proof of a right or a contract are archived in accordance with legal provisions (5 or 10 years after the end of the commercial relationship, as the case may be).
3. Recipients of personal data collected
The personal information collected is intended exclusively for AVVINUE and will not be transferred or exchanged to third parties, other than for the purposes referred to in article 2 above.
As such, banking and billing data will be communicated to:
Only authorized personnel of the group and of AVVINUE service providers may have access to the personal data collected and be required to process them, without prejudice to their possible transmission to the bodies responsible for a control or inspection mission in accordance with the legislation and / or the regulations in force or for the purposes of responding to a judicial or administrative decision.
Subject to their perfect anonymization, AVVINUE is founded, in compliance with the textual provisions in force, to use the personal data of the Users, in particular for statistical purposes, measurement, transfer and / or exchange to third parties.
4. Transfer of personal data
The personal data of the Users collected is hosted in Europe / France.
The data host to which AVVINUE uses, as part of the storage of User data is :
IBM Cloud Storage
London, United Kingdom
In the event that AVVINUE uses service providers located outside the European Union as part of the collection and / or processing of Users' personal data, AVVINUE undertakes to verify that appropriate measures have been put in place to ensure that the data personal Users benefit from a level of protectionadéquat accordance with Article 5 below.
5. Protective measures put in place by AVVINUE
AVVINUE collects and processes the personal data of Users, in compliance with the regulations in force.
When the disclosure of a User's personal data to third parties is necessary and authorized, AVVINUE ensures that these third parties guarantee said personal data the same level of protection as that implemented by AVVINUE. In this context, AVVINUE asks each of its contractual partners for confirmation of compliance with the applicable regulations.
AVVINUE implements technical and organizational measures to ensure that the storage of Users' personal data is secure for the period necessary for the exercise of the purposes pursued.
AVVINUE draws the attention of Users to the fact that no transmission or storage technology is completely foolproof.
Also, in the event of a breach of Users' personal data, likely to create a high risk for the rights and freedoms of the latter, AVVINUE will inform the competent supervisory authority of this breach in accordance with the terms and conditions provided for by the regulations in force.
Users must exercise caution to prevent unauthorized access to their personal data and in particular to their computer and digital terminals (computer, smartphone, tablet in particular).
6. User rights
In accordance with the regulations in force, Users have the following rights, subject to legal and regulatory limitations:
Right to information on the collection and processing of personal data
AVVINUE undertakes to make its best efforts to ensure that the information communicated to Users is accessible, precise and transparent on the conditions for the collection and processing of their personal data.
Right of access / right to erasure ("right to be forgotten") / right of rectification / right of opposition / right to limit processing
Any User may, at any time, access the personal information concerning him held by AVVINUE He has the right to receive a copy in electronic form (for any additional copy, AVVINUE will be entitled to demand the payment of fees based on administrative costs. caused).
Each User has the right to request the deletion and / or rectification of their personal data concerning them when they are incorrect or obsolete. AVVINUE may retain certain personal data when required by law or in the event of a legitimate reason.
Users can object at any time for legitimate reasons:
- the use of their personal data, for direct marketing purposes, or
- the reuse of their personal data for processing other than those listed in article 2 above, except in the event of fulfillment by AVVINUE of one of its legal and / or regulatory obligations.
Users have the right to request that the processing carried out on their personal data be limited to what is strictly necessary. This right is applicable only:
- if the User concerned disputes the accuracy of his personal data;
- if the User concerned justifies that the processing of his personal data is unlawful and requests a limitation of their use rather than erasure;
- if AVVINUE no longer needs the personal data of the User concerned and these are still necessary for the said User for the establishment, exercise or defense of legal claims ;
- if the User concerned opposes the processing of his personal data based on the legitimate interest of the controller, justifying an overriding legitimate interest.
Right to complain to a supervisory authority
Any User, who considers that the efforts made by AVVINUE to preserve the protection of his personal data do not guarantee the respect of their rights, has the possibility of lodging a complaint with the competent supervisory authority (CNIL or any other authority mentioned on the list available from the European Commission).
Right to portability of their personal data
Users benefit from a right to the portability of their personal data, authorizing them to obtain from AVVINUE the said personal data concerning them, in a structured, commonly used and readable format.
In this context, Users can request that their personal data be transmitted to another data controller.
Right to decide the fate of personal data following death
Users also have the right to organize the fate of their personal data after their death by adopting general or specific directives that AVVINUE undertakes to respect.
In the absence of such directives, AVVINUE recognizes the heirs of the possibility of exercising certain rights, in particular the right of access if it is necessary for the settlement of the estate of the deceased and the right of opposition.
Exercise by Users of their rights
In order to exercise their rights, any User can contact AVVINUE, according to the following contact details:
Personal data service
57 rue Président Edouard Herriot - 69 002LYON
To help them in the exercise of their rights, AVVINUE informs Users that the CNIL has established and made available to them, on its website accessible at www.cnil.fr , models of letters.
Before processing the Users' request (s), AVVINUE will be justified in verifying their identity, asking them for any useful proof.
AVVINUE will respond to the requests of each User as soon as possible and in any case one (1) month from the justification, by the User in demand, of his identity.
In the event of the complexity of the requests and / or their number, this period may be extended by two (2) additional months, AVVINUE undertaking in any event to inform the User concerned of the extension and the reasons for the postponement.
7. Modification of the Charter
AVVINUE reserves the right to make changes to the Charter at any time in order to comply with legislative and regulatory changes and / or to improve its policy for processing and protecting personal data.
In the event of modification, a new version will be updated and put online with the date of the last update of the Charter.
Any new version of the Charter must be subject to prior acceptance by the Users.