Privacy Policy

Last updated on October 6, 2021

This privacy policy (hereinafter the "Privacy Policy") governs your ("Your," "You," "Your" as applicable) access to the website of JERING SAS, whose registered office is located at 5 Avenue du Général De Gaulle, 94160 Saint-Mandé, France, registered in the Créteil Trade and Companies Register, under number 843 146 218 ("Episto"), accessible at the following URL:
https://www.episto.fr/ (the "Website"), and Your participation in campaigns organized by Episto on its behalf and/or on behalf of its partners (the "Campaigns") via any means of communication as specified in this Privacy Policy. The Privacy Policy also governs the collection and processing of Your personal data by Episto or by any of its affiliates.

1. General Information
By accessing and/or using the Website, You agree to all of the terms and conditions set forth in the Privacy Policy and the terms and conditions of the Website and, in particular, to the terms and conditions of access to and/or use of the Website as they relate to Your age. EPISTO is responsible for the Data collected under the Privacy Policy, and acts as a data controller in accordance with applicable law and this Privacy Policy.

‍2. Data Collection
EPISTO collects Your personal data (hereinafter referred to together as the "Data"): (i) Data regarding Your browsing of the Website, (ii) Data submitted when You participate in Campaigns, (iii) Data to send You a newsletter regarding EPISTO's activities, and (iv) Data to fulfill Your order for products.

2.1. Browsing Data
When You browse the Website, Data about Your computer hardware and software may be collected by EPISTO through the use of tracking devices such as cookies. This Data may include: Your IP address, Your browser, domain name, time and date of connection and the address of the referring website. EPISTO processes the Data in order to: enable the Website to function properly, including to: ensure that content is displayed correctly, improve the functionality of the Website, ensure that use of the Website is secure and, to protect You from fraudulent use of the Website, including by searching for errors and compiling statistics on the habits of visitors to the Website. Browsing Data is kept only for the time necessary to achieve the purpose for which it was collected and for any period defined in accordance with local regulations and instructions.

2.2. Newsletter Subscription
When You subscribe to the Newsletter, EPISTO collects Your email address in order to send You commercial and promotional emails, and to send You questionnaires in order to survey Your opinion about the Website and about possible new services that could be offered to You. If You have consented to receive the Newsletter, EPISTO will keep Your Data until You unsubscribe, until You request us to delete Your Data, or after a period of two years from the last newsletter sent to You by EPISTO.

2.3. Participation in Campaigns
If You decide to participate in Campaigns organized by EPISTO, please note that Your answers to the Campaign questions could be considered as Data and could include, if You fill in this information, personal data relating to Your age, Your professional situation, Your zip code and Your interests. When You participate in the Campaigns, We ask You for Your express consent to the processing of Your Data as follows: the transfer of Your answers in an anonymized way, in statistics and/or aggregated with the answers of the other participants in order to compare and analyze the results with commercial partners related to the Campaign; if You have given Your express and specific consent: the transfer of Your email and last name, first name, for the sending of the invitation to participate to a survey. Warning: Although Your Data is published anonymously, We invite You to be vigilant before participating in the Campaigns and consenting to the various types of data processing. Certain Data, in particular relating to Your age, location and professional situation, when combined, could allow third parties to recognize You, and thus, to know Your responses to the Campaigns. In no case EPISTO can be held liable for any damage resulting from such an event. If You have consented to respond to Campaigns, EPISTO will keep Your responses anonymized until You ask Us to delete them, or after a period of two years from the end of the Campaign.

3. Third-Party Sites/Apps
The Campaign may link to websites and/or applications operated by third-party companies over which EPISTO has no control. This Privacy Policy applies only to information collected by EPISTO through the Campaign and the Conversations and does not apply to third-party websites. You are solely responsible for any Data which You choose to disclose to such third-party websites. EPISTO does not monitor, control or endorse the Data collection or privacy practices of these third-party companies. EPISTO encourages You to review the privacy policies of the websites which You choose to visit in order to understand how those websites collect, use and share Your information.

4.1. Facebook
Please note that the Campaigns can be hosted on the Facebook website, which is accessible at the following URL: https://www.facebook.com. We have no affiliation with Facebook. To learn about how Facebook uses Your Data, we invite You to consult their privacy policy at:
https://www.facebook.com/policy.php. Under no circumstances shall EPISTO be liable for any use of Your Data by Facebook.

4.2. Instagram
Please note that the Campaigns can be hosted on the Intagram website, which is accessible at the following URL: https://www.instagram.com/. We have no affiliation with Instagram. To learn about how Instagram uses Your Data, we invite You to consult their privacy policy at: https://help.instagram.com/help/instagram/519522125107875/?locale=en_US. Under no circumstances shall EPISTO be liable for any use of Your Data by Instagram.

4.3. Snapchat
Please note that the Campaigns can be hosted on the Snapchat website, which is accessible at the following URL: https://www.snapchat.com. We have no affiliation with Snapchat. To learn about how Snapchat uses Your Data, we invite You to consult their privacy policy at: https://snap.com/fr-FR/privacy/privacy-policy/. Under no circumstances shall EPISTO be liable for any use of Your Data by Instagram.

4.4. Linkedin
Please note that the Campaigns can be hosted on the Linkedin website, which is accessible at the following URL: www.linkedin.com. We have no affiliation with Linkedin. To learn about how Linkedin uses Your Data, we invite You to consult their privacy policy at: https://www.linkedin.com/legal/privacy-policy. Under no circumstances shall EPISTO be liable for any use of Your Data by Instagram.

5. Transfer of Data

5.1. Internal Use
EPISTO guarantees that the Data is only used internally and in the European Union for the purposes described in Section 2 of the Privacy Policy. The Data will not be sold to any third party, nor will it be transferred outside the European Union.

5.2. Campaigns
EPISTO may organize Campaigns for its trusted partners for commercial purposes. In such a case, You will be informed in the Campaign, and Your Data will be transferred via secure means to these third parties, for the purposes specified in the Campaign and for which You have given Your consent.

5.3. Trusted Partners
EPISTO may share Your Data with its trusted partners in order to provide hosting services (AWS/Heroku), to analyze Data related to Your use of the Conversation (AppSignal).

5.4. Legal Disclosures
EPISTO may disclose Data, without prior notice, if required to do so by law and/or in the event that this transfer is strictly necessary to: (a) comply with the law or with a legal proceeding brought against EPISTO, (b) protect and defend the rights and/or property of EPISTO, (c) act in an emergency to protect the personal safety of EPISTO users and/or the public, and (d) as necessary to provide the Services You have requested.

6. Security and storage of Data
Taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the data processing carried out under this Privacy Policy, EPISTO secures Your Data by implementing adequate internal and/or third-party technical devices in order to protect it from unauthorized access, loss, damage and/or misappropriation. The Data is stored on a third-party server located in Europe for the periods of time specified in Section 2 and on Facebook with regard to Data related to Campaigns.
When the retention period expires, the Data is anonymized and is retained for statistical or evidentiary purposes. When these purposes have expired, the Data is destroyed.

7. Your Rights
In accordance with applicable law, You have the right to access, rectify, portability and/or erasure of Your Data as well as to restrict its use, disable cookies and/or withdraw Your consent for the processing of Your Data at any time. To do so, You may at any time make this request at the following email address:
dpo@episto.fr or by postal mail at the following address: EPISTO, Personal Data, 5 Avenue du Général De Gaulle, 94160 Saint-Mandé, France. Please note that the exercise of Your rights may have the impact of limiting certain services provided by the Website, and that to ensure compliance with applicable law, EPISTO may be obliged to retain some of Your Data for evidentiary purposes. EPISTO will inform You in such a case. You have the right to contact the French Data Protection Authority (CNIL) at any time regarding Your requests under this section (www.cnil.fr).

8. Amendments to the Privacy Policy
EPISTO reserves the right to amend this Privacy Policy at any time. Any amendments will be the subject of a special notice on the Website. You acknowledge and agree that your use of or access to the Website after the date of such amendments shall constitute your acceptance of the Privacy Policy as amended.

9. Applicable Law
This Privacy Policy is governed by French law. Any dispute and/or objection shall be submitted to the competent court of Paris. This Privacy Policy is written in French. The invalidity of a clause shall not result in the invalidity of the Privacy Policy. The temporary or permanent non-application of one or more of the clauses of this Privacy Policy shall not constitute a waiver of the other clauses.

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