Confidentiality Policy

The purpose of this confidentiality policy is to inform users of the Track-a-Poo application of the methods of collecting, processing and using their personal data and of their rights in terms of the protection of personal data with regard to the provisions applicable in this area, in particular Act 78-17 of 6 January 1978 on Data Processing, Data Files and Individual Liberties, known as the "Data Processing and Individual Liberties Act", and the European Regulation on the Protection of Personal Data 2016/679, known as the "GDPR".

INFOSTRATES, a "Société par Actions Simplifiée" (simplified joint stock company) with its registered office at ZAC de la Valentine, 4 Montée du Commandant de Robien, 13011 Marseille, registered in the Marseille Trade and Companies Register under number: B 418 748 125, hereinafter referred to as "the Publisher", is responsible for processing the data collected within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and Law no. 78-17 of 6 January 1978.

Data collection - Legal basis for processing

The categories of User personal data processed by the Publisher under these T&Cs are as follows:

The collection and processing of the aforementioned data is justified by the Publisher's legitimate interest insofar as this data is necessary for the provision of the Application's services.

The data is collected by the Publisher directly from Users and the Referring Agency.

Users are informed of the existence of the processing of their data when they register for services and have the right to object to such processing at a later date, subject to the reservations provided for by the regulations in force, in particular Articles 17 and 21 of the GDPR, in the case of data processing justified by a legitimate interest or by the need to perform a contract.

The Publisher's personal data processing policy can be consulted directly from the application download page on the Stores. Validation of the User Account implies acknowledgement by the User that he has been informed of the conditions for processing his personal data as set out herein, and that he accepts them unreservedly.


Purposes of processing

Users' personal data collected during registration and use of the Application are processed to enable use of the services offered by the Application, such as in particular the identification of the User and his pet(s) with a view to accessing the studies offered by the Publisher via the Application, and its Referring Agency.


Circulation of data

The Publisher only uses the aforementioned data for its own needs and those of its partners, such as veterinarians, laboratories, commercial partners, food manufacturers and technical service providers, solely for the purposes set out in this confidentiality policy.

The User is hereby informed and expressly consents to his data being passed on to the categories of recipients referred to in the previous paragraph.

The data will not be used for any other purpose and will not be passed on to third parties other than the aforementioned persons.

The Publisher may, however, use technical service providers, in particular for hosting the Application on shared server infrastructures.

In this case, the User's data may be accessible to the technical service provider, strictly within the framework of the service provided. In this respect, the Publisher undertakes to contractually and technically regulate the access of the service provider to personal data in the strictest possible way, in particular by means of confidentiality agreements.

In the event that the Publisher transfers personal data to a foreign country, in particular if its servers hosting the data are located outside the European Union, the Publisher undertakes to ensure that the contracts concluded with the service providers concerned include the standard contractual clauses established by the European Commission to guarantee the security and confidentiality of the transferred data.


Retention period

The User’s personal data is kept for the entire period of validity of the User Account, for the purpose of providing the services. They are then kept for a period of 5 years following the deletion of the User Account, for probationary and archival purposes.

The User is informed that the processed data transmitted to the partners of the Editor or the referring Veterinarian in the context of the use of the services are likely to be kept and processed by them, without intervention of the Editor, for a period longer than that provided for in the preceding paragraph, in particular to meet the legal obligations imposed on them.


Security

The Publisher undertakes in particular to:


Users' rights

In accordance with the «Data Protection Act» of 6 January 1978 and Regulation (EU) 2016/679 of 27 April 2016, Users have an individual right of access, rectification, erasure, limitation, opposition and portability of data concerning them.

To exercise these rights, the User must make the request to the publisher, indicating his full name, address and e-mail address, under the following conditions:

The Publisher may, if it deems it necessary, verify the identity of the User by transmitting a copy of a valid signed identity document.

Users also have the right to lodge complaints with the competent supervisory authority concerning the exercise of the aforementioned rights. For Users domiciled in France, the competent supervisory authority is the CNIL.


Scope of the Privacy Policy

The information provided herein regarding data processing concerns only the use of the Application, excluding data processing carried out by the Publisher’s partners, outside the Application