Version 3


<aside>

Help center

Legal Information

Accessibility

Ethics

Terms of Use

Privacy Policy

</aside>

1. Identification and introduction

Efalia Engage is a simplified joint stock company with a capital of 41,190 euros, registered in the Paris Trade and Companies Register under number 812 620 318, whose registered office is located at 17 rue Meslay, 75003 Paris, France ("Efalia Engage" or "We"), which offers consulting and development of digital platforms for consultation and citizen participation, according to the following general terms of use Terms of Use (the "Services").

Efalia Engage processes personal data about you in connection with the use of the web application it operates and markets (the "Application"), and its website accessible through the following address https://www.flui.city/ (the "Site") as part of the Services.

Efalia Engage respects the privacy and protects the personal data of users of the Services ("Data").

Efalia Engage is aware of the importance of maintaining the confidentiality of your Data and is committed to protecting your Data as described in this Privacy Policy. The Privacy Policy may change as described in Section 13 below.

2. Object

The purpose of this policy is to explain to you the methods of collection, processing and use of your Data and your rights with regard to the protection of your Data in accordance with the applicable provisions in this area.

3. Our role in handling your data

As a SaaS platform provider, Efalia Engage has a dual role in data processing:

4. What Data may we collect?

When you use the Services, we may collect the Data listed below:

Identity and address

Your title, gender, first and last name, profile picture, email address, home address, neighborhood, date of birth and gender at birth;

Activity and use of the Services

This data relates to your activity on the Site or Application, such as the type of content you view, the content you post, the frequency and duration of your activities;

Technical information

the version of the Application used, the type of operating system, the model of smartphone, the browser used and its version, the time zone used, the language used, your notification preferences and IP address; and

Your browsing history and activity in connection with the use of the Services.

The data that you must provide in order to benefit from the Services are indicated as such in the collection forms. If you do not provide this information, you will not be able to access the Services.

5. Why do we collect your Data, and for how long?

We process your data for the following purposes and on the following legal grounds:

Traitements & Finalités Bases légales Durées de conservation
Gestion des comptes utilisateurs
Inscription et utilisation de la plateforme.
Personnalisation de l’expérience.
Gestion des préférences.
Vérification de l’identité.
Demandes et réclamations.
Modération. Exécution du contrat, obligation légale Tant que l’utilisateur à un compte ou après 36 mois d’inactivité.
Statistique de représentativité
Fournir aux clients des statistiques agrégées sur l’activité et la représentativité des utilisateurs. Consentement Modifiable dans le profil utilisateur. Tant que l’utilisateur à un compte ou après 36 mois d’inactivité.
Statistique d’utilisation des services
Amélioration des services et développement de nouvelles fonctionnalités. Intérêt légitime 3 mois
Réalisation d'enquêtes de satisfaction clients Consentement Le temps de la relation commerciale.

To what extent do we share Data with our customers?

In addition to the data collected by the Clients themselves on the Application for which they are responsible for processing, we are required to transmit :

Your identification data

In the course of fulfilling our contractual obligations to client organizations (e.g., securing access to a consultation; e.g., allowing tracking of event registrations)

Your contact information

For matters strictly related to the use of the Efalia Engage platform or, with your specific and prior consent, in the context of a non-commercial use outside of the Application (e.g. subscription to the client organization's newsletter).

How do we ensure the privacy of Data in voting and survey responses?

We only share with our Customers aggregated information (non-individualized data) about votes and responses to surveys/polls conducted on the Application, such as the results of a survey/poll. In other words, we do not share with them any Individualized Data about you in connection with your votes or your participation in surveys/polls published on the Application.

6. To whom will your Data be transmitted?

Other than as set forth in Section 5, we only share your information with our service providers who help us operate our business, in which case these third parties are required to comply with the GDPR framework.

7. Where do we store our databases?

Our production base is kept on the servers of our subcontractor which are necessarily located on the territory of the European Union.

Efalia Engage ensures that the security and privacy policies of the service providers it works with are consistent with this Privacy Policy to ensure the security of your Data.

8. What are your rights to your Data?

You have the following rights, under the conditions set by the applicable law: the right of access to all your Data, the right to rectify or delete your Data, the right to object, the right to limit and the right to portability. You also have the right to define directives concerning the conservation, deletion and communication of your Data after your death.

You may exercise these rights or ask any questions regarding your Data and its processing by writing to Us at the following address: [email protected] or by postal mail to the following address: (i) Efalia Engage SAS, 17 rue Meslay, 75003 Paris, France or (ii) Efalia Engage Belgium SRL, avenue Louise 523, 1050 Brussels, Belgium

In the interest of confidentiality and protection of personal data, we must ensure the identity of the user before responding to his request, thank you for attaching a signed copy of your identity card.

Moreover, you can also directly and via your personal space :

You may also delete your account by sending a request to us at [email protected].

Finally, you have the right to lodge a complaint with the competent supervisory authority.

9. What cookies do we use?

When you use the Services, cookies may be automatically installed on your browser and terminal. Cookies are blocks of data that are used to record information about your browsing and use of the Services. Efalia Engage uses the cookies listed below to analyze how you use the Services and to be able to provide you with customized Services and more relevant information.

Technical / strictly necessary cookies (internal cookies, New Relic)

These are cookies that are essential for the functioning of the Application and the Site.

They allow you to navigate on the Application and the Site in a secure and fluid manner and to use its functionalities. When you are connected, these cookies allow us to identify you (session cookies), to deal with any technical errors and to allow you to use the essential features of the Application and the Site.

Functional cookies (Facebook, Google+ Platform, Youtube, Vimeo)

These cookies enable specific and optional features on Efalia Engage to improve your user experience. They allow you to use third-party services within Efalia Engage that allow authentication (via Facebook or Google) or to view content hosted on other platforms (YouTube or Vimeo).

With the exception of the so-called "strictly necessary" cookies, the installation of these cookies requires your express consent. To avoid depositing superfluous cookies, your consent will be requested for each third-party service requiring the deposit of a so-called functional cookie (Facebook, Google, YouTube or Vimeo), prior to the first use. This choice can be modified at any time via your account settings. Also, you can manage, deactivate or authorize cookies by changing the settings of your Internet browser by consulting the links below:

The use of the Application and the Site may result in the installation of certain cookies issued by third parties (communication agencies, audience measurement companies, social networks, YouTube, etc.) which Efalia Engage does not control. The issuance and use of cookies by third parties are subject to the privacy policies of these third parties.

11. What security measures have been implemented?

In order to guarantee the security of your data, Efalia Engage takes all the necessary precautions, whether physical, logical, administrative or organizational, with regard to the nature of your data and the risks presented by the various processes, to preserve the security of the data and prevent it from being distorted, damaged or accessed by unauthorized third parties.

authorized to access it. As such, we use SSL encryption for data transmission between endpoints and our service providers' servers and we monitor and manage access to your information within Efalia Engage.

In addition, the password for your identifiers to access the Services must be composed of at least 8 characters and contain an upper case letter, a number and a special character.

12. What about third-party sites?

Links on the Services may direct you to external sites. In this regard, you should note that the personal data protection policies of these sites may differ from the present policy. It is therefore recommended that you read the personal data protection policy of each of the sites concerned.

In any case, Efalia Engage cannot be held responsible in the event that the content of one of the sites contravenes the legal and regulatory provisions in force.

13. Update of the Privacy Policy

We reserve the right, at any time, to modify this Privacy Policy, in particular in accordance with the legal and regulatory context and the doctrine of the supervisory authorities (e.g. the Commission Nationale de l'Informatique et des Libertés (CNIL) in France, and the Commission de la Protection de la Vie Privée (CPVP) in Belgium). If the changes are material, we will notify you in advance by email or through a pop-up message on the Site and the Application, so that you can review the revised Privacy Policy before continuing to use the Services.