Privacy Policy

Effective as of 17/04/2024.

For your convenience, we have provided an English translation of this page. This translation is for informational purposes only and is currently being updated. The definitive version of this page is the French version.

ARTICLE 1: PREAMBLE

This privacy policy aims to inform users of the Betina site:

• About how their personal data is collected. Personal data refers to any information that can identify a user. This may include: their first and last name, age, postal or email address, location, or IP address (non-exhaustive list);
• About the rights they have concerning their data;
• About the person responsible for processing the collected and processed personal data;
• About the recipients of this personal data;
• About the site's cookie policy.

This policy complements the legal notices and the General Conditions of Use available to users at the following address: www.askbetina.com/privacy

ARTICLE 2: PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA

In accordance with Article 5 of the European Regulation 2016/679, personal data is:

• Processed in a lawful, fair, and transparent manner in relation to the data subject;
• Collected for specific, explicit, and legitimate purposes and not further processed in a way incompatible with those purposes;
• Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, with respect to the purposes for which it is processed, is erased or rectified without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

The processing is only lawful if, and to the extent that, at least one of the following conditions is met:

• The data subject has consented to the processing of their personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which the controller is subject;
• Processing is necessary to protect the vital interests of the data subject or of another natural person;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, particularly when the data subject is a child.

ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED IN CONNECTION WITH NAVIGATION ON THE SITE

Article 3.1: Collected Data

The personal data collected in the context of Betina's activities are as follows:

• user’s email address upon their first connection to the site www.askbetina.com;
• documents, files, or any other information that the user chooses to upload or share on the site [www.askbetina.com], as well as the search terms entered by the user when using the internal search tools.

The collection and processing of this data serve the following purpose(s):

• identification and authentication: to ensure a secure and personalized use of the services of the site [www.askbetina.com], it is essential to be able to identify and authenticate users through the services of Betina;
• specific offers and services: the collection of information allows for providing tailored and personalized access to Betina's services;
• security: to ensure the security of the site, prevent fraud, and protect users, it is sometimes necessary to collect and analyze usage data to detect and address suspicious activities; and
• use of analytics software: use of analytics software to analyze and measure activity on the site [www.askbetina.com], while ensuring that no cookies are placed on users' devices during this information collection.

Article 3.2: Data Collection Mode

When the user navigates on the site www.askbetina.com, the following data is automatically collected:

• the type of browser and version;
• the operating system;
• visited pages;
• duration of the visit;
• traffic source;
• screen resolution;
• approximate geographical location.

It is important to emphasize that this data is collected anonymously and does not allow for the identification of an individual. It is used solely to improve the user experience and optimize the website. The collection thus does not require the placement of cookies on the client's browser.

These are stored by the data controller under reasonable security conditions, for a period of 12 months.

The company may retain some personal data beyond the periods announced above to fulfill its legal or regulatory obligations.

Article 3.3: Data Hosting

The site www.askbetina is hosted by:

Contabo GmbH

Aschauer Strasse 32a

81549 Munich, Germany

Article 3.4: Transmission of Data to Third Parties

The collected data may be transmitted to specific partners of Betina to ensure the proper functioning of Betina's services. Currently, we share information with:

• Open AI, United States: for the operation of language models
• Microsoft Azure, United States: for the use of hosted AI models
• Stripe Technology Europe, Ireland: to manage transactions and payments

We guarantee that these partners adhere to high standards of data protection and operate in compliance with the applicable regulations.

Article 3.5: Policy on "Cookies"

The cookies used on the site www.askbetina.com are solely for authentication purposes. In accordance with the General Data Protection Regulation (GDPR), these essential cookies, crucial for the proper functioning and security of the site, are not subject to explicit acceptance by the user. No other tracking or advertising cookies are used on the platform.

ARTICLE 4: DATA CONTROLLER AND DATA PROTECTION OFFICER

Article 4.1: The Data Controller

Personal data is collected by FEDERAGE SAS, a simplified joint stock company with a capital of 100€, whose registration number is 828 743 369 R.C.S. Paris.

The data controller can be contacted as follows:

By mail at the address: 44 boulevard du Temple, 75011, Paris;

By email: Contact

Article 4.2: The Data Protection Officer

The data protection officer of the company or the data controller is:

Arnaud RAMPONNEAU

44 boulevard du Temple, 75011 Paris

Contact

If you believe, after contacting us, that your "Computer and Liberties" rights are not respected, you may file a complaint with the CNIL.

ARTICLE 5: THE USER'S RIGHTS REGARDING DATA COLLECTION AND PROCESSING

Any user concerned by the processing of their personal data can assert the following rights, in accordance with European Regulation 2016/679 and the Data Protection Act (Law 78-17 of January 6, 1978):

• The right to access, correct, and delete data (set forth respectively in Articles 15, 16, and 17 of the GDPR);
• The right to data portability (Article 20 of the GDPR);
• The right to restrict (Article 18 of the GDPR) and oppose data processing (Article 21 of the GDPR);
• The right not to be subject to a decision based solely on automated processing;
• The right to determine the fate of data after death;
• The right to lodge a complaint with the competent supervisory authority (Article 77 of the GDPR).

To exercise your rights, please send your request to FEDERAGE SAS, 44 boulevard du Temple, 75011 Paris or by email to this address

For the data controller to comply with the request, the user may need to provide certain information such as: their first and last names, email address, and account number, personal space, or subscriber number.

Visit cnil.fr for more information on your rights.

ARTICLE 6: CONDITIONS FOR MODIFYING THE PRIVACY POLICY

The publisher of the site www.askbetina.com reserves the right to modify this Policy at any time to ensure compliance with the law in force.

Any modifications shall not affect subscriptions previously made on the site, which remain subject to the Policy in force at the time of the subscription and as accepted by the user during the validation of the subscription.

The user is invited to review this Policy each time they use Betina's services, without the need for formal notification.

This policy was issued on 17/04/2024.