1. About this Policy

This Privacy Policy explains how we ("Transvibe", "we", "our") collect, share, and use your personal information when you use our website transvibe.com (the "Site") or subscribe to our services as a customer or provider.

2. Personal Information We Collect and Why

The types of personal information we collect about you and the reasons we process them are as follows:

• Email address, electronic identification data (including when you sign up via Google or Outlook):
  • Why we collect it: To provide our services to our customers (including trial users), manage access to our services, and enable sharing features.
  • Legal basis for processing: Contractual necessity.
• Identification data, electronic identification data, and internet connection usage data:
  • Why we collect it: To generate business statistics and traffic related to the usage of our services.
  • Legal basis for processing: Our legitimate interest in understanding the popularity of our services to optimize their visibility or interface.
• Identification data, electronic identification data, and internet connection usage data:
  • Why we collect it: To provide personalized responses to your inquiries via the chatbot or when you contact us.
  • Legal basis for processing: Our legitimate interest in responding to requests.
• Email address, identification data:
  • Why we collect it: To manage our relationship with customers and providers (including invoices and payments).
  • Legal basis for processing: Contractual necessity.
• Name, email address:
  • Why we collect it: To send you marketing updates and messages about our services.
  • Legal basis for processing: Consent (unless a legal exception applies, in which case we would rely on our legitimate interest to promote our services).
• Any relevant or potentially relevant information for a dispute or legal proceedings involving us:
  • Why we collect it: For disputes and legal proceedings.
  • Legal basis for processing: Our legitimate interest in defending our rights and interests in court.

3. Sharing of Personal Data by Transvibe

We may share your personal information with the following categories of recipients:

• Our third-party service providers who process data on our behalf, including in the areas of billing and payment services, customer support, website hosting, marketing and newsletters, and data analysis.
• Any competent law enforcement authority, regulatory agency, government agency, court, or third party when we believe disclosure is necessary: (i) in compliance with applicable law or regulation, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect your vital interests or those of another person.
• Our auditors, advisors, legal representatives, and similar agents in connection with the consultancy services they provide to us for legitimate business purposes, subject to the contractual prohibition on using personal data for other purposes.
• A potential buyer (and its agents and advisors) in the context of any proposed purchase, merger, or acquisition of all or part of our business, provided the buyer is informed that your personal data will only be used for the purposes disclosed in this Policy.
• Any other person if you have given prior consent to the disclosure.

4. Protecting Your Privacy

We will process personal data in accordance with this Policy as follows:

• Fairness: We will process personal data fairly. This means we are transparent about how we process personal data and will do so in accordance with applicable law.
• Legality: We will process personal data only on lawful grounds.
• Purpose limitation: We will process personal data for specific and legitimate purposes and will not process it in a manner incompatible with those purposes, except as authorized by applicable data protection laws.
• Data minimization: We will process personal data that is adequate, relevant, and limited to what is necessary for the purposes for which the data is processed.
• Accuracy: We will take appropriate measures to ensure that the personal data we hold about you is accurate, complete, and, if necessary, up-to-date. However, it is also your responsibility to ensure that your personal data is as accurate, complete, and current as possible by promptly informing us of any changes or errors.
• Data security: We use appropriate technical and organizational measures to protect the personal data we collect and process about you. These measures are designed to provide a level of security appropriate to the risk associated with processing your personal data.
• Limited retention: We will retain your personal data in a form that allows you to be identified for as long as necessary to fulfill the purposes for which we process your data, and we will not store your data for longer, except as required to comply with applicable laws.

5. Data Storage, Retention, and Deletion

We retain the personal data we collect from you when we have a continuing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting obligations). We retain customer data for a maximum of 2 years following the termination of our contractual relationship. However, we will retain accounting-related personal data for a maximum of 10 years.

When we no longer need to process your personal data for legitimate business purposes, we will delete or anonymize it. If that is not possible (for example, because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from further processing until deletion is possible.

6. International Data Transfers

Your personal data may be transferred to and processed in countries other than the one in which you reside. These countries may have data protection laws that differ from those in your country (and in some cases, may not offer the same level of protection).

Specifically, our servers are located in France, and our third-party service providers operate in the EU and the United States. This means that when we collect your personal data, we may process it in one of these countries.

However, we have taken appropriate measures to ensure that your personal data remains protected in accordance with this Policy. This includes implementing the European Commission's standard contractual clauses for personal data transfers with our third-party service providers and partners. Further details can be provided upon request.

7. Your Data Protection Rights

You have the following rights in relation to your personal data:

• If you wish to access, correct, update, or request the deletion of your personal data, you can do so at any time by contacting us at: [email protected].
• Additionally, in certain circumstances, as stipulated in applicable data protection legislation, you may object to the processing of your personal data, request that we restrict the processing of your personal data, or request the portability of your personal data. You can exercise these rights by contacting us at the email address above.
• If we have collected and processed your personal data with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we have carried out before your withdrawal, nor will it affect the processing of your personal data carried out on legal grounds other than consent.
• You have the right to unsubscribe from marketing communications we send you at any time. You can exercise this right by clicking the "unsubscribe" or "opt-out" link in the marketing emails we send you.
• If you have a complaint or concern about how we process your personal data, we will strive to address these concerns. If you believe we have not adequately addressed your complaint or concern, you have the right to file a complaint with a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

8. Links to Other Websites

The Site may contain hyperlinks to third-party websites owned and operated by others. These websites have their own privacy policies, and we encourage you to review them. They will govern the use of any personal data you submit during your visit to these websites.

We are not responsible for and have no liability for the privacy practices of these third-party websites, and your use of such websites is at your own risk.

Last updated: 22/10/2023