PRIVACY AND PERSONAL DATA PROTECTION POLICY
WILCO takes protecting your privacy and personal data very seriously. This is why WILCO, which is responsible for processing the data you provide, is committed to protecting your privacy and data in line with all legal requirements in particular Regulation No. 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (henceforth referred to as General Data Protection Regulation or GDPR) and French Data Protection Law n°78-17 of 6 January 1978 (referred to as French Data Protection Law).
WILCO can be contacted by email at the following address: firstname.lastname@example.org
B – IN WHAT CONTEXT DOES WILCO COLLECT PERSONAL DATA FROM USERS?
WILCO processes personal data from Users in the following situations:
- when Users express interest in one of the themed programs developed by WILCO for startups, midcaps and large corporations
- when Users fill in the contact form to apply to one of the themed programs offered by WILCO
- when users fill in the contact form to sign up for a Q&A webinar relating to the aforementioned themed programs offered by WILCO
C – HOW EXACTLY DOES WILCO USE THIS PERSONAL DATA? WHAT IS THE LEGAL BASIS?
As a data processor, WILCO collects personal data from Users in a transparent, loyal and lawful way. The main objective when collecting the data is to provide Users with services that enable a safe, optimized, efficient and personalized experience.
The following table informs Users about (i) the different types of personal data collected by WILCO, (ii) how WILCO uses this personal data and (iii) the legal basis and exceptions justifying its processing, and therefore making it legal and loyal.
|What different types of personal data are collected by WILCO?||On what legal basis and/or exception is the processing of this data based?|
|When Users sign up to receive information about the themed programs or WILCO newsletter, WILCO collects their first and last name, company and email address.||The processing of this data is based on article 6 of the GDPR, which states that this is legal provided that the User has agreed to share their personal data for one or more specific purposes.|
|Via the contact forms on pages dedicated to themed programs, WILCO collects Users’ first and last name, company, job role and email address.||The processing of this data is based on article 6 of the GDPR, which states that this is legal provided that the User has agreed to share their personal data for one or more specific purposes.|
|Via the contact forms to become a mentor for the startups accelerated by WILCO, WILCO collects the User’s first and last name, telephone number, email address, and link to their LinkedIn profile.||The processing of this data is based on article 6 of the GDPR, which states that this is legal provided that the User has agreed to share their personal data for one or more specific purposes.|
|Via the contact forms to join the WILCO team on the “Team” page of the WILCO website.|
|How does WILCO use this data?||On what legal basis and/or exception is the processing of this data based?|
|Manage the signup process for the website newsletter for interested Users.|
|Manage the signup process for Users to receive information about the themed programs offered by WILCO on the website.|
|Manage the signup process via contact form for Users to become a mentor and coach the startups accelerated by WILCO.|
|Manage the process for Users to sign up for the Q&A webinars relating to the themed programs offered on the WILCO website. Prospection (in particular sending information related to the themed programs offered by WILCO).|
|Manage exchanges with Users interested in joining the WILCO team via the contact form on the “Team” page of the WILCO website.|
D – HOW LONG DOES WILCO KEEP USERS’ PERSONAL DATA?
Data retention periods
WILCO keeps personal data for the period necessary to achieve the objective for which the data is being processed.
WILCO keeps the personal data provided in contact forms and/or applications for 2 years.
In the event of a dispute, WILCO reserves the right to retain any data that may be useful during the entire period of the dispute. This data is then placed in a separate archive database for a period of 5 years following exhaustion of domestic remedies.
E – WHAT RIGHTS DO USERS HAVE IN RELATION TO THEIR PERSONAL DATA?
In line with applicable regulations, Users have the following rights:
access: Users have the right to access the personal data relating to them held by WILCO (provided that the request is not unfounded or excessive, particularly because of its repetitive nature) and obtain a copy of it.
modify: Users have the right to ask for the personal data to be modified if it is incorrect or no longer relevant and/or update the data if it is incomplete (provided that the request is not unfounded or excessive, particularly because of its repetitive nature).
delete: under certain circumstances, Users have the right to delete their personal data. This is not an absolute right given that WILCO may need to retain the User’s personal data for legitimate legal reasons.
restrict processing: Users have the right to request that the processing of their personal data is restricted, meaning that WILCO retains the data but cannot use or process it. This right applies in specific circumstances including:
- If the User contests the exactness/ correctness of the personal data – in this case, processing is restricted while WILCO checks whether the personal data is correct.
- If the processing is illegal but the User does not want the data to be deleted and instead demands that its usage is restricted.
- If WILCO no longer needs to process the personal data, but the User still requires it in order to establish, uphold or defend their rights.
- If the User objects to the processing based on the legitimate interests pursued by WILCO, while verifying whether the legitimate reasons pursued by WILCO prevail over those of the User or not.
oppose processing: the User can, at any moment, oppose the processing of their personal data for reasons relating to their specific situation, unless WILCO asserts legitimate and compelling reasons for its processing that prevail over the User’s interests, rights and freedoms or when this data is necessary to establish, exercise or defend a right in court.
data portability: Users have the right to receive the personal data relating to them, which they gave to WILCO and is present in WILCO’s database, in a structured, machine-readable and commonly used format. This only applies to the data the User has directly or indirectly provided, when the processing is based (i) on the User’s consent or on the performance of a contract and (ii) is carried out using automated processes.
define special directives relating to the conservation, deletion and communication of the User’s personal data after their death.
lodge a complaint with a supervisory authority: the User has the right to lodge a complaint with the French National Commission for Informatics and Freedoms (CNIL) to contest the practises used by WILCO in relation to the protection of personal data and privacy.
The User can, at any moment, exercise the aforementioned rights by sending a request to the following email address: email@example.com
F – WHAT RESPONSIBILITIES DO USERS HAVE IN RELATION TO PERSONAL DATA PROTECTION?
The User undertakes to ensure, as far as necessary, that their personal data is up to date. The User also undertakes to ensure that this personal data is precise, complete and sincere.
G – WHO RECEIVES/ACCESSES THE PERSONAL DATA PROVIDED BY USERS?
WILCO undertakes to keep all the personal data collected on the website and only share it in specific circumstances in line with applicable regulations.
Communicating personal User data internally: certain personal data provided by Users can be accessed by WILCO employees if they need this data to perform the objectives previously outlined in point C.
Communicating personal User data with third-party service providers: WILCO can give access to third-party service providers subcontracted to carry out services relating to the website including hosting, storage, analysis, communication, data processing, managing contact forms, database or other IT maintenance.
These service providers exclusively follow instructions from WILCO and will only have access to personal data to carry out the aforementioned services and will be subject to the same security and confidentiality requirements as WILCO.
I – HOW CAN USERS CONTACT WILCO FOR ANY REQUESTS OR QUESTIONS RELATING TO THEIR PERSONAL DATA?
Updated May 31, 2021