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DCbrain – PRIVACY POLICY

This privacy policy (“Privacy Policy”) will explain how DCbrain uses the personal data we collect from you when you use our website (“Website”). By using our services or communicating with us about them, you acknowledge that your personal information will be processed in accordance with this Privacy Policy, as revised from time to time.

For certain uses of the Website, you may be asked to provide personal data. When this occurs, we will indicate what types of personal data are required. You may choose not to submit the requested data, but this may limit your access to the Website services.

Please read this Privacy Policy carefully to understand how we will treat your personal data before you share your information with us.

The Data Controller

For the collection and processing of personal data under this Privacy Policy, the data controller is:

DCbrain, a simplified joint stock company, whose registered office is located at 35 rue du Bac – 92600 Asnières sur Seine, registered with the Nanterre Trade and Companies Register under number 805 052 735 (“DCbrain”).

DCbrain has appointed a Data Protection Officer (DPO), who can be contacted by email at dpo@dcbrain.com and whose role is, in particular, to ensure that DCbrain complies with the French Data Protection Act of January 6th 1978 (as amended), the EU General Data Protection Regulation of April 27th 2016 and any other applicable laws regulating the processing of Personal Data (hereinafter the “Data Protection Regulations”), and to respond to any requests and questions that are submitted.

a) How is your Personal Data collected and processed by DCbrain?

b) What Personal Data is collected?

When you use the Website, DCbrain will collect the personal data you provide us, including personal identification information (e.g. name, email address, location, phone number, etc.).

In addition to the personal data you provide to DCbrain, DCbrain may collect, record and process additional data, including personal data, generated as a result of using the Website. This may include the following types of data:

Data from the used equipment, such as a unique device ID, version of the operating system and settings of the device you use to access a service;
Information about the use of a service, such as the time at which you use the service and the type of service that is used;
Location details from your device or derived from your IP address that is provided to us when you use a particular service;

Data available from external sources. We may receive information about you from public or commercially available sources.

c) How do we collect your data?

You directly provide DCbrain with most of the data we collect when you use the Website. In particular, we collect data and process data when you:

Fill in the “Contact Us” form;
Request a demo ;
Register to the newsletter ;
Send us an email;
Share the webpages of our Website on social media platforms;
Download files on the Website (such as ebooks, reports);
Use or view the Website via your browser’s cookies.

DCbrain may also receive your data indirectly from publicly accessible sources (e.g. Google, LinkedIn) or non-publicly accessible sources.

d) How will we use your data?

DCbrain will process your Personal Data it collects when you use the Website, in accordance with this Privacy Policy. Your Personal Data may be used for the following purposes:

Website Browsers / Administration. We use your Personal Data for administrative purposes, including to help us better understand how visitors access and use our Website and applications; to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, partners and us; and to enforce our policies, directives and processes.
Marketing. To the extent permitted by law and as described under Section 3 (Marketing-Commercial prospection) below, we may use your Personal Data for marketing and promotional purposes, including communications through email or equivalent electronic means. For example, we use your Personal Data, such as your email address for news and newsletters, research, event updates, product data, and to otherwise contact you about services or information we think will interest you.
We use your Personal Data to communicate with you, including responding to requests for assistance, information, newsletter, or career information. We may communicate with you in a variety of ways, including email, via your social media accounts if you have agreed, and/or text message.
Customer service. We use your Personal Data for customer service purposes, including providing services to you, for technical support or other similar purposes and to establish and maintain customer accounts.
Research and development. We use your Personal Data for research and development purposes, including improving our Website, applications, services, and customer experience and for other research and analytical purposes dedicated to improving our products, services, businesses, operations and processes.
Legal compliance. We use your Personal Data to comply with applicable legal regulations, including responding to an authority or court order or discovery request.
No automated decisions. There is no fully automated decision making by DCbrain based on your personal data.

e) What is the basis for the processing of your Personal Data?

We process your Personal Data in accordance with the provisions set out in the GDPR and other applicable Data Protection laws and regulations. The legal basis for processing your Personal Data are:

To comply with contractual obligations or to take steps at your request before entering into a contract. When you subscribe to a particular service through the Website, the purposes of processing your Personal Data are primarily determined by that service and we will process your information so that we may provide that service to you, assist you and answer your requests, or evaluate if we can offer you a product or service and under which conditions. In this respect, the purpose of the contact form, is to establish a relationship. The legal basis for this processing is the execution of a contract or pre-contractual measures. If you decide not to provide us with the data necessary to establish contact, we shall be unable to contact you for this purpose.
As a result of your consent. When you have consented to the processing of your Personal Data by us for certain purposes through the Website, for instance through the Contact Us form. However, if we need to carry out further processing for purposes other than those for which you provided us with your consent, we will inform you and, where necessary, obtain your consent. You may withdraw your consent at any time. For further information on the right of withdrawal, please see Section 5 (What are your data protection rights?) below.
Within the scope of a legitimate interest. On occasion, where we have a legitimate interest to process your data, we may not need your consent to do so, however, we must inform you that we do this; examples of this are for:
- The analysis and optimisation of the Website;
- Ensuring IT security and the operation of DCbrain’s IT;
- Prevention and investigation of criminal acts.
- On the basis of DCbrain’s legal obligations or in the public interest. In some cases the processing of your Personal Data will be necessary for DCbrain to fulfil legal or public interest obligations.

f) How do we store your data?

Your personal data will be stored by us and our service providers in accordance with applicable data protection laws to the extent necessary for the processing purposes set out in this Privacy Policy. As a global enterprise, our usage of the Internet almost always involves the international transmission of personal data, both within and outside the European Economic Area (EEA). In case of international transfers originating from the EEA, where the European Commission has recognized a non-EEA country as providing an adequate level of data protection, your personal data may be transferred on this basis.

For transfers to non-EEA countries whose level of protection has not been recognized by the European Commission, we will either rely on a derogation applicable to the specific situation (e.g. if the transfer is necessary to perform our contract with you ,such as when making an international payment) or implement the Standard Contractual Clauses adopted by the European Commission.

f) For how long will your Personal Data be stored?

Your data will be kept for the duration of our relationship (for example until you unsubscribe to a newsletter) and kept for a maximum of two years after the end of this relationship.

For prospects and Personal Data sent through online forms, information is kept for two years.

For any other data and/or purposes, your personal data are retained only for the time necessary to achieve the purpose for which such personal data were collected and for any required or permitted period under applicable laws. Once the applicable time period has expired, we will delete your data by including it in batches of data to be flagged for deletion after the relevant time period.

g) Who will receive your data?

We communicate your Personal Data only to identified and duly authorized recipients. These include:

Affiliates and subsidiaries of the DCbrain group of companies (“DCbrain group”)
Financial or judicial authorities, state agencies or public bodies, upon request and to the extent permitted by law;
External providers performing services on DCbrain’s behalf.Marketing – Commercial prospection

3) Marketing – Commercial prospection

For sending commercial solicitations by email on products similar to those ordered by customers: the legal basis of the processing is the legitimate interest of DCbrain (Cf. article 6.1.f) of the GDPR), namely to promote our products to our customers.

For sending commercial solicitations by e-mail on other products offered by DCbrain: the legal basis of the processing is the consent (Cf. article 6.1.a) of the GDPR), as required by article L. 34-5 of the French Post and Electronic Communications Code.

If we use electronic prospecting, your consent will be required, except if you are already a customer and the commercial prospecting deals with products similar to those we already provide you with.

If you have agreed to receive marketing communications, you may always opt out at a later date. You have the right at any time to stop DCbrain from contacting you for marketing purposes or giving your data to other members of the DCbrain group. If you no longer wish to be contacted for marketing purposes, please contact us at: marketing@dcbrain.com

If you are invited to and/ or attend one or our events, we will collect and process your contact information and any other information we may need to manage our invitation and your attendance in accordance with this Privacy Policy.

4) Cookies

This website uses cookies. This website stores cookies on your computer or device. These cookies are used to help us collect information about how you use our website and enable us to remember you. This information is used to customize your experience and for analytics about our visitors on this website and other media.

The Website uses the following third party cookies:

Essentials (1)

Essentials cookies allow basic functionalities, the Website cannot function properly without those cookies.

Name	Provider	Purpose	Expiry
borlabs-cookie	Borlabs Cookie	Save visitors’ preferences selected in Borlabs Cookie’s Cookie Box	1 year

Statistics (1)

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Name	Provider	Purpose	Expiry
_ga,_gat,_gid	Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland	Cookies used for analysing this Website. Generates statistical data on how visitors use the Website	2 months

Third party media (3)

Content from video platforms and social media is blocked by default. If cookies from third party media are accepted, access to these contents do not need manual consent.

Name	Provider	Purpose	Expiry
Google Maps	Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland	Authorize Google Maps contente	6 months
Twitter	Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland	Authorize Twitter content	Unlimited
Youtube	Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland	Authorize Youtube content	6 months

5) What are your data protection rights?

DCbrain would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access– You have the right to request copies of your personal data that DCbrain holds.
The right to rectification– You have the right to request that DCbrain correct any information you believe is inaccurate. You also have the right to request DCbrain to complete any information you believe is incomplete.
The right to erasure– You have the right to request that DCbrain erase your personal data, under certain conditions.
The right to restrict processing– You have the right to request that DCbrain restrict the processing of your personal data, under certain conditions.
The right to object to processing– You have the right to object to DCbrain processing your personal data, under certain conditions.
The right to data portability– You have the right to request that DCbrain transfer the data that we have collected to another organization, or directly to you, under certain conditions.
The right to decide what happens to your personal data after your death.You have the right to give instructions regarding the storage, deletion and disclosure of your personal data after your death.

(Collectively a “Data Subject Access Request” or “DSAR”)

If you make a DSAR, we have 30 days to respond to you. If you would like to exercise any of these rights, please contact us at: dpo@dcbrain.com

Or write to us: DCbrain – Attn. Data Protection Officer. 46 rue de l’échiquier, 75010 Paris, France.

If you consider that DCbrain does not respect its obligations in terms of protection of Personal Data or does not respond to your requests in a satisfactory or timely manner, you may contact the National Commission for Data Protection and Liberties (CNIL-France) via its website (www.cnil.fr) or by mail (CNIL, Service des Plaintes, 3 place de Fontenoy – TSA 80715 -75334 Paris Cedex 07).