Details of versioning and variations
- v1 published on 31/03/2020
This Agreement takes effect when you click on an “I Accept” button or checkbox presented with these terms or, if earlier when you use the Website (the “Effective Date”). You represent to us that you are lawfully able to enter into contracts (e.g. you are not a minor). If you are entering into this Agreement for an entity, such as the company you work for, you represent to us that you have the legal authority to bind that entity.
Before you submit any information on or through this website, please carefully review this Policy to understand our views and practices regarding your information and how we will treat it.
Please note that this Policy applies only to information collected through this Website and not to information you may provide to any third-party sites to which the Website may link, except as expressly provided herein. Third parties may include:
- Web analytic tools, like Google Analytics.
- Embedded web content, like videos from Youtube and Vimeo.
- Iframes from where we present external content to our site, e.g. from www.Supersaas.fr
- Embedded maps, like Google Maps.
- Web fonts from an external supplier
For the purpose of data protection laws applicable from time to time to you in the location that you provide your information (“Applicable Law”), LightOn SAS. will be a “data controller” (or such equivalent or replacement terminology as appropriate) for the information you provide through the website. There may be other controllers as well (e.g., advertisers), and we encourage you to consult their privacy policies to learn more about their privacy practices.
1. INFORMATION WE COLLECT
We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, such as from your browser or device.
A. Information You Provide Directly to Us
We may collect information from you during your use of or access to the website, such as when you:
- Fill in forms;
- Provide us with feedback;
- Subscribe to a service or request certain features (e.g., newsletters, updates, and other products or services);
- Use certain features that require your information to function (e.g., forms);
- Communicate with us by phone, e-mail or otherwise;
- Report a problem with our website;
The information you provide directly to us may concern you or others and include, but are not limited to: (i) name and surname; (ii) email address; (iii) age (iv) country of residence and time zone; (v) phone numbers and other contact details; (vi) demographic information; and (vii) birthdate.
You do not have a statutory or contractual obligation to provide us with your information; however, if you do not provide us with your information, we may not be able to provide you with the services you have requested or you may be limited in your use of our Website (e.g., if you do not provide us with your email address, we will not be able to send you newsletters).
B. Information that is Passively or Automatically Collected
- Device/Usage Information
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Website. As described further below, we may collect and analyse information such as (a) IP addresses, geolocation information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the website; and (b) information related to the ways in which you interact with the Website, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content (such as advertisements) viewed and the order of those pages, statistical information about the use of the Website, the amount of time spent on particular pages, the date and time you used the Website, the frequency of your use of the website, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
- Location Information
We and our service providers may automatically collect location information, including general information (e.g., IP address, zip code) from your computer or mobile device. If you access the Website through a mobile device, we may also ask you to share your specific geo-location information with us. The Website may use this location information to provide customized location-based services, content, promotional offers and other information that may be of interest to you. We may also use location information to improve the functionality of the Website.
- Cookies and Other Electronic Technologies
We and our service providers may also collect data about your use of the Website through the use of Internet server logs, cookies, and/or tracking pixels. A web server log is a file where website activity is stored to distinguish you from other users of our Website. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure the popularity of the Website and associated advertising, and to access user cookies. As we adopt additional technology, we may also gather additional information through other methods.
A visit to a page on the Website may generate the following types of cookies:
- Anonymous analytics cookies
- Geo-targeting cookies
Anonymous analytics cookies
Every time someone visits our Website, software provided by another organisation generates an ‘anonymous analytics cookie’. These cookies can tell us whether or not you have visited the site before.
Your browser will tell us if you have these cookies and, if you don’t, we generate new ones. This allows us to track how many individual users we have, and how often they visit the site. We cannot, and we do not use these cookies to identify individuals. We use them to gather statistics, for example, the number of visits to a page.
These cookies are used by software which tries to work out what country you are in from the information supplied by your browser when you click on a web page. This cookie is completely anonymous, and we only use it to help target our content.
Other third-party cookies
On some pages of the Website, other organisations may also set their own anonymous cookies. They do this to track the success of their application, or to customise the application for you. Because of how cookies work, our website cannot access these cookies, nor can the other organisation access the data in cookies we use on our Website. For example, when you share an article using a social-media sharing button (for example, Facebook) our Website, the social network that has created the button will record that you have done this.
How do I turn cookies off?
It is usually possible to stop your browser accepting cookies, or to stop it accepting cookies from a particular website. All modern browsers allow you to change your cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. To understand these settings, the following links may be helpful, or you can use the “Help” option in your browser for more details.
C. Information Collected by and from Social Media and Other Content Platforms
When you “like” or “follow” us on social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to Us. We may also collect your information if you sign up for one of Our promotions or submit information to Us through social media sites.
D. Information from Affiliates and Non-Affiliate Third Parties.
The Website may include cookies and tracking mechanisms from social media platforms through which the social media platform may collect information about you, such as mobile advertising identifier, cookie data, and IP address, as well as non-personal information (e.g. screen size), for purposes that include targeting advertisements.
We may also obtain information, such as demographic information, from our affiliates or from third parties, such as marketers, partners, researchers, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and others.
2. HOW WE USE YOUR INFORMATION
We may use your information for the following purposes:
- For the purposes for which you provided it;
- To carry out Our obligations arising from any contracts entered into between you and Us, including the provision to you with information, products and services that you request from Us, online content and dealing with your requests and enquiries;
- To process a transaction you initiate or to provide the features, services and products available through the Website;
- To send you information about your relationship or transactions with Us, account alerts, or other communications, such as newsletters to which you have subscribed;
- With your consent, to send you SMS messages;
- To notify you about new features, changes and/or offerings of the Website, including, but not limited to, updates, discounts, events, news about our services, products, and/or general news;
- To contact you with information, surveys, or advertising that we believe may be of interest to you, regarding both our products and services and those of third parties;
- To process and respond to your inquiries or to request your feedback;
- For internal research and reporting;
- To analyse and improve the content and features of the Website;
- To ensure that content from the Website is presented in the most effective manner for you and on the device or browser from which you are accessing it;
- To personalise the content and advertising that you may see on the Website, including across difference devices and browsers;
- To measure or understand the effectiveness of advertising we serve to you and others;
- To allow you to participate in interactive features of our Website when you choose to do so;
- To enforce the legal terms that govern your use of the Website;
- To keep our Website safe and secure;
- To use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine the jurisdiction in which you are accessing the Website; and
- To administer and troubleshoot the Website.
Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.
We may aggregate and/or de-identify information collected through the Website. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, and/or others.
If you ever provide to us any information that classifies as “sensitive personal information” (for example racial or ethnical origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences), We will only use this information to provide the service you require in accordance with this Policy and we will ask for your explicit consent to such processing.
3. WHEN WE DISCLOSE YOUR INFORMATION
LightOn SAS may disclose and/or share your information to or with any non-affiliated third parties under the following circumstances:
Consent: We may disclose your information to any third parties based on your consent to do so.
Service Providers: We may provide access to or share your information with select third parties who perform services on our behalf and for any other legitimate business purpose. These third parties may provide a variety of services to us, including without limitation billing, sales, marketing, advertising, market research, customer support, fulfilment, data storage, analysis and processing, and legal services.
Business Partners: We may provide your information to individuals and companies with whom we have business relationships to provide you with special coupons, discounts, or promotions, or to offer products and services to you for purchase. We encourage these partners to adopt and post privacy policies. However, the use of your Information by such parties is governed by the privacy policies of such parties and is not subject to our control.
Protection of LightOn SAS and others: By using the Website, you acknowledge, consent and agree that we may access, preserve and disclose your information, including, but not limited to, any user content, if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (a) comply with legal process; (b) enforce this Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of LightOn SAS, its agents and affiliates, and/or the public. This includes exchanging information with other companies and organisations for fraud protection, and spam/malware prevention, and similar purposes.
Business Transfers: As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of LightOn assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets.
4. LEGAL BASIS FOR PROCESSING PERSONAL DATA
Our legal grounds for processing your personal data are as follows:
To honour our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our customers or to take steps at customers’ request in anticipation of entering into a contract with them
Legitimate Interests: In many cases, we handle personal data on the grounds that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
- Customer service
- Protecting our customers, personnel and property
- Analysing and improving our business
- Managing legal issues
- We may also process personal data for the same legitimate interests of our customers and business partners.
Legal Compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.
Consent: Where required by law, and in some other cases, we handle personal data on the basis of consent. Where we handle your personal data on the basis of consent, you have the right to withdraw your consent.
5. PERSONALIZED CONTENT AND ADVERTISING
A.Online and Email Analytics
We may use third-party web analytics services on the Website, such as those of Google Analytics. These service providers use the sort of technology previously described in the “Cookies and other electronic technologies” section to help us analyse how users use the Website, including by noting the third-party website from which you arrive, and provide certain features to you. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Website. We may also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
If you receive an email from Us, we may use certain tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
B. Tailored Online and Mobile Advertising
We may personalise the content and advertising that you see when using the Website through the use of third-party advertising technologies that allow for the delivery of relevant content and advertising on the Website. The ads may be based on various factors such as the content of the page you are visiting, the information you provide, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
To opt-out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Website, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored.
When using a mobile application you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to opt-out of tailored in-app advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. We do not control how the applicable platform operator allows you to control receiving personalised in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. We also may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. You can opt-out from third-party interest-based advertising on some Android devices and Google apps by visiting Google Settings, Ads and then click on ‘Disable ads based on interests.’ You can also opt-out of some interest-based advertising on your mobile device by downloading the TrustArc Privacy App available at https://www.trustarc.com/consumer-resources/privacy-app/.
Please note that to the extent advertising technology is integrated into the Website, you may still receive advertisements even if you opt-out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
C. Notice Concerning Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform online services that they do not want certain information about their webpage visits collected over time and across websites or services. We are committed to providing you with meaningful choices about the information collected on the Website for third-party purposes, and that is why we provide links to the Network Advertising Initiative and the Digital Advertising Alliance opt-out pages, as well as choices provided by Google Ads, Google Analytics, and TrustArc. However, we may not recognise or respond to every browser-initiated DNT signal, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.
6. YOUR RIGHTS AND CHOICES
If you have provided contact information through the Website and decide that you do not want LightOn to use that information in accordance with this Policy, you can opt-out of future use at any time by contacting us as described below.
Individuals in the European Economic Area (“EEA”) and many other jurisdictions have certain legal rights to obtain confirmation of whether we hold personal data about them, to access personal data we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. You may also have rights to object to our handling of your personal data, restrict our processing of your personal data, and to withdraw any consent you have provided. To exercise these rights, please contact us, as described below, with the nature of your request. Our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will typically take the form of your e-mail address and any password submitted upon registration. While we strongly encourage you to first raise any questions or concerns about your personal data with us, you also have a right to contact the relevant supervisory authority.
Many of the rights described here are subject to significant limitations and exceptions under applicable law (e.g., objections to the processing of personal data, and withdrawals of consent, typically will not have retroactive effect).
We have implemented administrative and technical security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure, and although we will do our best to protect your information, we cannot and do not guarantee that the measures we take will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, as no Internet and/or other electronic transmissions can be completely secure and any transmission is at your own risk.
It is important for you to protect against unauthorised access to your password and to your computer so we advise that you sign off when you have finished using a shared computer and strongly recommend that you do not use the browser’s password memory function as that would permit other people using your device to access your information. You are responsible for maintaining the security of your account username and password in the case We have given you (or where you have chosen) a password which may enable you to access certain parts of the Website. You may not provide these account credentials to any third party. If you believe that your account username and/or password have been stolen or been made known to others, you must contact us immediately as described below and change your password immediately. We are not responsible if someone else accesses your account through information that they have obtained from you. To the fullest extent permitted by law, we disclaim all liability and responsibility for any damages you may suffer due to any loss, unauthorised access, misuse or alterations of any information you submit to the Website.
8. DATA RETENTION
We will keep your information only for as long as is reasonably necessary for the purpose that it has been processed, taking into account any legal requirements under Applicable Law. For the avoidance of doubt, we will retain your information to continue offering Website services to you. In the case we have given you (or where you have chosen) a password which enables you to access certain parts of our Website under a personal account, If you terminate your account, any association between your account and information we store will no longer be accessible through your account. Nevertheless, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Information may persist in copies made for backup and business continuity purposes for additional time.
9. TRANSFERS OF YOUR INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA
Your information may be transferred and stored outside the European Economic Area (EEA) in the following circumstances:
The cookies used by Google Analytics may be sent to the U.S., a country outside the European Economic Area (EEA). However, Google complies with the EU-US Privacy Shield Network and has an active Privacy-Shield certification.
We will also transfer your information outside the EEA or to an international organisation in the unlikely event that we are required to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
10. THIRD-PARTY LINKS AND SERVICES
The Website may also include widgets and social media features, which are interactive mini-programs that provide specific services from another company (e.g., displaying the news, opinions, music, etc.). Information such as your email address may be collected through these features. These features may collect your IP address and set cookies to enable them to function properly. We are not responsible for nor do we endorse the privacy practices or the content of such third party services. Any information you provide via those services is subject to their applicable privacy policies and is not covered by this Policy.
11. INFORMATION FROM CHILDREN
The Website is not directed to children under the age of 13 and such children are not permitted to use the Website. If we discover we have received any “personal information” from a child under the age of 13 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 13, please contact us as described below.
12. CHANGES TO THIS POLICY
We reserve the right to change this Policy at any time to reflect changes in the law, our data collection, and use practices, the features of our Website, or advances in technology. Please check this page periodically for changes. Your continued use of the Website following the posting of changes to this Policy will mean you accept those changes.
13. QUESTIONS ABOUT THIS POLICY
If you have any questions about our Policy, to exercise any of your rights, or for any other privacy-related inquiries, you can contact us through support[at]lighton.ai