PRIVACY POLICY

At Init ML, protecting your personal data is our priority.

When you use the application ClipDrop (hereinafter the "Application"), we may collect personal data about you.

The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR").

  1. Who is the data controller?

The data controller is Init ML, simplified joint-stock company, registered with the Registry of Trade and Companies of Bobigny under the number 885 384 289 and whose head office is located at 211 rue Etienne Marcel, 93100 Montreuil (hereinafter “Us” or “We”).

  1. What personal data we collect?

Personal data is a data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.

We may collect the following personal data:

  • Identification data (e.g. full name, email and postal addresses) ;
  • Login data (e.g. logs, IP address);
  • Economic and financial details (e.g. bank details) ;
  • Images, texts and photographs.

The user acknowledges and accepts that content of a personal or confidential nature is downloaded, stored, and carried out under his/her sole responsibility. The company shall not be held liable in any way in this respect.

     

  1. On what legal basis, for what purposes and for how long do we keep your personal data?

Purposes

Legal basis

Data retention period

To provide you with our services available on our Application (analyse and process images, transfer them from one device to another, store your photos on our cloud for service improvement purposes)

When you have created an account : performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract

When you haven’t created an account : our legitimate interest to provide you with our services

When you have created your account: personal data are retained for the duration of your account.

When you have not created your account: images, photographs and texts are retained during two year.

In addition, personal data may be archived for probationary purposes for a period of 5 years.

To perform operations related to contracts, orders, and customer relationship management

Performance of a contract to which you are party

Personal data are retained for the duration of our business relationship.

In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years.

The data related to your credit card are retained by our payment service provider.

The CVV2 (Card Verification Value), listed on your credit card details, will not be stored.

To create a database of customers and prospects

Our legitimate interest in developing and promoting our business

For our customers: their personal data are retained for the duration of our business relationship.

For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action). 

To send newsletters, requests and direct marketing mailings

For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news

For our prospects: your consent

Personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action) or until you withdraw your consent.

To answer to your information request and other inquiries

Our legitimate interest in responding to your inquiries

Personal data are retained during the processing of your request and is deleted once the request has been processed.

To comply with our legal and regulatory obligations

Legal and regulatory obligations

Invoices are archived for a period of 10 years.

In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years.

To elaborate analytics of navigation, site audience, purchases.

Your consent

The personal data are retained for 2 years

To process data subjects’ requests to exercise their rights

Our legitimate interest in responding to your requests and keeping records of them

If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted.

If you exercise your right to object to direct marketing: we keep this information for 3 years.

  1. Who are the recipients of your personal data?

Will have access to your personal data:

  1. The staff of our company;
  2. Our processors: web hosting provider and cloud provider, payment provider, mailing provider;
  3. Our partner: Stripe who provides us with e-payments and carry out their own processing, as described in their privacy policy ;
  4. If applicable: public and private organisations, exclusively to comply with our legal obligations.

  1. Are your personal data likely to be transferred outside the European Union?

Your personal data is hosted for the duration of the processing on the servers of the company Google Cloud Platform, located in the United States of America.

As part of the tools, we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

  • Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR : in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or
  • The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR : in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited to the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or under an approved certification mechanism; or
  • The personal data are transferred under the any appropriate safeguards described in Chapter V of the GDPR.

  1. What rights do you have regarding your personal data?

You have the following rights with regard to your personal data:

  • Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.

  • Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.

  • Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.

  • Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.

  • Right to erasure (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.

  • Right to file a complaint to a competent supervisory authority (in France, the CNIL), under GDPR article 77, if you consider that the processing of your personal data constitutes a breach of applicable regulations.

  • Right to define instructions related to the retention, deletion and communication of your personal data after your death.

  • Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.

  • Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
  • Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.

  1. What cookies do we use?

For more information on cookies management, please consult our Cookies Policy.

  1. Contact information for data privacy matters

Contact email: privacy@clipdrop.co

Contact address:  2261 Market Street #4357, San Francisco, CA 94114, United States

  1. Modifications

We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

Entry into force: July 31 2022