Privacy policy / GDPR

1. Purpose / Scope of application / Terms

The present revolin Privacy Policy applies to the policy implemented by the company called Lock & co, owner of revolin brand and in charge of revolin activities, concerning the collection and use of your information when visiting the revolin websites (including the revolin mobile applications), or when using the revolin services.

This document explains (I) the origin and nature of the data that Lock & co collects, (II) the reason that it is collected, (III) the way that we use it and (IV) the rights that you have regarding this data, in compliance with law no. 78-17 of 6 January 1978 modified and Regulation (EU) 2016/679 of the European parliament and of the council 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, and repealing Directive 95/46/EC “GDPR” (collectively referred to as the “Personal Data Protection Legislation”).

The revolin Privacy Policy is also significant because it guarantees you a positive experience founded on trust when visiting the revolin websites or when using revolin services. It also allows us to respond precisely and completely to your questions concerning the collection and use of your personal information.

Furthermore, each revolin product or service may, if necessary, be accompanied by specific provisions regarding personal information and confidentiality, all of which are stated in the related terms and conditions of use.

The revolin Privacy Policy does not apply to third-party websites or mobile applications to which you could be redirected when using the revolin websites and applications. We invite you to view the disclaimers and privacy policies of these sites.

By using the revolin services, you declare to understand and agree to accept the terms of the revolin Privacy Policy without reserve.

In this document, we will name:

• Revolin “services”: revolin applications, revolin.io website, revolin product
• You: the person using revolin services or the legal structure represented by this person
• Revolin: revolin services and the team working on revolin services within Lock & co

2. Nature of the information collected by revolin

When viewing the websites or using the services of revolin, our company collects information which concerns you in two ways:

• directly, when you complete our forms and/or newsletter requests by providing the information which concerns you (such as your name, email address, etc.) (hereafter “Personal information”) and/or
• automatically, without you completing forms (hereafter “Browser Data“).

3. Communication of your Personal Information

3.1 Collection of your consent

To satisfy the purposes listed in Article 5 of the revolin Privacy Policy, revolin may establish a file made up of Personal Information provided at the time of the creation of a user account, when completing forms and/or when using revolin services.

In the present document, you are informed about the manner and conditions under which revolin processes your Personal Information.

You may give your express approval beforehand for collection and processing of your personal information by revolin, on the revolin websites and/or when using the revolin services, in conformity with the provisions of the law on Information Systems and Freedoms (notably, by means of boxes to be checked).

3.2 Personal Information collected by revolin

revolin may collect the following personal information from you directly, when creating a user account, when completing forms and/or when using revolin services:

• your last name, first name, email address;
• name of your company, your country, your telephone number;
• postal address and/or delivery address;
• your identifiers (username and password);
• your opinion concerning the revolin services;

When we collect personal data through our online forms, an asterisk (*) indicates a mandatory field to be filled in the relevant form.

4. Collection of Browser Data

Browser Data notably concerns:

• the identifier and content of a cookie stored by us on your terminal;
• the IP (Internet Protocol) address of the terminal connected to the Internet;
• the date and time of connection of a terminal to an electronic communication service;
• the type of operating system used by the terminal (Windows, MacOs, etc.);
• the type and version of the browser software used by a terminal (Internet Explorer, Safari, Chrome, etc.);
• the language of use of the browser software used by the terminal.

Browser Data is collected by the installation of cookies on your terminal (computer, tablet, smartphone, etc.).

A cookie is a small file downloaded to your terminal when you visit a website, which makes it possible to activate certain website functionalities and revolin services. Cookies may be installed at the initiative of revolin or by third parties to satisfy the purposes indicated in Article 5 of the present document (such as, notably, identifying your computer, generally securing your access to the revolin services, etc.).

4.1 Type of cookies installed from the revolin sites

Technical cookies and cookies related to functionality

These cookies allow revolin:

• to implement security measures for the revolin websites and applications;
• to improve your comfort when browsing, notably by giving you access to specific functionalities making it possible to improve the fluidity and personalization of your browsing experience such as, for example:
• adapting the presentation of the revolin websites or services to the display preferences of your terminal (language used, display resolution, etc.);
• memorizing your Personal Information in a form which you have completed at the time of your subscription to one of the revolin services;
• storing of revolin services for faster access to these various pages.

Removal of these cookies does not prevent browsing on the revolin websites, but it is likely to significantly downgrade the user experience. Removing these cookies may also prevent normal use of revolin services.

You may configure your web browser in a restricted manner, block or remove the cookies of the revolin services, regardless of the browser used. See 4.2 Configuration of web browsers and of your terminal.

Cookies for audience measurement and tracking of your activity

These cookies allow revolin:

• to establish statistics concerning the volumes of visitation of revolin websites and services (number of visits, of single visitors, of pages viewed, etc.) and to compile reports and statistics concerning the use of various elements (headers and content visited, clickstream);
• to improve the interest and ergonomics of the revolin websites and services, and of the various elements that they include;
• to offer you editorial content adapted to your interests;
• to detect eventual browsing difficulties.

Removal of these cookies does not prevent browsing on the revolin websites. However, refusing cookies could have the effect of displaying editorial content which is not suited to your centers of interest.

Period of retention: these cookies have a maximum lifespan of 13 months after first being placed on the user terminal.

If you do not want the revolin services to record cookies on your terminal, you may click the links below:

List of tracking cookies used by revolin

• Cookie name : Google Analytics, Information links / how to desactivate: https://tools.google.com/dlpage/gaoptout
• Cookie name : Google Adwords, Information links / how to desactivate: https://www.google.com/settings/u/0/ads

Cookies placed on revolin sites by third parties.

revolin may include computer applications from third parties on the revolin services, which allow you to share content coming from revolin services with other persons, or share your viewing experience or opinions concerning content from the revolin websites or services with others.

This is notably the case for the “Share” or “Like” buttons from the social networks such as “Facebook” “Twitter”, “LinkedIn” and other similar sites.

The fact that a social network or media provides such a button makes it possible for you to be identified, even if you did not use this button when viewing the revolin services. In fact, this type of button may allow the relevant social network or media to track your browsing on the revolin services, due solely to the fact that your account on the social network or media was active on your terminal (open session) while browsing the revolin services.

revolin has no control over the process used by the social networks to collect information relative to your browsing on the revolin websites or services, and associated with the personal information at their disposal.

revolin invites you to view the privacy protection policies of these social networks to become familiar with the manner of collection, purposes for use– notably advertising– and browser information which they may collect thanks to these buttons. These protection policies may allow you to exercise your choices with these social networks, notably by setting the parameters of your user accounts on each of these networks.

To become familiar with the privacy protection policy of the aforementioned social networks (without this list being exhaustive), click the URL of your choice:

• Facebook
• Twitter
• Linkedin
• Google
• Google Chrome

4.2 Configuration of web browsers and of your terminal

You may configure your web browser in a restricted manner, block, or remove the cookies of the revolin services, regardless of the browser used. Thus, based on the specificities of the principal web browsers available, you may view the settings or confidentiality menu of the browser of your choice.

Regarding the principal browsers available free of charge as of the effective date of the revolin Privacy Policy (without this list being exhaustive):

• Edge™
• Internet Explorer™
• Firefox™
• Safari™
• Chrome™
• Android™
• Opera™

Each User may configure the parameters of data sharing, confidentiality and Internet browsing from the settings menu of his terminal when such functionality is available.

5. Use of your Personal Information by revolin

The personal information that revolin may collect from you directly when creating a user account and/or when completing forms and/or when using the revolin sites and/or services may be used by revolin for the following purposes:

• Performing “customer management” operations concerning:

• - Customer requests (information requests, quotations, orders);
• - Provision of the revolin Services;
• - Customer relationship management (including but not limited to performance of satisfaction surveys, complaints management, etc.).
• - Legal Basis for the processing purpose

• Performance of a Contract;
• Legitimate interest

• - Categories of personal data

• Contact data;
• revolin service usage data

• Improving your user experience on the revolin websites and applications

• - To conduct promotional activities (notably the organization of games and contests) ;
• - To handle your requests related to the right to access, to correct or express objection regarding your personal information ;
• - To handle eventual outstanding amounts due or disputes ;
• - To manage your opinions concerning revolin services (as well as the content/products made available via the revolin services) ;
• - To recognize you when you are browsing and, if applicable, to adapt the revolin websites and services, as well as the content and advertising that they diffuse (I) to the characteristics that you have provided and which may be known by revolin (age, sex, etc.) and, if applicable, (II) to your previous visits, of which revolin may be aware ;
• - To allow you to benefit from certain additional services (participation in one of our games or contests, receiving our newsletter, etc.).
• - Legal Basis for the processing purpose

• Compliance with legal obligations ;
• Performance of a Contract ;
• Legitimate interest

• - Categories of personal data

• Account registration data ;
• revolin service usage data ;
• Browsing data

• Conducting operations relative to direct marketing, including:

• - Management of technical operations of prospection (which notably includes technical operations such as standardization, enrichment of your Personal Information and elimination of duplicates); development of commercial statistics ;
• - Performance of sales activities (in compliance with the provisions of Article 7 hereafter);
• - Transfer, lease or exchange of our files containing your Personal Information (in accordance with the provisions of Article 7 hereafter);
• - Establishment of profiles, for conducting activities aimed at building customer loyalty, prospecting, surveys and targeted promotions
• - Legal Basis for the processing purpose

• Consent ;
• Legitimate interest

• - Categories of personal data

• Contact data

6. Recipients of your personal information

Those who may access your Personal Information include:

• the personnel of revolin in the marketing or sales departments, the departments in charge of handling customer relations and prospection, the administrative departments, the departments responsible for auditing of internal procedures, the logistics and IT departments, as well as their hierarchical managers;
• persons responsible for auditing (internal to revolin but also the statutory auditor, etc.)
• subcontractors within the framework of signed contracts (I) mentioning the obligations incumbent upon them regarding security and confidentiality of personal data under the Law on Information Systems and Freedoms and (II) notably specifying the objectives of security having to be attained;
• current or future subsidiaries of revolin;
• any company as part of any operation of change of control of revolin (including but not limited to acquisition of a majority stake in the company, partial contribution of assets, transfer of business assets and goodwill, merger, etc.);
• ministerial officers and auxiliaries of the legal system, if applicable, within the framework of exercising any procedure and/or provision of public law and order;
• French supervisory authority (Commission Nationale de l’Informatique et des Libertés) and/or any other competent authority;
• commercial partners of revolin (in conformity with the provisions of Article 7 hereafter.

7. Direct marketing

At the time of creation of your user account and/or when subscribing to or using certain revolin services made available on the revolin websites and/or applications, you may eventually be asked about:

• receiving information on current or future revolin services;
• receiving information on services of revolin partners;
• receiving newsletters dedicated to certain themes (internal comms, team rituals, future of work, company culture etc.) developed by revolin or its partners.

If applicable, you will be able to subscribe to each offer above by checking the boxes indicated for these purposes.

If you choose to subscribe to a newsletter or if you agree to receive direct offers from revolin (or from its partners) by email, you have the right to object to receiving any new newsletters or any new offers by direct email from revolin (or from its partners):

Regarding newsletters:

• by either clicking on the hypertext link appearing in each newsletter received and reproduced hereafter “si vous ne souhaitez plus recevoir d’emails, vous pouvez vous désabonner” (if you no longer wish to receive emails, you may unsubscribe);
• or, if you have created a user account, by using the subscription cancellation function which is provided in the “Mon Compte” / “Mes Préférences” (my account/my preferences) section - when that feature becomes available.

Regarding direct prospecting by email:

• by clicking the hypertext link intended for this purpose, appearing in each email of solicitation sent.

Regarding revolin products or services:

• you may be contacted directly by email by the teams of revolin concerning products or services similar to those that we have provided to you via revolin websites or services. Under such circumstances, you are always able to object, free of charge, to any new solicitation by using the hypertext link intended for this purpose.

8. Data retention

We keep your Personal Information as long as your user account is active or as long as necessary to provide you with the revolin Services.

We keep your Personal Information processed for information or marketing purposes (emails, notifications, or other messages) in accordance with the CNIL deliberation n°2016-264 of July 21, 2016 (three (3) years from the data collection or from the last contact with you).

You have the possibility to suppress your user account at any time or to object to direct marketing or unsubscribe from such mailing lists by exercising the rights granted by the Personal Data Protection Legislation.

You understand that the retention of your Personal Information in our system shall be of legitimate interest with regard to administrative, legal and security matters. This retention beyond the duration of the purposes set forth in Article 5 is necessary for us (i) to process your requests to exercise your rights to object to processing, to restrict the processing concerning you and to erase your Personal Information and (ii) to comply with our legal obligations (including resolving dispute) or our legal, tax, audit, and accounting obligations and (iii) to respond to any requirements from competent authority (supervisory authority, law enforcement agencies, etc.).

We are committed to maintain a high level of security and confidentiality of your Personal Information, to strictly limit the access of the Personal Information to authorised persons only and not to process such data for purposes other than those set forth in Article 5.

9. Information and exercising of your rights

In compliance with the provisions of the Personal Data Protection Legislation (in particular articles 15 to 22 of the GDPR), you may:

• send us any request for information relative to the revolin Privacy Policy and to the processing of your personal information;
• access to information regarding the processing of your Personal Information (categories of data, purposes, etc.);
• suppress your user account by connecting to your account and modifying the parameters (if such option is available) or by contacting us par email;
• amend or update your Personal Information which are inaccurate, by connecting to your account and modifying the parameters (if such option is available) or by contacting us par email;
• delete your Personal Information by connecting to your account and modifying the parameters (if such option is available) or by contacting us par email;
• limit the processing activities of your Personal Information, when the accuracy of the Personal Information is contested by you (limitation for a period enabling us to verify the accuracy of the Personal Information), or the lawfulness of such processing is contested by you (but you authorize us to resume such processing), by contacting us by email;
• receive the personal data concerning you, which you provided to us, in a structured, commonly used and machine-readable format by contacting us by email; you are informed that data that are derived, calculated or inferred from Personal Information provided by you are excluded from the right to data portability, to the extent that such inferred data are created by revolin and is not provided by you;
• object at any time to your personal data being processed for direct marketing purposes by unsubscribing from the mailing list by clicking on the hyperlink contained in such direct marketing emails;
• object to us processing your personal data on grounds relating to your particular situation and may decide not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
• lodge a complaint with the French supervisory authority « Commission Nationale de l’Informatique et des Libertés », 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, Tel :+33(0)1 53 73 22 22

In the event of unfounded or excessive requests from you, in particular because of their repetitive character, revolin reserves the right to refuse to act on request, when such requests are subsequent to a prior request relating to the same subject matter which was duly processed by revolin.

Your requests should be sent in writing or by email to the contact information indicated below, signed and accompanied by a photocopy of an identity document bearing the signature of the holder. The request should indicate the address where the response should be sent. We have a period of 1 (one) months following receipt of the request to respond. That period may be extended by 2 (two) further months where necessary, taking into account the complexity and number of the requests.

Lock & co:

37 rue Louise Weiss
75013 Paris (FRANCE)

contact@revolin.io

10. Security and confidentiality

revolin implements organizational and technical of security measures intended to guarantee the confidentiality and integrity of your personal information. All data stored on our servers is protected by measures such as secure portal under HTTPS protocol, encryption of data in transit under TLS protocol, firewalls, antivirus software, access management, intrusion detection.

However, due to the very nature of a worldwide public communication network such as the Internet, you acknowledge that complete security of electronic transmissions through the Internet and integrity of Personal Information cannot be warranted.

In case of a security breach resulting in a personal data breach, we commit to implement the corrective measures as soon as possible and notify such personal data breach to the supervisory authority competent, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons, in accordance with the Personal Data Protection Legislation.

11. Transfer of Personal Information abroad

Within the framework of the purposes listed in Article 5, all or a portion of the Personal Information collected may be sent to recipients located in a country other than France.

revolin makes certain that your Personal Information is effectively protected. As such, all transfers are sent to recipients located:

• in countries having, according to the criteria established by the European Commission, an adequate level of protection of personal data;
• in countries not offering adequate personal protection but to which the transfer is done within the framework of standard contractual clauses specified by the European Commission, or by the adoption of “binding corporate rules”;
• in the United States, provided that these recipients satisfy the conditions set forth by the “Privacy Shield” established by the United States Department of Commerce.

12. Changes to the Privacy Policy

We may make changes to this Privacy Policy from time to time, and if we make significant changes, we will inform you by displaying a prominent notice when you connect to the revolin websites or by email (at the email address provided in your user account), in order to give you the opportunity to assess such changes before their effective date.

If you disagree with any of such changes to the Privacy Policy, you may suppress your user account.

If you choose to consult our websites and/or use the Services after the display or receipt of a revolin notice regarding any changes made to this Privacy Policy, this means that you unconditionally accept such updated Privacy Policy.

13. How to contact us

You may send us your questions and comments regarding this Privacy Policy, by sending an email to:

contact@revolin.io

Lock&co Data Protection Officer:

contact@revolin.io

Privacy policy as of 19/05/2023

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