Charter relating to the protection of users' personal data

1. Who are we

JOIN, a simplified joint stock company with a single shareholder, registered in the Paris Trade and Companies Register under no. 833 938 269, with its head office at 62 rue du Faubourg Poissonnière - 75010 Paris (hereinafter, “We”) (hereinafter, “We”) is the main person responsible for the processing of your personal data collected in connection with the use of the sites www.join-stories.com and studio.join-stories.com (hereinafter, collectively, the “Site”) and the JOIN STORIES software in order to create web stories (hereinafter the “Services”). For any information relating to your personal data, you can contact JOIN by email at privacy@teamjoin.fr

2. Purpose of this charter

The purpose of this charter is to inform you about the means we use to collect your personal data, in the strictest respect of your rights. In this regard, we inform you that we comply, in the collection and management of your personal data, with law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms, in its current version (hereinafter, the “Data Protection Act”), as well as Regulation (EU) 2016/679 of 27 April 2016 relating to the protection of natural persons with regard to the processing of personal data and to the free movement of this data (hereinafter, the “RGPD”).

3. Nature of personal data collected by JOIN

Personal data is any information that identifies you directly (for example, your name, first name, email address, and telephone number) or indirectly (for example, your account ID, IP address, or cookie ID). The data we collect falls into three categories: (a) data that you provide to us, (b) data that we collect through automated means, and (c) data that we collect from other sources.

3.1. About the personal data you provide to us

You may be required to communicate personal data to us when you:

• Request a demo on our Site.
• Use our Services.

In this context, we are required to process the following personal data:

• Identification and contact information (name, first names, company, postal and email addresses, telephone numbers) to provide you with information about our products and services, answer your questions, allow you to be authenticated and access your online account.
• Data relating to your transactions on the Site, details of your purchases and subscriptions, etc. to ensure the smooth running of our contractual relationship.
• Files uploaded to the Site by you, containing for example photos and videos, as well as stories generated to advise you, solve technical problems, identify product improvements and communicate about our products and services.

3.2. About the personal data we collect through automated means

We use automated technologies such as cookies to collect data from your computer or mobile device (phone or tablet) when you use our Site and/or Services.

We collect the following technical data to allow our website to function properly, to offer you products and services adapted to your interests (including advertising) and to carry out audience measurements: IP address, browser, operating system, etc.

3.3. About personal data we collect from other sources

In the event that you import files such as photos or videos from third party platforms (in particular Instagram) onto the JOIN platform, we are required to process these files in order to advise you, solve technical problems, identify product improvements, and communicate about our products and services.

4. For what purposes and on what legal basis do we use your personal data?

The legal basis for our collection of your personal data is as follows:

1. Provide you with pre-contractual information when you provide us with personal data during your visit to our Site to enable us to respond to your requests for information on our Services.
2. Execute the contract concluded when you use our Services.
3. Offer you products adapted to your interests (including advertising) and carry out audience measurements when you consent to the deposit of social network cookies, advertising cookies and audience measurement cookies.

Your personal data is collected to meet one or more of the following purposes:

1. Advise you to enable you to create better stories: editorial advice, tips for using Templates and tips for using features.
2. Assist in the resolution of technical problems.
3. Identify product improvements as well as new templates to create.
4. Manage your access to certain Services available on the Site and their use.
5. Manage your access to certain Services available on the Site and their use.
6. Create a file of registered members, Users, Customers and Prospects.
7. For our customers: send you newsletters, solicitations and promotional messages. If you do not wish to do so, we give you the option to express your refusal on this subject when collecting your data.
8. Develop commercial and attendance statistics for our Services.
9. Manage unpaid invoices and possible disputes regarding the use of our products and Services.
10. Personalize responses to your requests for information.
11. Comply with our legal and regulatory obligations.

When collecting your personal data, we inform you whether certain data must be provided or if they are optional. Mandatory data is necessary for the operation of the Services.

With regard to optional data, you are entirely free to indicate it or not. We also tell you what are the possible consequences of a lack of response.

5. Recipients of the data collected

Our company staff, the services responsible for control (in particular the auditor) and our subcontractors will have access to your personal data. Public bodies, exclusively to meet our legal obligations, judicial officers, ministerial officers and organizations responsible for debt collection may also be recipients of your personal data.

6. Transfer of personal data

Your personal data will not be transferred, rented or exchanged for the benefit of third parties.

7. Retention period of personal data

7.1. Regarding data relating to the management of customers and prospects

Your personal data is kept for the time strictly necessary to manage our commercial relationship with you. Regarding possible prospecting operations intended for you, your data may be kept for a period of 3 (three) years from the end of our commercial relationship. Data that makes it possible to establish proof of a right or a contract, which must be kept in order to comply with a legal obligation, will be kept for the period provided for by the law in force.

Personal data relating to a prospect, not a customer, may be kept for a period of 3 (three) years from their collection or the last contact from the Prospect. At the end of this period of 3 (three) years, we will be able to contact you again to find out if you wish to continue to receive commercial solicitations.

7.2. Regarding identity documents

If the right of access or correction is exercised, the data relating to identity documents may, if necessary, be kept for the period provided for in article 9 of the Code of Criminal Procedure, i.e. 1 (one) year. If the right to object is exercised, this data may be archived for a period of 3 (three) years.

7.3. Regarding bank card data

Financial transactions relating to the payment of purchases and fees via the Site are entrusted to a payment service provider who ensures their smooth and secure processing. For the purposes of the Services, this payment service provider may receive your personal data relating to your bank card numbers, which it collects and stores in our name and on our behalf.

We do not have access to this data. To allow you to make regular purchases or to pay the related costs on the Site, you can agree, via a check box expressly provided for this purpose on the Site, that the data relating to your bank cards be kept for the time you register on the Site and at least until the moment you complete your last transaction.

By checking the box expressly provided for this purpose on the Site, you are giving us your express consent for this storage. Data relating to the visual cryptogram or CVV2, written on your bank card, is not stored. If you do not check the box above, we will not keep your personal data relating to your bank card numbers beyond the time necessary to allow the transaction to be completed.

In any event, the data relating to them may be kept, for the purpose of proof in the event of a possible dispute of the transaction, in intermediate archives, for the duration provided for by Article L 133-24 of the Monetary and Financial Code, in this case 13 (thirteen) months following the debit date. This period may be extended to 15 (fifteen) months in order to take into account the possibility of using deferred debit payment cards.

7.4. Regarding the management of lists of objections to receiving prospecting

Information allowing your right to object to be taken into account is kept for a minimum of 3 (three) years from the exercise of the right of opposition.

8. security

We inform you to take all useful precautions, organizational and technical measures appropriate to preserve the security, integrity and confidentiality of your personal data and in particular, to prevent them from being deformed, damaged or from being accessed by unauthorized third parties. We will also use secure payment systems that comply with the state of the art and applicable regulations.

9. Transfers of personal data outside the European Union

If necessary, your personal data may be transferred to a country located outside the European Union, it being specified that in the event that the recipient country does not ensure a level of protection of personal data equivalent to that of the European Union, we undertake, in the absence of an adequacy decision, to take all necessary measures to ensure the protection of your personal data on the basis of appropriate guarantees.

For more information on the protective measures in place, please contact us at privacy@teamjoin.fr.

10. Access to your personal data

In accordance with Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms, and the RGPD, you have the right to obtain the communication and, where applicable, the correction or deletion of data concerning you, by contacting:

• Email address: privacy@teamjoin.fr
• Postal address: 175 rue Saint-Martin, 75003 Paris, France

Persons whose data are collected on the basis of our legitimate interest, as mentioned in article 4, are reminded that they may object to the processing of data concerning them at any time. However, we may have to continue processing if there are legitimate reasons for the processing that prevail over your rights and freedoms or if the processing is necessary to establish, exercise or defend our legal rights.

11. Right to define guidelines for data processing after your death

You have the right to define guidelines for the storage, deletion and communication of your personal data after your death. These instructions may be general, i.e. they then relate to all personal data that concerns you. In this case, they must be registered with a trusted digital third party certified by the CNIL. The instructions may also be specific to the data processed by our company. They should then be sent to us at the following coordinates:

• Email address: privacy@teamjoin.fr
• Postal address: 175 rue Saint-Martin, 75003 Paris, France

By sending us such instructions, you expressly give your consent for these instructions to be stored, transmitted and executed as provided herein. In your instructions, you can designate a person responsible for carrying them out. When you have died, the latter will then have the right to read these instructions and ask us for their implementation. In the absence of designation, your heirs will have the right to take note of your instructions upon your death and ask us for their implementation. You can change or revoke your instructions at any time by writing to us using the contact details above.

12. Portability of your personal data

You have a right to the portability of the personal data that you have provided to us, understood as the data that you have declared actively and consciously in connection with the access and use of the Services, as well as data generated by your activity in the context of the use of the Services. We remind you that this right does not apply to data collected and processed on a legal basis other than consent or the execution of the contract between us. This right can be exercised free of charge, at any time, and in particular when you close your account on the Site, in order to recover and keep your personal data. In this context, we will send you your personal data, by any means deemed useful, in an open standard format commonly used and readable by machine, in accordance with the state of the art.

13. Submission of a complaint before a supervisory authority

You are also informed that you have the right to file a complaint with the CNIL: via its website at the address https://www.cnil.fr/fr/plaintes or by mail: 3, place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

14. Limitation of treatment

You have the right to obtain the limitation of the processing of your personal data, in the following cases:

• During the period of verification that we implement, when you contest the accuracy of your personal data.
• When the processing of this data is unlawful, and you want to limit this processing rather than deleting your data.
• When we no longer need your personal data, but you want it to be retained to exercise your rights.
• During the period of verification of legitimate reasons, when you have objected to the processing of your personal data.

15. Changes

We reserve the right, at our sole discretion, to modify this charter at any time, in whole or in part. These changes will come into force as of the publication of the new charter. Your use of the Site following the entry into force of these modifications will constitute recognition and acceptance of the new charter. Otherwise and if this new charter does not suit you, you will no longer have to access the Site.