Contentsquare Foundation Privacy Policy
Effective Date: 23/03/2022
Table of contents
1. Introduction
2. Scope of the Privacy Policy
3. Who is responsible for processing your Personal Data?
4. What Services do we provide you?
5. Which Personal Data do we process about you and how?
6. Why do we use your Personal Data?
7. How long do we keep your Personal Data?
8. When and to whom we share your Personal Data?
9. How do we transfer your Personal Data globally?
10. How do we secure your Personal Data?
11. What are your privacy rights and how to exercise them?
12. Additional information
1. Introduction
This privacy policy (“Privacy Policy”) provides information on the collection, storage, use, sharing, disclosure and transfer (“Processing”) by the Contentsquare Foundation (“Foundation”, “we”, “our”, or “us”) when you use our website (https://contentsquare-foundation.org/), when you use our products and other services (collectively, the “Services”) and when you interact with or participate in our events and programs. It also provides you with information about your privacy rights in relation to such Processing of your Personal Data.
For the purpose of this Privacy Policy, “Personal Data” means information that relates to an identified individual or to an identifiable individual, as defined under applicable data protection laws. “You” means the individual accessing or using the Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Services, as applicable.
2. Scope of the Privacy Policy
This Privacy Policy applies to the Processing of Personal Data in relation with our website and Services and to any other Processing performed by the Foundation.
3. Who is responsible for processing your Personal Data?
The Foundation aims to promote digital accessibility for people with disabilities by raising awareness through events, volunteer opportunities, and raising donations.
For the purpose of Processing activities identified under this Privacy Policy, the Foundation is the Data Controller of your Personal Data, as such are defined under applicable data protection laws.
The Foundation is a foundation registered in France (SIREN no. 892547811) and located 7 rue de Madrid 75008, Paris, France.
Data Protection Officer and contact details
The Foundation has appointed a data protection officer (“DPO”) to oversee the protection of your Personal Data. If you have any questions about this Privacy policy or about our data protection practices, you can contact our DPO at Contentsquare Foundation, Attn: DPO, 7 rue de Madrid 75008 Paris, France. Email to foundation@contentsquare.com.
4. What Services do we provide you?
As part of the Services, the Foundation provides a product called Readapt (“Product”). Our Product is a solution that adapts text from digital interfaces (e.g. websites and digital documents) to increase the reading comfort of those with visual or reading challenges like dyslexia.
Please note that no Personal Data is processed when using Readapt. The Foundation, however, does process some of your Personal Data when you contact us to report bugs or suggestions to improve the Product. This is only so that we can respond to your request.
Some usage data is captured in order to measure the use of the Product. This usage data is anonymized and in no way linked to any of your Personal Data. Usage data refers to data that is not deemed as Personal Data, processed as part of the use of the Product by you including how many times you adapt text.
5. Which Personal Data do we process about you and how?
The Foundation collects and processes Personal Data that directly identify you (e.g. name, email, contact details, etc.) and that indirectly identify you (e.g. unique identifiers, behavioral data, etc.), from the following sources:
When you provide such Personal Data directly to us
When you interact with us (register for an event, support our work through a donation, submit an inquiry, contact us about our Services etc.), we may collect the following categories of Personal Data about you:
| Category of Personal Data | Examples of Personal Data |
|---|---|
| Identification and contact data | First and last name, email address, address, telephone number |
| Financial Data | Method of payment and transaction data |
| Professional or Employment-Related Data | Job position, workplace and industry |
| Any other Personal Data you voluntarily choose to provide | Personal Data in request or feedback you send us |
When you use our website and such Personal Data is collected automatically
When you visit or interact with our website, we may collect or generate through cookies the following categories of Personal Data about you:
| Category of Personal Data | Examples of Personal Data |
|---|---|
| Unique identifiers | IP address, cookie IDs, device IDs, web beacons, pixels, and other similar technologies |
| Device and technical data | Domain server, type of device/operating system/browser used to access the Sites, local and language settings; session logging, heatmaps and scrolls; screen resolution, ISP, referring or exit pages; date and time of your visit |
When you use our Services, we may also process de-identified and aggregated data for gauging the efficacy and usefulness of our services.
6. Why do we use your Personal Data?
Below you will find a summary of the purposes for which we process your Personal Data with the legal basis for this processing:
| Purpose of processing | Legal basis |
|---|---|
| Contact you about the Foundation’s events, volunteer and fundraising opportunities (including communications based on your interests, personal and business characteristics, and location) | Consent or legitimate interest |
| Organize, manage, facilitate access to our events, programs, and other Services | Legitimate interest |
| Administer donations you make to the Foundation | Compliance with a legal obligation |
| Respond to your request | Legitimate interest |
| Conduct research or surveys to help us improve our Services and strategic development. Your participation is always voluntary and only anonymized and aggregated data will be used as result of the surveys, unless you consent to us publishing your feedback. | Consent or legitimate interest |
| Administer and deliver functionality on our website | Legitimate interest |
| Analyze, develop, improve and optimize the use, function and performance of our website, customize or personalize your experience | Legitimate interest |
| Manage the security and operation of our website, facilities, and networks and systems | Legitimate interest |
| Fulfill our legal, regulatory and tax obligations | Compliance with a legal obligation |
| Respond to regulators, law enforcement authorities or other government officials request or your data protection requests | Compliance with a legal obligation |
| Defend a legal claim | Compliance with a legal obligation |
7. How long do we keep your Personal Data?
Your Personal Data will be stored by us and our service providers in accordance with applicable data protection laws and data protection authorities guidelines to the extent necessary for the processing purposes set out in this Privacy Policy. Subsequently, we will delete your Personal Data or take steps to properly render the Personal Data anonymous, unless we are legally obliged to keep your Personal Data longer (e.g. for legal, regulatory, tax, accounting or auditing purposes).
Below you will find a summary of the data retention related to each purpose of processing:
| Purpose of processing | Data retention |
|---|---|
| Contact you about the Foundation’s events, volunteer and fundraising opportunities (including communications based on your interests, personal and business characteristics, and location) | 2 years from your last contact or as soon as you request that we stop contact you for this purpose |
| Organize, manage, facilitate access to our events, programs, and other Services | For the time necessary to achieve this purpose |
| Administer donations you make to the Foundation | 6 years from your last donation |
| Respond to your request | 2 years from your request |
| Conduct research or surveys to help us improve our Services and strategic development. Your participation is always voluntary and only anonymized and aggregated data will be used as result of the surveys, unless you consent to us publishing your feedback. | For the time necessary to achieve this purpose |
| Administer and deliver functionality on our website | For the time necessary to achieve this purpose |
| Analyze, develop, improve and optimize the use, function and performance of our website, customize or personalize your experience | 13 months |
| Manage the security and operation of our website, facilities, and networks and systems | For the time necessary to achieve this purpose |
| Fulfill our legal, regulatory and tax obligations | For the time necessary to achieve this purpose and then archived as required by applicable law or regulation |
| Respond to regulators, law enforcement authorities or other government officials request or your data protection requests | For the time necessary to achieve this purpose and then archived as required by applicable law or regulation |
| Defend a legal claim | For the time necessary to achieve this purpose and then archived as required by applicable law or regulation |
8. When and to whom we share your Personal Data?
In connection with one or more of the purposes outlined in the Section 4 above, we may disclose your Personal Data to:
Service providers
We may share your Personal Data to third parties (including our affiliates) to perform services complementary to our own, namely - hosting, data analytics, consulting, development, support, marketing and advertising, data and cyber security. Our service providers may perform the services on our behalf, under our instructions, in accordance with our agreement and in compliance with appropriate technical and organizational security measures to protect your Personal Data.
Other third parties
We may disclose your Personal Data to third parties, including government authorities or public authorities, courts, intergovernmental or supranational bodies for legal processes or protection of life and safety where we believe that access, use, preservation, or disclosure of the information is reasonably necessary, including:
- To comply with laws, regulations, legal process or to respond to lawful requests;
- To enforce or apply our agreements;
- To protect the rights, interests, property, or safety of the Foundation, our customers, you and others;
- In connection with claims, disputes, or litigation;
- To protect you and others from fraudulent, abusive, or unlawful use of the website, and other fraudulent activity.
Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
9. How do we transfer your Personal Data globally?
Your Personal Data may be accessed, processed and stored in countries where we or our service providers maintain facilities outside the European Economic Area (EEA).
Except for adequate countries recognized by the European Commission, you should be aware that legal protection for Personal Data in countries outside the EEA may not be equivalent to the level of protection provided in the EEA. However we take steps to put in place suitable safeguards to protect your Personal Data when transferred outside the EEA such as entering into the ‘standard contractual clauses’ of the European Commission.
10. How do we secure your Personal Data?
In order to protect your Personal Data held with us and our service providers, we use industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 6 above.
11. What are your privacy rights and how to exercise them?
You have rights for the Personal Data we process about you. You can choose to object to, restrict our use of your Personal Data, delete, change or correct your Personal Data, access your Personal Data by emailing at foundation@contentsquare.com.
Subject to applicable data protection laws, you have multiple privacy rights in respect of the Personal Data we process about you:
- request confirmation that we are processing your Personal Data;
- request a copy of Personal Data we hold about you;
- request that we update Personal Data we hold about you or correct such data that is inaccurate or incomplete;
- restrict the way in which we use your Personal Data (e.g., if we have no legal right to keep using it) or limit our use of your Personal Data (e.g., if your Personal Data is inaccurate or unlawfully held);
- object to our processing of your Personal Data relating on grounds to your particular situation or if your Personal Data is processed by us for direct marketing purposes, object at any time to the processing of your Personal Data for such marketing;
- withdraw the consent that you have given us to process your Personal Data (where we process your Personal Data on the basis of your consent);
- request that we delete the Personal Data we hold about you; and
- lodge a complaint with the relevant data protection authority regarding our processing of your Personal Data.
If you want to exercise one or more of the rights mentioned above, you can submit your request by emailing us at foundation@contentsquare.com. Please note that as part of your data subject request, we may require additional information and documents, including Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 5 above.
12. Additional information
Updates and Amendments
We may update and amend this Privacy Policy from time to time. The “Effective Date” at the top of this webpage mentions when this Privacy Policy was last revised. Any changes will become effective when we post a revised version of this Privacy Policy. We encourage you to review this Privacy Policy periodically to remain informed about how we are protecting your Personal Data.
Questions, Concerns or Complaints
If you have any comments, questions or concerns about this Privacy Policy or our handling privacy practices, please contact us at foundation@contentsquare.com.
External Links
While our website may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our website for the website or application of such third parties and to read the privacy policies of each and every website or service you visit. This Privacy Policy applies only to this website and data processing set out in Section 2 above.