TCHARTER RELATING TO THE PROTECTION OF USERS' PERSONAL DATA

1. Definition of personal data:

According to the law, personal data is any data that allows a natural person to be identified, directly or indirectly. Examples of direct identification: A name, a first name, a photo of a face, a video showing a person, a sound extract of a person's voice. Example of indirect identification: A social security number, an employee number, a telephone number.

2. Purpose of this charter

In order to take into account the requirements linked to the General Data Protection Regulations according to law no. 78-17 of January 6, 1978 relating to computing, files and freedoms, the user accepts the processing of data described in this present charter.

3. Identity of the data controller

The EXPERTISE CHOIX B accounting firm, whose head office is located at 9 AVENUE DU RHIN 54520 LAXOU, acts according to the processing of personal data that it carries out as data controller, joint controller or subcontractor.

4. Data Protection Officer

For any information concerning your personal data, please send a letter to the Data Protection Officer (DPO) at the following address: donnees@clementine.fr

5. Personal data we collect

The data you transmit to us is based on your consent. The categories of data we collect are as follows:

• Identification data: Name, first name, photos, identity card, passwords, profession, company (Name, Company Name, SIRET).
• Authentication data: Username, passwords, country of connection, IP address, logs, User ID
• Professional and tax data: VAT declaration, credit cards
• Banking data: bank account

The collection of certain personal data is a legal obligation on our part and we cannot delete it.

The collection of data is necessary for the purposes of executing the contract for our services.

This personal data allows us to achieve these purposes:

1. Guarantee your access and use of services in our My Clémentine application
2. Carry out operations to manage your accounting concerning purchase invoices, sales invoices, expense reports, mileage allowances.
3. Prepare an accounting balance sheet
4. Ensure the synchronization of your bank accounts in the My Clémentine application
5. Send newsletters and promotional messages. We offer you the possibility of refusing the collection of this data by sending us a message to this address: donnees@clementine.fr

6. Recipients of the data collected

The processing of your data will be accessible by the personnel of our company as well as by the competent control services and our subcontractors.

As part of the use of our services, we may transfer your data to the following parties:

• Service providers enabling transactions to be carried out
• Banking organizations
• Data hosting provider
• User behavior analysis tool
• Software error and bug management tool
• Software error and bug management tool
• Internal communication tool
• Tool for statistical analysis and improvement of the use of our services

Your personal data may be transmitted to public bodies such as government officials or debt recovery services.

We may need to connect you to your Google Drive space via an authentication screen where you will need to enter your email address and password to take advantage of our file import functionality from Google Drive. This data is not stored on our site. We may also ask you to read and download your Google Drive files for storage on our site as defined in these terms.

7. Transfer of personal data

The EXPERTISE CHOIX B accounting firm will never disclose, assign, rent or transmit your personal data to third parties other than those mentioned in this charter.

8. Data retention period

9. Data security

We regularly update our systems in order to guarantee a high level of protection of your data and to anticipate possible intrusions. However, we cannot guarantee 100% security of the data you transmit to us via the internet.

We implement the following means:

• Data encryption
• Regulated access control
• Quality in hosting system design
• Hosting your data within the European Union

10. Accommodation

We ensure that your data hosted by our provider Amazon Web Service complies with the GDPR:

We implement the following means:

• Data encryption
• Regulated access control
• Quality in hosting system design
• Hosting your data within the European Union

11. Cookies

12. Right of access to your data

To exercise your right of access to your data, the request must be validated by the data controller with verification of your identity. You therefore have the right to access, modify, limit and delete your personal data. You can make your request to the following address: donnees@clementine.fr or by post to 9 AVENUE DU RHIN 54520 LAXOU

13. Right to modify your data

You have the right to modify your personal data if you wish to inform us of any data in our possession that is incorrect. In this case, please contact us at the following address: donnees@clementine.fr or by post at 9 AVENUE DU RHIN 54520 LAXOU

14. Right to delete your data

You have the right to have your personal data deleted. However, for your request to be admissible, the information to be deleted must not be subject to a legal obligation on our part (see legal obligation data). You can make your request here: donnees@clementine.fr or by post to 9 AVENUE DU RHIN 54520 LAXOU

15. Right to the portability of your data

You have the right to portability of your personal data to recover part of your data in a computer-readable format: donnees@clementine.fr or by post to 9 AVENUE DU RHIN 54520 LAXOU

16. Right to object to the processing of your data

You have the right to object to your personal data. However, as for the right to delete data, i.e. for legitimate reasons requiring us to process your data, we will not be able to respond favorably to your request. You can exercise this right at the following address: donnees@clementine.fr or by post to 9 AVENUE DU RHIN 54520 LAXOU

17. Right to restriction of processing

You have a right to limit the processing of your personal data when:

• You contest the accuracy of your data
• The processing of your data is unlawful
• We no longer have any use for processing your data but you would like to keep part of it
• During verification period for legitimate reasons

18. Submitting a complaint regarding your personal data

To the extent that EXPERTISE CHOIX B does not meet its obligations regarding your personal data, you have the possibility of filing a complaint with a supervisory authority (CNIL).

19. Date of entry into force of this charter

This charter came into force on June 26, 2020.