YOURBAN may need to process the personal data of its prospective customers and users (hereinafter the ‘Data Subjects’) collected via its website accessible at https://yourban.io/ (hereinafter the ‘Website’).

It assumes, in this context and vis-à-vis these persons, the capacity of data controller with regard to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter the ‘GDPR’).

The purpose of this privacy policy is to inform Data Subjects about how YOURBAN processes their personal data, as well as their rights in this respect.

More specifically, Data Subjects are informed of the following.

✔ Identity of the data controller

YOURBAN is a simplified joint stock company, registered in the Nanterre Trade and Companies Register under number 911 661 627, with its registered office at 8 rue Auguste Bailly - 92600 Asnières-sur-Seine, represented by Mrs Amélie JARIEL, in her capacity as Chairman.

YOURBAN's Data Protection Officer:
Mr Eliott Colson
Contact email address: [email protected]

✔ Data collected

YOURBAN may collect, in whole or in part, the following personal data (hereinafter referred to as ‘Personal Data’) from Data Subjects:

Identification data :
- Last Name
- First Name
- Email address

Usage data :
- Internet Protocol address (e.g. IP address) of the device,
- Browser type and version,
- Pages of the Site visited
- Time and date of visit, time spent on these pages,
- Type and unique identifiers of the device and other diagnostic data
- Cookies collecting personal data

In accordance with the principle of data minimisation or ‘Privacy by default’, YOURBAN only collects data that is strictly necessary for the purpose for which it is processed.

✔ Purposes of processing and basis

The Data is processed for the following purposes and on the following grounds:
- Canvassing and commercial solicitation : Consent of the Data Subject
- Sending newsletters : Consent of the Data Subject
- Promotional and loyalty-building activities : Consent of the Data Subject
- Management of any request made by a User : Performance of the contract between YOURBAN and the Data Subject
Purposes linked to the deposit of cookies, i.e. :
- Personalising and improving the User's experience on the Site (personalisation cookies) : Consent of the Data Subject
- Carrying out statistics and audience measurement (statistical cookies) : Consent of the Data Subject

✔ Recipients

The Data processed is destined, depending on the requirements:
- the authorised departments of YOURBAN
- services responsible for control (chartered accountant and auditor in particular);
- any sub-contractors of YOURBAN;
- partners of YOURBAN;
- public bodies, when required by law.

✔ No assignment or transfer

The Personal Data collected will not be transferred, rented or exchanged for the benefit of a third country or an international organisation.

✔ Exercise of the rights of the persons concerned
‍
- Right of access to data : The Data Subject has the right to obtain from YOURBAN access to his/her Personal Data collected by YOURBAN.
- Right to rectification of data : The Data Subject has the right to obtain from YOURBAN, as soon as possible, the rectification of any Personal Data which is inaccurate. In particular, the Data Subject has the right to have incomplete Personal Data completed.
- Right to erasure of data : In exercising their right to be forgotten, Data Subjects have the right to request the deletion of their Personal Data. YOURBAN is obliged to erase Personal Data in the following situations:
  - When the Personal Data is no longer necessary for the purposes for which it was collected;
  - In the event of withdrawal of the consent of the Data Subject on which the processing is based (and where there is no other legal basis for the processing);
  - If the Data Subject objects to the processing of the Personal Data (and where there is no compelling legitimate reason for the processing);
  - When Personal Data is processed unlawfully;
  - When the Personal Data must be deleted in order to comply with a legal obligation.
- Right to limit processing : The Data Subject may, in the following cases, request YOURBAN to limit the processing of his/her Personal Data, i.e. that his/her data be temporarily made inaccessible:
- When he/she disputes the accuracy of one or more of his/her Personal Data;
  - When the processing is unlawful and the Data Subject objects to the erasure of the data and instead requests a restriction on its use;
  - When the Data Subject needs his/her data for the establishment, exercise or defence of legal claims and YOURBAN no longer needs it for the purposes of processing;
  - When the Data Subject has objected to the processing: in this case, the limitation will be effective for the time necessary to ascertain whether the legitimate reasons pursued by YOURBAN prevail over those of the Data Subject. YOURBAN undertakes to inform the Data Subject before making his/her data accessible again.
  - The Data Subject has the right to object at any time to the processing of his/her Personal Data.
- Right to object to processing : The Data Subject may request YOURBAN (i) to retrieve the Personal Data that he/she has provided or (ii) to transfer them to another data controller, insofar as the processing of such data is carried out using automated processes.
- Right to data portability : Your Data Subject may request YOURBAN (i) to retrieve the Personal Data that he/she has provided or (ii) to transfer it to another controller, insofar as the processing of such data is carried out using automated processes. If this right is exercised, the data will be provided or transmitted in a structured, commonly used and machine-readable format.
- Right of complaint : The Data Subject may lodge a complaint with a supervisory or judicial authority.
- Right to give instructions in the event of death : The Data Subject may lodge a complaint with a supervisory or judicial authority. The Data Subject has the right to give instructions concerning the fate of his/her data in the event of death.
- Right to withdraw consent : If the processing is based on the consent of the Data Subject, the Data Subject may withdraw his/her consent at any time, without prejudice to the lawfulness of the processing based on consent carried out prior to the withdrawal of consent.

To exercise these rights, the person concerned must send an email to YOURBAN at the following address: [email protected].

Each request must be accompanied by proof of identity. In the event of reasonable doubt as to the identity of the person making the request, they may be asked for additional information necessary to confirm their identity.

✔ Data retention period

Prospects :

Personal Data is kept for a period of three (3) years from the date of collection.
It is however specified that :

- The aforementioned period is renewed each time a positive response is received from the prospect following a personalised solicitation;
- The above-mentioned period is applicable subject to the withdrawal of the prospect's consent.


Users who make a request to YOURBAN :

Personal Data is kept for the duration of the processing of the User's request and for one (1) year thereafter.

They are then archived for a period of five (5) years for evidential purposes.

In general, cookies are stored on the User's terminal for a maximum period of thirteen (13) months, subject to the User's choices and in particular their opposition to the placing and reading of cookies on their terminal.

✔ Data security

YOURBAN ensures the security of Personal Data by implementing appropriate organisational and technical measures to guarantee a level of security appropriate to the risk to the rights and freedoms of the persons concerned.