PRIVACY POLICY
PREAMBLE
The company Team Vitality places great importance on protecting the privacy and data of users of its website https://rushbee.agency (hereinafter the "Website"). It therefore ensures that it adopts and strictly adheres to a privacy policy that complies with applicable regulations, in particular Regulation (EU) 2016/679 known as the General Data Protection Regulation ("GDPR").
When the terms "you", "your", or "yours" are used, they refer to users of the Website.
This personal data protection policy (hereinafter the "Policy") is intended to inform you of the personal data that may directly or indirectly identify you ("Personal Data") that may be collected via the Website, as well as how it may be used and what rights you have over this data.
The Policy may be modified at any time by Team Vitality, in particular to comply with legislative, regulatory, case law, editorial and/or technical developments. You are advised to refer to the latest version of the Policy before browsing or using the Website.
WHO IS THE DATA CONTROLLER?
The data is collected by Team Vitality, a simplified joint stock company with a share capital of €73,442, whose registered office is located at 102, Boulevard de Sébastopol – 75003 Paris, and registered with the Paris Trade and Companies Register under number 794 387 498 ("Team Vitality").
WHAT PERSONAL DATA IS COLLECTED?
Personal Data you provide us
The Personal Data collected by Team Vitality is the data that you provide directly by filling out a contact form or subscribing to a newsletter, namely:
First name, Last name;
Email address.
Personal Data collected automatically by Team Vitality
Team Vitality may also collect your browsing data through data collection tools: digital identifiers including cookies, IP address and device identifiers, client identifiers, tags, beacons, and any other appropriate technical means whose use is detailed in Article 5.
Personal Data of minors
In accordance with Article 8 of Regulation (EU) 2016/679 and the French Data Protection Act, only minors aged 15 or older can consent on their own to the processing of their Personal Data.
If the user is a minor under the age of 15, the consent of a legal representative will be required so that their Personal Data can be collected and processed.
ON WHAT LEGAL BASIS IS PERSONAL DATA COLLECTED AND PROCESSED? FOR WHAT PURPOSES?
Your Personal Data is only processed by Team Vitality in cases permitted by applicable law.
Legal basis
In accordance with Article 6.1.a) of the GDPR, your Personal Data is collected and processed on the basis of your free, specific, informed, and unambiguous consent, which you express by explicitly accepting the content of this Policy when using the Website, filling out a contact form, or subscribing to a newsletter.
Purposes
Accordingly, you are informed that the data collected on this legal basis is used to:
Send you information about the activities of the RushBee agency through newsletters, from which you may unsubscribe at any time by clicking the dedicated link. Such newsletters may include advertisements on behalf of Team Vitality’s partners;
Carry out (in an anonymous manner) statistical analyses of the Website's activity in order to measure satisfaction and quality of services, and to improve and optimize the Website;
Facilitate your use of the Website and personalize your experience according to your interests and needs, in particular by providing a suitable language (French or English).
Team Vitality only collects data that is adequate, relevant, and limited to what is necessary in view of the purposes for which it is processed.
These purposes are specific and legitimate and, under no circumstances, will your data be further processed in a manner incompatible with these purposes, unless your prior consent is obtained.
WHO ARE THE RECIPIENTS OF PERSONAL DATA?
Team Vitality undertakes never to communicate your Personal Data to any third party intending to use it for direct marketing purposes, unless you have been expressly informed of this possibility and have given your prior express consent.
The Personal Data collected by Team Vitality may be communicated, for the purposes described above in Article 3, to the following persons:
Authorized personnel within the company Team Vitality and, more specifically, depending on the case, the marketing, commercial, and growth media departments, as well as their hierarchical superiors, each having limited access only to the data necessary for the specific purpose they are pursuing;
Service providers, agents, or vendors engaged by Team Vitality, in particular those in charge of ensuring the provision of the Website and analyzing user behavior; the subcontractors processing Personal Data are bound by contract with Team Vitality under which they commit to complying with GDPR requirements;
The purchaser of Team Vitality in the event of a merger or acquisition;
Competent authorities upon request, in accordance with current regulations.
All persons working with or under the responsibility of Team Vitality and having access to Personal Data are required to maintain the confidentiality and security of the Personal Data and to implement appropriate protective measures.
COOKIES AND OTHER TRACKERS
The Website uses tracking tools such as cookies and IP addresses to process traffic statistics and information, facilitate navigation, and improve the service for the user’s comfort.
Tracking tools allow, during each of your visits and based on the purposes defined in Article 3, the study of your behavior during your navigation on the Website in order to provide you with a better browsing experience and usage of our services.
What are cookies?
A cookie is a small text file containing information, which is stored on your device’s hard drive (e.g., computer, tablet, or mobile phone) when you visit the Website using your browser. It is sent by the Website’s server to your browser. The cookie file allows its issuer to identify the device in which it is stored during the validity or storage period of the cookie in question.
How to disable cookies?
You can prevent cookies from being stored by configuring your browser software.
If the user decides to disable cookies, they may continue browsing the Website. However, any malfunction of the site caused by such action shall not be considered the responsibility of Team Vitality.
WHAT IS THE RETENTION PERIOD FOR PERSONAL DATA?
Team Vitality retains Personal Data only for the time necessary to fulfill the purposes pursued, subject to legal archiving possibilities, obligations to retain certain data, and/or data anonymization.
Personal Data will thus be deleted no later than three years from the last contact with the user.
Cookies and other trackers will be retained only for a period of thirteen (13) months from their insertion in your Internet browser.
WHAT SECURITY MEASURES ARE IMPLEMENTED?
The Website uses an SSL certificate to ensure that information and data transfers through the Website are secure.
Since Personal Data is confidential, Team Vitality limits its access to only those employees or service providers who need it to perform processing.
All persons with access to Personal Data are bound by a duty of confidentiality and may be subject to disciplinary and/or other sanctions if they fail to comply with these obligations.
When Team Vitality uses subcontractors, such communication is governed by a contract to ensure the protection of such information.
The data is hosted and processed on secure servers located within the European Union and operated by Team Vitality’s subcontractors acting in compliance with GDPR requirements.
If the integrity, confidentiality, or security of a User’s Personal Data is compromised, Team Vitality undertakes (i) to notify the CNIL within 72 hours after becoming aware of the breach and (ii) to inform the data subject as soon as possible when the breach is likely to result in a high risk to the rights and freedoms of the data subject.
WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
Subject to the limits provided by applicable law, you have the following rights concerning the processing of your Personal Data:
Right to information
The User has the right to be informed in clear and simple terms about the conditions under which their Personal Data is used.
Right of access
The right of access allows you to obtain confirmation from Team Vitality as to whether or not your Personal Data is being processed and under what conditions, and to receive a copy of such data.
Right to rectification
You have the right to obtain from Team Vitality, as soon as possible, the rectification of any of your Personal Data that may be inaccurate, incomplete, ambiguous, or outdated.
Right to erasure
You have the right to request from Team Vitality the deletion, as soon as possible, of your Personal Data when one of the following reasons applies:
Your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed;
You wish to withdraw your consent on which the processing of your Personal Data was based, and there is no other legal basis justifying this processing;
You believe and can establish that your Personal Data has been subject to unlawful processing;
Your Personal Data must be deleted to comply with a legal obligation.
Right to withdraw consent
When Team Vitality processes your Personal Data based on your consent, that consent may be withdrawn at any time using the tools provided to you for that purpose.
However, and in accordance with applicable law, the withdrawal of your consent only applies for the future and does not affect the lawfulness of the processing carried out before such withdrawal.
Right to restriction of processing
Applicable law provides that this right may be invoked in certain cases, in particular the following:
When you dispute the accuracy of your Personal Data and for the time required to verify its accuracy;
When you believe and can establish that the processing of your Personal Data is unlawful, but you oppose the deletion of the data and instead request the restriction of its use;
When Team Vitality no longer needs your Personal Data but you still require it for the establishment, exercise, or defense of legal claims.
Right to object to the processing of Personal Data
You may object at any time to the processing of your Personal Data for direct marketing purposes. You may also object to profiling. In this case, you will no longer receive personalized offers.
Right to data portability
You have the right to request that we provide your Personal Data to you or transfer it to another service provider.
Right to decide the fate of your Personal Data after your death
You have the right to determine what happens to your Personal Data after your death by establishing general or specific directives. Team Vitality undertakes to comply with these directives.
In the absence of such directives, Team Vitality acknowledges that the heirs may exercise certain rights, in particular the right of access (if necessary for the settlement of the deceased’s estate) and the right to object (in order to close the deceased’s user accounts and oppose the processing of their Personal Data).
Right to lodge a complaint with a supervisory authority
If any of your rights are not respected or if the processing is unlawful, you may file a complaint with the national data protection authority (in France, this is the Commission Nationale de l’Informatique et des Libertés, CNIL – see contact info: https://www.cnil.fr/en/contact-cnil).
HOW TO EXERCISE YOUR RIGHTS
For any question related to this Policy and/or to exercise your rights as described above, you may contact Team Vitality by mail or electronically at the following address: dpo@rushbee.ag
Your request must be made in writing, signed, and accompanied by a copy of an identity document bearing your signature.
Team Vitality undertakes to respond to you as soon as possible and, in any case, within one month from the date of receipt of your request.
If necessary, this period may be extended by two months given the complexity and number of requests received by Team Vitality. In such case, you will be informed of the extension and the reasons for the delay.
If your request is submitted electronically, the information will also be provided to you electronically when possible, unless you expressly request otherwise.
IS PERSONAL DATA TRANSFERRED TO RECIPIENTS LOCATED IN THIRD COUNTRIES?
No transfer of Personal Data outside the European Union is carried out.