1 GENERAL INFORMATION
This charter sets out the conditions for handling of information collected by the WIIDII company, a simplified joint-stock company with capital of EUR 586 024.37, registered at the R.C.S. of Bordeaux (Companies Register) under the number 803025972, and whose headquarters are situated at 3 rue Allée Fabre d’Églantine – 33160 SAINT MÉDARD EN JALLES – FRANCE, as part of its concierge and personal assistance service which combines artificial intelligence and human intervention, as described in its Terms of Service or ToS.
The WIIDII company (hereafter referred to as “WIIDII” or as “we”) attaches great importance to the protection and the respect of the private life of any person whose personal data it processes as part of the services listed above (hereafter referred to as “you”).
This charter aims to inform you of our practices regarding the collection, use and sharing of the information that you supply us via our Application or more generally as part of our relationship.
This policy, as well as our Terms of Service and any document which refers to it, presents the way in which we handle personal data we collect and that you provide. We invite you to read this document carefully, to get to know and understand our practices regarding the handling of your personal data.
You particularly benefit from the right to refuse certain aspects of the handling of your personal data at any moment (see point 6 below for more information). To exercise these rights, you may contact our Data Protection Officer in accordance with the method defined in article 9 below.
Please Note: In the case of any discrepancies in meanings of any translated versions of these Policies, the meaning of the French Language version shall prevail.
2 INFORMATION COLLECTED
We are likely to process the following data:
Some data is sent to us directly by you (see 2.1), other data is sent to us automatically (see 2.2). You have several rights regarding the handling of this data (2.3).
2.1 INFORMATION SENT DIRECTLY BY YOU
By using our Application, you are required to send us information which is able to identify you and is necessary for the use of WIIDII’s personal assistance Service.
2.1.1 Personal Data Sent
Personal data is sent when you fill in forms (the subscription form for example) or when you ask to create a personal space on the website managed by another company, whether it be by means of the Application, by phone, email or any other means of communication. Data is also sent when you inform us of a problem or a complaint with a Service Provider.
This information in particular contains the necessary data for the subscription to the service we provide on our Application or access to any other mobile application published by WIIDII, namely on behalf of other companies, enabling access to WIIDII’s personal assistance Service.
This data is:
- Your full name,
- Email address,
- Postal address,
- Date of birth,
- Phone number,
- Subscription code sent to you by your Professional Adherent
- And your password.
This information is mandatory as it is necessary for the carrying out of services. If this is not sent to us, you will not be able to access the Application as we will not be able to provide you with the service.
You may also send us other data, such as your bank details, your location, or your personal preferences. If you do not send us this information, you will not be able to benefit from all of the Application’s features, and some of our services will not be accessible to you.
2.1.2 Other Important Information for Use of Service
This information contains data that you send us directly as part of the use of WIIDII’s personal assistance Service. This information is essential to carry out services.
This data is:
- A copy of all of the exchanges that have occurred between you and WIIDII;
- A copy of all of the reservation or information requests carried out via our Application;
- The detail of the financial operations carried out for you by our intermediary via the Application or by any other means, including phone or email, in particular containing information regarding your reservations and your purchase of goods or services;
- The detail of your visits to our Application and the contents you accessed;
- Data that we may ask you to provide when you flag a problem regarding the use of our Service;
- Data linked to your location after you have accepted that we collect and process this data;
- A copy of your passport, your driver’s license, your identity card or any other similar document that you accepted to provide if this information is necessary to reserve or purchase a service;
- Proof (of any kind) of your consent for reservations or the purchase of goods or services carried out via the Application and your acceptance of the Terms of Service and/or sales conditions of a third-party Service Provider;
- A copy of all of the requests of written or spoken messages to your contacts;
- A copy of all the documents that you have asked to be saved in order to consult them at a later time via the Application (passport, identity card, driver’s license, blood group card, vaccination card, loyalty cards and, more generally, any official or unofficial identification card).
If you would like us to book medical appointments, you must give us your express consent to process the corresponding data. Failing that, this data will immediately be deleted, and we will not be able to process your request. Furthermore, we will not be able to process requests regarding a person other than the user without the express consent of the person concerned.
2.2 Data Collected Automatically
Every time you log into the Application, we are likely to collect, in accordance with the applicable legislation and with your agreement, if need be, information regarding the devices on which you use our services or the networks from which you access our services, such as your IP address, connection data, type and version of the mobile used, type and version of the operating systems of your mobile device, data regarding your navigation history on our Application, in particular your use of different pages, the content you access or check, the search terms you use, the downloading errors as well as any phone number used to contact us.
We also collect information about your use of our Application, such as:
- the number of requests you make using the Application,
- The nature of the information that you wish to obtain via the Application,
- The number of connections to the Application, their dates and times.
This data is only sent to third parties anonymously.
2.3 Your Rights to this Data
When giving evidence of your identity and if the conditions to exercise these rights are fulfilled, you can use your right of access, right of rectification, right of deletion, right to the limitation of handling, right to refuse, right of portability, right to lodge a complaint with the CNIL and your right to determine the fate of your data after your death. These procedures are detailed in point 6 below.
2.4 Period of Data Conservation
- Your Personal Data is archived for three years following the end of your subscription;
Categories of the following Personal Data are likely to be kept for different periods of time:
Financial data (payment requests for example) are kept for the length of time required by laws applicable to fiscal and accounting matters (6 years after the end of your subscription concerning billing data);
The proof of your consent to purchases, reservations or orders of goods or services for the length of time required by the applicable laws (6 years after the end of your subscription).
When you send us information to book a medical appointment, the corresponding personal data will be deleted as soon as the request has been completed.
3 HOW WE USE THE DATA COLLECTED
The Application’s goal is to combine machine and human beings in order to offer the best semi-automated personal assistance service.
The Application works to create a dialogue with you. To be more consistent, the Application must learn and memorise all the information that you give.
The more you use the application developed by WIIDII, the more it gets to know you and will answer you in a more personalised manner.
We use the data we collect to:
- Ensure the service which links you to Service Providers (that may be WIIDII’s commercial partners) and send them your request,
- Enable the formalisation of service contracts or deliveries of material or immaterial goods, between you and the Service Providers, in your name and on your behalf, as part of the authorisation that you have given us by accepting our Terms of Service;
- Make appointments, including with professionals whose activity is regulated, at your request (and in the case of medical appointments, on the condition of having obtained your express consent for data processing). In any case, the service is limited exclusively to booking the appointment;
- Supply you with the information you require as part of your requests;
- Send you information via the Application, by email or by any other means of communication;
- Receive your payment requests for Service Providers, by credit card or any other means, as part of the mandate you entrusted us with by accepting our Terms of Service;
- Enable you to personalise your profile on our Application;
- Send you, in accordance with the applicable legal provisions and with your agreement when the legislation requires it, marketing, advertising and promotional messages, as well as information relative to the use of our services, our reservation processes, or to suggest or advise you on goods and services that may interest you;
- Inform you of modifications that we have made to our services;
- Verify the information that we have collected on your subscription or when using our Application;
- Manage our Application and carry out internal technical operations as part of the resolution of problems, data analysis, tests, research, analysis, studies and polls, anonymously;
- Improve and optimise our Application.
Furthermore, we use information in order to make suggestions, personalise and improve our personal assistance Service. Geographic information may come from the precise location of devices (if you have authorised us to collect it), IP addresses and information concerning your use of our Service.
For example, we use the information at our disposal to develop, test and improve our Service and our Application, by carrying out grading and research.
4 RECIPIENTS OF COLLECTED INFORMATION?
4.1 THROUGH OUR SERVICES, SOME INFORMATION WILL BE SENT TO:
- Professional Adherents that authorised you to use the Application by sending you a code;
- Service Providers (service providers, goods suppliers, search engines, reservation offices, transport companies, train companies, or airlines, etc.)
- as part of reservations, information, details on purchasing goods and services;
- contacts to whom you have asked us to send a message or information.
We are also likely to share information about you, with other companies of the WIIDII group that currently exist or that may be created in the future, in particular your Personal Data.
Regarding information relative to your payment details, you may save details of your bank card in your personal space on the Application. The saving of these details will be done via a secure interface that locally stores information in a secure and compartmentalised part of your mobile device. The data is only available via the Application. Neither the user of the mobile device (even you), nor any other application will have access to it. The data is encrypted via the AES 256-bit algorithm (a standard used by organisations of the United States government), with a strong, random and unique encryption key for the user, that is stored in a secure space on the WIIDII servers. It is therefore impossible to access via your mobile device or to directly take advantage of the saved payment card. Once this information has been supplied in your personal space, the details of your payment card are modifiable (reset of all of the editing fields) but not visible (the user of the mobile device cannot see the information saved).
In order to guarantee maximum security, no bank information is stored on the WIIDII servers, the mobile device contains the encrypted data of your card and the server contains the encryption key. It is therefore impossible to have access to the payment card details without having these two sets of information simultaneously (that are both stored on two independent and different secure platforms).
4.2 DATA IS ONLY SHARED WITH THIRD PARTIES MENTIONED ABOVE IN THE FOLLOWING CASES:
- When we use a Service Provider for the execution of a contract agreed between you and this Service Provider, for the supply of goods or services, to send information, or for the reservation of an event or a service.
- In order to supply or to improve our personal assistance Service;
- As part of reservations, we are asked to share with the Service Provider some of your Personal Data such as your surname, first name, postal address, mobile phone number and email address, payment references and bank card details for remote payments, in order to supply the requested services;
- If we use a search engine or analytical solution to supply information you request via the Application;
- If you make an express request (for example when you ask us to send a message to a contact, subscribe to a service supplied by a Service Provider by identifying yourself or creating a personal space);
- When we have the legal obligation to do so or if we think that in good faith it is necessary to respond to a claim against WIIDII or the Professional Adherent, conforming to any judicial request, bring proof of your consent for any contract established with Service Providers, such as the Terms of Service or the Service Provider’s Terms of Service and their Privacy Policies, in emergency cases that may threaten public health or the physical integrity of a person, as part of enquiries or investigations, or in order to guarantee the rights, goods and security of WIIDII, Professional Adherents and more generally any third party;
- If WIIDII or any part of its assets are bought by a third party, the data in our possession will be transferred to the new owner if required.
We draw your attention to the fact that if you ask us to share some of your information, particularly your Personal Data, with Service Providers, through the connection services made available by the Service Providers, their confidentiality policies will be applicable to you. We have no control on the collection or the processing of your data by the Service Providers on their own platform.
We inform you that when WIIDII is required to order something on behalf of a client, WIIDII will refuse to consent to the processing of any of the client’s personal data that is not necessary for the carrying out of the service.
The legitimate interests we have for the processing of your data is the following:
- To create, supply, take charge and maintain the features of the Application, the goal of which is to offer a service of personalised assistance, making daily tasks and access to public information easier;
- To protect our Application, verify accounts and activities, fight against harmful behaviour, detect and avoid inappropriate content, ensure that your requests do not contain any harmful content, are not inappropriate or illegal, investigate suspicious activities or the violation of our conditions or rules of use;
- On an anonymous basis, to supply services of measurement and analysis and other commercial services,
- On an anonymous basis, to supply precise and reliable reports to our partners (especially Professional Adherents), developers and other commercial partners, to guarantee a fair pricing system and precise statistics on performance, and to demonstrate the utility of the Application;
- On an anonymous basis, in the interest of our partners (namely the Professional Adherents), to help them understand the behaviour of their clients, their employees and their members and to improve commercial offers, to approve our subscription pricing systems and to evaluate efficiency when using our Application;
- On an anonymous basis, to carry out research and development tasks in order to improve current knowledge base and to develop a digital system of personal assistance that is affordable and efficient for all users.
- To share information with others, especially law enforcement agencies, and to respond to legal requirements, in order to stop and control fraud, the unauthorised use of WIIDII, the violation of our conditions or rules, or any other dangerous or illegal activity, to protect WIIDII’s intellectual property rights and those of its partners, especially Professional Adherents, our users or any other person as part of investigations or regulatory demands.
5 How and when is your data transferred?
As a general rule, we keep your Personal Data within the French territory. However, in order to maintain a 24/7 service, we are likely to share information connected to you, especially your Personal Data, with other companies in the Wiidii group, located outside of the European Union, and especially in Canada. Since 1983, in Canada, there has been a law on the protection of personal information which added the Personal Information Protection and Electronic Documents Act (PIPEDA) in 2000 and the Canadian Charter of Rights and Freedoms.
Your personal data can be transferred outside of Europe when it is needed to complete or execute a contract agreed in the interests of the person concerned with Wiidii.
In any case, the transfer of your Personal Data is strictly limited to what is necessary to supply the WIIDII Service.
6 WHAT ARE YOUR PERSONAL DATA RIGHTS?
6.1. You have the right to obtain confirmation that personal data that concerns you is or is not handled by us and that when it is, you have the right to access the said personal data. If you exercise this right, you will receive a copy of your Personal Data in our possession (“right of access”).
6.2. You may also request the deletion of your Personal Data as well as the rectification of erroneous or obsolete Personal Data (“right of deletion and right of rectification”). Please note that we are likely to keep some information related to you when the law requires it or when we have a legitimate motive to do so. For example, this is the case if you have committed fraud or violated our Terms of Service.
6.3. You have the right to limit the processing of your Personal Data (“right to limitation”). Please take note that this right only applies if you contest the accuracy of your Personal Data for the duration allowing us to check its accuracy, in the case of the illicit use by us, and you require us to limit its use rather than delete it. We no longer need personal data at the end of this processing, but you still need it for the establishment, exercise or defence of legal claims, in case you exercise your right of refusal through the verification whether our legitimate grounds prevail over yours.
6.4. You have the right to lodge a complaint with the appropriate supervisory authority or to obtain compensation from the appropriate courts if you consider that we have infringed on your rights.
6.5. You also have the right to the portability of your data, that is to say the right to receive the Personal Data that you supplied us with in a structured format, currently in use and machine legible, and the right to forward this data to another data controller (“right of portability”).
6.6. When the processing of personal data requires your consent, you have the right to withdraw it at any time. The withdrawal of consent does not compromise the legality of the processing based on the consent given before withdrawal.
6.7. You have the right to refuse the processing of this personal data relating to you at any time, and whose processing is based on a legitimate interest. In this case, we will cease to process this data, unless we show that there are legitimate or urgent reasons for processing that prevail over the interests and the rights and freedoms of the person concerned, or for the acknowledgement, the exercise or the defence of rights in court.
When personal data is processed for market research purposes, the person concerned has the right to refuse the processing of this personal data concerning them for said purposes, at any moment. When the person concerned refuses this processing for market research purposes, the personal data is no longer processed for these means.
To exercise these rights, you may contact our Data Protection Officer in accordance with the method defined in article 9 below.
6.8. You have the right to sign up to “Bloctel” or a similar service list to refuse cold calling: https://conso.bloctel.fr/.
7 LINKS TO OTHER WEBSITES
Our Application regularly sends you links to the websites of Service Providers which are third-party companies. Please note that these websites have their own Privacy Policies and the we accept no responsibility for the use of the information that is gathered by these sites when you click on these links. Please read the Privacy Policies of these websites before sharing your Personal Data.
- Sending an email to our Data Protection Officer Charlotte Lamotte at the following email@example.com
- Or by sending us a letter to the following address: WIIDII – FAO Charlotte Lamotte, Delegate for the Protection of Data –208 Quai de Paludate, 33800 BORDEAUX – FRANCE.
- Or by contacting the Commission Nationale de l’Informatique et des Libertés (National Commission for Data Protection and Liberties)
3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07
Tel: 04 53 73 22 22