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Privacy policy

This English translation is provided for information only. In the event of any discrepancy, the French version prevails.

The website available at the following address: www.monga.io (hereinafter the “Site”) and the platform called “Monga App”, accessible at the following address: app.monga.io (hereinafter the “Platform”), are the property of MONGA, a simplified joint-stock company (société par actions simplifiée) with share capital of 518,260 euros, registered with the Nanterre Trade and Companies Register under number 887 521 862, whose registered office is at 119 bis rue de Colombes, 92600 Asnières-sur-Seine, France (hereinafter “MONGA”), which, as controller of personal data, attaches great importance to the protection of and respect for privacy.

The purpose of this privacy policy is to inform any person using the Site and/or the Platform (hereinafter the “Users” or the “User”), when browsing the Site and/or using the Platform, of MONGA’s practices regarding the collection, use and sharing of the information that Users provide, and of their rights.

The Site and the Platform comply with French and European standards on the protection of privacy and personal data, in particular French Law no. 78-17 of 6 January 1978 on information technology, data files and civil liberties (known as the “Informatique et Libertés” law), as amended by Law 2004-801 of 6 August 2004, and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”).

Controller of the personal data collected

The controller of personal data is MONGA.

Nature of the data collected

The data collected on the Site and/or the Platform in connection with the use of the services is data that allows MONGA to identify Users directly or indirectly and to provide the Services.

It may include the following categories of data about its Users:

  • civil status, identity and identification data such as surname or company name, first name, username, email address, postal address, date of birth, landline and mobile telephone numbers; and/or
  • connection data such as the IP address, and browsing data such as cookies;
  • banking data required to purchase the services offered by MONGA.

Users who provide the personal data of a third party must confirm that they have that third party’s consent to MONGA’s use of that third party’s personal data and to its publication and/or dissemination on the Site and/or the Platform.

Purposes of the personal data collected

The personal data collected on the Site and/or through the Platform is used only for, and during, the performance of the services, for the following purposes:

  • registration and authentication of the User; and
  • sending notifications to the User in order to: keep the User informed, by email, of MONGA’s latest news and/or offers; send system messages (for example notifications, invoices, forgotten passwords, etc.); communicate various information about MONGA’s services; and/or send the User information about the offers of MONGA’s partners.

In addition, MONGA may use and/or retain data to meet, where applicable, its legal and/or regulatory obligations.

Aggregation with non-personal data

MONGA reserves the right to publish, disclose and use aggregated information (information relating to Users or to specific groups or categories of Users, combined in such a way that an individual User can no longer be identified or mentioned) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes and other commercial purposes.

When data is collected

The data collected by MONGA is freely provided by Users when browsing the Site and when registering on the Platform.

It may also be collected automatically when the Site and/or the Platform is used, in particular when the User:

  • browses the pages of the Site, even without having created an account and/or used the Platform;
  • creates an account on the Platform; and/or
  • sends a request to MONGA via the contact form or by email.

In all cases, the personal data collected:

  • will be obtained and processed fairly and lawfully;
  • will be recorded for specified and legitimate purposes;
  • will be used in accordance with those purposes;
  • is adequate, relevant and not excessive in relation to those purposes;
  • and will be subject to precautions designed to ensure the security and confidentiality of the data, in order to prevent it from being damaged, altered, destroyed or disclosed to unauthorised third parties.

Consent

This privacy policy is systematically brought to the attention of Users when they register on the Platform. Creating an account implies the User’s express, full and complete acceptance of this privacy policy.

By ticking the box “I acknowledge that I have read and understood the privacy policy and I accept it”, the User consents to their personal data being stored and processed by MONGA and/or any of its partners.

IMPORTANT: NOTICE TO USERS

ANY BROWSING OF THE SITE AND/OR USE OF THE PLATFORM AFTER THE PUBLICATION OF THIS PRIVACY POLICY CONSTITUTES UNRESERVED ACCEPTANCE OF IT.

If the User wishes to withdraw their consent to the processing of their data, they simply need to go to their account and make the request using the forms provided on the Platform, or make the request directly by email to the following address: contact@monga.io.

In addition, where required by law and/or in certain circumstances, the User’s consent will be obtained, or an opportunity to refuse will be offered, before any transfer of data.

Recipients of personal data

The recipient of the personal data collected on the Site and/or through the Platform is first and foremost MONGA.

As publisher of the Site and of the Platform, MONGA is the recipient of the personal data collected on them.

Personal data is not disclosed to third parties. However, other recipients may have access to personal data. Where applicable, these are MONGA’s internal service providers in charge of the Site and/or the Platform (administration, sales, marketing, legal, etc.) and its external service providers (technical service providers, internet access providers, communication agencies, etc.).

In the event of a change of control of MONGA, a merger, an acquisition, insolvency proceedings or any other form of transfer of assets, the data collected by MONGA may be transferred to third parties. Nevertheless, MONGA undertakes to guarantee the confidentiality of the personal data collected and to inform Users before such data is transferred or becomes subject to new privacy rules.

Where required by law, the User’s consent will be obtained, or an opportunity to refuse will be offered, before any transfer of data.

Users’ rights

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) and with French Law no. 78-17 of 6 January 1978 on information technology, data files and civil liberties (known as the “Informatique et Libertés” law), as amended by Law 2004-801 of 6 August 2004, the User has:

  • a right of access to their personal data;
  • a right to modify their personal data;
  • a right to rectify their personal data;
  • a right to the deletion and erasure of their personal data;
  • a right to object to the use of their personal data;
  • a right to restrict the processing of their data; and
  • a right to the portability of their data.

A User wishing to exercise any of these rights may send their request by email or by post to the following addresses:

  • Post: MONGA – 119 bis rue de Colombes, 92600 Asnières-sur-Seine, FRANCE
  • Email: contact@monga.io

When exercising any of these rights, the User must send MONGA the information needed to identify them: surname, first name, email address and, where applicable, postal address.

In addition, in accordance with the regulations in force, the request must be signed and accompanied by a photocopy of an identity document bearing the User’s signature, be clear, and specify in detail the right the User wishes to exercise and the address to which the reply should be sent when one of the rights listed above is exercised.

MONGA will then reply within a maximum of one (1) month of receiving the User’s complete request.

Given the complexity of the request and/or the number of requests, this period may be extended to two (2) months, provided that MONGA informs the User of the reasons for the extension within one (1) month of receiving the request.

MONGA informs Users of their right to lodge a complaint with the French data protection authority, the Commission Nationale de l’Informatique et des Libertés (hereinafter the “CNIL”), in one of the ways set out below:

Data retention period

Retention of data for the duration of the contractual relationship

The personal data collected from Users is not kept beyond the time needed to perform the obligations defined when the contract was concluded or the predefined duration of the contractual relationship, except for data that MONGA may need to keep as evidence, for legal or administrative purposes or in accordance with the legislation in force.

Retention of anonymised data after the contractual relationship / after the account is deleted

MONGA keeps the personal data collected from Users for the period strictly necessary to achieve the purposes described in this privacy policy. If the contract is terminated or the User’s account is closed, MONGA will keep, for one (1) year from the date of termination of the contract or closure of the account, the information provided when the account was created, namely: the identifier used to create the User’s account; surname and first name; associated postal addresses; usernames used; associated email or account addresses; telephone numbers; the password and the data used to verify or change it, in their latest updated version. Browsing data will be kept for a maximum of six (6) months, in line with the CNIL’s recommendations. After this period, it will be anonymised and kept for statistical purposes only, and will not be used in any other way whatsoever.

Deletion of data after the User’s account is deleted

Procedures for purging the personal data collected from Users are in place to ensure its effective deletion once the retention or archiving period needed to achieve the specified or mandatory purposes has been reached.

Deletion of data after a period of inactivity

For security reasons, if the User has not logged in to the Platform for a period of one (1) year, the User will receive an email inviting them to log in as soon as possible, failing which the User’s personal data will be deleted from MONGA’s databases.

Links

When the Site and/or the Platform is used, MONGA reserves the right to recommend the services of third parties or potential partners. Users may therefore access various links directing them to third-party sites and/or the sites of potential partners.

MONGA shall not be responsible for any information sent to or collected by these third parties.

This privacy policy does not govern third-party sites or third-party content accessed by the User.

MONGA exercises no control over hyperlinks and/or other promotional formats.

Consequently, MONGA gives no guarantee concerning, in particular, the personal data protection practices of the indexed websites, and shall in no event be held liable in the event of a dispute between a website indexed on the Site and/or the Platform and a User, in particular as a result of losses or damage suffered, the operators of the indexed websites being solely responsible for their personal data protection practices.

Cookies

A cookie is a text file that may be saved in a dedicated area of the hard drive of the User’s computer when an online service is consulted with their browser. In practice, cookies are small text files placed on the User’s computer by the websites the User visits. They are used to make websites work and make them easier to use. The cookie is sent by a website’s server to the User’s browser. Each cookie is assigned an anonymous identifier. A cookie cannot be used to trace an individual. When consulting the Site and/or using the Platform, Users are informed that cookies or other means of recording browsing data are used by the Site and/or the Platform, in particular Google Analytics, or by third parties providing services for the Site and/or the Platform, and placed on the User’s device (computer, mobile or tablet). MONGA or its partners such as Google Analytics may install, subject to the User’s acceptance, various cookies, in particular: session cookies, which disappear as soon as the User leaves the Site and/or the Platform; persistent cookies, which remain on the User’s device until they expire or until the User deletes them using their browser’s features; and statistics cookies (used to measure the Site’s audience). Only the issuer of a cookie can read or modify the information it contains. In accordance with the CNIL’s recommendations, when the User first connects to the Site, they will be expressly asked to accept the Site’s cookies.

Purpose of cookies

The cookies used by MONGA or its partners make it possible to identify Users, recognise their browser when they connect to the Site and/or the Platform, record how often they visit (traffic measurement) and their display preferences for their device, adapt and/or personalise the presentation of the Site and/or the Platform to improve the User experience, and optimise the Site and/or the Platform for the sole purpose of providing the services requested by the User. In addition, the cookies used on the Site and/or the Platform follow the International Chamber of Commerce guide, by category: strictly necessary; functionality.

Strictly necessary cookies

Strictly necessary cookies allow the User to browse the Site and/or the Platform. These cookies do not collect any information about the User that could be used for marketing purposes. MONGA uses these cookies to: ensure the operation of the Site and/or the Platform and/or the Services; secure the Site and/or the Platform and/or forms and protect them against malicious scripts. MONGA does not use these cookies to: collect information that could be used to promote products or services to the User; or remember the User’s preferences or username after their visit.

Functionality cookies

These cookies are used to provide services or to remember the User’s settings in order to improve their visit to the Site, their experience on the Platform and/or their use of the Services. MONGA does not use cookies to collect personal information that could be used to promote products or services to the User on other sites.

Audience measurement cookies

With the User’s consent, MONGA uses Google Analytics (Google Ireland Limited) and Hotjar (Hotjar Ltd, Malta), deployed through Google Tag Manager, to measure traffic on the Site, understand how it is navigated and improve its content. These cookies are only set after the User has accepted them in the banner provided for this purpose. If the User refuses, no audience measurement cookie is set and the Site remains fully accessible.

Chat and callback requests

The Site offers an instant messaging service (“chat”) and callback request forms. The chat only loads when the User opens it. The information entered (name, email address, phone number, company, messages) is sent to MONGA and stored in its customer relationship management tool in order to reply to the User; an alert is sent to the MONGA team in its internal Slack workspace, and the team’s replies may be emailed to the User. To find their conversation again, the chat keeps a technical identifier in the browser, which is strictly necessary for this service and exempt from consent. The chat and the forms set no audience measurement or advertising cookies.

Cookie retention period

In accordance with the CNIL’s recommendations, audience measurement cookies have a maximum lifetime of thirteen (13) months after they are first placed on the User’s device. The User’s choice, whether acceptance or refusal, is kept for six (6) months in their browser (local storage and, in the event of refusal, the technical cookie “mg_consent_refus”, which is exempt from consent); the User is asked again at the end of this period. The lifetime of cookies is not extended with each visit.

The User’s right to refuse cookies

When the User first browses the Site, a banner providing information on the use of cookies appears. It allows the User to accept or refuse audience measurement cookies with the same ease, without blocking navigation. No cookie subject to consent is set before this choice is made. The User can change their choice at any time using the “Manage cookies” link at the bottom of every page of the Site.

Users can also configure their browser to block, in whole or in part, the recording of cookies. For more information, the User can consult their browser’s help pages:

However, Users are informed that if they refuse the recording of cookies or uninstall a cookie, certain services may no longer work properly.

Transfer of personal data abroad

MONGA processes Users’ data within the European Union. Only audience measurement data, collected with the User’s consent, and the alerts sent to the MONGA team in Slack may be transferred to the United States by Google and Slack, under the EU–US Data Privacy Framework (European Commission adequacy decision of 10 July 2023). Nevertheless, in the event of an international transfer outside the European Union, a distinction should be made between: countries that are the subject of an adequacy decision by the European Commission, in which case the Data is transferred to a country providing a level of protection deemed sufficient and adequate under European data protection regulations; and countries whose level of data protection has not been recognised as adequate, in which case, to ensure that the transfer complies with European regulations and, in particular, to guarantee the security of the data, MONGA will base the transfer on protection mechanisms suited to each service provider and processor, such as the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules, or an approved certification mechanism.

Security

MONGA undertakes to implement the appropriate technical and organisational measures that are reasonably necessary under the regulations applicable to the protection of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, in order to guarantee a level of security appropriate to the risks to the rights and freedoms of natural persons in connection with the processing covered by this privacy policy. When personal data is transferred to third parties for processing, MONGA ensures that those third parties implement all appropriate technical and organisational measures to protect personal data in accordance with applicable laws. These measures are defined taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks identified. Depending on the needs, risks, costs and purpose of the processing, these measures may include pseudonymisation and encryption of data. This protection may be indicated by “https” in the browser’s URL and by a closed padlock symbol. Finally, in the event of a personal data breach likely to result in a high risk to the User’s rights and freedoms, MONGA undertakes to inform the User of this breach within a maximum of seventy-two (72) hours.

Changes to the privacy policy

MONGA reserves the right to modify and update this privacy policy at any time, in particular to take account of any legal and/or case-law developments and to meet the requirements of the regulations applicable to the protection of personal data. MONGA will inform Users of any significant changes or updates by email. The version that prevails is the one accessible online on the day the Site is consulted and/or the Platform is used. Any consultation of the Site and/or use of the Platform after publication of the amended privacy policy constitutes the User’s unreserved acceptance of the new privacy policy.

Contacts

For any request for information or to find out more about the processing of their personal data, including the exercise of the rights set out above, the User may contact MONGA from their account using the Platform’s contact form, or by email or post at the following address:

Email: contact@monga.io

Post: MONGA – 119 bis rue de Colombes – 92600 Asnières-sur-Seine, FRANCE

For any complaint or dissatisfaction regarding MONGA’s use of their personal data, the User may contact MONGA using the Platform’s contact form, or by email or post at the following address:

Email: contact@monga.io

Post: MONGA – 119 bis rue de Colombes – 92600 Asnières-sur-Seine, FRANCE

When the User contacts MONGA, they will be asked to identify themselves.

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