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FOLLOWO Privacy and Cookies Policy – www.followo.com

FOLLOWO respects and protects the privacy of registered users and users who only visit the website.

§1 Information concerning the collection of personal data

(1)Purpose and scope of this document

The purpose of this document is to inform you about the collection and processing of your personal data by Followo Sàrl during the consultation and use of our Internet platform www.followo.com. It is therefore addressed to three categories of people:

Members who hold a client user account;
Members holding a merchant account;
Non-registered visitors

(2)Concept of personal data / personal data

Personal data is any information that relates to you, such as, for example, your name, your postal address, your e-mail address, your telephone number, the history of your purchases or your behaviour.

(3)The responsible person for the processing of personal data

The controller in the sense of art. 4, paragraph 7, of the European General Regulation on the Protection of Personal Data (RGPD) is: Followo Sàrl, whose registered office is at rue de la Berra 59, CH-1630 Bulle (hereinafter: "Followo "," Us "or" our "). You can address your requests for data protection to the following address: info@followo.com.

(4)Collection and use of data in e-mail contacts

When contacting us by e-mail or through our contact form, the contact details you provide are recorded, as well as the content of your message, in order to answer your requests / questions. . We delete these data once their retention is no longer necessary to respond to your requests / questions or we limit the processing of such data when there are legal data retention obligations or when we store your data under interest legitimate. In principle, the data is stored in Switzerland. Please note, however, that the data attached to the emails and / or contact form you send to us may be stored abroad, but in this case, only in a country providing a level of adequate data or from a partner affiliated with both the EU-US program Privacy Shield and the Swiss-U.S program. Privacy Shield, programs ensuring an adequate level of data protection both under European law and Swiss law.

(5)Collection and use of data as part of the creation of a user profile

Our internet platform offers you the possibility to create a user profile. When creating such a profile, the data we ask you to provide us, and that we collect in this way, are the following: username, surname, first name, title, profession, date of birth, address e-mail, home address, phone number, profile picture (if you provide one), Facebook page (if you indicate it), personal or professional website (if you specify it) and status on the platform www.followo.com (individual or merchant). If your activities fall into the "merchant" category, we will ask you again to indicate the name of your company / company, the business area of it as well as the details of your credit card (card number, date expiration, holder, three-digit security number on the back of the card); please note that special rules apply to this category of users.

The data included in your user profile is retained as long as your user account is active. For legal reasons (obligation to keep the accounting documents) as well as our legitimate interest (defense of our rights in court), we can keep your data for a longer period, but not exceeding 10 years. In this case, your data is kept as an archive (processing limitation). You can delete your user account through the interface offered on www.followo.com, under the conditions described in the terms and conditions of use of the platform www.followo.com .

The data included in your user profile can be used to determine which advertising messages, among those of Followo's partner advertisers, are most likely to interest you and to allow us to post those messages on the pages you visit.

Please note that the following data from your user profile will be visible to any visitor to the www.followo.com platform: username, profile picture (if you provide one), status on the platform, number of followers , number of friends and friendships with other account holders.

Your user profile data is stored in Switzerland or in a member country of the European Union. Please note, however, that for technical reasons related to the structure and operation of the Internet, these may be transmitted to another country that does not provide an adequate level of protection.

(6)Collection and use of data in the context of the publication of curriculum vitae (CV)

Our Internet platform offers you the opportunity to submit your resume online, if you have a user account. The data you provide to us are: surname, first name, e-mail address, nationality, date of birth, gender, postal address, nationality, language (s) spoken, positions previously occupied and training followed. You can also download a document summarizing your life course.

Please note that, in this context, sensitive personal data, respectively profiles of personality within the meaning of Article 3 letter d of the Federal Data Protection Act, for example from the data you provide us, can be saved. By providing us with these data spontaneously, you consent to their treatment.

Please note that the information you post in this frame will be visible in their entirety by any visitor to the www.followo.com platform.

his data is related to your user profile. They are kept until you delete them or until the end of your user account. For reasons of a legal nature (obligation to keep the accounting documents) as well as in virtue of our legitimate interest (defence of our rights in court), we can keep these data for a longer period, but not exceeding 10 years. In this case, your data is kept as an archive (processing limitation).

(7)Collection and use of data as part of the insertion of an advertisement

Our Internet platform offers you the possibility to insert an ad, if you have a merchant account. When inserting an ad, we will ask you to provide us with all the data necessary to display your advertisement according to the category of products or services to which it belongs. This data is related to your user profile. They are kept for the duration of your ad. For reasons of a legal nature (obligation to keep the accounting documents) as well as in virtue of our legitimate interest (defence of our rights in court), we can keep these data for a longer period, but not exceeding 10 years. In this case, your data is kept as an archive (processing limitation).

Please note that the content of your ad will be published on the internet. In addition, the holders of a user account will be able to share those of your advertisements which they like.

The data is stored in Switzerland or in a member country of the European Union. Please note, however, that they may, for technical reasons, pass through another country that may not provide an adequate level of protection when you send them to us.

(8)Collection and use of data in connection with the conclusion of a subscription to the advertising services offered by Followo (electronic order of insertion of online advertising space)

Our Internet platform offers you the possibility to subscribe to our advertising services, services that allow you to increase the visibility of your ads, if you have a merchant account. When entering into such a subscription, we will ask you to provide us with all the data necessary to execute your order and to manage your subscription. This data is related to your user profile. They are kept for the duration of your subscription. For reasons of a legal nature (obligation to keep the accounting documents) as well as in virtue of our legitimate interest (defence of our rights in court), we can keep these data for a longer period, but not exceeding 10 years. In this case, your data is kept as an archive (processing limitation).

(9)Collection and use of data as part of the response to an advertisement (order of a product or service offered by a merchant account holder)

When responding to an ad on www.followo.com, please note that the data you provide, freely or at the request of the advertiser, will be transmitted to the advertiser. This data will then be processed exclusively by the advertiser, according to a confidentiality policy of its own, and will not be kept by Followo.

We invite you to inquire about the processing of your personal data with the advertiser.

Followo is only responsible for the transfer of any payments in connection with the order of a product or service offered by merchant account holder. In this context, we will collect and process your credit card details (cardholder name, card number, expiry date, three-digit code on the back of the card) as well as the data of the transaction in question. the purpose of ensuring the transfer of payments. These data may be kept for 10 years (obligation to keep the accounting documents and Followo's legitimate interest in defending its rights in court).

(10)Collection and use of data for the publication of images and videos

Our Internet platform gives you the opportunity to publish your images and videos. In this context, all data that you provide to us are likely to be published and, therefore, to be accessible to everyone.

We therefore invite you to pay close attention to the data you publish, as your photos and videos may contain sensitive data or simply data you do not want to be accessible to everyone.

(11)Collection and processing of data as part of news feed subscriptions ("Newsfeed")

You can subscribe to news feeds through our Internet platform. This will allow you to stay informed of the most attractive and up-to-date offers on the www.followo.com website.

This subscription is linked to your user account. Your different subscriptions to information feeds can be used to set your consumption preferences. This data is kept as long as your profile is active.

The collection of your personal data and the implementation of the treatments described above is based on your consent. You may at any time withdraw your consent and cancel your subscription to the various information flows from the interface of your user account.

§2 Transmission of your data to third parties

(1)The data intended to be published on www.followo.com according to the preceding provisions will be visible by any user visiting this platform.

(2)Other personal data is kept confidential. They are not communicated to third parties other than Followo's partners, according to the following categories:

Payment forwarding provider;
banking providers;
Merchant account holders (if you ordered a product or service from the merchant);
IT service providers (developer of software solutions, webmaster, web designer, data storage);
Social networks.

(3)It is also possible that your personal data must be communicated to third parties (public authorities) on the basis of a legal or contractual obligation incumbent on or incumbent upon our partners mentioned above, provided that the data communication considered necessary for the performance of that obligation.

(4)All our partners have their headquarters in Switzerland, the European Union or in a country providing an adequate level of data protection within the meaning of art. 45 RGPD. Where this is not the case, our partners participate in the Privacy Shield European Union Program - United States and Switzerland - United States, which is deemed to provide an adequate level of protection. Our partners are all subject to a confidentiality obligation regarding your data and are not authorized to use them for any purpose other than that contained in this document.

§3 Your rights

(1)You have the following rights regarding your personal data:

Right of access / right to information on data processing
Right to rectification or deletion of data
Right to limitation of data processing
Right to opposition against data processing
Right to data portability

(2)In addition, you have the right to complain about the processing of your personal data with a supervisory authority responsible for ensuring the protection of your data.

§4 Collection of personal data during the simple consultation of our Internet platform

(1)When only using the web page, that is to say when you do not send us any additional information, only the data that your browser sends to our server are collected. If you wish to consult our website, we will collect the following information which is technically required, so that the site is displayed and to guarantee a certain stability and security (the legal basis of the treatment is our legitimate interest in guaranteeing access to our internet platform and improve it):

IP address
Date and time of the request
Time zone difference with Greenwich Mean Time (GMT)
Query content (concrete page)
Access status / HTTP status code
Volume of data transmitted
Internet platform from which the demand comes
Navigator
Operating system and its interface
Language and browser version

(2)In addition, when using our website, cookies are stored on your computer. These are small text files, which are stored on your hard drive and deliver information determined by the function we give them. Cookies can not run programs or transmit viruses. They serve to make the Internet offer more effective and more user-friendly.

(3)Use of cookies

a) Our internet platform uses different types of cookies, the scope and functionality of which are explained below:
- Transient cookies (see letter b below)
- Persistent cookies (see letter c below).

b) Transient cookies are automatically deleted when you exit the browser. This includes in particular so-called "session cookies". These store a session ID, with which different requests from your browser can be assigned. This allows your computer to be recognized on your next visit to our website. Session cookies are deleted when you log out or when you close your browser.

c) Persistent cookies are automatically deleted after a specified period, which may vary depending on the different cookies. You can delete cookies at any time in the security settings of your browser.

d) You can configure the settings of your browser according to your wishes and refuse cookies from third parties or all cookies, for example. Please note that you may not be able to use all the features of our internet platform if you refuse cookies.

e) Our site uses the following cookies:

Exploiter	Technical Name	Aim	Period of validity
Google Analytics/ Followo	_ga	Statistics ; assigns a unique identifier to determine if you have visited our site	2 years
Google Analytics/ Followo	_gat	Statistics ; improves the speed of requests to the server	1 minute
Google Analytics/ Followo	_gid	Statistics ; allows you to individualize users according to certain advertising campaigns and determine with which search engine you have accessed our website	24 hours
Followo	cookie consent	Necessary ; keep in mind your agreement to the use of cookies	1 an
Followo	SESSID	Necessary ; keep you connected to your account	Deleted when you exit your browser

f) Google Analytics and Google Tag Manager

Our platform may use Google Analytics, a web analytics service of Google Inc. (hereinafter referred to as "Google") that assumes the storage of cookies by the user. These Cookies are intended to allow an analysis of the way you use our Internet portal. The information obtained through Cookies about your use of this Internet platform is transmitted to a server located in the United States of America and stored there. Your IP address will be contracted (anonymised) in the European Union or in Switzerland prior to its transmission to the United States of America, by the function "anonymize_ip". This function removes any reference to people in the collected IP addresses. It can be said that exceptionally happen that your IP address is contracted in the United States, after being transferred to one of Google's servers. This company participates in the Privacy Shield European Union - United States and Switzerland - United States program for all types of personal data. Companies participating in this program are deemed to provide an adequate level of protection within the meaning of art. 45 RGPD.

Google will use the information provided by Followo to evaluate the use you make of it, to report on users' activities and to provide other services related to the use of this Internet platform by using it.

The implementation of the processing of personal data described above is based on our legitimate interest within the meaning of art. 6, paragraph 1, letter f, RGPD, to compile statistics regarding the consultation and use of our website and to adapt it to the request.

You can oppose the collection of your IP address and prevent the use of information collected by Google by downloading and installing the following plug-in for your browser: http://tools.google.com/dlpage/gaoptout?hl=en .

You can also deactivate the relevant cookies in the appropriate menu of your Internet browser.

We can also use Google Tag Manager to manage the services associated with setting up ads based on user behavior. The Tag Manager tool itself is a domain free of cookies and does not collect any personal data. The tool activates other tags related to the Google services described above and below. When you have disabled cookies or installed the plug-in mentioned above, this deactivation is valid for all traceability markers implemented with Google Tag Manager and Google Analytics.

h) Remarketing

Our website may also use a remarketing application. This application allows you to view our advertisements after your visit when you visit other websites. For this purpose, cookies are stored on your device, whereby your online behavior on multiple websites is recorded and evaluated. Your visit to our Internet platform is saved. These data are collected in a pseudonymized manner.

The creation of user profiles and the implementation of the processing of personal data described above is based on our legitimate interest within the meaning of art. 6, paragraph 1, letter f, RGPD, to carry out direct marketing operations and to adapt the content of our Internet platform to demand.

i) Facebook connect Plug-ins social networks

Our Internet platform supports plug-ins to facilitate connection to different social networks. You are free to use this feature or not. If you are registered on one of the supported social networks, you can use the easy login feature on our internet platform to connect to the social network. To enable this feature, your device saves your login information to the relevant social network.

If you use this feature on our website, the social network will provide us with information about you. This provision of information is initiated by the fact that you are redirected (e) on the page of the social network after pressing the connection function and that it is requested by Facebook authorization to give access to your information your name, your profile picture, your gender, your network, your username, your friends list, your date of birth and other information you share with your friends). If you give permission, the social network will provide us with this information. A comparison of data is then made, in which we store only the data that we would normally have collected when registering on our site in order to provide our telemedia service (last name, first name, date of birth, country, place residence, e-mail address). In addition, certain statuses (such as "Like") and your username (username on the social network) are saved. For more information, we recommend that you refer to the privacy statement published by the social networks of which you are a member.

The data processing described above takes place on the basis of your consent. You can remove it at any time by removing the cookies attached to the domains of the social network concerned in the security settings of your browser.

j) DoubleClick by Google

Our website may also use the DoubleClick by Google online marketing tool. DoubleClick places cookies in order to provide you with relevant advertising, to improve campaign reporting, or to prevent the same ad from showing you repeatedly. Google collects, by means of a cookie-ID, which ads have been activated in which browser and can thus avoid the repeated display of the same advertisement. Using this cookie-ID, DoubleClick is also able to generate conversions, which relate to ad requests. This is the case, for example, when after seeing a DoubleClick ad, you view the advertiser's site with the same browser and buy something from it. According to Google, DoubleClick cookies do not contain personal data.

Your browser establishes a direct connection with the Google server. We have no influence on the extent and use of the data collected by Google. By using GoogleClick, Google obtains the information that you viewed a page on our website or clicked on one of our ads. If you're registered on a Google service, Google may link your visit to your account. Even when you are not registered to Facebook, or not logged in to your account, the advertiser may collect and save your IP address and other data about your connection (for example, date and time).

You can indicate your opposition to these profiling activities in several ways:

by properly configuring the settings of your Internet browser, in particular, by disabling cookies-third, which avoids the display of advertisements from thirdparty sites;
configuring your browser in such a way that cookies from the www.googleadservices.com domain are blocked
if you have an account with Google, setting it up appropriately using the following link: https://adssettings.google.com/ ;
Disabling targeted ads from different advertisers participating in the About Ads self-regulatory program www.aboutads.info/choices ;
by permanently disabling Google's targeted advertising in your Chrome, Firefox or Internet Explorer browser by installing the pug-in which you can download by clicking on the following link: https://support.google.com/ads/answer/7395996 .

Google processes your personal data also in the United States of America and participates in the Privacy Shield European Union - United States and Switzerland - United States program for all types of data.

(4)Integration of YouTube videos

a) We have included YouTube videos in freely accessible content, videos that are hosted on the Internet portal http://www.youtube.com and that you can read directly from our website.

b) When you visit our website, YouTube obtains the information that you have viewed the page of our corresponding site. In addition, the data cited above in § 4 (1) is communicated to YouTube. This data collection occurs regardless of whether you have an account with YouTube or are connected to YouTube. When you sign in to your Google Account (YouTube is owned by Google), your personal data is strictly associated with your account. If you wish to avoid such an association, it is necessary to disconnect before activating the play button of the video. YouTube stores your data in a user profile used for advertising purposes, market research and improving the offer offered through its Internet portal. Such use may include (even for nonconnected users) the purpose of displaying targeted advertising and informing other users of the YouTube network of your activities on our website. To exercise your right to object to the creation of a user profile, we invite you to contact YouTube.

c) You will find further information about the purpose and extent of YouTube collection of your personal data and the use of it in the Google Privacy Statement. You'll also get information about exercising your rights and protecting your privacy: https://policies.google.com/privacy?hl=en&gl=en Google processes your personal data also in the United States of America and participates in the Privacy Shield European Union - United States and Switzerland - United States program for all types of data.

d) The creation of user profiles and the implementation of the processing of personal data described above is based on our legitimate interest within the meaning of art. 6, paragraph 1, letter f, RGPD, to carry out direct marketing and to adapt our website to the request.

(5)External geolocation function

a) This platform uses the Google Maps offer. This allows us to offer you an interactive map directly on our Internet platform.

b) By visiting the page with this feature, Google obtains the information that you viewed the page. In addition, the information mentioned above under § 4 (1) is also transmitted, as well as your geographical location, if you allow Google to access this data. Such transmission of information occurs regardless of whether you have an account with Google or are connected to it. If you are logged in, the above-mentioned personal data may be associated with your Google Account.

c) Google organizes the collected data about you as a user profile and uses this data for the purposes of commercial advertising, market research and improvement of its own services. Such data exploitation takes place (also for non-registered users) in order to offer targeted advertising to social network users and to inform them of your activities on our Internet platform. To oppose the processing of your personal data as described above, you should contact the social network in question.

d) You can get more information about data collected and processed directly from Google using the following links:

Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA; https://policies.google.com/privacy?hl=en . Google participates in the Privacy Shield European Union - United States and Switzerland - United States program for all types of personal data

e) The implementation of the processing of personal data described above is based on our legitimate interest within the meaning of art. 6, paragraph 1, letter f, RGPD, to provide relevant and interactive content on our Internet platform.

§5 Objection or revocation against the processing of your data

(1)If you have given your consent to the processing of your personal data, you may revoke it at any time. This is the case, for example, if you have subscribed to our newsletter. Such revocation only has an influence on the processing of data subsequent to its notification. Therefore, withdrawal of your consent does not compromise the lawfulness of the treatment based on that consent prior to withdrawal.

(2)If we base the processing of your personal data on the basis of our overriding interest, you may object to the processing. This is for example the case if the processing is not necessary for the execution of a contract concluded with you. When exercising this opposition, we ask you to explain the reasons why we should not treat your personal data as we have done so far. In the event of a justified objection from you, we will examine the situation and we will stop or limit the processing of the data or we will indicate to you the overriding interests on which we will base ourselves to continue the processing of your personal data.

(3)Of course, you may object at any time to the processing of your personal data for advertising and data analysis purposes. You can inform us of your objection by sending a simple e-mail to the following address: info@followo.com.

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