Privacy Policy
Date last updated: October 2022.
The purpose of this privacy policy (the "Policy") is to formalize our commitment to the privacy of users of Roger.ai (the "Site") operated by Kaskal (individual business of Jean-Charles Touzalin).
The Privacy Policy and the Terms & Conditions of the Site form a contractual set. All capitalized terms not defined in the present Policy are defined in the Terms & Conditions which can be consulted here.
In the course of providing our Site, we process your personal data in accordance with the General Data Protection Regulation 2016/679 of 27 April 2016 ("GDPR") and under the conditions set out below.
Personal data means any information relating to an identified or identifiable natural person. We collect and process personal data for the purpose of providing our Services or communicating with you about those Services only, in strict compliance with the GDPR.
We only collect personal data that is adequate, relevant and limited to what is necessary for the purposes for which it is processed. Thus, you will never be asked to provide personal data considered as "sensitive", such as your racial or ethnic origins, your political, philosophical or religious opinions.
By registering on the Site, you authorize us to process your personal data in accordance with this Policy. If you do not agree to the terms of this Policy, please refrain from using the Site and the Services.
1. When do we collect your personal data and what data is collected?
We may collect and store your personal data, including when you:
We use your personal data to enable the provision and management of the Site Services and to respond to your specific requests. We also use your personal information to operate and improve our Services, our Site and our approach. This information is used solely by us and allows us to better tailor our Services to your needs.
If you have opted-in to receive emails and messages from us when you create your Account, then you will receive email and messages about our products and promotions. We will then use the personal data you provided when you registered. You can unsubscribe from these mailings at any time.
1.1 Browsing the Site
Connection Data. Each time you connect to our Site, we collect personal data such as, but not limited to, your IP address and the MAC address of your computer, the date and time of connection, and information about the browser you are using.
Navigational data. We also collect information that identifies how you access the Site, which pages you visit and for how long. In doing so, we may use Cookies as described in paragraph 6 below.
1.2 Creating an Account
Access to our Services requires the creation of an Account. In accordance with the General Terms and Conditions, when starting a conversation with our chatbot, an Account will be automatically created with your first and last names, and your Facebook ID.
1.3 Payment
Some of the available Services are subject to a fee. To this end, you agree that we may use external service providers who may collect personal data for the purpose of enabling the proper functioning of the services for processing payments by credit card or any other means of payment and, where applicable, for the delivery of products or services.
To pay for your purchase, you must provide your billing information as well as your payment information, including your credit card number, the validity date, the security code and the name of the cardholder in case of payment by credit card
We keep details of your payments, as well as details of the purchases you make. Transaction details are held by the external provider. This retention is for internal purposes, including accounting, compliance and legal purposes, in accordance with paragraph 5 of this Policy.
1.4 Joining our Newsletter
When creating your Account, you may give your prior consent to receive newsletters from us regarding news, new products, services and promotions as part of the Services.
You may also consent to receive our newsletters directly by entering your email address in the appropriate spaces on the Site.
In any case, you have the right to withdraw your consent to receive such newsletters at any time and without charge under the conditions provided in paragraph 6 of the Charter.
1.5 Contacts
In order to follow up on requests you may make to our Customer Service Department and to confirm your information, we may use your first and last name, e-mail address and telephone number.
2. How do we protect your personal data?
We have put in place technical and organisational security measures to ensure the security, integrity and confidentiality of all your personal data, in order to prevent it from being distorted, damaged or accessed by unauthorised third parties. We ensure an appropriate level of security, 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 and likelihood thereof.
However, it is specified that no security measure is infallible and that we are not able to guarantee absolute security for your personal data.
3. When do we share your personal data?
3.1 Sharing your personal data with third parties
When you browse the Site, your personal data may be passed on to external service providers. These third parties provide a service on our behalf to enable the smooth operation of credit card payments and other Services.
Personal data may be transferred to countries outside the European Union (such as in Ireland and in the US) for the purpose of providing our Service.
In accordance with the GDPR, all transfers of personal data to a country outside the European Union and/or which do not offer a level of protection considered sufficient by the European Commission have been subject to cross-border flow agreements that comply with the standard contractual clauses issued by the European Commission.
Other transfers of personal data to the United States are governed by the E.U. - U.S. PRIVACY SHIELD: click here for more information.
Except where a third party asks you to accept a privacy policy and terms of use specific to that third party, third party companies that have been provided with your personal data have agreed to process your personal data only for the purpose of providing our Services.
We will never, without your prior consent, share your personal data with third party companies for marketing and/or commercial purposes.
3.2 Sharing with authorities
We may disclose your personal data to administrative or judicial authorities where disclosure is necessary for the identification, arrest or prosecution of any individual who may be infringing our rights, or of any other user or third party. Finally, we may be legally required to disclose your personal data and cannot object to such disclosure.
4. How long do we keep your personal data?
We will only keep your personal data for as long as you register on the Site in order to ensure your identification when you log in to your Account and to enable the provision of the Services.
Thus, if you unsubscribe from the Site, your personal data will be deleted and only kept in archive form for the purpose of establishing proof of a right or contract.
In any case, we will keep your personal data for no longer than is necessary for the purposes for which they are processed in accordance with the uses set out in this Charter and in compliance with laws and regulations.
5. Cookies: how do we use them?
5.1 What is a cookie?
A cookie is a text file that may be deposited on a terminal when an online service is consulted with a browser. A cookie file allows its issuer, during its period of validity, to recognize the terminal concerned each time this terminal accesses digital content containing cookies from the same issuer.
In any case, the cookies deposited on your navigation terminal with your agreement are destroyed 13 months after their deposit on your terminal.
5.2 What is the purpose of the cookies issued on our Site?
The cookies we issue allow us to:
During your navigation on the Site, cookies from social networks may be generated, in particular via the sharing buttons which collect personal data.
When you first visit the Site, a cookies banner will appear on the home page. A clickable link allows you to learn more about the purpose and operation of cookies and refers you to this Charter. Continuing to browse on another page of the site or selecting an element of the Site (in particular: image, text, link, etc.) signifies your acceptance of the deposit of the cookies concerned on your computer.
5.3 How can you control the cookies used?
You can configure your browser software at any time so that cookies are recorded in your terminal or, on the contrary, that they are rejected (either systematically or according to their sender). You can also configure your browser software so that you are offered the option of accepting or rejecting cookies from time to time, before a cookie is stored in your terminal.
Caution: any parameter setting is likely to modify your navigation on Internet and your conditions of access to certain services requiring the use of cookies. We decline all responsibility for the consequences linked to the degraded functioning of our services resulting from the impossibility of recording or consulting the cookies necessary for their functioning and which you would have refused or deleted. This would be the case if you tried to access our content or services that require you to be identified. This would also be the case if we (or our service providers) were unable to recognise, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings or the country from which your terminal appears to be connected to the Internet.
5.4 How do I configure my browser?
Each browser has a different configuration for managing cookies and your choices. It is described in the help menu of your browser, which will allow you to know how to modify your wishes regarding cookies. Below you will find information about the main browsers.
Internet Explorer / Edge
In Internet Explorer, click the Tools button, then click Internet Options.
On the General tab, under Browsing History, click Settings.
Click the Show Files button.
Firefox
Safari
Google Chrome
For more information on cookies, you can consult the CNIL website.
6. What are your rights?
You are the only one who has communicated the data in our possession, through the Site. You have rights to your personal data. In accordance with the regulations on the protection of personal data, in particular articles 15 to 22 of the RGPD, and after having proved your identity, you have the right to ask us for access to personal data concerning you, to correct or delete them.
In addition, within the limits of the law, you also have the right to object to the processing, to limit it, to decide on the post-mortem fate of your data, to withdraw your consent at any time and the right to portability of the personal data provided.
You can contact our Services to exercise your rights directly through our Facebook Messenger page.
Furthermore, you can unsubscribe from our newsletter at any time by clicking on the unsubscribe link at the bottom of each email.
7. Can we change the Privacy Policy?
We reserve the right to modify the Policy at any time. It is thus recommended to you to consult it regularly. If we make any changes, we will post those changes on this page and in such other places as we deem appropriate, depending on the purpose and extent of the changes.
Your use of the Site after any modification means that you accept these modifications. If you do not agree with any material changes to this Policy, you should discontinue use of the Site.
8. Data Protection Officer and contact
We have appointed a Data Protection Officer (DPO), Jean-Charles Touzalin, that can be contacted directly through our Facebook Messenger page.
If you have any questions about your personal data or if you wish to delete your Account, please contact us through our Facebook Messenger page.
9. The National Commission for Information Technology and Civil Liberties ("CNIL")
We remind you that you can contact the CNIL directly on the CNIL website or by mail at the following address Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy - TSA 80715, 75334 PARIS CEDEX 07.
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