PRIVACY POLICY

	The purpose of this Privacy Policy is to detail the conditions under which Troov SAS collects, exploits, retains and protects personal data relating to users of the website www.Troov.com (the "Site"), and more generally services operated by Troov and to detail the contractual relationship between Troov and any user of the Site regarding his personal data (the "User").
	The website www.Troov.com is operated by Troov SAS, a French company registered at the commercial court of Nanterre under number 834 337 370, and whose head office is located at 110 bd Bineau, 92200 Neuilly-Sur-Seine (hereafter "Troov" or "us"). The data controller in the sense of the European General Regulation on Data Protection number 2016/679 of 27 April 2016 (the "RGPD") is Troov.
	We thank you for reading this Privacy Policy carefully to understand how your personal data will be used when you use the Site.

	In this Privacy Policy, the term "personal data", has the meaning set forth in section 4 of the GDPR.
	By your use of the Site, you agree to the collection and use of your personal data in accordance with this Privacy Policy.
	You are never obliged to share your personal data, but if you choose not to do so, we may not be able to provide you with certain services.
	We reserve the right to change this Privacy Policy from time to time, in which case a modified version of the Privacy Policy will be posted on the Site.
	This Privacy Policy was last updated on 18/10/2018.
	1. Nature and use of collected data

	1.1 Nature
	In connection with the use of the Site, Troov may collect the following categories of personal data relating to the Users:
	- Name
	- First name
	- Birth date
	- Profile picture
	- Email or postal address, telephone or any other indication allowing interpersonal communication with Users
	- Bank details (RIB, IBAN or bank card numbers)
	- Connection data (IP addresses, event logs ...)
	- Any identifying element associated with a lost or found object that is likely to allow finding and authenticating the owner of a lost object
     
	We may also collect personal data about you even if you have not made yourself a declaration of loss of your property in the case of a declaration of an object found either on our Site or on the database of a public or private property management service for the purpose of returning to you the property you have lost. If you intend to oppose such processing of your personal data, you may of course exercise this right at any time in the manner indicated in paragraph 5 below.
	Users may deactivate their personal account on the Site at any time, but Troov may then retain the information necessary to enforce its contractual rights or obligations, comply with its legal or regulatory obligations and / or resolve a dispute.
	Finally, we will be able to monitor and / or record our communications with you, on any channel, for quality, training, fraud detection or compliance purposes.

	1.2 Use
	Personal data provided by Users is intended to connect those who lose and those who find objects or public or private services in charge of the management of found objects. Personal data may also be used for the purposes following:

	● Authentication and administration of your account;
	● Reset your password;
	● Execution of payments;
	● Communications related to your use of the Site (feedbacks, abnormal use, fraud ...);
	● Communications related to services provided by Troov or potential new services;
	● Information about changes to our services;
	● Sending marketing communications;
	● Reply to a request made by email;
	● Problem solving on the Site;
	● Archives, research and statistics
	● Administrative needs;
	● Prevention and detection of fraud;
	● Security; and
	● Optimization of the presentation of the Site on your equipment.

	If necessary, we can contact you by e-mail, via social networks, phone, chat, SMS or mail.

	1.3 Duration of conservation

	We will be able to keep your personal data for the duration necessary to achieve the purpose for which it was collected and to comply with our legal and regulatory obligations. Thus this period will be in principle one year for the declarations of loss of object and for the declarations of objects found may be 3 years in order to comply with Article 2276 of the Civil Code which allows those who have lost an object to claim it for 3 years from the day of the loss, against the one in whose hands the object is.

	2. Security of your personal data
	At Troov, we know that your personal data is valuable, and we make every effort to ensure their safety, including the following precautions:

	● Presence of confidentiality clauses in all our service contracts with natural or legal persons having access to your personal data;
	● Access to your profile protected by an identifier and a password;
	● Personal data stored on secure servers; and
	● Encryption of your personal data during their transmission via the https protocol.

	Despite our efforts, the transmission of information on the Internet is never completely secure, so we cannot guarantee the security of your personal data that are transmitted at your own risk.
	By sending us your personal data, you agree to this transfer, processing and backup. We will take all reasonable precautions to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

	3. Communication of your personal data to third parties
	Troov may be required to disclose your personal data in accordance with any law, regulation or decision of a competent regulatory or judicial authority. In general, we undertake to comply with all the legal rules that could prevent, limit or regulate the dissemination of information or data and in particular to comply with Law No. 78-17 of 6 January 1978 on the computing, files and freedoms and with the RGPD.

	As part of the service provided, we may also be required to communicate your personal data to:
	- Any company of our group, a company of our group being defined as a company controlling Troov, controlled by Troov or under the same control as Troov within the meaning of Article L.233-3 of the Commercial Code;
	- Any other service managing objects lost or found in order to increase the chances of returning lost objects to those who lost them;
	- Our employees, agents and service providers; and
	- Our business partners if you have agreed to be contacted by them for commercial purposes.
    
	Finally, in the event that we take part in a merger, acquisition or any other form of asset transfer, we undertake to guarantee the confidentiality of your personal data and to inform you before the any personal data is transferred or subject to new rules of confidentiality.

	4. Links to third party sites
	In the event that the Site contains links to third party sites, they are provided for informational purposes only, without Troov guaranteeing their content or availability. Moreover, browsing these third-party sites would be subject to the terms of use and privacy policy of said third party sites, and Troov cannot be held responsible for the fate of personal data the Internet User would be required to communicate to third party sites.

	5. Your rights
	Under the GDPR, you have a number of rights in connection with the collection and processing of your personal data.

	5.1 Right to information
	You have the right to be informed about the collection and use of your personal data, which is the purpose of this Privacy Policy.

	5.2 Access rights
	You have the right to access personal data that we may hold about you. In order to exercise this right when you log into your account on the Site, you shall:

	- Formulate this request in writing or by sending us an email to [email protected];
	- attach proof of identity and address; and
	- Specify the personal data you want to access.

	5.3 Right of rectification
	You have the right to rectify the personal data that we hold about you if they are inaccurate or incomplete. In order to exercise this right for personal data non-modifiable directly when you log in to your account on the Site, you shall:

	- Formulate this request in writing or by sending us an email to [email protected];
	- attach proof of identity and address; and
	- Specify the personal data that you want to rectify.

	5.4 Right to erasure or right to be forgotten
	You have the right to request the erasure of your personal data when there are no compelling reasons to continue processing.
	This right is not absolute, however, and applies only in the following situations:

	- When personal data are no longer necessary for the pursuit of the purposes for which they were originally collected or processed;
	- When the personal data has been collected and processed on the basis of your consent and you decide to withdraw that consent;
	- Where the treatment is based on legitimate interests and there is no longer any legitimate interest justifying further processing;
	- When the personal data are processed for direct marketing purposes and you oppose this treatment;
	- When the personal data are processed illegally;
	- When we must proceed to such an erasure in order to respect a legal obligation; or
	- When personal data has been processed to provide information society services to a child.

	In the event this right to cancellation applies, you must do the following to exercise it:

	- Formulate this request in writing or by sending us an email to [email protected];
	- attach proof of identity and address; and
	- Specify the personal data that you want us to erase.

	5.5 Right to withdraw or restrict consent to treatment

	When you consent to the processing of your personal data you have the right to withdraw, block or delete all or part of the processing of your personal data for the future, including under the conditions described in Article 18 of the RGPD.
	To exercise this right, you shall:

	- Formulate this request in writing or by sending us an email to [email protected];
	- attach proof of identity and address; and
	- Specify the personal data or the treatment you want to restrict.

	5.6 Portability right of your personal data
	You have the right to obtain and reuse the personal data that we hold about you for personal purposes for different services.

	To exercise this right, you shall:

	- Formulate this request in writing or by sending us an email to [email protected];
	- attach proof of identity and address; and
	- Specify the personal data you want to port.

	5.7 Right to object

	You have the right to object to:

	- Treatment based on legitimate interests or the performance of a public interest task / the exercise of public authority (including profiling);
	- Direct marketing (including for profiling); or
	- Treatment for scientific, historical or statistical research purposes.

	To exercise this right, you shall:

	- Formulate this request in writing or by sending us an email to [email protected];
	- attach proof of identity and address; and
	- Specify the treatment you want to oppose.

	5.8 Complaint
	In the event that we are unable to respond satisfactorily to your requests, you may file a complaint with a supervisory authority. In France it is the CNIL, 3 place Fontenoy -TSA 80715- 75 334 Paris cedex 07 (tel: +33 1 53 73 22 22)

	6. Modification of this Privacy Policy
	Any change we may make to our Privacy Policy will be posted on this page and, if applicable, will be notified to you by email, phone, SMS or mail.
	It is your responsibility to review our Privacy Policy on a regular basis to ensure that you are aware of its latest version, as this is the last available version of this Privacy Policy that applies each time you access the Site.

	7. Contact
	If you have any questions about this Privacy Policy or to exercise any of your rights described in section 5 above, please contact us by email at [email protected]

	8. Cookies
	When you interact with the Site, we make every effort to make this experience easy and enjoyable. For this purpose, when you browse the Site, a web server sends a cookie or other similar tool on your computer equipment. We may thus by means of cookies and / or other similar technologies, keep the following information: data relating to your visits to the Site, including the type and version of the internet browser that you use; the type, manufacturer and model of the computer equipment you use; any website from which you have arrived on the Site; your IP address the operating system of your computer equipment; traffic data; location data; weblogs and other communication data, whether for our own billing purposes or otherwise; and the resources you access.
	A number of the cookies we use only last for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and last longer.

	However, and in accordance with the recommendations of the CNIL, the maximum duration of storage of cookies is 13 months maximum after their first deposit in the Internet user's terminal, just like the duration of the validity of the consent of the Internet user to the use of these cookies. The lifetime of cookies is not extended at each visit. The consent of the Internet user must therefore be renewed at the end of this period.
	We use cookies and / or other similar tools (such as pixel codes or in-app IDs) for the following purposes:

	8.1 Cookies strictly necessary

	- Allow you to browse the Site;
	- Manage your login session so that you can easily switch from one page to another on the Site and that your requests for pages are loaded smoothly and securely.

	8.2 Quality

	- Collect anonymous statistical information about the use of the Site (including the time spent on the Site) and from where you arrive on the Site, in order to improve the Site and to learn which parts and which functions of the Site are the most popular with Internet users;
	- Remember that you have already come to the Site. This allows us both to identify the number of unique visitors we receive and to ensure that we have enough capacity for the number of Internet users we receive.

	8.3 Features

	- Know if you have already come to the Site;
	- Automatically login to your account on the Site when you have already logged in before;
	- Prevent and detect possible frauds;
	- Customize elements of the layout and / or content on the Site to enhance your experience.

	8.4 Other

	- Conduct research and statistical analysis related to your navigation on the Site.

	We may store information about you using cookies that we may access when you return to the Site.
	Cookies do not usually contain personal data but may include the type and version of the Internet browser you are using, the type, manufacturer and model of the computer equipment you use, the website from which you are arrived on the Site, your IP address, the operating system of your computer equipment and information about your Internet connection.
	If you want to delete cookies that are already on your device, please refer to the instructions in your file management software to locate the file or directory that stores the cookies.
	Further information on the deletion or control of cookies is available on www.cnil.fr/en/cookies-tools-to-control them. Please note that by deleting our cookies or disabling them for the future, you risk not being able to access certain areas or features of the Site.
	We work with a number of external providers who may also post cookies on the Site, such as:

	- Google Analytics;
	- Google AdWords; and
	- Google Maps

	This list may change in the future, in which case this Privacy Policy will be updated accordingly.
	These external providers are responsible for the cookies they post on the Site and, for more information about these cookies, you must refer to their specific privacy policies.