Last modified: 11/15/2020
The site https://www.troov.com is operated by Troov SAS, a company incorporated under French law registered in Neuilly-Sur-Seine under number 834 337 370, and whose head office is located at 110 bd Bineau, 92200 Neuilly-Sur-Seine (ci -after “Troov” or “us”).
The data controller within the meaning of the European General Data Protection Regulation number 2016/679 of April 27, 2016 (the “GDPR”) is Troov However in certain cases Troov may be the subcontractor of a data controller, this the latter being a professional client of Troov and the contract between the parties having expressly indicated that this client is responsible for processing the data collected by its employees, Troov then being its subcontractor.
You are never required to share your personal data, but if you choose not to do so, we may not be able to provide you with certain services.
- Nature and use of the data collected
1.1 Nature In the context of the use of the Site, Troov may collect the following categories of personal data concerning Internet users:
● Last name
● First name
● Email address
● Phone number
● User profile picture
● Bank details
● Connection data (IP addresses, event logs, etc.)
● Shopping centers and / or stores and / or places visited as well as the date and time of the visit and the fields that have been added (ex: number order)
● List of lost and / or found objects
● Description of lost and / or found objects (including photos)
● Lost / found locations Internet users can deactivate their personal account on the Site at any time, but Troov can then keep the information necessary to implement its contractual rights or obligations, comply with its legal or regulatory obligations and / or resolve a dispute. Where applicable, we may also collect the following personal data:
● Your last name, first name and email address, as well as any other personal information that you decide to provide, if you contact us by email at the address provided below ; and ● Your last name, first name and email address if you subscribe to our newsletter. If you contact us, we may keep a record of this exchange, your first and last name, and your email address. We may, through cookies (see below) 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 you are using ; the type, manufacturer and model of IT equipment you are using; any website from which you came to the Site; your IP address; the operating system of your IT equipment; traffic data; location data; weblogs and other data from communication, whether for our own billing needs or otherwise; and the resources you access. We may also track your use of the Site by means of cookies and / or similar tracking devices. Finally, we may monitor and / or record our communications with you, on any channel, for quality, training, fraud detection or compliance purposes.
The personal data provided by Internet users may be used for any purpose for which you have expressly opted for as well as for the following purposes:
● Authentication and administration of your account;
● Resetting your password;
● Execution of payments;
● Communications related to your use of the Site (feedback, abnormal use, fraud, etc.);
● Communications related to services provided by Troov or potential new services;
● Information on changes to our services;
● Sending of marketing communications and satisfaction survey questionnaires;
● Response to a request formulated by email;
● Problem solving on the site;
● Archives, research and statistics;
● Administrative needs;
● Prevention and detection of fraud;
● Optimization of the presentation of the Site on your equipment.
If necessary, we can contact you by e-mail, phone, chat, SMS or post.
In addition, we reserve the right to use your data once anonymized, for example to compile statistics or reports on the use of our services.
1.3 Retention period
We may keep your personal data for the time necessary to achieve the purpose for which they were collected and to comply with our legal and regulatory obligations. This period is a minimum of one year and can be up to three years for the Lost and Found Management Service
2.Security of your personal data
At Troov, we know that your personal data is valuable and we do our best to ensure their security, including through 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 a username and password;
● Personal data stored on secure servers;
● Encryption of your personal data during their transport via the https protocol.
Despite our efforts, the transmission of information over the Internet is never completely secure, so we cannot guarantee the security of your personal data which is transmitted at your own risk.
Please note that your personal data may be transferred, processed or saved outside the European Union in compliance with the GDPR.
3.Communication of your personal data to third parties
Troov may be required to disclose your personal data in application of a law, regulation or by decision of a competent regulatory or judicial authority. In general, we undertake to comply with all 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 relating to the IT, files and freedoms and the GDPR.
As part of the service provided, we may also be required to communicate your personal data to:
- Any company in our group, a company in 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;
- Our employees, agents, partners and service providers such as our hosts as part of the provision of the service
- Our business partners if you have consented to be contacted by them for business purposes, these partners may be Troov’s customers such as those with whom you have yourself been in contact (for example stores visited by you which you have led to use our Services) or other professionals who could offer you goods or services.
Finally, in the event that we take part in a merger, acquisition or any other form of asset transfer, we are committed to ensuring the confidentiality of your personal data and to informing you before they are are transferred or subject to new confidentiality rules.
4.Links to third party sites
In the event that the Site contains links to third party sites, these will be provided for informational purposes only, without Troov guaranteeing either their content or their availability. In addition, browsing on these third-party sites would be subject to the conditions of use and the confidentiality policy of said third-party sites, and Troov cannot be considered responsible for the fate of personal data that the Internet user may be required to communicate to said third-party sites.
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
5.2 Access rights
You have the right to access the personal data that we may hold about you. In order to exercise this right for personal data not directly available when you log into your account on the Site, you must: - Make this request in writing; - Attach proof of identity and address; and - Specify the personal data to which you wish to have access.
5.3 Right to rectification
You have the right to have the personal data we hold about you rectified if it is inaccurate or incomplete. In order to exercise this right for non-modifiable personal data directly when you log into your account on the Site, you must: - Make this request in writing; - Attach proof of identity and address; and - Specify the personal data you wish to rectify.
5.4 Right to erasure or right to be forgotten
In some cases, you have the right to request the erasure of your personal data where there is no compelling reason to continue processing it.
This right is not absolute, however, and only applies in the following situations: - When the personal data are no longer necessary for the pursuit of the purposes for which they were initially collected or processed; - When the personal data has been collected and processed on the basis of your consent and you decide to withdraw this consent; - When the processing is based on legitimate interests and there is no longer a legitimate interest justifying the continuation of the processing; - When personal data is processed for direct marketing purposes and you object to this processing; - When personal data is processed illegally; - When we have to carry out such erasure in order to comply with a legal obligation; or - When the personal data has been processed to provide information society services to a child.
In the event that this right to erasure applies, you must do the following to exercise this right: - Make this request in writing; - Attach proof of identity and address; and - Specify the personal data that you want us to erase.
5.5 Right to restrict processing
You have the right to block or delete the processing of your personal data for the future, under certain conditions described in Article 18 of the GDPR.
To exercise this right, you must: - Make this request in writing; - Attach proof of identity and address; and - Specify the personal data or the processing you want to restrict.
5.6 Right to portability of your personal data
You have the right to obtain and reuse the personal data we hold about you, for personal purposes for various services.
To exercise this right, you must: - Make this request in writing; - Attach proof of identity and address; and - Specify the personal data you wish to obtain porting.
5.7 Right of objection
You have the right to object to: - Processing based on legitimate interests or the performance of a task in the public interest / the exercise of public authority (including for profiling); - Direct marketing (including for profiling); or - Processing for scientific, historical or statistical research purposes.
To exercise this right, you must: - Make this request in writing; - Attach proof of identity and address; and - Specify the treatment you want to oppose.
When you interact with the Site, we do everything possible to make the experience easy and enjoyable. To this end, when you browse the Site, a web server sends a cookie or other similar tool to your computer equipment.
Cookies are small pieces of information that are sent to your computer equipment when you browse a website and store on that equipment. 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 retention period for cookies is a maximum of 13 months after their first deposit in the Internet user’s terminal, as is the period of validity of the Internet user’s consent to the use of these cookies. The lifespan of cookies is not extended on each visit. The consent of the Internet user must therefore be renewed at the end of this period.
8.1 Strictly necessary cookies - Allow you to browse the Site; - Manage your login session so that you can easily move from one page to another on the Site and that your page requests are loaded smoothly and securely.
8.2 Quality - Collect anonymous statistical information on the use of the Site (including the time spent on the Site) and where you arrive on the Site, in order to improve the Site and to learn which parts and which functions of the Site are more popular with Internet users; - Remember that you have already visited 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 - Find out if you have already visited the Site; - Automatically log into your account on the Site when you have logged in previously; - Prevent and detect possible fraud; - Personalize elements of the layout and / or content on the Site in order to improve your experience.
8.4 Others - Carry out research and statistical analyzes in relation to your browsing on the Site.
We may store information about you using cookies that we can access when you return to the Site.
Cookies generally do not contain personal data, but they can include the type and version of the Internet browser you are using, the type, manufacturer and model of the computer equipment you are using, the website you are from arrived on the Site, your IP address, the operating system of your computer equipment and information relating to your Internet connection.
If you want to delete cookies that are already on your device, please refer to the instructions of your file management software to locate the file or directory that stores the cookies.
Further information on deleting or controlling cookies is available at www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser
. Please note that by deleting our cookies or disabling them for the future, you run the risk of not being able to access certain areas or features of the Site.
We work with a number of external service providers who may also publish cookies on the Site, such as: - Google Analytics; - Google Adwords; and - Google Maps
These external providers are responsible for the cookies they post on the Site and, for more information on these cookies, you should refer to their specific privacy policies.