(Last modified on Oct. 11, 2019)
By visiting or using the Website, you agree to be bound by the terms of this Policy. If you do not agree to all the provisions contained in the Policy, you are not authorized to use the Website.
Potloc reserves the right, at any time and without prior notice, to modify or replace any of the Policy. Any changes to the Policy can be found at this URL. It is your responsibility to check the Policy periodically for changes. Your use of the Website following the posting of any changes to the Policy constitutes acceptance of those changes. If there are any significant changes to the Policy that materially affect the way we treat your information, you will be notified by email.
The Policy should be read in conjunction with the TOU, as both these documents govern your use of the Website.
If you have any questions about the Policy or if you wish to inquire about and / or access any Personal Information (as defined below) Potloc holds about you, please contact: Potloc France at email@example.com or at 71 rue Réaumur, 75002 Paris France.
1. General Statement of Privacy
Potloc takes your privacy and security of Personal Information (as defined below) very seriously. We have provided a secure environment and this strict Policy that describes the limited ways the information is used and the limited access to such information
2. Scope of Policy
Personal Information. This Policy covers the processing of information relating to an identified or identifiable natural person (“Personal Information”) gathered by Potloc when you are using the Website and provide insights and opinions when answering our surveys. This Policy also covers Potloc’s processing of any Personal Information that Potloc may share with its business partners or other third parties under very limited circumstances.
Third Party Services. This Policy does not apply to the general practices and processing of information (whether personal or not) by third parties that Potloc does not own or control, including but not limited to any third-party websites or services (“Third-Party Website” or “Third-Party Service”) that you elect to access through the Website or via a link from the Website. While we attempt to facilitate access or link only to those Third-Party Websites or Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Websites or Third-Party Services. We encourage you to carefully review the privacy policies of any Third-Party Website you access or Third-Party Service you use.
Limited Collection. Potloc does not gather any of your Personal Information while you are using the Website, except as provided in this Policy. Where you have provided Personal Information or where we have collected Personal Information, it will only be used for the stated purpose, as detailed more specifically in the next sections.
Personal Information collected, purposes and legal basis. The following is a list of Personal Information that Potloc may collect from you when you use the Website and what we use it for.
- While visiting the Website, participating in surveys or providing a Testimonial you may be required to provide the following accurate and truthful Personal Information: first name, email address, age, gender, postal code, marital status, primary occupation and household income. You may also choose to provide us with additional Personal Information when you fill out free fields in our questionnaires. These Personal Information are used by Potloc, in the context of the consumer surveys it conducts on behalf of its customers, leading to the establishment and transmission of statistics. Potloc's activities actually consist in conducting surveys on behalf of its client towards a targeted audience. Potloc determines the questions asked, and therefore, some of the Personal Information required, depending on the purpose and nature of the survey in question, as well as on the expected results. The processing of such Personal Information is based on your express consent.
- When you visit the Website to access the results of a survey, as a customer of Potloc, you provide Personal Information, such as your e-mail address, first and last name. This processing is carried out on the basis of the execution of the contract between you and Potloc.
- We may also use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you as further described in Section 5 (Mailing List Management). In particular, Potloc may contact you individually following a survey or a Testimonial to provide you with information that may be of interest to you. Such processing is based on your express consent. If you have not consented to the reception of such communications, Potloc will not contact you for this purpose.
3. Non-disclosure of Personal Information to Third Parties
Limited Disclosure. Except as provided in this Section 3, and in Sections 5 (Mailing List Management) and 6 (Security and Encryption of Information) and unless Potloc’s users expressly consent to receive commercial electronic messages from identified third parties, in which case Potloc would only communicate to such third parties the email addresses of consenting users, Potloc does not divulge any Personal Information collected via the Website to third parties.
Moreover, subject to situations where Potloc’s users expressly consent to receive commercial electronic messages from identified third parties, in which case Potloc may sell, rent, trade or license to such third parties the email addresses of consenting users, Potloc does not sell, rent, trade or license any Personal Information regarding its users to third parties. Only the employees, representatives, subcontractors, officers, agents, or assigns of Potloc (collectively, the “Representatives” ) are responsible for the management and development of the Website, and only these individuals have access to the information collected there. These Representatives all have been instructed to comply with the Policy.
We may share any information we have collected about you or that you have submitted (whether Personal Information or not):
- in response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims or demands;
- if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person, or any violation of the TOU;
- if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Website infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Website generally);
- to a parent company, subsidiaries, joint ventures, or other companies under common control with Potloc (in which case we will require such entities to honour this Policy) to properly create consumer research reports or to carry out geolocated campaigns ;
4. Collection, Use, and Disclosure of Non-personal Information
Usage Information. We collect information about usage of the Website from within the Website (“Usage Information”), but none of this information identifies you personally. For example, each time you use the Website, we automatically collect the list of most used screens by users. Usage Information can also consist in your testimonials and answers (“Testimonials”) to the questions we ask you within the framework of surveys available on the Website with the purpose of obtaining your views on local retail projects and various consuming habits you may have (“Surveys”). We use Usage Information collected in this manner (i) to better understand your needs and the needs of the Website users in the aggregate; (ii) for statistical purposes to keep track of the usage of the Website with a view to introducing improvements; (iii) for statistical purposes to synthetize your (and other Website users’) views and opinions collected through the Surveys; and (iv) to trace any fraudulent or criminal activity, or any activity in violation of the TOU. In this context, Potloc may also contact you individually to provide you with information that may be of interest to you if you gave your consent to such communications.
Limited Disclosure. We may share certain Usage Information with third parties so as to optimize our Website, provide statistics on the use of our Website and provide statistics on your views and opinions collected through the Surveys, or provide targeted marketing offers.
5. Mailing List Management
Third Party Service Providers. Potloc may use Third-Party Services to manage our mailing list and send out emails. In which case, Personal Information is transferred to such Third-Party Service providers in order for the mailing list to function properly. Your Personal Information is only used for the proper sending out of email. If Potloc uses any such Third-Party Service provider, it will obtain representations from them that they do not use this Personal Information for any other purpose and will not transfer or sell your Personal Information to any other third party.
Unsubscribe. You may unsubscribe from Potloc’s mailing list at any time, by following the link at the bottom of all Potloc emails, by using the following link: https://app.potloc.com/en/community/subscriptions/edit or by contacting us at firstname.lastname@example.org.
6. Security and Encryption of Information
Security. Potloc uses only industry best practices (physical, electronic and procedural) in keeping any data collected (including Personal Information) secure. In addition, Potloc uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Website, and these third parties have been selected for their reliability in terms of security, both electronic and physical. You acknowledge that our third-party vendors and hosting partners may be located in jurisdictions or countries where the privacy laws may not be as protective as those in your home province, state, country or other governmental jurisdiction.
Risks Associated with the Internet or Wireless Data Transmission. Despite Potloc’s best efforts to ensure third parties will not access or obtain your Personal Information through the Website, complete confidentiality and security cannot currently be guaranteed on the Internet and/or where data is transferred via wireless digital technology of any type. Communication in this manner is subject to interception, loss, or alteration. You acknowledge and agree that Potloc cannot be held responsible for any losses or damages whether pecuniary or otherwise resulting from the transmission of your Personal Information in this manner and that such communications are at your own risk.
7. Retention of Personal Information
Your Personal Information are only retained for the period necessary to achieve the purpose of the processing, i.e.:
- Your Personal Information processed for the purpose of survey and statistical purposes will not be retained after the end of the corresponding survey;
- Your Personal Information processed for the purpose of sending you commercial communications or contacting you individually to provide you with information that may be of interest to you, will not be retained more than three (3) years after our last contact with you;
- Cookies will not be retained for more than thirteen (13) months.
8. Transfer of Personal Information
Your Personal Information may be transferred by Potloc outside the European Economic Union or to countries that do no not have laws that provide sufficient protection for Personal Information. Your Personal Information may actually be transferred inside the Potloc Group, in particular to Canada. When we transfer your Personal Information outside such countries, we will ensure that it is protected by appropriate safeguards (i.e. the recipient will signed the model contractual clauses approved by the European Commission).
9. General Information Transfert from the Website
Any information (personal or not) the Website collects while you use it may be stored locally on your computer or handheld or tablet device (“Device”) and then transferred to servers controlled by Potloc, and Potloc may obtain this information as a result of the data being sent to our servers from the Website. The information, however, is only used (or not used) by Potloc as described elsewhere in this Policy.
The following is a complete listing and description of what functions on your Device that were developed by third parties are accessed and / or modified by the Website. Unless otherwise specified, these permissions apply both to iOS Devices and Android Devices.
- Localisation services. Allows the Website to determine your location through network services to adapt the content locally.
11. Your rights
In accordance with the applicable regulations, you have the right to access, rectify, delete and to request the portability of your Personal Information where applicable, as well as the right to set guidelines regarding the fate of your Personal Information after your death.
You can request to access to your Personal Information directly via the following link: https://app.potloc.com/en/community/data-requests/new
You can also request the restriction of the processing or object to the processing of your Personal Information under the conditions provided by the applicable regulations. Finally, when the processing of your Personal Information is based on your consent, you have the right to withdraw your consent at any time.
You can exercise your rights by contacting: email@example.com or send your request to 71 rue Réaumur, 75002 Paris France.
You also have the right to file a complaint with the Commission Nationale de l'Informatique et des Libertés ("CNIL") if you consider that the processing of your Personal Information by Potloc does not comply with the applicable regulations.
12. Compliance with Privacy Laws and Anti-Spam Laws
Privacy. This Policy and Potloc’s practices in general are designed to be in compliance with the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the processing of personal data and on the free movement of such data ("GDPR") and the French Act n°78-17 of 6 January 1978 on information technology, data files and civil liberties ("LIL"). If you have any questions regarding this compliance, please contact us at firstname.lastname@example.org.
This Policy and Potloc’s practices in general are designed to be in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”, S.C. 2000, c. 5) and Quebec’s An Act Respecting the Protection Of Personal Information in the Private Sector (R.S.Q. c. P-39.1). If you have any questions regarding this compliance, please contact us at email@example.com.
Anti-Spam. Potloc is committed to ensuring that we respect anti-spam legislation, specifically the Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications). If you feel you have received emails from us in violation of these laws, please contact us at firstname.lastname@example.org.
Potloc is committed to ensuring that we respect anti-spam legislation, specifically the U.S. CAN-SPAM Act of 2003 (15 U.S.C. Ch. 103) and the Canadian law informally known as Canada’s Anti-Spam Law (“CASL”, S.C. 2010, c. 23). If you feel you have received emails from us in violation of these laws, please contact us at email@example.com.