As a controller, NAÏO TECHNOLOGIES has implemented this “Policy of Protection and Confidentiality of Personal Data” to inform its prospects, customers, providers and partners, and more generally any user of a robot designed by NAÏO TECHNOLOGIES and any person interested by NAÏO TECHNOLOGIES’ activities, about categories of Personal Data concerning them which are processed, the purpose of the processing, the recipients of these Personal Data and the rights which benefit the persons whose Personal Data are processed.
This Policy is part of the Regulation (EU) 2016/679 (“General Data Protection Regulation” or “GDPR”) and of the amended French law n °78-17 of 6 January 1978 relating to computing, files and freedoms.
This policy may be amended or supplemented at any time by NAÏO TECHNOLOGIES, in particular to comply with any legislative, regulatory, jurisprudential or technological developments.
1 – Definitions:
- « Personal Data » means any information relating to a natural person, identified directly (name, surname, image, video …) or indirectly (telephone number, bank account number, fingerprint …). Are excluded from the concept of Personal Data: anonymized data, corporate data and machine data.
- « Sensitives Personal Data » means Personal Data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs or trade union membership, and processing of genetic data, biometric data for purpose of uniquely identifying a natural person, data concerning heath or data concerning a natural person’s sex life or sexual orientation.
- « Data Subject » means individual, natural person identified or identifiable, whose Personal Data are Processed. In this Policy, Data Subjects are NAÏO TECHNOLOGIES’ prospects and customers as well as any natural person or legal representative of a company having acquired for the purpose of its activity a robot designed by NAIO TECHNOLOGIES, that this purchase was made directly from NAÏO TECHNOLOGIES or indirectly via a Distributor of NAÏO TECHNOLOGIES.
- « Controller » means the person who determinate, alone or jointly with others, the purposes and means of the processing of Personal Data: here the Controller is the company:NAIO TECHNOLOGIES, simplified joint stock company whose head office is located 235 rue de la Montagne Noire, 31750 ESCALQUENS (France), registered in the Trade and Companies Register of TOULOUSE under number 538 138 033.
- « Processor » means the person in charge of process Personal Data on behalf of the Controller, in accordance with his specific and written instructions.
- « Processing » means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
2 – What are the Personal Data and Data Subjects concerned by processing carried out by NAÏO TECHNOLOGIES ?
NAÏO TECHNOLOGIES can collect and process the following Personal Data relative on Data Subjects:
- Those relating to the identity, in particular the name, first name;
- Those relating to his professional activity: profession, professional contact details, as postal address, e-mail and telephone number.
NAÏO TECHNOLOGIES does not collect or access to any Sensitive Personal Data relating to the Data Subjects.
It is specified that are not Personal Data because they do not permit to identify the user of the robot, data from the use of robots relating to the time of use, the frequency of use, the sector on which the robot is used or those concerning the state of the robot (software version, battery status, technical information).
3 – What are the purpose of the processing and the legal bases justifying this processing?
Personal Data on Data Subjects are only processing by NAÏO TECHNOLOGIES for the following purposes:
- Performance of a contract signed with the Customer: processing of Personal Data to communicate with the customer, the signature of the contract, the delivery of the robot and of his equipment, invoicing, training for using the robot and for the performance of the robot guarantee and customer support;
- Legitimate interest to processing Personal Data on any user of the robot identified near to NAÏO TECHNOLOGIES as such, for his training for using the robot, for the performance of the robot guarantee and for support;
- Legitimate interest to processing Personal Data about Data Subjects to inform him about NAÏO TECHNOLOGIES business, to send him invitation to exhibitions or events organized by NAÏO TECHNOLOGIES (in particular for the FIRA), or in which NAÏO TECHNOLOGIES participates, in the business area of the Data Subject;
- Base on Data Subjects consent, for business development. Data collected via contact forms or event registration forms can be used by the sales department of NAÏO TECHNOLOGIES to suggest to the person identified in these forms, NAÏO TECHNOLOGIES’ products and services.
4 – Who are Data’s recipent?
Personal Data processing by NAÏO TECHNOLOGIES may be communicated to the following natural or legal persons:
- Authorized NAÏO TECHNOLOGIES’ staff members;
- Eventual NAÏO TECHNOLOGIES’ subsidiaries;
- NAÏO TECHNOLOGIES’ Distributors;
- Any natural or legal person who can be involve, as a Processor, for the performance of the contract concluded between the Data Subject and NAÏO TECHNOLOGIES, these subsidiaries or Distributors.
NAÏO TECHNOLOGIES does not transfer any Personal Data outside the European Union. If for a specific purpose justified by the execution of the contract, by a legal obligation or by a legitimate interest, Personal Data must be transferred outside the European Union, the Data Subject will be previously and expressly informed. The Data Subject is informed that this will be the case in particular if this person is located on a territory outside the European Union on which is located a NAÏO TECHNOLOGIES’ Distributor to which its professional contact information will be transmitted to facilitate the communication.
NAÏO TECHNOLOGIES never market the Personal Data of his clients, prospects, providers and partners.
5 – What is the storage period of Personal Data?
Personal Data collected and processed by NAÏO TECHNOLOGIES are only stored for the period necessary for carry out the purpose defined and for the period the relevant law impose a period of storage (common law about limitation period, legal obligation to store invoices, annual accounts, etc.).
At the end of the storage period, the Personal Data stored will be destroyed without a copy being kept.
6 – How are Personal Data protected?
NAÏO TECHNOLOGIES undertakes to take all reasonable precaution to protect the Personal Data processed against accidental or unlawful destruction, loss, modification, disclosure or unauthorized access. These precautions include technical, physical and organizational security measures, such as preventative measures against unauthorized access, base on the sensitive nature of the information and the level of risk associated with the Personal Data processing.
NAÏO TECHNOLOGIES guarantees to the Data Subjects that all their Personal Data are stored on datacenter located on the European Union territory, meeting the needs of all the security and confidentiality requirements regarding both access to the premises in which the datacenter are located and remote access to the datacenters.
7 – What are the rights of the Data Subjects?
Any Data Subject concerned with processing of his Personal Data by NAÏO TECHNOLOGIES has the following rights in accordance with the regulation:
- Right of access: means the right to obtain from the Controller confirmation as to whether or not Personal Data concerning him or her are being processed, and, where that is the case, access to the personal data and the information about the processing.
- Right of rectification of inaccurate or incomplete Data.
- Right to erasure (right to be forgotten) especially the personal data are no longer necessary in relation to the purposes for which they were collected, if the Data Subject withdraws consent on which the processing is based for the processing, if there are no overriding legitimate grounds for the processing or is the processing is unlawfully.
- Right to restriction of processing.
- Right to Data portability in a structured, commonly used and machine-readable format.
- Right to object to the reuse of his contact information for the purpose of solicitations, including commercial, during an order or the signing of a contract.
Any Data Subject can, by justifying his identity, exercise these right at any time, by sending to NAÏO TECHNOLOGIES au e-mail to moc.s1580276332eigol1580276332onhce1580276332t-oia1580276332n@tca1580276332tnoc1580276332 or an letter to NAIO TECHNOLOGIES, Personal Data Processing, 235 rue de la Montagne Noire, 31750 Escalquen (France)
The Data Subject may lodge a complaint with the French Independent Supervisory Authority, the “Commission Informatique et Libertés” (CNIL) on its website www.cnil.fr or by send a letter 3 place de Fontenoy, 75334 Paris Cedex 07 (France).
8 – Modification of the “Policy of Protection and Confidentiality”
NAÏO TECHNOLOGIES may modify this “Policy of Protection and Confidentiality of Personal Data” to reflect the evolution of its practices or to comply with legal or regulatory evolutions. Any modification to this “Policy of Protection and Confidentiality of Personal Data” will be communicated to the Data Subject.