If you have any questions about this Policy please contact us using the details in the “Contact us” section below. This Policy contains important information about your personal rights to privacy. Please read it carefully to understand how and why we use your personal information.
Who we are
Gonzague Leruth founded Exclin with the goal of making disruptive innovation happen – using the power of the Systems Thinking approach. As such, this website is operated by Exclin SASU (registered company 843 880 444 RCS Paris). Exclin SASU is the controller of the personal information that is collected through the site or otherwise as set out below.
How we collect information about you:
When you give it to us directly
For example, personal information that you give us by filling in forms on our website or communicating with us by phone or letter.
When you give it to us indirectly
Your personal information may also be shared with us by third parties. To the extent we have not done so already, we will notify you when we receive personal information about you from them and tell you how and why we intend to use that personal information.
When you visit our website
When you visit our website, we automatically collect the following personal information:
(a) Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
(b) Information about your visit to the website, including the uniform resource locator (URL) clickstream to, through and from the site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.
We may combine your personal information from one or more of these sources for the purposes set out in this Policy.
What personal information do we process?
We may collect, store and use the following kinds of personal information:
- name and contact details, including email address and office location, where applicable, social media identity and any additional information that’s shared about an individual or organisation;
- information about your computer / mobile device and your visits to and use of our website, including for example your IP address;
- any other information shared with us as per the section “How we collect information about you” above.
Do we collect/share sensitive personal information?
Data privacy law identifies certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health or ethnicity. In limited cases, we may collect and/or use your sensitive personal information (also known as special category data). Normally we will only do so where we have your explicit consent, but there may be other circumstances permitted under data privacy law.
How and why we use your personal information?
Your personal information may be used for the purposes specified in this Policy, including:
- to provide you with services or information which you request;
- to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve your interactions with our website, for example by ensuring that content is presented in the most relevant and effective manner for you and for your computer;
- to report on the results and impact of our work;
- as part of our efforts to keep our website and our internal operations safe and secure.
Filming and photograph at events
Please note that we (or our service providers) or third party (including Project partner) event hosts may film or photograph those attending or taking part in our events.
We may use the footage or photographs for publicity and marketing/fundraising purposes. For example, in print and/or digital material (including social media) or via external advertising and press outlets, all of which may be made available to the public.
We may use your contact details to provide you with information about our work which we consider may be of interest to you.
We will obtain your consent to contact you via email for these purposes (for example, via signing up on our website).
See the section “Our legal basis for processing your information” for more information about our use of legitimate interests.
We may send the following marketing materials but please note that recipients can unsubscribe from marketing emails at any time:
- Updates about Exclin – including email, newsletters, magazines and other publications informing you about our work;
- Campaigns – information about our Projects, including how you can support such campaigns and updates about the progress of our campaigns;
- Events – Note that if you sign up to an event, we will also send you administrative communications about how you can take part. On occasion we will also send you a reminder about the same event in future years in case you want to participate in it again.
Where possible we cleanse and remove out of date contact details by checking it against publicly available records such as deceased records. This helps us to improve the delivery rate of our mailings and minimise wasted expenditure.
Depending on your settings or the privacy policies for social media messaging services like Facebook, Twitter and Instagram you may receive targeted advertisements about Exclin through our use of social media audience tools.
For example, Facebook’s ‘Custom’ and ‘Lookalike’ Audiences’ programmes may enable us to display adverts to our existing supporters when they visit Facebook, or other people who have similar interests or characteristics to our supporters. We may provide your personal information including your email address to Facebook, so it can determine whether you are a registered account holder with them, or so that Facebook create a “lookalike” audience. Our adverts may then appear when you access Facebook. We only work with social media networks that provide a facility for secure and encrypted upload of data and immediately delete any records not matching with their own user base.
For more information or to manage your social media ad preferences, please see Facebook’s “About Custom Audiences” guide (https://www.facebook.com/business/help/744354708981227) and its Data Policy.
Will we share your personal information?
Unless stated in this Policy, we do not share (unless we have your consent to do so), sell or rent your personal information to third parties.
Security of and access to your personal information
We take proportionate and appropriate measures to safeguard your personal information and to prevent the loss, destructions, misuse or alteration of it. For example, your personal information is only accessible by appropriately trained staff and contractors, and stored on secure servers. In general, the personal information that we collect from you will be stored at a destination within France or the European Union. However, we use agencies and/or suppliers to process personal information on our behalf. Your personal information may therefore be transferred or stored outside, and/or otherwise processed by contractors operating outside France or the European Union, who work for us or for one of our suppliers.
In these cases we will take all steps reasonably necessary to ensure that the recipient implements appropriate safeguards to protect your personal information (for example, by entering into a contract approved by the European Commission or, if the company is based in the US, checking that it is certified under the EU-US Privacy Shield).
The transmission of information via the Internet is never completely secure, and although we do our best to protect it, we cannot guarantee the security of personal information transmitted via the Internet.
Our legal basis for processing your personal information
Exclin SASU must rely on a lawful basis to collect and use your personal information. Data privacy law specifies various grounds, and we consider the following to be relevant to our use of personal information:
- Where you have provided your consent – For example, to send you direct marketing by email or SMS.
- Where it is necessary so that we can comply with a legal obligation to which we are subject.
- Where it is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract – For example if you are assisting with or otherwise involved in one of our Projects under a contract.
- Where there is a legitimate interest in us doing so.
Personal information may be collected and used if it is reasonably necessary to achieve a legitimate interest (as long as that processing is fair, balanced and does not unduly impact your rights).
Those legitimate interests include the following:
- Administration and operational management, including responding to solicited enquires, providing information, research, events management, the administration of our Projects and employment and recruitment requirements; and
- Campaigning, including administering campaigns, analysis, targeting and segmentation to develop communication strategies and maintaining communication suppressions.
In general, our legitimate interests include running Exclin SASU as a company and pursuing our aims and ideals. However, “legitimate interests” can also include your interests, such as when you have requested information or services from us, and those of third parties (for example, beneficiaries of our Project work – including ensuring those who require help and support are directed to the most appropriate organisations to provide it).
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights.
How long do we keep your personal information
Whatever your relationship with us, we will only store your personal information for as long as necessary to fulfil the purposes we collected it for, including the purposes of satisfying any legal, accounting or reporting requirements.
Usually this will be for a specified amount of time in accordance with our internal retention policy. That length of time may vary depending on the reasons for which we are processing the personal information and whether we have a legal (for example under financial regulations) or contractual obligation to keep it for a certain amount of time.
Subject to the above, generally, we typically retain personal information relating to people who have signed up to our mailing lists for 6 years after their last interaction with us and we will then consider whether to retain for a further six years.
Once the retention period has expired, personal information will be confidentially disposed of or permanently deleted.
If you object to further contact from us, we will keep some basic information about you on a “suppression list” in order to avoid sending you unwanted communications in the future.
You have a number of legal rights in relation to our use of your personal information. These rights include:
- Right to object – you have the right to object to processing where we are (i) relying on the legitimate interests as a legal basis, (ii) using your personal information for direct marketing or (iii) using your personal information for statistical purposes.
- Right to withdraw consent – where we are using your personal information on the basis of your consent, you can withdraw that consent at any time.
- Right of access – you can ask for confirmation of what personal information we hold about you and request a copy of that personal information. Provided we have successfully confirmed your identity (we need to be sure we are only releasing your personal information to you), we will provide you with your personal information subject to any exceptions that apply.
This is sometimes called a “subject access request” and can be done by writing to us at the postal address in the “Contact us” section below.
- Right of erasure – in some cases, you can ask us to delete your personal information from our records (or to anonymise it). We may retain some limited personal information in order to ensure you are not contacted by us in the future.
- Right of rectification – if you believe our records concerning you are inaccurate; you have the right to ask us to update them. You can ask us to check the personal information that we hold about you if you are unsure.
- Right to restrict processing – in certain situations you have the right to ask us to restrict the processing of your personal information if there is disagreement about its accuracy or legitimate usage.
- Right to data portability – where we are processing your personal information using automated means on the basis of consent, or to perform a contract, you may ask us to transfer it to another service provider in a usable format.
To exercise any of these rights, please send us a description of the personal information in question, along with an explanation of the rights you wish to exercise, using the contact details in the “Contact us” section below. In some cases, we may ask for proof of identification or further information before we can process your request.
Please note that these rights only apply in limited circumstances. For more information, we suggest that you consult guidance from the Commission nationale de l'informatique et des libertés (CNIL) – https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles – or please contact us using the details in the “Contact us” section below if you are unsure.
Third party websites
Due to the nature of our work, our website may contain links to other sites. This Policy does not cover those external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website or if you are involved in one of our Projects, please visit the website of those partners who are listed on the website as being involved so you can understand how they collect, use and share your personal information.
Changes to this Policy
We keep this Policy under regular review and may update it from time to time, so we recommend that you check it regularly. Where necessary we may also notify you of changes to this Policy by email. This Policy was last updated on 29 February 2020.
Contact us (including complaints)
If you have any questions or concerns (including complaints) about this Policy or about the way in which your personal information is being used please let us know by contacting us in the following ways:
49, rue de Ponthieu
In each instance, please ask for or address your communication to the Data Protection Officer.
You are entitled to make a complaint at any time to the Commission nationale de l'informatique et des libertés (CNIL), the French regulatory authority for data privacy (https://www.cnil.fr/fr/services-en-ligne). We are always grateful for the opportunity to resolve your concerns before you approach the CNIL, so appreciate if you would contact us in the first instance.