Privacy Policy
June 2021
Your privacy is important to us: this privacy policy informs you of how your data is collected, used, disclosed, transferred and stored, and of your rights in relation to it.
This is in line with the personal data protection scheme:
➝ Regulation (EU) 2016 / 679 of the European Parliament and of the Council of 27 April 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, entitled the “General Data Protection Regulation” (GDPR), in force since May 25, 2018 ;
➝ Law n°78-17 of January 6, 1978 relating to information technology, files and freedoms, known as the “Information Technology and Freedoms” law.
Our platform contains links to other websites, this does not mean that we endorse these sites. It is recommended to regularly consult the personal data protection policies of these third-party sites: their personal data processing may be different from ours.
Definitions
In the body of this Privacy Policy, each of the following terms shall have the meaning given by its definition
- Review: a rating, evaluation or comment given by a Participant on the quality of a Product;
- Participants’ database: all the personal data relating to the Participants;
- Client: natural or legal person who uses the services of Trustt;
- General Sales Conditions (GSC): conditions applicable to the Client purchasing products or services from Trustt;
- Personal data: any information that can directly or indirectly identify a natural person;
- Questionnaire: a list of questions to answer in a survey or poll;
- Software: software solution as a service (Saas) accessible via a remote server;
- Opt-in: consent of a natural person allowing the sending of emailing;
- Participant: consumers and influencers identified and/or selected to answer the various questionnaires;
- User: person using the products or services of Trustt.
We take care to collect only data that is strictly necessary for the purpose of the processing carried out.
PURPOSE OF PROCESSING, DATA COLLECTED AND LEGAL BASIS
Unless otherwise specified, all Data requested by Trustt are mandatory and their absence may make the provision of the Services impossible. In case Trustt specifies that certain Data are not mandatory, the Users are free not to communicate them without any consequences for the availability or functioning of the Service.
| PURPOSE OF PROCESSING | COLLECTED DATA | LEGAL BASIS |
| Customer care | Name, first name
E-mail address Phone number Conversations (tickets and exchanges on the platform) Logs and pages viewed by the person concerned IP address Interactions with software |
Execution of a contract |
| Commercial communication / customer loyalty / newsletter | First and last names
E-mail address |
Legitimate interest or consent |
| Constitution of a database called “Influencer” and selection of the influencer panel | First and last names
Age Social networks and/or personal blog URL Posts on social networks and/or blog Metadata of publications (location, date, comments, etc.) Language preference Consumer habits |
Legitimate interest |
| Execution of the Influencer Contract | First and last names
Age Mailing Address E-mail address Social networks and/or blog |
Execution of a contract |
| Client billing | Full name, postal address (natural person) or company name, postal address VAT number (legal person)
E-mail address E-mail exchanges Quotes Invoices Payment data (payment terms, balances, outstanding payments, discounts granted) |
Execution of a contract |
| Management of reviews / answers to forms | First and last names
Mailing address Telephone number Age Social networks and/or blog Product Information Answers to forms IP address User name Password Language preference |
Legitimate interest |
| Management of data subject’s rights requests | First and last names
Mailing address E-mail address E-mail exchanges Copy of ID |
Legal requirement |
| Management of accounting and legal matters | First and last names
Mailing address E-mail address Payment details Quotes Invoices Email exchanges |
Legal requirement |
|
Surveys |
First and last names
Age Consumer habits and reviews |
Legitimate interest |
We ask that you do not share with us any personal documents or sensitive information such as health information, religious beliefs, etc.
We collect your personal data directly when you provide your contact information to create an account with us or when you interact with our Software (for example, by leaving a review through our Software).
In addition, we collect your personal data indirectly when we receive information about you from third parties (social networks, partners, etc.).
USE OF PERSONAL DATA
We use your personal data to:
- Improve our platform and services;
- Conduct surveys for Trustt and our Clients;
- Provide our services via our Software;
- Train our staff;
- Manage accounting and legal matters;
- Obtain qualified reviews for Trustt and our Clients;
- Securing our platform.
STORAGE TIME
In accordance with the regulations in force, we keep and store personal data only for the time strictly necessary for the purposes defined herein.
| PURPOSE OF PROCESSING | STORAGE TIME | LEGAL BASIS |
| Accounting and billing management | 10 years | L. 123-22 of the Commercial Code (FR) |
| Managing a client file | For the duration of the commercial relationship. From the end of this commercial relationship, they will be kept for a maximum of 3 years for commercial prospecting purposes |
Simplified Standard No. 48 |
| Managing a prospect file | From the time of collection of the personal data or the last contact from the prospect, this data will be kept for a period of 3 years |
Simplified Standard No. 48 |
| Obligations arising in the course of trade between traders / between traders and non-traders | 5 years | L.110-4 of the Commercial Code (FR) |
| Litigation management | To its end | Simplified Standard No. 48 |
| Audience statistics | These data will be kept for less than 13 months | Simplified Standard No. 48 |
STORAGE, TRANSFER AND SECURITY OF PERSONAL DATA
Trustt guarantees that your personal data has never been sold to third parties and will never be sold.
Nevertheless, we would like to inform you that your personal data may be shared with selected third parties. Therefore, we undertake to verify that all subcontractors and partners comply with the regulations in force and more specifically with the RGPD. These subcontractors and partners will only have limited and controlled access to your personal data for the purposes strictly limited by the execution of their services.
Some of these subcontractors or partners may be located in countries outside the European Union. Therefore, we ensure that the necessary safeguards are in place to guarantee a sufficient level of protection so that compliance with applicable regulations is not compromised.
In any case, Trustt has implemented technical measures in order to protect your Data against any malicious intrusion and to prevent any loss, alteration or disclosure of personal data to unauthorized persons. To this end, Trustt guarantees:
- Techniques for anonymizing and pseudonymizing your Data;
- Regular backups of your Data;
- Protection of the access control of your Data through authentication and authorization control measures;
- Awareness actions for employees and good practices relating to the processing of personal data.
In addition, we require our partners to provide sufficient guarantees to comply with the regulations in force.
Notwithstanding all these measures and our efforts, please note that the Internet is not a completely secure environment. Therefore, it is impossible to guarantee that the processing of your Data is completely secure.
Therefore, in case of a violation, Trustt undertakes to notify the CNIL of the violation that poses a risk to the rights and freedoms of the persons concerned as soon as possible, in accordance with the applicable regulations
RIGHTS OF THE PERSONS CONCERNED
In accordance with the regulations in force, you have various rights at any time with regard to the processing of your personal data.
➝ Access right
ou can access your personal data. If you have a Trustt user account, you can access your personal data related to your account, including your reviews. If you do not have an account, you can contact us at the following email address: contact@trustbeauty.io to request information about your personal data.
➝ Right of portability
You can request the download of your personal data by contacting us at the following email address : contact@trustbeauty.io
➝ Right of rectification
If you have a Trustt user account, you can change your personal information yourself. Otherwise, you can contact us at the following e-mail address: contact@trustbeauty.io to request the rectification of your personal data.
➝ Right to deletion
You can request the deletion of your personal data by contacting us at the following email address: contact@trustbeauty.io
➝ Right to limitation and opposition
In cases where we have asked for your consent, you may withdraw your consent at any time to limit the collection of your personal data by contacting us at the following email address: contact@trustbeauty.io
➝ Right to file a complaint with the CNIL
You can lodge a complaint with the CNIL, when your rights do not seem to be respected. To do this, you can contact the CNIL.
We guarantee that we will reply within one (1) month of your request, provided that you send us a copy of your identity card as an attachment.
Person in charge of the treatment
The person responsible for processing personal data is the company MAKEUP BAG.
SAS Makeup Bag
16 quai Alphonse le Gallo
92 100 Boulogne-Billancourt (FRANCE)
RCS Nanterre : 791 644 958
VAT NUMBER : FR 78791644958
CNIL declaration : n°1799236 v 0
contact@trustbeauty.io
Information about MAKEUP BAG is available in its legal notice.