Effective date: January 1, 2024
Pharaday (we) attach great importance to the protection of your Personal Data and undertake to ensure that your Personal Data is processed in strict compliance with the Applicable Laws and Regulations on Personal Data Protection as defined in Article 2 Definition of our Privacy Policy.
This Pharaday’s Privacy Policy explains how Pharaday processes and protects his customers Personal Data.
Our Privacy Policy will enable you to better understand how your Personal Data is processed, as well as the means available to you to exercise your rights under Applicable Laws and Regulations on Personal Data Protection.
This Privacy Policy is applicable to all processing of Personal Data implemented by Pharaday in providing its services through the Pharaday’s platform and its website.
Pharaday takes the protection of your Personal Data very seriously. We are used to secure our process and databases, and we protect your data in the same way we protect ours. Our awareness of these matters makes us a reliable partner for the security and confidentiality of your data. We know that in the digital area, processing the data you entrust us with is crucial to fulfill our duty to provide you with the best services and to help you make the best decisions.
The terms and expressions starting with a capital letter in this Privacy Policy have the meaning given to them in this section 1 or in this Privacy Policy, whether used in the singular or in the plural. The terms and expressions starting with a capital letter and not defined in this Article are defined in the GDPR (in particular under its article 4 Definition).
Applicable Laws and Regulations on Personal Data Protection means the Regulation EU 2016/679 of 27 April 2016 on the protection of natural persons with regard to the Processing of Personal Data and on the free movement of such data and any local law supplementing it (“GDPR”); the Directive 2002/58/EC of 12 July 2002 concerning the Processing of Personal Data and the protection of privacy in the electronic communications and any local law supplementing it (“ePrivacy”), each as updated from time to time, and all derived and related laws and regulations, including for national when applicable.
Pharaday means a French simplified joint-stock company with a single shareholder (“société par actions simplifiée à associé unique”) with a capital of 10 000,00 euros, incorporated and registered in R.C.S of Bordeaux (FRANCE) with company number 983618216, whose registered office is at 5 rue Fénelon 33000 Bordeaux – France.
Pharaday provides to Customers the Pharadays Platform.
Customer means a company who suscribed to one or many Pharaday apps and services on Pharaday platform.
Pharaday’s platform means the digital solution provided by Pharaday to its Customers allowing to access the different services and apps offered by Pharaday.
Customers act as Data controller for Personal Data they processed within the scope of their own data Processing activities.
Pharaday act as:
- Data controller for Personal Data processed within the scope of our own data Processing activities (see section 4 below)
- Data processor for Personal Data entrusted to us by our Customers. When we act as Data processor, we process the data upon the documented instructions and guidelines of the Data controller always with respect to Applicable Laws and Regulations on Personal Data Protection.
We undertake to comply with the general principles arising from Applicable Laws and Regulations on Personal Data Protection, and to be able to prove this compliance at any time. We agree to process Personal Data:
- Lawfully, fairly and in a transparent manner in relation with the Data subject;
- For specified, explicit, legitimate purposes and not further processed in a manner that is incompatible with those purposes (except if it is in accordance with article 89(1) of the GDPR;
- Adequate, relevant, and limited to what is necessary in relation to the purposes for which these data are processed;Accurate and where necessary, kept up to date;
- Kept in a form which permit identification of Data subjects for no longer than necessary for the purposes for which Personal data are processed;
- In a manner, that ensures appropriate security of the Personal Data;
- In compliance with the principles of privacy by design and by default in terms of tools, products, applications of services.
The table below details the reasons why we process Personal Data, which Personal Data we process, upon which legal basis and for how long.
How do we share your Personal data with and why?
We may share your Personal data with our personnel subject to a prior confidentiality obligation, to the competent authorities upon request according to Applicable Laws and Regulations on Personal Data Protection, and with our service providers for instance for the hosting of your data, management of our systems etc.
In any case, we are being vigilant to ensure the confidentiality of the data sharing and we also ensure that our providers present sufficient guarantees before sharing with us the data.
According to Applicable Laws and Regulations on Personal Data Protection your have rights which allow you to exercise a real control over your Personal data and how we process them:
- You can request access to your Personal data
- Your can ask for the correction and the deletion of your Personal data
- You can object to the processing of your Personal data based on legitimate interests and for commercial prospecting purposes
- You can suspend the use of your Personal dataYou can withdraw your consent at any time
- You have rights against an automated decisionYou can request the portability of part of your Personal data
- You can lodge a complaint to the competent Supervisory authority
If you which to exercise the rights listed above, please contact us:
- At our office: Pharaday, 5 rue Fénelon 33000 Bordeaux
- Or by email: contact@pharaday.ai
Considering the state of art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, Pharaday implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
- The pseudonymisation and encryption of Personal Data;
- The ability to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
- The ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
- A process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the Processing.
In the event our activities require a transfer of Personal Data to a country outside the EEA, we agree to provide a lawful framework to this transfer according to Applicable Laws and Regulations on Personal Data Protection.
The cross-border data transfer shall be conditioned to on any export being carried out (i) on the terms of appropriate safeguards (for instance the EU standard clauses on the transfer of Personal Data in their latest version in force and according to the module applicable to the Personal Data transfer), or based on as adequacy decision.
We may modify this Privacy Policy at any time, considering product, legal and regulatory changes.
The version that prevails is the one accessible online on our website. You therefore must refer to the version available online at the time of your access and use our website or the Pharaday’s Platform.
However, the Personal data will always be processed in accordance with the current applicable Privacy Policy at the time of their collection, unless otherwise permitted by law.
For any query with this Privacy Policy or with the way Pharaday processes your Personal data, please contact us by email to: om@pharaday.net or by letter: Pharaday, 5 rue Fénelon 33000 Bordeaux.