Partoo Privacy & Cookies Policy

(Effective Date: May 15, 2022)

This Partoo Privacy & Cookies Policy (this “Privacy Policy”) explains how your personal information is collected, used and disclosed by Partoo SaS,. and the Partoo affiliates listed in the “Data Controllers and Contacting Us” section below (“Partoo”, “us”, or “we”) and how we collect information through the use of cookies and related technologies. It also tells you how you can access and update your personal information and describes the data protection rights that may be available under your country’s or state’s laws, including (in the European Economic Area (“EEA“), and UK), a right to object to some processing that we carry out or, where we rely on consent, how to withdraw that consent.

This Privacy Policy applies to personal information we obtain from or about you when you (i) visit all Internet sites operated by Partoo that link to this Privacy Policy (collectively, the “Sites“) and interact with our products (e.g. Presence Management, Review Management, Review Booster, Store Locator, Messages and future) made available through such Sites (collectively, the “Products“); (ii) interact with our social media pages and advertisements, customer services, communications, webinars or blogs; or (iii) participate in our events and demonstrations.

Unless otherwise stated, Partoo acts as the data controller for the data processing operations described in this Privacy Policy.

We may provide additional information about our privacy practices at other points, for example, when we ask you to provide personal information in connection with a particular service, and where this will help us provide more relevant and timely information.

We reserve the right to make changes to our practices and this Privacy Policy at any time. If we change the way we handle your personal information, we will update this Privacy Policy and notify you as appropriate.

This Privacy Policy addresses the following:

INFORMATION THAT WE COLLECT ABOUT YOU
USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
USES MADE OF YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR PROCESSING
DISCLOSURES OF YOUR PERSONAL INFORMATION
WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO PARTOO’S DIRECT MARKETING
EUROPEAN DATA PROTECTION RIGHTS
MISCELLANEOUS

1. INFORMATION THAT WE COLLECT ABOUT YOU

Customers, Site Visitors, and End Users

Information Provided by You upon Registration and/or Making a Purchase. When you register for an account on a Site and/or purchase a Product subscription or service from us, we collect information that allows us to identify you, such as:

Name
E-mail address
Address (where entered as part of a “business/location scan”)
ZIP/Postal code
Office phone
Mobile phone
Credit card number
Billing address
Partoo login details (username and password)

Information Provided When You Contact Us. We also collect personal information that you voluntarily provide to us when you contact us with a question or comment about our Products and services, download our whitepapers or sign up for product demonstrations or events. Typically, this includes:

Name
E-mail address
Organization name
Phone number
Information about your position
Information about your interests and preferences
Content of the communication

Automatically Collected Information. When you access our Sites and some of our Partoo powered properties, we automatically collect (i) technical information about your device including your device’s internet protocol (IP) address, your browser type and version, time zone setting, and operating system and platform; and (ii) information about your visit, including the URL clickstream to, through and from our Sites (including date and time), Products you viewed or searched for, your account/session activity (when logged in), the content (and any ads) that you view or interact with, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Some of this information is collected using cookies and related technologies. See Section 2 for more detail.

Information Collected From Our Third-Party Resellers. We may partner with third-party resellers to receive information about you, such as name and contact information. This helps us to fulfil your service requests and/or provide you with Products and services that may be of interest to you. The reseller will be the controller in respect of any customer account set up information that you provide directly to them (and we will act as the reseller’s processor in this regard).Information Collected in Connection with our Products. Where our customers use our Products, we compile statistical and other information related to the performance and operation of the relevant Products and reviews collected from our third-party publishers including name/alias of reviewers collected from third-party publishers, and will use or share such information with our customers and prospective customers to provide our Products, for research and development purposes, and to provide analytics, reports and benchmarking about our Products (e.g. yearly barometer, whitepapers..). We also use such aggregated information for our own promotional purposes. We use cookies and similar technologies both on our Sites and our customer sites to collect some of this information (see Section 2 for more detail). If you use our Products to solicit or monitor reviews or otherwise process personal information about your customers, employees, or web visitors (collectively, “End Users”), we will process such personal information on your behalf as data processors. This may include contacting End Users on your behalf or sharing and receiving such personal information with and from publisher sites in accordance with your instructions. We have no direct relationship with End Users. You are responsible for ensuring that you have complied with all applicable data protection legislation (including obtaining any necessary consents) to allow us to process such personal data to provide our Products and services. If you are an End User and believe you have received an email from us on behalf of one of our customers, please contact that company directly with any questions.

Information Collected from Other Third-Party Sources

We collect data from the following third parties:

Data brokers, social media networks and advertising networks – Commercially-available data such as name, address, email address, preferences, interests, and certain demographic data.
Analytics Providers – We also receive non-personal data, such as aggregated or de-identified demographic/profile data, from third-party sources including select partners and companies that specialize in providing enterprise data, analytics and software as a service.

In order to ensure data accuracy and offer a superior customer experience by providing you with better personalized services, content, marketing and ads, in some cases we link or combine the information that we collect from the different sources outlined above with the information we collect directly from you. For example, we compare the geographic information acquired from commercial sources with the IP address to derive your general geographic area. Information may also be linked via a unique identifier such as a cookie or account number.

Where necessary, we obtain information to conduct due diligence checks on business contacts as part of our anti-corruption compliance program and in accordance with our legal obligations.

Partners, Publishers and other Service Providers

We will process certain contact information about individuals within organizations that we work with such as publishers, mailing houses, payment providers, IT hosting and maintenance providers, events companies and other service providers.

2. COOKIES AND OTHER TRACKING TECHNOLOGIES THAT WE USE

Partoo uses cookie technology in order to offer you a better and more personalised web service. Within this Partoo Cookie Policy (the “Cookie Notice”) we provide you full transparency about how and for which purpose we use cookies on this website.

What is a cookie and what is it used for?

A cookie is a small text file that is stored and/or read by your web browser on the hard disk of your end device (e.g. computer, laptop or smartphone) by websites you visit. Nearly every website uses cookie technology to make websites work and to optimize design and functionality. Cookies also make your interactions with websites more secure and faster, since they can remember your preferences (e.g. such as login and language), by sending the information they contain back to the originating website (first-party cookie) or to another website to which it belongs (third-party cookie), when you revisit the respective website using the same end device. Based on the function and the purpose for which cookies are used they are typically divided into the following categories, which are used by Partoo on this website:

Analytical and performance cookies allow us to recognise and count the number of visitors and to gather information about how the website is used (e.g. which pages a visitor opens most often and whether the user receives error messages from some pages). This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Marketing and targeting cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. We may also share this information with third parties (such as advertisers) for this purpose. Usage of third party cookies

Usage of third party cookies

Please note that Partoo is using the services of third parties to learn about your usage of this website to optimize your user experience and to show you advertising outside of this website. These third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

What to do if you don’t want cookies to be set?

You can withdraw your cookie consent at any time. In order to do so, please refer the provisions below:

Modification of your web browser settings
If you want to delete the cookies stored on your device and configure your web browser to refuse cookies, you can do it by using the preference settings of your web browser. We can usually find the navigation settings relating to cookies in the « Options », « Tools » or « Preferences » menus of the web browser you use to access to this website. Nevertheless, depending on the existing web browsers, various means can be used to disable cookies. To get more information: please click on the following links: Microsoft Internet Explorer, Google Chrome, Safari, Firefox, Opera

Please note, that if, by configuring your web browser, you refuse the use and storage of cookies on your computer, will be able to surf on our website. However, some options or features might not work properly.

By using online platforms to control advertising cookies:
With regard to advertising cookies placed by third parties, you can also connect to the Youronlinechoices site, offered by digital advertising professionals grouped within the European Digital Advertising Alliance (EDAA). You will be able to refuse or accept cookies used by member advertising professionals.

Do you have questions regarding the Partoo cookie policy?

If you have questions with respect to the Partoo Cookie Policy, please feel free to contact us by using our email contact@partoo.fr

3. USES MADE OF YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR PROCESSING

Providing personal information is optional; however, in order to provide you with access to our Products, services and other resources such as whitepapers and demos, providing certain personal information (e.g., contact information and name, log-in details) may be necessary in order to receive these services and resources. You may choose whether or not to receive electronic marketing communications from us and we will only send you such communications where we have the appropriate consents to do so (to the extent required by applicable law). For more information on your choices, please see Section 5 below.

We process personal information through electronic and manual means for the following purposes:

Customers and Website Users

To fulfil a contract or to take steps linked to a contract. This includes:

to administer access to your accounts;
to process orders, provide our Products and services, and send you service-related communications;
for customer support purposes including responding to your queries and investigating any complaints about the Sites;

As required to conduct our business and pursue our legitimate interests, in particular:

to improve and personalize your experience with us and our Sites and to tailor content, communications, advertisements and offers to you;
to administer our Sites, conduct identity verification and other fraud detection activities;
to send you information you have requested;
to monitor, maintain and improve the performance of our Sites, communications, services and Products, analyze trends, usage and activities in connection with our communications, services and Products, validate users and ensure their technological compatibility with users, and optimize our marketing efforts and measure the effectiveness of our advertising campaigns;
for our own internal functions such as keeping our Sites secure, management and corporate reporting, internal research and analytics and to improve business efficacies;
to enforce compliance with our terms of use and other policies or otherwise in connection with legal claims, compliance, regulatory and investigatory purposes as necessary (including disclosure of such information in connection with legal process or litigation);
to create aggregate and statistical data (which cannot be used to identify you). For example, aggregate data may include data that describes the general demographics, usage or other characteristics of a Site’s users. We reserve the right to transfer and/or sell aggregate or group data about a Site’s users for lawful purposes.

Where you give us consent:

Where you ask us to send marketing information via a medium where we need your consent under applicable law (for example email marketing in some countries). For more information about how to modify your preferences about marketing communications, please see Section 5;
Where you give us consent to place cookies or similar technologies;
On other occasions where we ask for your consent, for the purpose we explain at the time.

As required by law:

In response to requests by government or law enforcement authorities conducting an investigation.

Partners, Publishers and other Service Providers

We use contact information about individuals within other organizations that we work with in order to fulfill our contractual obligations or as required to conduct our business and pursue our legitimate interests including for our own internal functions such management, corporate reporting, and record keeping.

Partners, Publishers and other Service Providers

4. DISCLOSURES OF YOUR PERSONAL INFORMATION

We will share your personal information with the third-parties listed below for the purposes that are described in this Privacy Policy or otherwise with your consent.

Service Providers & Partners. We engage service providers or partners to manage or support certain aspects of our business operations on our behalf. These service providers or partners may be located in the Europe or in other global locations and may provide services such as product delivery, advertising and marketing activities (including digital and personalized advertising), IT services, customer care, email service providers, data hosting, and management or support of our Sites. Our service providers and partners are required by contract to safeguard any personal data they receive from us and are prohibited from using the personal data for any purpose other than to perform the services as instructed by Partoo.

Advertisers. We may also transfer information about you to advertising partners (including the ad networks, ad-serving companies, and other service providers they may use) so that they may recognize your devices and deliver interest-based content and advertisements to you. The information may include your name, postal address, email, device ID, or other identifier in encrypted form. The providers may process the information in hashed or de-identified form. These providers may collect additional information from you, such as your IP address and information about your browser or operating system and may combine information about you with information from other companies in data sharing cooperatives in which we participate.

Affiliates. Partoo is a global business, headquartered in France. Your personal information collected by us in accordance with this Privacy Policy is used and shared amongst Partoo Sas and the Partoo affiliates for the purposes of delivering our Products and services, managing your accounts, hosting, IT, security, support, billing, marketing, and communications. The list in Section 8 describes the management responsibility for respective data processing activities by the listed Partoo affiliates.

Legal Requirements. We disclose personal information to government authorities or other third-parties if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with a subpoena, court order or similar legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of any Site or the public, (d) protect against legal liability, (e) to investigate fraud or other unlawful activity, or (f) or as otherwise required or permitted by law.

Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, including in bankruptcy, your personal information may be part of the transferred assets. You will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Publishers. If you have requested us to do so, we provide personal information to third-party publishers (e.g. Google) that we work with. For example, if you have provided your name, job title and/or a biography to be published on a third-party publisher’s website.

International Transfers of Personal Information. Your personal information is stored on servers in the EU. We also transfer your personal information to our affiliates and other service providers who perform functions on our behalf which are based around the world, including in countries outside of the EEA, UK, and Switzerland which may have different data protection standards to those which apply to your country of residence.

Where your personal information is transferred outside of the EEA, UK, and Switzerland, and where this is to an affiliate or service provider in a country which is not subject to an adequacy decision by the EU Commission or considered adequate as determined by applicable data protection laws, we will take steps to ensure your personal information is adequately protected by safeguards such as the Standard Contractual Clauses (“SCCs”) approved by the EU Commission. A copy of the relevant mechanism can be obtained for your review on request by using the contact details in Section 8.

In addition, although Partoo Sas. relies on safeguards such as the SCCs to receive personal information from the EEA, UK, and Switzerland and despite recent developments from the Court of Justice of the European Union, Partoo Sas. continues to participate in and has certified its compliance with the EU-US Privacy Shield and the Swiss-US Privacy Shield Frameworks.

5. WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO PARTOO’S DIRECT MARKETING

Where we rely on consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above in Section 3. You have the absolute right to opt out of our direct marketing at any time, and EEA, UK, and Swiss individuals can also opt out of profiling we carry out for direct marketing at any time. To stop receiving newsletters or marketing communications from us, you can use the unsubscribe mechanism in the relevant communication or you can send an email to contact@partoo.fr with information necessary to process your request. Please note that this will not stop you from receiving service related messages (i.e., non-marketing communications) such as email messages to let you know our service has been suspended for maintenance.

6. EUROPEAN DATA PROTECTION RIGHTS

Where our entities within the EEA, Switzerland, or the UK process your personal data or where we process personal data of individuals located in the EEA, Switzerland, or the UK, you may have the right to ask us for a copy of your personal data, to correct, delete or restrict processing of your personal data, to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share (port) this data to another controller. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we are not required to process such data in order to meet a contractual or other legal requirement).

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests which we have described above. You can obtain information on any of our balancing tests by contacting us using the details below.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are set out in applicable data protection laws. We will inform you of the relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, please email contact@partoo.fr with the information necessary for us to process your request. If you have unresolved concerns, you may have the right to complain to an EU, UK or Swiss data protection authority where you live, work or where you believe a breach may have occurred.

If you deactivate your account, we will delete, block or anonymize your personal information so that it is no longer possible to identify you, subject to our retention policy below.

If you have provided a location review to one of our customers, please contact that customer directly if you have any questions about their privacy practices or wish to stop receiving communications from or exercise your rights in respect of personal data processed by that customer.

7. MISCELLANEOUS

Third-Party Websites and Services. The Sites may contain links to third-party owned and/or operated websites or utilize third-party services. We are not responsible for the privacy practices or the content of such websites or services. Please contact these third-parties directly for information regarding their privacy practices prior to providing them with any information. Parts of the Sites utilize YouTube API Services. These YouTube API Services are subject to the privacy practices currently found at https://www.youtube.com/t/terms. Some of our solutions are integrated into our customers’ own websites, applications and communications (“Customer Solutions“). Where this is the case, we do not interact directly with the ultimate end user of these Customer Solutions and the customer will be responsible for the operation of these Customer Solutions and any personal information collected in connection therewith. We are not responsible for the processing of personal information by these Customer Solutions save to the extent that we receive any personal information via these Customer Solutions on behalf of the customer or the reseller in order to fulfil the Product and service requests. In these cases, we will act as a data processor and this Privacy Policy will not apply to such personal information. Please contact the relevant customer or reseller directly if you have questions regarding their data collection practices or any communications you may receive from them.

Blogs and Public Features of the Sites. Some of our Sites offer publicly accessible blogs or community forums. You should be aware that any personal information you submit there can be read and collected by other users of these forums and could be used to send you unsolicited messages and for other purposes. Our blog is managed by a third-party application that may require you to register to post a comment. We do not have access to or control of the information posted to the blog. None of the information that you provide using these features is protected by this Privacy Policy. We are not responsible for the personal information you choose to submit in these forums or the use thereof by any third-party. You will need to contact or log into the third-party application if you want the personal information that was posted to the comments section removed. To learn how the third-party application uses your information, please review their privacy policy.

Security. We take commercially reasonable steps to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from a Site may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any personal information to us or to any other party via the Internet. When you enter sensitive information (such as a credit card number) on our order forms or login credentials (such as username and password) on our platform login, we encrypt the transmission of that information using secure socket layer technology (SSL).

Retention. We will retain your information for as long as your account is active or longer if needed to provide you services, comply with our legal obligations, resolve disputes or enforce our agreements. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity. For instance, in respect of data held for the management of customers and prospects, we consider the lead time necessary to develop and maintain our commercial relationships and how recent our interactions are with you. We may rectify, update or remove incomplete or inaccurate information, at any time and at our own discretion.

Data Controllers and Contacting Us. The relevant controller for your information is set out below. Our “contact us” page contains e-mail links that allow you to contact us directly with any questions or comments that you may have. If you have any questions about this Privacy Policy or our privacy practices or to make a complaint about our compliance with applicable privacy laws, please feel free to contact us at contact@partoo.fr or at the relevant affiliates below. Where more than one entity is listed, please send your query to contact@partoo.fr

Data Contoller	Responsible for
Partoo Sas 130 rue du Mont-Cenis 75018 Paris	Commercial, IT, Care, Marketing activities around the globe
Localoo Hazte Ver, S.L.U. Carrer de Provença 339 08037 Barcelona, Spain	Commercial, IT, Care, Marketing in Spain and Portugal
PARTOO SOFTWARE PRIVATE LIMITED B Wing, Level 7, The Capital,G block BKC, Behind ICICI Bank,Plot C70,Bandra East,Mumbai, Mumbai City, Maharashtra, India, 400051	Commercial, IT, Care, Marketing in India