Last Updated August 30th, 2022
Gavekal-IS requires that you provide current and accurate personal information. Gavekal-IS will protect the information you have provided in a manner that is safe, secure and professional. Gavekal-IS and its employees are committed to protecting your privacy and to safeguarding the information we receive from you via our website at www.gavekal-is.com (the “Site, our support platform, mobile applications and tools and services offered on the Site and mobile application (together the “Services”). This Privacy Policy explains our information practices, the kinds of information we may collect, how we use and share that information, and how you can opt-out of a use or correct or change that information. This Privacy Policy is incorporated by reference into Gavekal-IS’ Terms of Service (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms.
As used in this Privacy Policy, the term “Personal Information” shall mean any information relating to an identified or identifiable natural person, including, but not limited to, such person’s first and last name, or email address. This Privacy Policy applies to Personal Information that Gavekal-IS collects and processes in the course of our business, including on the Site and the Gavekal-IS platform, but excludes all users’ email data. This Privacy Policy also describes the choices available to you regarding our use of your Personal Information and how you can access, update and request deletion of this information. The use of information collected through the Services shall be limited to the purpose of providing the service for which Gavekal-IS’ client has engaged us. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.
Gavekal-IS complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.
This Privacy Policy applies to all of Gavekal-IS’ operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch of Gavekal-IS that we may subsequently form.
When you create an account, use the Services, request services or information, or contact us directly, we may ask you to provide some or all of the following types of information:
3.1 Account Information:
When you register to use the Services with an email address, we collect your full name, company or organization name, email address and password you create. When signing up for a paid plan, Gavekal-IS will also collect credit card information and use a third-party intermediary to manage credit card processing. This intermediary adheres to the PCI-DSS standards and is not permitted to store, retain, or use your billing information except for the sole purpose of credit card processing on Gavekal-IS’ behalf.
3.2 Communications with Us.
When you contact us inquire about the Services, request customer service or technical support, or request other information, we may collect your name, email address, phone number or mailing address. We may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
3.3 Posting on the Site.
Gavekal-IS offers a community forum in which you may post information on a publicly accessible site. If post information on the community forum, it will be publicly accessible.
3.4 Automatic Data Collection.
As is true of most websites and mobile applications, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, mobile device identifiers, and advertising identifiers. We use this information, which does not identify individual users, to analyse trends, to administer the Site, to track users’ movements around the Site and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personal information.
We, as well as third parties that provide content, analytics, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.
For detailed informations about cookies, see our cookies policy.
We acquire, hold, use, and Process Information for a variety of business purposes, including:
5.1 To Provide Services or Information Requested by Clients.
Gavekal-IS may use Personal Information to provide the Services, fulfil requests for products, Services, or information, including information about potential or future Services.
5.1.1 Administrative Purposes.
Gavekal-IS may use Personal Information about you for its administrative purposes, including to:
5.2 Marketing Gavekal-IS Products and Services to Clients.
Gavekal-IS use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described below.
5.3 Research and Development.
Gavekal-IS may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services.
5.4 Anonymous and Aggregated Information Use.
Gavekal-IS may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Gavekal-IS’ Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Gavekal-IS may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Gavekal-IS and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
5.5 Other Uses.
Gavekal-IS may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
Gavekal-IS does not sell or otherwise disclose Personal Information about you, except as described in this Policy or as you explicitly consent to. We may share your information as described in this Privacy Policy:
6.1 Vendors and Service Providers.
We may share Personal Information we receive with vendors and service providers only as necessary to provide the Services to us. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site.
6.2 Business Partners.
Gavekal-IS may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Gavekal-IS may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Gavekal-IS. Gavekal-IS requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Gavekal-IS provided them.
6.3 Displaying to Other Users.
If you post content to the community forums, it may be displayed publicly on the Site.
6.4 Interest-Based Advertising and Third-Party Marketing.
Gavekal-IS may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day).
6.5 Social Media Widgets.
Our Site may include social media features, such as the Facebook Like button and widgets, such as the ‘Share This’ button or interactive mini-programs that run on our Site. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
6.6 Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures).
We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce Gavekal-IS policies or contracts; (v) to collect amounts owed to Gavekal-IS; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
6.7 Merger, Sale, or Other Asset Transfers.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Gavekal-IS will endeavour to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.
6.8 Privacy Shield.
With respect to transfers to third parties that process Personal Information pursuant to our instructions, Privacy Shield requires that Gavekal-IS remain liable should its vendors and service providers process Personal Information in a manner inconsistent with the Privacy Shield Principles.
6.8 Data Transfers
We may store all Personal Information we collect anywhere in the world on our servers, on the servers of our affiliates or the servers of our service providers.
6.9 Data Retention
Gavekal-IS will retain your information for as long as your account is active or as needed to provide you services. We will also retain personal data we process on behalf of our clients for as long as needed to provide services to our client. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
7.1 Email and Telephone Communications.
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. You will continue to receive transaction-related emails regarding products or services you have requested and administrative communications, such as updates to the Terms or this Privacy Policy. We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
7.2 Mobile App Push Notifications and Location Data.
Our mobile app may occasionally send you push notifications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Gavekal-IS may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
7.3 “Do Not Track”.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honour DNT signals or similar mechanisms transmitted by web browsers.
7.4 Cookies and Interest-Based Advertising.
You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://preferences-mgr.truste.com/, and www.aboutads.info/choices/(or if located in the European Union at http://www.youronlinechoices.eu/). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
7.5 Rights of Access, Rectification, Erasure, and Restriction.
You can modify, update, or delete your account information at any time by clicking on the Login icon in the global navigation bar at the top right of the site screen or by contacting us at contact@gavekal-is.com. You may inquire as to whether Gavekal-IS is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information for any reason by contacting us at contact@gavekal-is.com. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws. We will respond to any requests for access to Personal Information within 30 days.
7.6 Data Controlled by Clients.
We process information at the direction of our clients. An individual who seeks access, or who seeks to correct, amend, or delete data that is processed by Gavekal-IS for its client should direct his query to contact@gavekal-is.com . If the client requests Gavekal-IS to remove the data, we will respond to their request within 30 business days.
The Service and Site are not intended for, nor does Gavekal-IS knowingly collect any personal information from children under the age of 16. If you have reason to believe that any Personal Information from any children under the age of 16 has been collected or submitted to Gavekal-IS for any reason, please notify Gavekal-IS at contact@gavekal-is.com, and Gavekal-IS will seek to remove such information as soon as practicably possible.
The security of your Personal Information and our clients’ information is important to us. Gavekal-IS maintains reasonable security measures to protect your information from loss, destruction, misuse, unauthorized access or disclosure. When you enter sensitive information, such as a credit card number, on our order forms and login credentials on our platform login page, we encrypt the transmission of that information using secure socket layer technology (SSL). These technologies help ensure that your data is safe, secure, and only available to you and to those you provided authorized access. However, no data transmission over the Internet or information storage technology can be guaranteed to be 100% secure due to the nature of the distributed network that is the Internet. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at contact@gavekal-is.com.
Our site includes links to other Sites whose privacy practices may differ from those of Gavekal-IS. If you submit Personal Information to any of those sites, you acknowledge that Gavekal-IS has no control over such third-party websites, and your information is governed by their privacy policies. Given the fact that Gavekal-IS has no ability to exercise control over such third parties, you agree that Gavekal-IS shall not be held liable for any claims related to your interaction with, or delivery of personal or other information to, such third-party websites.
In compliance with the Privacy Shield Principles, Gavekal-IS commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Gavekal-IS at the address listed at the bottom of this privacy policy.
Gavekal-IS is committed to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs or Swiss FDPIC for more information or to file a complaint. The services of EU DPAs and Swiss FDPICs are provided at no cost to you.
Gavekal-IS may update this Privacy Policy from time to time. You can review the most current version of this Privacy Policy at any time at www.gavekal-is.com. Your continued use of the Site or Services constitutes your agreement to be bound by such changes to the Privacy Policy. Your only remedy, if you do not accept the terms of this Privacy Policy, is to discontinue use of the Site and Service. If we make any material changes, we will notify you or our client by email sent to the e-mail address on your account or by means of a notice on the Site prior to the change becoming effective.
If you have questions regarding this Privacy Policy or about the security practices of Gavekal-IS, please contact us by email at contact@gavekal-is.com.
Gavekal Intelligence Software
27 bis rue Copernic
75116 Paris
France
