Privacy Policy

1) Introduction

This privacy policy (the “Policy”) informs users about how Tilkal, acting as data controller, processes their personal data when browsing the website www.tilkal.com (the “Site”).
Tilkal is a French simplified joint-stock company (société par actions simplifiée) with a share capital of €175,336, having its registered office at 91 boulevard de Sébastopol, 75002 Paris, France, and registered with the Paris Trade and Companies Register under number 828 499 988 (“Tilkal”).
When you browse the Site, Tilkal may, in the cases described in this Policy, collect certain personal data about you. As data protection is an important matter for us, this Policy is intended to inform you about how your data is used and about your rights regarding such data.
This Policy implements the rules applicable to the protection of personal data, in particular the principles set out in Regulation (EU) 2016/679 of April 27, 2016 (the General Data Protection Regulation, or “GDPR”) and French Act No. 78-17 of January 6, 1978, as amended (the “French Data Protection Act”).

2) About Tilkal

Tilkal is a software platform for traceability and transparency for manufacturers and brands, based on blockchain and big data technologies. All of its activities and products are presented on the website www.tilkal.com.
For any information regarding the operation of the Site, users are invited to consult the Site and, in particular, the Site's terms of use (the “Terms of Use”).

3) What data does Tilkal process?

In order to allow users to get in touch with Tilkal for further information, Tilkal may collect the last name, first name and email address of users who request to be contacted. When subscribing to the newsletter, Tilkal will collect the user's email address.
This information is collected through forms created and managed using the Plezi tool (newsletter subscription, demo request, document request).
Data relating to the user's activity on the Site is collected through the use of cookies.
When sending email communications (in particular newsletters), carried out using the Plezi tool, Tilkal also collects data relating to interactions with these communications, such as email opens and clicks on the links they contain, by means of a tracking indicator (tracking pixel) and tracking links.

4) Why and how does Tilkal collect users' data?

Tilkal processes users' personal data only for the purposes listed below, for which Tilkal has identified the applicable legal basis in accordance with current regulations:

1. To process and respond to contact requests and follow up on relationships with prospects and users expressing interest in Tilkal.
This processing is based on the explicit consent of the user requesting to be contacted. Requests for contact, demos or documents are collected through forms created and managed via the Plezi tool. The user may withdraw their consent at any time by contacting Tilkal by email.

2. To send users commercial communications and measure their effectiveness.
This processing is based on the explicit consent given by the user to receive such communications when subscribing to the newsletter on the Site, via a form managed by the Plezi tool. Email campaigns are also managed and sent using this tool.
In order to improve the quality of its communications, Tilkal measures email opens and clicks on the links they contain by means of a tracking indicator (pixel) and tracking links. This information is used in particular to assess campaign performance, improve their content, adjust their frequency and offer more relevant communications.
The user may withdraw their consent to receive these communications at any time by clicking on the unsubscribe link provided for this purpose. They may also object to the measurement of opens and clicks via the mechanism provided for this purpose in their communication preferences or by contacting Tilkal at the address indicated in this Policy. Such objection does not result in unsubscribing from communications.

3. To carry out aggregated statistical monitoring of Tilkal's activities and improve the Site and Tilkal's offerings.
This processing is based on Tilkal's legitimate interest, as data controller, Tilkal ensuring that this processing does not adversely affect users' privacy or, more generally, their prevailing fundamental rights and freedoms.

5) With whom does Tilkal share users' data?

Users' data is processed by Tilkal's internal departments.
Tilkal also uses Plezi, a marketing automation service provider, acting as a data processor for the management of email campaigns and the creation of contact forms (newsletter subscription, demo request, document request). Plezi is only authorized to process users' data on behalf of and in accordance with Tilkal's instructions, under a data processing agreement compliant with Article 28 of the GDPR.

6) How long does Tilkal retain users' data?

Tilkal retains users' personal data for the time necessary to achieve the purposes set out above, namely:
- For contact requests, for eighteen (18) months after the last contact;
- For email addresses collected upon newsletter subscription, the retention period is two (2) years from the last time the user expressed interest in the Site. At the end of this two (2) year period, the user's email address will be removed from the mailing list.
The data is then archived for the legal limitation period and subsequently deleted. When data is no longer necessary, Tilkal ensures that it is strictly deleted.

7) How does Tilkal ensure the security and confidentiality of personal data?

Protecting users' privacy and the security of their data is an important matter for Tilkal. In this regard, Tilkal has implemented technical and organizational measures to protect the personal data it processes and to prevent any incident likely to result in the loss, misuse, alteration or unauthorized disclosure of users' data.
Should such an event occur, Tilkal has implemented measures to react promptly and, where necessary, to inform the CNIL (the French data protection authority) and users in accordance with applicable rules.
Users' data is stored on a server in encrypted form.
Tilkal undertakes not to disclose users' data and to ensure that it is used solely for the proper operation of the Site.

8) Users' data and transfers outside the EU/EEA

Tilkal does not transfer any data outside the EU/EEA.
However, the service providers and any data processors used by Tilkal may transfer data outside the EU/EEA. Where applicable, Tilkal will ensure that such transfers are made on the basis of appropriate safeguards to ensure the security of users' data. As of the date of this Policy, the Plezi tool used by Tilkal hosts data within the European Union, such that no transfer outside the EU/EEA occurs in connection with its use.

9) What are users' rights and how can they be exercised?

Under the GDPR and the French Data Protection Act, users have certain rights that they may exercise at any time, subject to proof of identity, by contacting Tilkal at the following address: contact@tilkal.com

- Right of access: users may ask Tilkal to confirm whether their personal data is being processed and, where applicable, obtain information about the characteristics of the processing. If they wish, users may also obtain a copy of their processed data;
- Right to rectification: users may ask Tilkal to rectify, correct and update their personal data at any time;
- Right to erasure: users may ask Tilkal to erase their data in certain cases;
- Right to restriction of processing: users may ask Tilkal to restrict processing to the mere storage of their data, under certain conditions;
- Right to object: under certain conditions, users may object to the implementation of processing operations on their data. Users may also object, at any time, to the measurement of email opens and clicks carried out by means of a tracking pixel and tracking links. Such objection does not affect their subscription to Tilkal's communications.
- Right to data portability: users may ask Tilkal to provide them with their data in a structured, commonly used and machine-readable format, or to have it transmitted directly to another data controller, but only where the processing is based on the user's consent or on the performance of a contract entered into with Tilkal.

Users also have the right to define directives regarding the fate of their data after their death, as well as the right to lodge a complaint with the CNIL.

Finally, Tilkal informs users that it does not carry out any automated decision-making, including profiling, using users' data.

10) Cookies

Use of the Site may result in a cookie being placed on the user's device.
A cookie is a file consisting mainly of letters and numbers, of limited size, stored on the user's device.
A cookie may be placed on a user's computer in particular to record information relating to browsing, with the aim of improving the technical conditions of browsing and the user experience.
Users will always be informed before a cookie is placed. In addition, the user's consent will always be required before a cookie is placed, unless it is strictly necessary for the services offered on the Site or its sole purpose is to enable or facilitate electronic communication.
The Site uses cookies whose function is to facilitate and streamline users' connection to and browsing of the Site. These cookies are strictly necessary for the operation and security of our website.

Google Analytics and Matomo cookies: These cookies make it possible to obtain anonymous and aggregated traffic statistics for the Tilkal site in order to optimize its usability, navigation and content. You can easily object to their use via the cookie banner provided for this purpose.
However, users will not be able to disable cookies that are strictly necessary for the operation of the Site through this mechanism. To disable them, users must configure their internet browser accordingly. Nevertheless, this may affect the proper functioning of the Site.
Data collected using these cookies is retained for a maximum period of thirteen (13) months from the date they are placed on the user's device.

11) Changes to this Policy

Tilkal reserves the right to amend this Policy from time to time, in particular to take into account future legislative and regulatory developments as well as best practices. This Policy may also be amended to reflect any changes in the conditions of processing of users' data, or for any other reason Tilkal deems useful.
Tilkal will inform users of any material changes by all appropriate means.

12) Contacting Tilkal

For any question or complaint relating to this Policy, the processing of their data, or the exercise of their rights, users may contact Tilkal by writing to contact@tilkal.com