Privacy Policy Zealy
The purpose of this document is to inform you about the way in which your personal data will be processed when you use the services of Freyja Labs and its website https://zealy.io/ (hereinafter the “Website”).
Freyja Labs offers Users to create or join communities.
The Website is developed by Freyja Lab, a French simplified joint stock company having its head office in 1 Avenue du Champs de Mars CS 30019 45074 Orléans CEDEX 2 and registered at the Trade Register of the Chamber of Commerce of Orléans under n°913 157 103 (hereinafter “We” or “Freyja Labs”)
The terms defined with a capital letter shall have the same meaning as those defined in the Terms of Use which are accessible through the following URL link: link to the Terms of Service.
We also encourage you to read our cookie policy.
1. Purpose of the privacy policy
Anyone who browses our website, creates an account, uses our service, is concerned by the collection and processing of their personal data.
We have created this privacy policy (hereinafter the “Policy”) in order to inform you in a clear and transparent way about the Processing of your Personal Data.
Freyja Labs is the data controller (hereinafter the “Data Controller”).
We collect Personal Data from Users who browse our Website and/or have created an account. (hereinafter “You” or the “User”).
2. Purposes of the processing of personal data
“Personal Data” is any information relating to an identifiable natural person (data subject), an identifiable natural person is one who can be identified, directly or indirectly (by reference to an identifier such as a name, a number, a location data, online identifiers…
“Processing” is any operation which is performed on Personal Data (collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use…)
Your Personal Data is only collected when Freyja Labs has a legal basis for doing so.
The table below summarizes the purposes of Processing, categories of Personal Data, the legal bases and corresponding retention periods.
| Purpose | Concerned Data | Legal basis | Retention |
|---|---|---|---|
| Account creation and authentication |
| Performance of the Terms of Service between You and Freyja Labs | Until You delete your account or 3 years from your last contact with us |
| Account Personalization |
| Your consent | Until You delete your account, withdraw your consent or 3 years from your last contact with us |
| Administrator account management |
| Performance of the Terms of Service between You and Freyja Labs | Until you delete your account or 3 years from your last contact with us |
| Member account management |
| Performance of the Terms of Use between You and Freyja Labs | Until you delete your account or 3 years from your last contact with us |
| Improving our Website and Services |
| Legitimate interest | 25 months |
| Marketing | Administrator Contact information | Legitimate Interest | Duration of Your use of the Services increased by 3 years. |
In any event, we undertake to delete your Personal Data from our databases at the end of these various periods, subject to the retention of certain information for a period after the closure of your account to meet our legal accounting and tax obligations.
3. Who is your personal data transmitted to?
3.1. Freyja Labs employees
Authorized Freyja Labs employees have access to your information to ensure the correct operation of the website, to provide you with the service, to respond to your requests and to manage the commercial relationship with you.
3.2. Third party Services
When you use the services to interact with a third-party website, application or other software component, that third party may collect personal data about you. Freyja Labs is not responsible for this data collection and invites you to review the privacy policies of these third parties:
3.3. Cookie providers
Your personal data are transmitted to third parties depositing cookies on the website according to the choices made via the cookies banner and subject to your consent, under the conditions provided in the Cookies Policy.
3.4. Other providers
Our service providers also have access to your personal data during their provision of services to us.
These service providers include hosting and maintenance providers, IT developers and newsletter managers as well as payment service providers.
Freyja Labs undertakes to only communicate your information and Personal Data to authorized and trusted service providers, who process them on our behalf, according to our instructions and in accordance with this Privacy Policy and in compliance with any other appropriate security and confidentiality measures.
3.5. Community Administrators
Administrators of communities you have joined may also have access to your personal data in the course of their management of their communities.
4. Personal data transfers outside the European Union
Your Personal Data may be transferred outside the European Economic Area, in particular because of the use of services providers.
In this case, these transfers are carried out with appropriate guarantees to ensure a sufficient level of protection of privacy and fundamental rights, including the signing of standard contractual clauses adopted by the European Commission. A document listing the data transfers and guarantees implemented by Captain Data will be sent to you if you request it by e-mail to the following address privacy@zealy.io.
5. Your rights
You have certain rights regarding your Personal Data, as follows:
- Right of access: You have the right to access your personal data and supplementary information, subject to certain restrictions. This right allows you to be aware of and verify the lawfulness of the processing carried out.
- Right to rectification: You have the right to have personal data rectified, if it is inaccurate or incomplete. You can exercise this right directly from your account settings.
- Right to erasure: You have the right to request the deletion or removal of your personal data. It can be exercised when the processing of Personal Data is no longer necessary for the purposes for which they were collected or, if applicable, when you withdraw your consent to the processing.
- Right to restriction of the processing: GDPR You have the right to restrict the processing of your personal data in certain circumstances, such as
- where you have objected to processing of your data, or
- where you have contested the accuracy of your data. This means that you can limit the way that we use your data. This is an alternative to requesting the erasure of your data.
- Right to object to the collection and processing of all or part of your Personal Data: You have the right to object to certain types of processing of your personal data where this processing is carried out in connection with our legitimate interest. This right is not absolute and applies only to Personal Data collected for commercial prospecting purposes, including profiling when it is linked to commercial prospecting activities. When you choose to object to such processing, we ask you to indicate the reasons for your objection so that we can balance our legitimate interests against your request.
- Right to limit the processing of Personal Data. This right is not absolute, and can only be applied when:
- a request for rectification has been made under the right of rectification described in 8.2. You may then request that the processing of your Personal Data be stopped for the time necessary to verify the accuracy of the requested rectification.
- you wish to object to the deletion of your Personal Data whose processing was unlawful;
- Freyja Labs no longer needs the Personal Data in accordance with the purposes of processing, but they are still necessary for the establishment, exercise or defense of legal claims;
- You wish to exercise your right to object as described in section 8.5. You may then request that the processing of your Personal Data be stopped for the time necessary to balance our legitimate interests against your request.
- Right to data portability, i.e., to obtain, in a structured and machine-readable form, the personal data that you provided to us directly on the basis of your consent or on the basis of a contract with Freyja Labs, provided that such processing is automated.
- Right to define the handling of your personal data after your death and give instructions regarding whether Freyja Labs should communicate this data (or not) to a previously designated third party.
You may exercise the above-mentioned rights by contacting us at the following e-mail address: privacy@zealy.io
After contacting us, if you believe that your rights have not been respected, you also have the right to lodge a complaint before a data protection authority.
Before we can respond to a request to exercise one or more of your rights, we may ask you to confirm some of your Account information to verify your identity. In case of reasonable doubt, we may ask you for identification.
Freyja Labs undertakes to respond to your requests concerning the Privacy Policy or the exercise of your rights, as soon as possible and within one calendar month of receiving the request.
If your request is complex or you make more than one, the response time may be a maximum of three calendar months, starting from the day of receipt.
If you believe processing of personal data relating to you infringes your rights or data protection regulation You also have the right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés also known as CNIL.
6. Changes to this Privacy Policy
The privacy Policy may be amended and updated to reflect changes in Freyja Lab’s data protection practices, or to ensure compliance with regulations when they are amended.
In this case, we will set up a way to inform you of this change.