Your privacy is very important to us. Please read below to see how Plume Labs handles the information you provide when using your Flow device and its Application. Before you get to the details, here are a few of our fundamental privacy principles:
- Personal information you provide when logging onto the Flow Application and when using the device remains secure and confidential at all times. We do not sell it to any third parties.
- We aggregate and de-identify certain information, particularly air pollution data, generated by our users to to further climate change research and other business purposes. None of it is traceable back to you.
- Your personal information can not be viewed by any other Flow user.
- We give you several ways to control the privacy of your personal information and are continuously working to enhance privacy options available to you.
Plume Labs SAS is headquartered in Paris, France. Plume Labs SAS. is the controller of your personal data for the purposes of EU data protection law.
11 bis rue Bachaumont
1. Definition and nature of personal data
The term "personal data" encompasses any information that could be used to identify you, such as your name, your email address, your city, your geolocation, or any other information about yourself that you choose to share with us.
We collect and process your personal data in compliance with French law n°78-17 of January 6, 1978 on Information Technology, Data Files and Civil Liberties (hereinafter referred to as the “French Data Protection Act”), as well as the European Union’s General Data Protection Regulation (regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, hereinafter referred to as the “GDPR”).
3. Identity of the entity responsible for collecting data
The entity responsible for collecting and processing your personal data is Plume Labs SAS, a French simplified joint stock company (“société par actions simplifiée”) registered with the Registry of Trade and Companies of Paris under the number 803 473 974, whose head office is located at 11 bis, rue Bachaumont - 75002 Paris - FRANCE (hereinafter referred to as “Us” or “We”).
4. Basis for processing of personal data
- As necessary to provide our services through our Application;
- Your consent to our collection and processing of this data;
- A legitimate interest in providing and improving our Application on a sustained basis, and keeping the Application safe and secure.
Your personal data is processed to meet one or several of the following requirements:
- To manage your access to the services provided through the Application and their use;
- To maintain a file of registered members, users and customers;
- To send newsletters, updates and promotional advertisement (you have the possibility to opt-out of receiving such communications at any point);
- To generate service usage statistics that help provide and improve our services;
- To organize promotional games, sweepstakes or any promotional operation, (excluding gambling and online gambling);
- To collect customer reviews and feedback on products, services or contents;
- To customize our answers to your support requests;
- To fulfill our legal and regulatory requirements.
We will inform you, when collecting your personal data, whether some of these data are mandatory or optional. Mandatory data are necessary for the provision of our services. Optional data may help us provide you with a better service but you can use the Application without disclosing them.
5. Recipients of the collected data
Your personal data will only be collected by our employees and subcontractors.
We may preserve and share your information with third parties including law enforcement, public or governmental agencies, or private litigants if we determine that such disclosure is necessary to comply with the law, including to respond to court orders, warrants, subpoenas, or other legal or regulatory process.
6. Transfer or sale of personal data
Your personal data will not be sold, transferred or rented to a third party.
We may share your information with third parties and subcontractors who provide services to Plume Labs, such as supporting and improving the Application, promoting the Application, processing payments, or fulfilling orders. We may also engage service providers to collect data about your usage of the Application on our behalf, for statistical purposes or so that we or they may promote Plume Labs.
These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We ensure that we have clear data protection requirements for all of our third party providers.
7. Personal data storage period
7.1 Data on current and potential customer management
Your personal data shall be stored no longer than the time strictly necessary for the management of our commercial relations with you. However, any data providing the proof of a right or a contract and that must be stored in compliance with a legal obligation shall be so for the period stated by the legislation currently in force.
Personal data collected in the context of potential promotional operations may be stored for a period of three years from the end of the commercial relations with you.
Personal data relating to potential customers may be stored for a period of three years from their collection or the last contact from the potential customer.
Beyond that three-year period, we may contact you again to find out if you still wish to receive commercial solicitations.
7.2 Identity documents
When exercising your right of access or correction, data relating to identity documents may be stored for the time limit provided for in article 9 of the French Criminal Procedure Code, namely one year. When exercising your right to object, these data may be archived for the limitation period provided for in article 8 of the French Criminal Procedure Code, namely three years.
7.3 Management of opt-out systems
All information taking into account your right to object shall be stored for at least 3 (three) years from the exercise of this right.
We take your privacy very seriously. As a consequence we take all necessary precautions, as well as all appropriate organizational and technical measures, to maintain the security, the integrity and the confidentiality of your personal data, and to prevent that they be distorted or damaged and that they be accessed by unauthorized third-parties.
We inform you that your personal data are stored, for the term set forth above, on the servers of the companies OVH SAS and Amazon Web Services, both located in the European Union.
Your personal data shall remain within the European Union or other countries providing an adequate level of data protection (such countries being selected by the European Union).
11. Access to your personal data
In compliance with the French Data Protection Act and the GDPR, you have the right to access and rectify any information about you. You can exercise this right and get access to the information about you by contacting us at the:
- Email address: firstname.lastname@example.org
- Postal address: 11 bis, rue Bachaumont - 75002 Paris - FRANCE
12. Right to define instructions related to the processing of data after your death
You have the right to define instructions with regard to the storage, the erasure and the communication of your personal data after your death.
These instructions may be general directions, which are focused on all personal data concerning you. In such case, they must be registered with a digital trusted third party certified by the French data protection authority (CNIL).
These instructions may also be specific to the data processed by our company. You are then required to provide these instructions to us at:
- Email address: email@example.com
- Postal address: 11 bis, rue Bachaumont - 75002 Paris - FRANCE
By providing to us these instructions, you hereby expressly consent that they be stored, transmitted and carried out on the terms and conditions set forth herein.
You have the right to appoint in your instructions a person in charge of their execution. After your death, this person shall be entitled to take knowledge of these instructions and to request to us their implementation. Failing such appointment, your heirs shall be entitled to take knowledge of these instructions and to request to us their implementation.
You may modify or revoke your instructions at any time, by writing to us at the abovementioned contact addresses.
13. Portability of your personal data
You have a right to portability of the personal data you have entrusted to us, understood as the data you have actively and deliberately declared when accessing to and using our services. You are reminded that portability right does not apply on data that were processed on a basis other than consent or the execution of a contract between us.
This right may be exercised free of charge, at any time, including when closing your account on the Application for instance, so that you may recover and store your personal data.
In this context, we shall provide your personal data, by any appropriate means, in an open standard, currently used and machine-readable format, in compliance with the state of art.
14. Complaints to the Data Protection Authority
If you are European Union resident, you are informed that you may lodge any complaints on the manner in which we handle your personal data with your local supervisory authority.
15. Restriction of processing
You have the right to obtain restriction on the processing of your personal data where one of the following applies:
- Within the period of verification that we carry out, if you contest the accuracy of your personal data;
- When the processing of these data is unlawful and you request the restriction of this processing, instead of erasing your data;
- When we no longer need your personal data, but you require their maintenance for the exercise of legal claims;
- Within the period of verification of the legitimate interests, if you have objected to the processing of your personal data.
17. Entry into force