The purpose of the Privacy Policy hereto is to inform you in a comprehensive and transparent way, on the use the Company WINGMIND (hereinafter the “Company”) makes of your personal information.

The personal data that the User can be brought to share with the Company is collected and processed by the Company in accordance with the French Data Protection Act of 6 January 1978 and the General Data Protection Regulation of 27 April 2016 (“GDPR”).

The Company commits to getting the Users’ consent and/or enable them to decline to their information being used for certain purposes, as soon as it is necessary.

Article 1: Purpose of Processing the User’s Personal Data

Personal Data collected is primarily processed by the Company (and the subcontractors acting on its behalf) and its authorised partners for the purpose of:

  • creating an Account on the Website;
  • ensuring the maintenance and the authentication of the User Account;
  • enabling the user to benefit from the services offered on the Website;
  • Enabling the User to access the TEAM Index, MyTEAM Index, WISDOM Index, MANAGEMENT Index, SCAN BUSINESS, and WINGMIND Alpha questionnaires;
  • Performing the TEAM Index, MyTEAM Index, WISDOM Index, MANAGEMENT Index, SCAN BUSINESS, and WINGMIND Alpha services;
  • Ensuring the monitoring and the sorting of the answers to the TEAM Index, MyTEAM Index, WISDOM Index, MANAGEMENT Index, SCAN BUSINESS, and WINGMIND Alpha questionnaires;
  • processing requests made on the Website of any nature whatsoever (information request, User information amendment request, first contact with an advisor, complaint);
  • Addressing newsletters, general and/or commercial information, reports, forms, and anonymized insights derived from WINGMIND Alpha to the User;

Subsidiarily, User data are also collected to:

  • preventing and fighting against online fraud (spamming, hacking, etc.)
  • improving the navigation on the Website;
  • collecting information to improve the Website (particularly with the use of cookies)
  • carrying out statistical studies;
  • complying with applicable legislation.

 Article 2: Personal Data Collected

When you use Services offered on the Website, you can be asked to give us the following information that we process in accordance with the purposes defined in Article1: your full name, address, email address, phone number, business title, the number of employees in the company.

The collection of certain personal data is compulsory to provide the Services of the Website and enable the authentication of the User.

As part of the TEAM Index, MyTEAM Index, WISDOM Index, MANAGEMENT Index, SCAN BUSINESS, and WINGMIND Alpha questionnaires, the company WINGMIND may collect specific data about you, contained in your responses to the questionnaires proposed by the Company.

In the context of the WINGMIND Alpha questionnaire, all responses collected will be anonymized and aggregated in the final report, and no identifiable information will be included.

Article 3: Recipient of collected personal information

Only WIGMIND and its potential subcontractors are the recipient of your personal data.

We strictly request from our subcontractors that they use personal data only to manage the services that we ask them to provide and they cannot by any means, sell the personal information collected.

We also require that our subcontractors act in compliance with applicable laws with regards to personal data protection and to pay particular attention to the confidentiality and security of such data.

Your personal information can be shared in accordance with a law, a regulation, a decision from a regulatory or judicial authority and finally, if necessary, for WINGMIND to preserve its rights and interests.

Article 4: Retention Period and Storage of Personal Data Collected

Your personal information is kept by the company WINGMIND for a period of time that does not exceed the necessary period of time for the purposes for which they were collected as indicated in Article 1 and such period cannot exceed 12 months.

Your personal data are either stored on our databases or on those of our subcontractors, which are located within the European Union.

We attach great importance to the security of your data.

This is the reason why we initiate all appropriate measures to avoid to the extent possible, any alteration or loss of your data or any unauthorised access thereto.

Article 5: User Rights

Under applicable European legislation, you have the following rights:

  • right of access and communication of data,
  • right of amending and  updating;
  • right to withdraw a consent at any time;
  • right to refuse, for legitimate reasons, that your personal information be processed;
  • right to limit the processing and the portability of your data;
  • right to make a complaint to the CNIL;
  • data portability rights with regards to data given by Users when the processing of such data is automated and based on Users’ consent or on a contract;
  • right to determine the outcome of User data upon death and to choose if WINGMIND should communicate (or not) any data to a designated third party;

These rights can be exercised by contacting the Company at the following email address: contact@wingmind.co

Article 6: Cookies

In addition to personal information, the Company also uses cookies and web beacons as part of the supply of Services offered on the Website and more generally to connect and browse the Website.

Cookies are files sent to your browser and saved on the computer hard drive.

The cookies used by the Company record information relating to the navigation of the computer on the Website (pages browsed, date and time of browsing, etc.) that the Website will be able to read during subsequent visits.

The information collected does not identify the User personally.

These cookies are used by WINGMIND to:

  • enhance the navigation on the Website as then enable to display inputted information as part of the use of an Account during the last connection;
  • carry out statistical studies with regards to Site use (number of sessions, connection time, etc.) and to measure the traffic on the Website.

During your first connection to the Website, you are informed by a banner that the information relating to your browsing may be recorded in files called “cookies”.

The use of cookies is widespread on the Internet.

However, you have the right to refuse at any time to their use by configuring your browser preferences on your computer so as to no longer accept cookies.

Nevertheless, if you refuse or deactivate cookies, you will no longer have the possibility to (i) access certain parts of the Site or (ii) use certain Services.

In such cases, WINGMIND shall bear no liability for the consequences of the partial operation of the Website and of the services potentially proposed by WINGMIND, resulting from (i) the User refusing cookies (ii) the impossibility for WINGMIND to record or access the necessary cookies for their operation because of the User’s choice.

For the management of Cookies and user choices, the configuration of each browser is different. It is described in the help menu of your browser, which will tell the User how to modify his preferences in respect of Cookies.

At any time, the User can decide to give and modify his choices in respect of Cookies.

Finally, by clicking on the social network icons for Twitter, Facebook, Linkedin and Google Plus on WINGMIND’s Website or on its mobile application, if the User has accepted the storage of cookies by pursuing the navigation on the Website or the mobile application of WINGMIND, Twitter, Facebook, Linkedin and Google Plus can also store cookies on your devices (computer, table, mobile phone).

These types of cookies are only stored on your devices if you have consented to them, by continuing to browse the Website.

At any time, the User can nevertheless withdraw his consent for WINGMIND to store cookies.

Article 7- Data Processing Officer

The personal data processing officer is: David CHOURAQUI / contact@wingmind.co

As a data processing officer or as a subcontractor, WINGMIND takes the proper measures to ensure the protection and the confidentiality of any nominative information it retains or processes in accordance with the provisions of the French Data Protection Act and GDPR.

Article 8- Privacy Policy Changes

 The privacy policy hereto can be the object of regular revisions and updates, particularly for technical reasons and/or to comply with applicable regulation. We therefore invite you to regularly review the privacy policy for any modifications