Version dated October 8, 2024This Privacy Policy applies to the website www.navlead.com and the NavLead application, the use of which implies full acceptance of these terms and the General Terms of Service available on said website, which refer to this Policy.The capitalized terms in this Policy are defined in the General Terms and Conditions of Sale available on the website www.navlead.com and in the NavLead application.

‍1. Principles of what NavLead does

‍As part of its activity, NavLead collects, stores, and processes personal data provided via www.navlead.com and through the NavLead application by entrepreneurs and professionals (natural persons), such as identity and contact details, billing data, login credentials, IP addresses, hyperlinks, VAT numbers, bank details, and information related to users profiles through www.navlead.com or the NavLead application (hereinafter referred to as the “Site”).The primary objective of this document is to present in a concise, transparent, understandable, and easily accessible format how your data is processed, allowing you to understand the conditions under which your data is handled.NavLead complies with the obligations arising from the European Regulation No. 2016/679 on the protection of personal data (also known as the “GDPR”) and the national laws implementing it in the countries where NavLead operates. NavLead also ensures compliance with France’s “Informatique et Libertés” law dated January 6, 1978, as amended by Law No. 2004-801 of August 6, 2004.NavLead is committed to collecting only the data necessary to provide optimal service, ensure confidentiality and security, and facilitate the exercise of your rights over your data, including when working with service providers.NavLead may also track your behavior on the Site for purposes such as user support, analysis, research, service development, fraud prevention, risk assessment, regulatory compliance, investigation, and to enable you to use and access the Site.Data is collected lawfully, and no data is collected without informing the individuals involved.When NavLead processes data, it does so for specific purposes: every data processing operation has a legitimate, determined, and explicit purpose.For each processing operation, NavLead commits to only collecting and using data that is adequate, relevant, and limited to what is necessary for the purposes defined.

‍2. Data Controller

‍The data controller for the personal data collected is Wydin, a simplified joint-stock company with a capital of €10,000, registered under number 921 024 188 with the Paris Trade and Companies Register, with its headquarters at 13 rue de Naples, 75008 Paris, represented by its President at that address.The data controller can be contacted either by mail at its headquarters address or by email at contact@navlead.com.

‍3. Data that may be collected

‍NavLead does not process special categories of data (sensitive data) such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, or data concerning the sexual life or sexual orientation of individuals.In the context of your use of the services of the Site and your navigation on the Site, NavLead may collect and process several categories of data, either from data you provide on the Site or information resulting from your use of the Site, as detailed below:Identification data: such as title, first and last names, electronic, phone, and postal contact information, photos, ID card data.Professional data: such as profession or professional contact information.Economic and financial data: such as bank details, VAT numbers, billing data, accounting contacts.Navigation data: such as login data and logs, IP address, necessary cookies, and other cookies (refer to the cookie policy available in the Site’s Terms of Use).Transaction data: such as identification and contact details of the users, amounts and services concerned, transaction frequency.Data related to interactions with our NavLead teams: such as the content of exchanges, their duration, and follow-up.Statistical data: such as data on the connection and navigation data, usage data of the Site’s modules, and commercial data like completed transactions.Feedback and review data: such as user comments on the Site.

‍4. Purposes of data processing

‍The data collected allows NavLead to provide, administer, protect, and improve its services, develop new ones, offer technical support, manage production and subscriptions, evolve its services, and protect both Site USERS and NavLead itself from fraudulent use of the Site.Collected data is also processed to provide NavLead with information necessary for performing its online intermediary service, fulfilling legal and regulatory obligations, conserving, publishing, and archiving production records, and for NavLead’s legitimate business interests.Data is only used for the purposes for which it was provided.

‍5. Recipients of the data

‍The recipients of the data collected are exclusively Wydin, authorized Wydin members, and anyone acting on behalf of Wydin within its online intermediary activity (such as payment service providers or Site hosting providers).NavLead applies an access control policy that ensures data is shared only with authorized personnel.When NavLead uses a service provider, personal data is shared only after obtaining a commitment and assurances from the provider regarding security and confidentiality.NavLead may share user data to respond to information requests from investors, accountants, or auditors, especially during potential fundraising or to verify the use of funds raised, or to ensure legal and regulatory compliance of NavLead and the Site.NavLead retains or discloses information if it reasonably believes it is necessary to meet legal or regulatory obligations, court orders, administrative requests, protect a person’s safety, address fraud, security, or technical issues, or protect users’ rights or property.

‍6. Data storage location

‍The data collected is stored on servers located in France and/or within the European Union.

7. Data retention period

‍NavLead may retain personal data for the necessary duration of the operations for which the data was collected, as follows:Up to ten years after the last contact between NavLead and the user to comply with accounting, social security, and tax reporting obligations.Up to five years after the last contact for other cases.

‍8. Data security

‍NavLead implements appropriate technical and organizational measures to ensure the security, confidentiality, integrity, availability, and resilience of the information system used by the Site and your data, and to protect processed data from destruction, loss, alteration, unauthorized disclosure, or access.NavLead commits to deploying all reasonable means to ensure the security and confidentiality of your data, including:Encrypting most of its services using TLS/SSL technology.Verifying your email address upon account creation.

‍9. Your rights

‍Users whose personal data is collected have the following rights:The right to access personal data collected.The right to object to the processing of their data.The right to request the limitation of the processing of their data.The right to request access, rectification, deletion, or portability of their data.The right to withdraw consent regarding the collection and processing of all or part of their personal data.The right to provide instructions regarding the handling of their data after death.Users may exercise their rights by sending a request accompanied by a copy of an identity document certified as true to the original, dated, and signed, to contact@navlead.com or by post to Wydin, 13 rue de Naples, 75008 Paris, FRANCE.Requests that do not meet this formal requirement will be considered potentially fraudulent, and Wydin is not obliged to respond.

‍10. Account deletion / Subscription termination

‍The USER’s account on the NavLead Site can be deleted at any time by the USER. Account deletion leads to the permanent and irreversible erasure of the account and all its contents.However, the deactivation or deletion of the account during an active subscription does not terminate the subscription before its expiry, and the monthly subscription fee remains due until the subscription term ends.The termination of the subscription, or the deactivation or deletion of the account, does not automatically erase the personal data collected in connection with the subscription or account, which will be retained and managed for the indicated retention period, though you can request early deletion as mentioned in section 9 above.

‍11. Amendments

‍NavLead reserves the right to modify this Privacy Policy at any time. The most current version governs the use of your data and is available at www.navlead.com and on the NavLead application.If NavLead makes substantial changes to this policy, it will notify you via the email address you provided on the Site.

‍12. Clarifications, questions - Complaints

‍If you would like clarification or have any questions about this Privacy Policy, please contact us at: contact@navlead.comIf, after contacting us with a request accompanied by a certified copy of an identity document as mentioned above, you do not receive a response within 15 days, or if you feel that your “Informatique et Libertés” rights are not respected, you may file a complaint with the CNIL.In the absence of a satisfactory resolution by CNIL, the complaint may be brought before the Paris Commercial Court by Wydin or the user.

‍13. Applicable law

‍This Privacy Policy, its conclusion, execution, interpretation, termination, and any related matters are subject to French law.