Data Protection Charter

Date of last update: 01/10/2023

Data Collection and Processing Responsibility

The entity responsible for the collection and processing of data on the website of KOALIS S.A and/or for services provided by KOALIS S.A is KOALIS S.A, located at 2405 Route des Dolines, 06560 Valbonne. The Data Protection Officer (DPO) designation number is DPO-XXX. The DPO can be contacted by mail at the following address: KOALIS S.A, 2405 Route des Dolines, 06560 Valbonne, Data Protection Officer, and by email at dpo@koalis.net. This charter on personal data and its management allows us to explain in more detail how we collect, process, and store data, as well as the rights you have regarding this data.

Applicability of the Charter

This charter applies in particular to customers and users of the offers and services and to visitors to the KOALIS S.A website. It may be supplemented at any time by specific information that will be brought to your attention, concerning an offer or a new service. You are completely free to browse this site, provided you accept the General Terms of Use and Sale (CGUV) to access the services as well as the rules regarding the processing of your personal data and our cookie practices.

What Data is Collected by KOALIS S.A?

Personal data is any information that allows you to be identified directly or indirectly, which includes but is not limited to your name, first name(s), date of birth, age, gender, postal address, email address, or phone number. Depending on the case, KOALIS S.A processes your personal data, which is directly collected from you or results from the use of services. KOALIS S.A may also receive data collected from you by a third-party provider related to clairvoyance.

KOALIS S.A collects and processes the following categories of data:

• Identification data: name, first name
• Personal characteristics: date of birth, time of birth, place of birth
• Contact data: postal address, email, landline, and mobile phone number
• Personal life: profession, marital status
• Economic and financial data: payment methods, payment history, payment card (first six and last four digits)
• Connection data, service usage: connection logs, acceptance of General Terms, acceptance of the Charter, acceptance of data collection and processing, beep during telephone consultation
• Data for probative purposes: recordings of calls made to the Customer Relations Center and requests from Clients and Prospects, including at the Switchboard, Quality Service, Dispute and Collection Service, email exchanges, and/or any element you send to KOALIS S.A

Purpose of Data Collection

Personal data is collected for the execution of services offered, clairvoyance services via telephone, and to keep the client informed within the scope of services, offers, and information related to clairvoyance.

When creating a client profile (online and during phone calls), various information will be requested to identify you. This may vary depending on the medium used (internet, partner site offer, phone). The information required includes: your name, first name, phone number, email address, physical address, date of birth, city of birth, time of birth, profession, confirmation that you are not subject to a protection measure, and your payment card information, which is immediately encrypted.

Data Collected During Connection and Profile Use

During the user's connection to the Site, the IP address, connection logs, validation logs of the General Terms of Use and Sale, acceptance logs of the charter, and logs related to consent for the use of personal data are recorded. The use of services on the Site (including those of partners) allows for a profile to be filled, which may include an email address, phone number, date of birth, and gender (female/male).

Cookies Usage

Cookies are used when using the website. The user can disable cookies at any time from their browser settings. For simple browsing of the site, you do not need to provide us with personal data, except for the IP address and navigation/cookie data.

Do not disclose more information about yourself than necessary and ensure that this information is relevant and directly related to the purpose of the Site or solution. Do not share sensitive information, such as data about your philosophical, political, union, or religious opinions, sexual orientation, or health. Do not disclose personal information about a third party without their consent.

Why Does KOALIS S.A Collect and Process Your Data?

The collection and processing of your data allow us to execute the services you want to benefit from (including clairvoyance consultations), offer personalized services, and commercial offers that may interest you for a better understanding of your expectations and requests. More specifically, data processing by KOALIS S.A and its partners has the following purposes:

Welcome, Identify, and Ensure Services:

• Manage access and identity of the user/client and authenticate them
• Verification and authentication of data provided by the client
• Operate the Customer Relations Center (phone reception - switchboard and support - guidance up to the clairvoyance consultation)
• Manage call follow-up: when you contact our Customer Relations Center, KOALIS S.A and its partners use an automatic phone number detection system to save you time, as well as our Customer Relations Center

Satisfy and Support:

• Ensure Quality and Collection Service to take into account your feedback, your incoming mail, emails, and also assist you in finding solutions in case of payment difficulties
• Recover unpaid debts
• Manage access and use of clairvoyance services (Customer Relations Center) for subscribing to clairvoyance consultations
• Store customer or user data in the context of KOALIS S.A and its partners' business activity
• Manage requests related to the rights of individuals concerned
• Communicate for customer management purposes
• Invoice and collect payments
• Ensure Litigation Service: manage any disputes with clients and judicial requisitions

Secure:

• Prevent and detect fraud, malware (malicious software), and manage security incidents
• Manage telephone recordings for quality and probative purposes: calls may be listened to in real-time or recorded for training or service quality control purposes and security. This includes using recordings for processing complaints and detecting fraud. Recordings are kept for a limited time and then automatically destroyed unless KOALIS S.A and its partners have a legitimate interest in retaining a recording for a longer period, including in the context of a fraud investigation and for legal purposes

Communicate:

• Newsletter subscription
• Personalize services by displaying advertisements based on the user's browsing history, according to their preferences
• Manage the website's operation and optimizations - e-marketing activities: we use your data for marketing purposes. These activities include:
  • Using your contact information to send you regular information about services related to clairvoyance. You can easily unsubscribe from these marketing communications at any time by clicking the "Unsubscribe" link found in all our newsletters and communication materials.
  • Personalized offers, created from your information, may be offered to you, mobile applications and third-party websites/apps (including social networks), and the content displayed to you on the site may also be personalized. These may include offers from KOALIS S.A, KARABA MARKETING DIGITAL

Store and Archive Data:

• Store and archive customer or user data to meet legal obligations; regional websites or other offers provided by partners that may interest you
• When participating in other promotional activities (such as contests), certain information will be used to properly manage these activities

We may also contact you on other occasions by email, mail, phone, or SMS, depending on the contact details you have previously provided us. We also process requests you send us, in particular, for the following reasons: information requests, consultations, appointment bookings, and to take advantage of offers. If you have not completed your call or received a response within a reasonable time, we may contact you to remind you of your request and assist you. When you use our services, we may send you a questionnaire or invite you to leave a comment about your experience. We send you other information about your consultations, such as summaries, appointment reminders, offers, CGUV, invoices;

Improvement of Services

We also use personal data for analytical purposes to improve our services, user experience, operation, and quality of our services, as well as to perform tests and solve problems.

Personalization of Services

Personalization of services by displaying advertisements based on the user's browsing history, according to their preferences.

Who Has Access to Your Data?

The data collected is intended for the internal services of KOALIS S.A and its subcontractors to support the execution of the Services, including trusted third parties for payment card payments, hosting providers, email service providers, fraud detection specialists, and authentication services.

Data may also be processed by partners of KOALIS S.A. This concerns situations where partners intervene in the provision of services. It may also concern processing for which you are asked to consent.

Guarantees Provided by KOALIS S.A for Your Data

Collection Principle

These data are collected through the various forms on our website and during your interactions with the Customer Relations Center in a completely transparent manner. The mandatory nature of the information to be filled in is generally indicated by an asterisk. In their absence or if they are not duly completed, KOALIS S.A will not be able to provide the requested service. The same applies to data collected by telephone.

Retention Period

KOALIS S.A does not retain your data longer than necessary. The retention period is related to the service with which they are associated and, in any case, for the duration of the business relationship and/or tax, accounting, management of potential disputes, recovery needs, criminally reprehensible activity, and to prevent possible illicit behavior, to conduct satisfaction surveys and ensure file compliance. This collection is carried out in compliance with the law, declarations previously made to the CNIL, and the General Data Protection Regulation (GDPR), concerning clients and prospects. We do not collect unnecessary data or in excessive quantity. Data is also subject to duly declared intermediate archiving to meet legal, accounting, and tax obligations.

Security and Confidentiality

We ensure the security of your data as well as ours. The data collected by KOALIS S.A and its partners are stored in a secure environment inaccessible to the public to prevent unauthorized access, use, loss, modification, destruction, or disclosure. All our data is backed up and stored as long as necessary to manage the business relationship and secure the rights of Users/Clients and KOALIS S.A. KOALIS S.A undertakes to implement and maintain, at its expense, an appropriate IT security program, taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of the processing of personal data and the risk (of varying probability and severity) to the rights and freedoms of Users/Clients. This program includes rigorous technical and organizational measures. Only authorized and qualified personnel within KOALIS S.A and its partners (qualified personnel, hosting provider) have secure access to your data. Technical and organizational measures may benefit from technological advances and future developments. Therefore, KOALIS S.A is authorized to use any appropriate alternative measures in this regard. However, these alternative measures should not provide a lower level of security than that provided by the laws for such measures. All significant changes must be properly documented and notified to the Client.

Are Your Data Processed Outside the EU?

Due to the organization of KOALIS S.A, the user/client authorizes the Site to transfer, store, and process their information within the European Union. By using the Site and telephone services, the user consents to the transfer of their personal data under these conditions. The data collected may be processed outside the European Union concerning hosting providers (including Google Cloud and Amazon Web Services). In this case, KOALIS S.A takes the necessary steps with its subcontractors and partners to ensure an adequate level of protection for your data and in full compliance with applicable regulations. The user/client also authorizes the Site to transfer only the information listed below to its subsidiaries and partners outside the EU. In any case, the said data could not identify you, namely: first name, date of birth, and city. Under no circumstances will this data be stored. In any case, the site remains responsible. Such transfers are framed by organizational and technical measures to ensure an adequate level of protection for the said data.

About Cookies and Anonymous Data

We also automatically and openly collect certain technical and anonymous data from you, including the IP address, dates and times of visits, and pages viewed. These data do not allow us to identify you directly or indirectly and are used to better understand individual behavior on the KOALIS S.A websites to improve and simplify navigation on these sites.

About IP addresses: we collect and process IP addresses for statistical purposes, click verification, and validation in our business activities and to monitor their use in a file declared to the CNIL. These are processed in compliance with the principles of personal data protection defined by current legislation.

User Rights and How to Exercise Them

At any time, you can:

• Request a copy of the personal data we hold about you
• Inform us of any changes to your personal data, or request that we correct any personal data we hold about you
• In certain situations, you can ask us to delete, block, or restrict the processing of your personal data, or object to certain of our processing methods of your personal data
• Request the portability of your Data as of May 25, 2018. In certain situations, you can also ask us to send your personal data to a third party that you have provided to us
• When we use your personal data following your consent, you have the right to withdraw it at any time, in accordance with applicable law. Additionally, when processing your personal data, in a legitimate interest or in the public interest, you can object at any time to our use of your personal data subject to applicable law
• You can also at any time ask us to stop receiving advertisements by contacting us directly and free of charge, or by using the unsubscribe link included in any marketing communication we may send you by email. If you wish to object to the processing of your personal data based on a legitimate interest and no unsubscribe mechanism is available directly, please contact us at dpo@koalis.net.

We thank you for immediately notifying us of any changes or inaccuracies in your personal data by contacting us. If we hold personal data about you that is not accessible on our website, you can send us your request free of charge. For any request concerning this Charter and the exercise of your rights or if you have a complaint, please contact our Data Protection Officer at: dpo@koalis.net.

To exercise your rights, you can choose to send your request (indicating your email address, name, first name, postal address, phone number) and a copy of your ID:

• By email to dpo@koalis.net
• By postal mail to the following address: Data Protection Officer, KOALIS S.A, 2405 Route des Dolines, 06560 Valbonne.

A response will be sent to you within a maximum of one (1) month from the date of receipt of your request. In case of a request to delete your data and/or exercise your right to request the deletion of your data, we may, however, retain them in archived form for the time necessary to meet our legal, accounting, and tax obligations.