The main purpose of this document is to provide you with information about the processing of personal data carried out by Libertify (“Liberty” or “we”) in a concise, transparent, intelligible and easily accessible form, to help you understand how your data are processed.
In order to ensure fair and transparent data collection, we provide information on each processing operation we carry out by means of information notices.
Data are collected fairly. No data is collected without the knowledge or information of the data subjects.
When we process data, we do so for specific purposes: each data processing carried out by us has a legitimate, specified and explicit purpose.
For each of the processing carried out, we undertake to collect and use only data that are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
We ensure that the data are kept up to date and take steps to ensure that data that are inaccurate are erased or rectified.
In the context of the processing of personal data, the purposes of which are presented to you below, we collect and process the following categories of data:
Identification data of data subjects;
Data on the use of the services offered on the Libertify platform;
Data necessary for the management of the contract;
Your exchanges with Libertify;
You will be informed whether the data to be provided are mandatory or optional at the time of their collection. If you refuse to provide mandatory data, Libertify will not be able to provide you with the Services (such as the creation of your user account, access to the platform’s functionalities or the processing of your order).
If you provide us with the personal data of a third party, we remind you that you are required to inform that person of the disclosure and processing of their personal data by Libertify and to communicate this policy to them.
The processing operations carried out by Libertify have the following purposes and legal bases:
|Ensuring the operation of the platform and the provision of servicesto users, in particular the establishment of a risk profile
|Performance of the contract
|Improving the quality and operation of the services
|Managing contracts (managing and tracking orders, payments)
|Performance of the contract
|Keeping general accounting
|Compliance with a legal obligation relating to a data storage requirement
|Establishing financial statistics concerning customers
|Monitoring customer relationship for complaint management
|Performance if the contract
|Managing prospects (notification of the launch of the platform)(2)
|Managing requests from competent authorities or courts (communication of requested data)
|Compliance with a legal obligation
|Managing pre-litigation or litigation relating to the contract or not
|Libertify’s legitimate interest in establishing proof of a right or contract(3)
3. In this case, Libertify must carry out a balancing test which aims to ensure that Libertify’s legitimate interest would not infringe the fundamental rights and freedoms of the data subjects. In its Opinion No. 06/2014, the WP29 proposes to balance the interests of the controller against the fundamental rights and freedoms of the data subjects. In doing so, several elements should be taken into account, such as:
This balancing test must be documented so that it can, if necessary, be reproduced in response to any request that the CNIL may make.