Data Protection Policy

PREDICTA LAB is committed to ensuring that the processing of personal data carried out as part of its activities complies with the General Data Protection Regulation ("GDPR") as well as the French Data Protection Act. PREDICTA LAB processes your personal data in accordance with this data protection policy ("Policy") and any instructions provided by third parties in the context of its subcontracting activities.

The third parties are:

• Customers using PREDICTA LAB's products and services to facilitate the verification of a person's digital footprint.

In this Policy, we explain how and why we use your data, what your rights are, and how to exercise them.

By accepting the Policy, you consent to the processing of your data.

What is personal data?

Personal data ("Personal Data" or "Data") refers to any information relating to an identified or identifiable natural person:

• Directly (name, first name, email address)
• Or indirectly (IP address, customer account number).

Who does this Data Protection Policy apply to?

This Policy applies to all our products and services (the "Products and Services"), which include our services facilitating the verification of a person's digital footprint, monitoring social networks to combat disinformation, and writing articles, as presented on our website www.predictalab.com (the "Site").

Our Policy aims to inform any person using our Products and Services or visiting the Site (the "User" or the "Client").

Who collects your Data?

The data controller, within the meaning of the GDPR, is SAS PREDICTA LAB, represented by Baptiste Robert as president.

How do we collect your Data?

PREDICTA LAB collects your Data online (including by email), on paper, or orally (during a physical appointment, video conference, or by phone), and this Policy applies regardless of the method of collection or processing.

The Personal Data that the User agrees to provide to us, regardless of the method of collection (online, on paper, or orally), is subject to the provisions of this Policy.

Why do we collect your Data?

Some of your Data is necessary for the processing and provision of our Products and Services. Failure to provide the information prevents the proper functioning of our Products and Services.

For informational purposes, you will find below a list of categories of collected data corresponding to the purposes pursued by our collection, as well as the legal basis for these collections.

To respond to your contact request:

Data categories collected: identity data (name, surname), contact data (email address). Legal basis: legitimate interest in providing you with our Products and Services.

To respond to your quote request:

• Data categories collected: identity data, contact data, quote number, professional life.
• Legal basis: pre-contractual measures taken at your request.

To enable you to order and use our Products and Services:

• Data categories collected: identity data (name, surname), contact data (email address, phone number), customer data (purchase order, billing and shipping address), professional life.
• Legal basis: contractual measures taken at your request.

To manage customer billing:

• Data categories collected: identity data (name, surname), contact data (email address, phone number), customer data (purchase order, billing and shipping address), professional life, economic and financial data.
• Legal basis: contractual measures taken at your request.

When creating a customer account to use our Products and Services:

• Data categories collected: identity data (name, surname) and contact data (email address), password.
• Legal basis: contractual measures taken at your request.

To offer you a subscription to our newsletter:

You can subscribe to our newsletter via the link provided for this purpose on our Website.

• Data categories collected: identity data (name, surname) and contact data (email address).
• Legal basis: you consent when you check the dedicated box, when you create an account.

You can unsubscribe from this newsletter at any time by clicking on the link provided for this purpose, which is present in each of the newsletters.

To process your response to a job offer:

• Data categories collected: identity data (name, surname), contact data (email address, phone number), information contained in the curriculum vitae and cover letter (photograph, professional background).
• Legal basis: pre-contractual measures taken at your request.

To conduct statistical traffic operations on our website:

• Data categories collected: browsing data (IP address).
• Legal basis: your consent when you accept the use of statistical cookies.

Are you required to provide your Personal Data?

When you subscribe to our newsletter or request a quote, the processing of certain data related to your identity and contact information is mandatory. Indeed, we cannot proceed with your subscription or provide a quote without processing this data.

Please note that when you give your consent to the processing of your Personal Data, you have the option to withdraw this consent at any time via the unsubscribe links provided in each promotional email.

What are your rights?

Subject to compliance with the legal obligations imposed on PREDICTA LAB in the context of its activities, each individual has the following rights:

• Request a copy of the Data from your customer account - Right of access
• Correct any inaccurate Data concerning you - Right of rectification
• Request the erasure of certain Data concerning you - Right to erasure
• Object to the processing of your Data; please note that this request is incompatible with the processing of your order for Products and Services - Right to object
• Decide at any time to withdraw your consent, for example via the unsubscribe link provided in each newsletter - Right of withdrawal
• Request the restriction of the use of your Data - Right to restriction of processing
• Object to the profiling of your Data - Right to object to profiling
• Exercise your right to data portability - for example, if you are a customer and wish to change providers and migrate your Data to another software

In the event of a Data breach that could result in a high risk to your rights and freedoms, you will be informed of this breach without undue delay.

You can provide instructions regarding the storage, erasure, and disclosure of your Data after your death, in accordance with Article 40-1 of the Data Protection Act.

How to exercise your rights?

These rights, as well as these instructions, can be exercised and addressed by writing to us:

• By postal mail to the following address:
  • Predicta Lab
  • Attention: Data Protection Officer (DPO)
  • 777 chemin de L'Espérès
  • 31370 BEAUFORT
• Or by email: [email protected]

In order to allow us to quickly identify you and respond to you, please include any elements that can establish your identity with your request (such as customer number or request made directly through your account). A response will be sent to you within 1 month following the receipt of the request. In certain cases, due to the complexity of the request or the number of requests, this period may be extended by 2 months.

You can also contact the National Commission for Data Protection and Liberties (CNIL), the regulatory authority responsible for enforcing personal data protection regulations in France, online at https://www.cnil.fr/fr/agir or by postal mail to the following address: Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy - TSA 80715, 75334 PARIS CEDEX.

How long do we retain your Data?

We only keep your Data for as long as necessary to carry out the operations for which they were collected, unless the law provides for a different retention period.

For example, in the context of sending newsletters or commercial prospecting, we retain your Data for a period of 3 years from our last contact, in accordance with the recommendations of the CNIL.

You acknowledge that the Data you provide to us and that is stored in our information systems is accurate and constitutes proof of your identity.

With whom do we share your Data?

The collected Data is shared, according to their respective needs and in accordance with the purposes mentioned above, with:

• PREDICTA LAB staff
• The staff of external hosting services for our website
• The staff of external services in the context of commercial prospecting
• The staff of external accounting services

Are your Data sent outside of the European Union?

We may share some of your Data outside of the European Union with service providers located outside of the European Union. However, each transfer is subject to a mechanism that provides an equivalent level of protection as guaranteed by European Union law.

What security measures have we taken to protect you?

We are committed to implementing all necessary technical and organizational measures to ensure the protection of your Personal Data.

For example, we implement the principle of data minimization and have taken out cyber risk insurance.

However, PREDICTA LAB cannot be held liable in the event of total or partial non-compliance with an obligation and/or failure of the operators of transport networks to the Internet and, in particular, its internet service providers or computer hardware. The damages due by PREDICTA LAB in the event of a service failure resulting from proven fault on its part shall correspond to the direct, personal, and certain prejudice resulting from the failure in question, to the express exclusion of any indirect damage. In the event of a Data breach and in accordance with regulations, PREDICTA LAB undertakes to notify them to the CNIL as well as to the individuals concerned in the event of a high risk to the rights and freedoms of natural persons, in the conditions provided for by the GDPR.

Modification of this Data Protection Policy

We may update this Policy by publishing a new version on our website. We undertake not to substantially lower the level of confidentiality of your Data without informing you and obtaining your consent if necessary.

Contact

If you have any questions regarding the Data Protection Policy, please contact us:

• By postal mail to the following address:
  • Predicta Lab
  • Attention: Data Protection Officer (DPO)
  • 777 chemin de L'Espérès
  • 31370 BEAUFORT
• Or by email: [email protected]