Privacy Policy

This Privacy Policy (hereafter the “Privacy Policy”) explains how the company uses and protects any of the information you provide when using our websites, online and/or offline forms, applications, and social media.

• The websites dedicated to the brand, products, and services of POLYGLOT SA (hereafter the “Website”),
• The applications related to the brand, products, and services of POLYGLOT SA (hereafter the “Applications”),
• The social media pages related to the brand, products, and services of POLYGLOT SA (hereafter the “Social Media”)
• – The forms related to the brand products, and services of POLYGLOT SA (hereafter the “forms”)
•  e-mails related to the brand, products, and services of POLYGLOT SA (hereafter “e-mails”)
• Websites, applications and social media, forms and emails are hereafter collectively referred to as “Sites”.
• “Personal Data” means any information relating to an identified or identifiable individual (as defined by the General Data Protection Regulation)

POLYGLOT SA headquarters are located at 76 avenue de la Liberté, L 1930 Luxembourg. It is responsible for the processing of your Personal Data (within the European Union Regulation (EU) 2016/679 of the European Parliament and the Council of April 27th, 2016, regarding the protection of individuals, the processing of their Personal Data and the free movement of such data, repealing the 95/46/EC Directive, hereafter referred to as the “General Data Protection Regulation”), and in charge of the processing of your Personal Data through the website (hereafter referred to as “we”, “us” and “our”).

You may view this Privacy Policy by clicking on the link called “Privacy Policy” or “Legal Notice” located at the bottom of each websites’ home page. We invite you to please read this Privacy Policy carefully.

This Privacy Policy applies to all users of our sites, whether registered or not.

What kind of Personal Data do we collect?

We collect and process personal information whether you are a registered user or not. It can be all or part of the data listed below:

• Title
• Last name
• First name
• Gender
• Date of Birth
• Address
• Phone number (including landline and mobile numbers)
• Email
• Data Location
• Areas of interest
• Profession
• Area of intervention
• Number of years of experience
• Browser data or device: IP address
• Applications usage data
• Data collected about the browsing interest and time spent visiting our sites (e.g., date and time of activity on the website, number of visits and links clicked on)
• Areas of interest checked in the forms
• Type of professional disciplines checked on the site
• Description of your professional project
• Information entered in the comments section of the forms
• Your bank details (via a secure payment page)
• Your business address
• Your photos posted on our directories or collected during our events
• The detailed presentation of your profile on our directories
• The content created by the user on social media, that you gave authorization to share such as photos, texts, videos, symbols, hashtags, recordings that you share on social media
• Your language preferences (language used for browsing, spoken languages)

If you have not completed any forms, this information will be treated anonymously. If you have identified yourself through a form, all this information can be collected from your profile in our database.

We ask that you do not send us or provide us with any sensitive Information on the website or through third parties.

“Sensitive Information” refers to Personal Data relating to sensitive aspects, such as:

• Racial or ethnic origin,
• Political opinions,
• Religious or other beliefs,
• State of your health and medical conditions,
• Criminal history,
• Trade union memberships,
• Sexual orientation.

Specific cases with the subdomain payment.tomatis.com, and websites that offer an online payment system – Your debit and/or credit card number entered online is encrypted and processed by secured online payment services such as “Stripe” or “PayPal”. We do not have access to your debit and/or credit card numbers which are encrypted by the payment services but we have the ability to debit your account with your prior consent.

How do we collect your Personal Data?

We collect your Personal Data as follows:

• Through the Websites – We collect your Personal Data through the Websites, online forms, product registrations and emails that you receive or send to us.
• Outside of the Internet – We collect your Personal Data outside of the Internet, especially when you contact customer service or visit our company (our offices and attend our Conferences etc.)
• When you download an Application – When you download and use an application, we track and collect the usage data from the application, such as the date and time of access on our server from your device, and what information and which files have been downloaded from the application based on your device number.
• Physical Location –We collect physical location data from your device using satellites, mobile phone relay antennas, or Wi-Fi signals, for example.
• Use of cookies – We collect your Personal Data through the use of cookies when you browse the websites. Our collection and processing of your Personal Data through cookies is governed by the Cookies Policy, which we invite you to read carefully.

The Personal Data that you provide to us through our websites is mixed with the Personal Data and other information that you provide to us (via the Internet or off the Internet), or that we obtain in any other way via the Internet or off the Internet.

What do we do with your information?

We collect your Personal Data in order to respond to your requests for information or requests to commercial offers / Administrative Interactions.

• To respond to your requests: If you send us a message, fill out an application or fill-out our contact form or our information form through the website, we will use your Personal Data to help us respond to your requests for information, suggestions, complaints, and requests for commercial offers.

Legal grounds for using your personal data: Our goal is to answer your requests.

• To send you administrative information, for example, information about the website and the modification of our Terms, Conditions, and Policies.
• We use your Personal Data to provide you with important information about the website, your transactions and any changes to our Terms and Conditions, Policies or this Privacy Policy.

Legal grounds for using your personal data: Our goal is to answer your requests and to inform you by email of the new changes in our Terms and Conditions and the status of your payment and/or your order.

Send targeted and relevant marketing communication.

We use your Personal Data to send you direct marketing communications via email and mail. Direct marketing communications to inform you of news, promotions, new products, or other similar activities about our business and brand as well as products and services from our affiliated companies.

Individual and professional documentation application forms, as well as all contacts and information forms, are part of our marketing communications.

Legal grounds for using your personal data: Your consent

To contact us using an online form, you must accept our Privacy Policy. You have the option of not completing the online form and instead of contacting us directly at the following address contact@pronounce.com

You may withdraw your consent to receive direct marketing communications by clicking on the “Unsubscribe” link at the bottom of each marketing email.

You may also notify us of your wish to withdraw your consent by email, phone or mail at the contact information mentioned in this Privacy Policy.

Analyze data through the use of the public profile on social media platforms and shared content.

We collect your Personal Data to measure your interactions in our social media platforms.

Legal grounds for using your personal data: Your consent

You have the option to accept or refuse the use of your Personal Data, including configuring cookies (see the Cookie Policy).

Profile trend analysis

We collect your Personal Data to improve our understanding of the types of profiles interested in our products and services. This allows us to better know our prospects and customers and to adapt our communication and our offers.

Legal grounds for using your personal data: Your consent

You can accept or refuse the use of your Personal Data by configuring cookies (see the Cookie Policy).

You can also contact us directly.

Behavior trend analysis

We collect your Personal Data, including your location and browsing data in order to measure your interactions on the sites. This allows us to improve your browsing experience and adjust our content according to your profile.

Legal grounds for using your personal data: Your consent

You can accept or refuse the use of your Personal Data by configuring cookies (see the Cookie Policy).

You can also contact us directly.

Compliance with our legal obligations

In order for us to comply with our legal obligations as well as with all legal procedures or decisions coming from governmental authorities, including any decisions coming from governmental authorities outside of your country of residence, we are legally bound and may have to disclose your Personal Details, only because it is strictly necessary to comply with such legal obligations, legal proceedings or government orders.

Legal grounds for using personal data: Compliance with our legal obligations.

Corporate Mergers & Acquisitions

We use your Personal Data in the case of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or inventory (including the case of a bankruptcy or similar proceedings).

Legal grounds for using your personal data: Our interest in implementing our business strategy.

Management of information technology

We use your Personal Data to diagnose server problems, administer the site and verify that it is working properly.

Legal grounds for using your personal data: Our interest in the management of our computer systems and networks in order to ensure that the website operates properly from a technical point of view.

Who do we communicate your Personal Data with and for what reason?

Your Personal Data is shared with the following companies who host our computer systems, provides system support services and conducts data analysis for the purposes described in the Privacy Policy;

• Google (Gmail, AdWords, and Analytics): provides support services for our computer system and conducts data analysis for the purposes described in the Privacy Policy.
• CRM, Hubspot: hosts our computer systems and provides systems support services.
• CMS: WordPress, Drupal, and Symphony, woocomerce: host our computer systems and provide systems support services.
• Providers sending emails Getresponse and Constantcontact who ensure the sending and delivery of marketing emails.
• Social media: Facebook, Twitter, and Instagram to carry out targeted campaigns.

Your Personal Data is communicated to the following companies who host our online payment systems:

• Stripe that provides online payments by debit and/or credit card or SEPA
• PayPal that provides online payments by debit and/or credit card or PayPal account
  
  

If necessary or appropriate, your Personal Data will be communicated to all authorities, affiliated companies and third parties involved: (a) in order to comply with our legal obligations; (b) to respond to requests from public and governmental authorities, including any public or governmental authorities outside your country of residence; (c) to enforce our terms and conditions; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, security or property, and/or those of our affiliates; and (f) to allow us to find any solutions available to us or to limit any prejudice we may suffer.

Third party Sites / Third party service providers

This Privacy Policy does not cover, and we do not accept any liability when it comes to the treatment and data protection policies of any third party, including any third party operating any sites whose link is present on such sites. The presence of a link on the sites does not imply endorsement, on our part or on the part of our affiliated companies, of the site to which the link refers to.

Third party advertising service providers

Please note that our online and email advertising and marketing service providers may use “pixels”, “web beacons”, “invisible GIFs” or other similar technologies within the websites in order to help us manage our advertising campaigns, online and by email, and improve their efficiency. For example, if a cookie is placed on your computer by a service provider, the latter may recognize the cookie when you visit the sites to find out which of our online advertisements may bring you to our sites, and the service provider may be required to provide us with the information for us to use. Please note that we may associate the other information provided to us by our service providers with the Personal Data about you previously collected by us.

We may use third-party advertising agencies for the purpose of displaying advertisements on our sites. These agencies may use information (with the exception of names, addresses, e-mail addresses or phone numbers) related to your visits to the sites in order to offer you advertisements concerning the products and services that are of interest to you.

What are your rights regarding the processing of your Personal Data, how can you exercise them and how can you contact us?

Your rights regarding the processing of your Personal Data

Here are your rights:

• Obtain a copy of any Personal Data that we have about you;
• To ask us to update or correct any inaccurate Personal Data, or to add any incomplete Personal Data;
• To request that we cease the processing of your Personal Data for direct marketing purposes.

In some cases, you also have the right to:

• Object to the processing of your Personal Data;
• Ask us to erase your Personal Data;
• Limit our processing of your Personal Data;
• Ask us to send you some of your Personal Data or to transfer it or to ensure that it is transferred to any other data manager.

To exercise your rights

You can contact our Data Protection Officer (DPO) at the following address:

POLYGLOT SA,
DPD
76 avenue de la Liberté,
L 1930 Luxembourg.

You can send us an email at the following address: privacy@tomatis.com

You can call us at 00 352 26 27 20

How long do we keep your Personal Data?

We intend to ensure the accuracy of your Personal Data and to keep it up-to-date. We will delete the Personal Data that we have about you when we don’t need to use it anymore.

If there is no communication with your registered profile or no contractual relationship, we will keep your Personal Data used for the purposes described in this Privacy Policy for a timeframe of up to 4 years, unless applicable regulation requires us to keep your Personal Data for a shorter or longer period.

The duration of 4 years is justified by the particular nature of our offers and services that require to gradually educate the professional and whose decisions to contract with us cannot be taken under a simple impulse. It is the case for people who have a professional profile and whose wish to integrate our services and products into their daily professional activity is a mature decision made and supported by a lot of information.

This is also the case for people who have an individual profile and whose willingness to benefit from our services and products is for their personal interest or that of a loved one. It is also a mature decision made and supported by a lot of information.

Finally, the conservation of your Personal Data is justified by the evolution of our offers and products which are brought to change gradually but drastically. Over the years, certain offers and services can significantly change and thus better meet your expectations. We think it is necessary to inform you of such changes.

What transfer of Personal Data do we make outside of the European Union?

For the purposes described in this Privacy Policy, we may transfer your Personal Data to providers located in countries outside the European Union such as in the United States (hereafter the “Third Countries”), which cannot guarantee an “adequate level of protection” under section 45 of the General Data Protection Regulation (GDPR):

In this scenario, our transfer of data will be subject to the following appropriate protection in accordance with the General Data Protection Regulation (GDPR), to ensure that your Personal Data is adequately protected:

• Standard data protection clauses adopted by the European Commission under Article 46 section 2 of the General Data Protection Regulation (GDPR) (Click here to access the European Commission’s decision on standard contractual clauses for transfers to subcontractors established in Third Countries),
• The EU-U.S. Privacy shield on transfers to U.S.-based companies (Click here to access the European Commission’s decision on the EU-U.S. protection shield).

In order to get all relevant information regarding all transfers of your Personal Data to Third Countries, you may contact our Data Protection Officer at the following address:

POLYGLOT SA
DPD
76 Avenue de la liberté
L-1930 Luxembourg.

You can send us an email at the following address: contact@pronounce.com

You can call us at 00 352 26 27 20

Applicable Law

This Privacy Policy is governed by and will be interpreted in accordance with the Luxembourg laws and all other applicable laws within the European Union.

You may print, download or otherwise store a copy of this Privacy Policy (and any revised version) for your records.

COOKIES MANAGEMENT POLICY

Cookies are small amounts of information stored in files within the browser of your computer. Cookies are accessible and registered by the websites you visit, and by the companies that display their advertisements on websites so that they can recognize the browser. Internet sites can only access the cookies they have stored on your computer.

By using our website, you consent to the use of cookies posted by our website.

Our website uses cookies necessary for the following actions:

• To offer you a simplified use of the website: We may register your login information so that you do not have to log in each time you visit the website; Remember which forms you have filled in to avoid refilling them before accessing other steps.
• To enable us to measure the audience and the efficiency of the website: To follow the statistical data on the website’s use (the use made of the website by the users and to improve the services of the website) and to help us measure and study the effectiveness of our content.
• To offer you targeted ads on social media related to the pages you visited on our site.
• To analyze your click stream data from our CRM in order to better target your interests and provide you with the most relevant information.

We do not use targeting cookies that would allow an external advertising service such as “google AdSense” to intervene directly on our website through banners or content.

We do not use social media cookies generated by their share buttons.

TERMS OF SERVICE

This website “the site” is published by POLYGLOT SA Société Anonyme with a capital of 266 800 Euros which ensures the direction of the publication.

Address:

POLYGLOT SA SA,
76 Avenue de la liberté,
L-1930 Luxembourg
Email; contact@pronounce.com,
Telephone: 00 352 26 27 20
RC Luxembourg: B 76 636
VAT No. LU 183 893 19

Website Hosting

The website and the domain name are hosted by the company OVH (http://www.ovh.com) OVH SAS with a capital of 500 000 euros – RCS Roubaix Tourcoing 42476141900011 Head office: 141 Quai du Sartel – 59100 Roubaix – France.

Personal Data

The processing of Personal Data is managed according to our general statement on the treatment of Privacy Cookies.

Cookies

The management of cookies is defined according to the terms defined in our cookie management policy.

General content

The content published on this website is purely informative. In no case may this content be considered as medical advice or means to replace it.

Content provided by third parties

The website maintains an online directory. The directory is updated directly by the members who have access to their files via the member access of the site. The publisher is in no way responsible for the content published by each member on their own profile via their member’s access.

References to third-party sites

Hypertext links to other sites from this site cannot, in any case, engage the responsibility of POLYGLOT SA

Location data

When you visit this website, data relating to your geographical location is processed in order to define your browsing language preferences, to localize you on the map and possibly to adjust the offers according to your currency and your place of connection. This data is processed according to our general privacy statement.

Copyright

The website content including downloadable files may not be reproduced or distributed without the permission of POLYGLOT SA

Passwords

Your password is personal and should not be shared.

Trademarks

PRONOUNCE is a trademark, POLYGLOT SA has exclusive use. Their use or modification is strictly prohibited (unless expressly permitted).