Privacy Policy

This privacy policy (the "Policy") informs you of the way in which the company PEER2ME – SARL RCS de Paris n°492 378 625 – 182 rue La Fayette 75010 PARIS (acting under the trade name Wekount) processes, in its capacity as data controller, your personal data collected on the https://www.wekount.io/ website (hereinafter the "Site").

This privacy policy also explains the data processing carried out in the context of PEER2ME's software solutions and the associated protection measures. Some of these processing operations are subject to specific protection policies described in dedicated pages that concern the solution deployed. These pages are referenced in this document.

PEER2ME is a specialist in developing connected commerce solutions that he offers to various physical locations that allow them to generate traffic, analyze visitor journeys and interact with them. If you have any questions about this Policy or the use of your data, please do not hesitate to contact our Data Protection Officer (DPO) by writing to privacy@wekount.io.

What are your rights and how can you exercise them?

Under the terms of the GDPR and the Data Protection Act, you have certain rights relating to the processing carried out using your personal data. As part of your right of access, you have the right to request information about the processing we carry out as well as a copy of your processed data. Thanks to the right to rectification, you have the possibility to rectify, correct and update your data at any time. You also have the right to object in certain cases to the processing of your information through the right to object. You can also ask us to limit the processing operations to the sole storage of your data, under certain conditions, under the right to restriction of processing. With the right to erasure, you can ask us, in certain cases, to erase your data. Under certain conditions, you have the right to request the recovery of your data or its transfer to another service provider under the right to portability. You also have the right to define directives relating to the fate of your personal data after your death as well as the right to lodge a complaint with the CNIL. We also inform you that we do not carry out any automated decision-making, including profiling, using your data.

The exercise of these rights is free of charge, and can be carried out at any time, subject to proof of your identity, by writing to privacy@wekount.io

Your data and transfers outside the EU/EEA

PEER2ME does not transfer any data outside the EU/EEA area.

However, service providers and any subcontractors we use may be required to transfer data outside the EU/EEA. When this is the case, we ensure that these transfers are made on the basis of appropriate safeguards to ensure the security of your data.

Collection of data on the WEKOUNT Website. IO, and the newsletter

What data do we collect on our wekount.io site?
As part of your registration on the Site and the creation of your account on our platform, we collect various information about you. We also collect and process some of your data when you have requested to be contacted for information about our products or when you enter a form to access a resource. This data includes:

- Your surname;
- Your first name;
- Your email address;
- Your telephone number, only if you wish to be contacted by phone;
- Data relating to your activity on the Site through the use of cookies.

As part of your subscription to the Wekount newsletter, we also collect and process your email address to keep you informed of our news and news or any other information that may be of interest to you. CookiesBrowsing the Site may result in the deposit of several cookies on your connection terminal. A cookie is a file consisting mainly of letters and numbers, of limited size, stored on your computer's browser or hard drive. These cookies are used for statistical purposes in order to:

- measure the audience of our Website;
- help us distinguish new visitors from previous ones on our Site;
- help us measure and study the effectiveness of our content.

We also use cookies in order to be able to contact and/or offer relevant content to visitors, as well as to help us personalise the content that appears during your visit to the Website. These cookies are kept for a period of 13 months from the time they are deposited on your connection terminal. You can refuse their installation by configuring your browser for this purpose or by customising your preferences when you arrive on the Website.NewsletterYou have the option of subscribing to Wekount's newsletter at any time by entering your email address in the space provided for this purpose. By clicking on "OK" you give us your consent to receive information, commercial or not, on Wekount news and the various content published on our Blog.

You have the right to withdraw your consent at any time and to unsubscribe from our mailing list by clicking on the unsubscribe link provided for this purpose.

Job application at Wekount

As part of an application for a job at Wekount, you may provide us with personal data such as first name, last name, email, telephone numbers, a CV, a cover letter or recommendations.

This data is only used in the context of Wekount's recruitment procedures and is not communicated to third parties. They are used to contact candidates for an initial contact, to communicate with them during the recruitment process and possibly to propose new offers to candidates who are not received during a first meeting.

In the event of a negative outcome to your application, this data is kept for 2 years by Wekount, unless you object. You can exercise your rights of access, rectification, limitation and deletion at any time via privacy@wekount.ioWhy and how do we collect your dataWe collect your data on the basis of your consent in order to:

- Be able to create your account allowing you to subscribe to Wekount's services and access the resources we make available to you;
- Be able to subscribe to our Newsletter to receive all the news about Wekount and the new products that we develop;
- To be able to contact you in the context of an enquiry.

You have the option of withdrawing your consent at any time by deleting your account or writing to us at privacy@wekount.io

The processing of your data may, in some cases, also be necessary in the context of the performance of a contract concluded with Wekount if you are a customer of Wekount.

The data and information we collect about you may in some cases be shared with our partners offering complementary solutions to Wekount. When this is the case, information is communicated to you on this subject when the collection form is validated.

How long is it kept?

In the context of the use of the services offered on the Site and the use of your Wekount account, we keep your data for up to three (3) days from the closure of your account or the cessation of the use of the services we offer on the Site.

With regard to the data collected when you subscribe to our newsletter, we keep it for a period of one (1) year after you unsubscribe.

In the context of an enquiry or other contact with Wekount, we keep your data for a period of three (3) years from your last interaction with our services.

How do we keep your data secure?

In order to ensure and guarantee the security of your data, we have put in place all the technical and organisational measures at our disposal to prevent your data from being unintentionally and accidentally lost, used, altered, or made available to the public without your permission.

If an event of this nature were to occur, we have implemented measures to react promptly and to inform you and the CNIL when necessary.

Data collected on behalf of Wekount's customers, via its software solutions

Audience measurement
As part of its audience measurement solution in physical locations, which makes it possible to establish attendance statistics, Wekount installs Wi-Fi sensors. In such a case, the data collected (the Mac address on your smartphone) is immediately anonymized and specific information and objection tools are made available to visitors, as specified in more detail below.

This processing is carried out by Wekount on the legal basis of legitimate interest.

When this solution is deployed at a Wekount customer, the physical location you access has an analytics system used for statistical purposes, to measure visitor traffic and to improve the customer experience that collects certain information about your smartphone, unless you object.

If you do not want your data to be collected, we invite you to deactivate your Wi-Fi before entering the store or to exercise your right to object by following this link: https://www.wekount.io/privacy

Below you will find more information about the personal data we collect, how we use it, as well as your rights and other useful information to help you make a decision transparency. Who is responsible for the processing of your personal data? PEER2ME, a limited liability company, whose registered office is located at 182 rue La Fayette 75010 PARIS and registered under number 492 378 625RCS Paris ("Wekount"), is responsible for the processing of your personal data for the activities described below, together with either the person in charge of the physical place you are about to enter, or the person responsible for the furniture equipped with an audience measurement system (the "Venue") (together, "we", "us"). You can request a copy of the outline of the agreement between Wekount and the Venue defining their respective obligations with respect to the protection of your personal data, by contacting us using the contact details set out below. What type of personal data do we collect? We only collect information related to smartphones that have Wi-Fi enabled and are connected to our boxes. Only the following data may be collected:

- the MAC address* of your smartphone, which is immediately anonymised;
- and the time and date of connection to the case, as well as the relative distance of your smartphone from the case.

No information relating to your identity (such as your first name, last name, email address or telephone number) is collected, nor do we have access to the content of your smartphone (contacts, messages, etc.).

*A MAC address is a 12-character identifier, consisting of numbers from 0 to 9, and letters from A to F (uppercase or lowercase). It can be divided by dashes or colons.

Examples:

1a-2b-3c-4d-5f-5F1A:2B:3C:4D:5F:5F

The MAC address is a physical identifier stored in a device with an internet connection. Unless it has been modified by the user, it is unique in the world. For what purposes and on what basis do we process your personal data? We process your personal data in order to provide reports on the number of visitors to the physical spaces of the Venue. These reports allow it to know the trends of its visitors visits.

In both cases, the processing of your personal data is justified by our legitimate interests, namely:

• to take into account audience measurements in physical locations to adjust offers and adapt the customer relationship in a non-individualized way;• to measure the impact of an advertising campaign by taking into account its effect on traffic, without data relating to the identity of people;• improve the customer experience and therefore the attractiveness of a physical place.

In addition, we may process your personal data in order to:

1) enforce our rights and obligations and for any legal proceedings involving you, initiated by or against you. We consider it to be in our legitimate interests to protect our organisation against any breach of a legal obligation owed to it and to defend ourselves in the event of a dispute.

2) protect the rights of third parties. This processing is necessary for compliance with our legal obligations. This processing is also necessary for the purposes of the legitimate interests pursued by Wekount. We consider that we have a legitimate interest in ensuring that our activities do not violate the rights of third parties.

3) in anticipation of and/or in connection with a commercial transaction such as a merger-acquisition, restructuring or sale for example. We consider it in our interest to be able to make informed decisions about the future of our company, with the aim of preserving and developing our business activities.

4) To respond to your requests for information, complaints and requests to exercise your rights. This processing is based on your consent, as well as our legitimate interest in responding to requests for information received from the public. In addition, in some cases, the processing is necessary for compliance with our legal obligations. With whom do we share your personal data? We share your data collected via our boxes, for the purposes described above, with:

- Other current or future Wekount entities;
- Any service providers acting as "processors";
- The authorities, our insurers, lawyers, auditors or other third parties, when justified by our legitimate interest (for example in the context of legal proceedings in order to defend our rights in court, or in connection with an M&A transaction), to the extent permitted by applicable law, or where necessary to comply with a legal obligation to which we are subject. In particular, your data may be transmitted to the competent authorities, at their request, in the context of legal proceedings, in the context of legal investigations and requests for information from the authorities or in order to comply with other legal obligations.

We may also share aggregated or anonymized information, which cannot reasonably be used to identify you. Your data and transfers outside the EU/EEAWe do not transfer data outside the EU/EEA area.

However, service providers and any subcontractors we use may be required to transfer data outside the EU/EEA. When this is the case, we ensure that these transfers are made on the basis of appropriate safeguards to ensure the security of your data. How long do we keep this data? Anonymised MAC addresses are only kept for the duration of the technical operation necessary to count visitor flow, they are then deleted, not being used for any other purpose.

Data of minors

We do not knowingly collect or request information from minors (users' date of birth or age are not collected. It is not possible to determine the age). If we discover that we have collected personal data from a minor, we will delete it as soon as possible.

Contact us

If you have any questions or complaints about the protection of your personal data collected via our boxes, you can contact us at the following contact details:

Wekount
182 rue La Fayette
75010 PARIS
Tél. : +33 (0)1 83 62 18 57
contact@wekount.io

You can also contact Wekount's Personal Data Protection Officer (DPO) at the following coordinates:

Wekount
182 rue La Fayette
75010 PARIS
Tél. : +33 (0)1 83 62 18 57
privacy@wekount.io

Last updated: February 20, 2020