Politique de Confidentialité

Data Processing Addendum
This Data Processing Addendum ("DPA"), forms part of the Agreement between Laconciergery
SAS ("Laconciergery") and the Customer (“Customer”) and shall be effective on the date both
parties execute this DPA (Effective Date"). All capitalized terms not defined in this DPA shall
have the meanings set forth in the Agreement.
1. Definitions
"Affiliate" means an entity that directly or indirectly Controls, is Controlled by or is under
common Control with an entity.
"Agreement" means Laconciergery’s Terms of Use, which govern the provision of the Services to
Customer, as such terms may be updated by Laconciergery from time to time.
"Control" means an ownership, voting or similar interest representing fifty percent (50%) or more
of the total interests then outstanding of the entity in question. The term "Controlled" shall be
construed accordingly.
"Customer Data" means any Personal Data that Laconciergery processes on behalf of Customer
as a Data Processor in the course of providing Services, as more particularly described in this
DPA.
"Data Protection Laws" means all data protection and privacy laws applicable to the processing
of Personal Data under the Agreement, including, where applicable, EU Data Protection Law.
"Data Controller" means an entity that determines the purposes and means of the processing of
Personal Data.
"Data Processor" means an entity that processes Personal Data on behalf of a Data Controller.
"EU Data Protection Law" means (i) prior to 25 May 2018, Directive 95/46/EC of the European
Parliament and of the Council on the protection of individuals with regard to the processing of
Personal Data and on the free movement of such data ("Directive") and on and after 25 May
2018, Regulation 2016/679 of the European Parliament and of the Council on the protection of
natural persons with regard to the processing of Personal Data and on the free movement of
such data (General Data Protection Regulation) ("GDPR"); and (ii) Directive 2002/58/EC
concerning the processing of Personal Data and the protection of privacy in the electronic
communications sector and applicable national implementations of it (as may be amended,
superseded or replaced).
"EEA" means, for the purposes of this DPA, the European Economic Area, United Kingdom and
Switzerland.
"Group" means any and all Affiliates that are part of an entity's corporate group.
"Personal Data" means any information relating to an identified or identifiable natural person.
"Processing" has the meaning given to it in the GDPR and "process", "processes" and
"processed" shall be interpreted accordingly.
"Security Incident" means any unauthorized or unlawful breach of security that leads to the
accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to
Customer Data.
"Services" means services, products, applications, tools, offline components and features
(individually the "Service" or collectively, the "Services") provided by our company Laconciergery
SAS, together with its affiliates, officers, directors, employees, agents and subsidiaries
(hereinafter "Laconciergery", "we", "our" or "us").
"Sub-processor" means any Data Processor engaged by Laconciergery or its Affiliates to assist in
fulfilling its obligations with respect to providing the Services pursuant to the Agreement or this
DPA.
2. Relationship with the Agreement
2.1 The parties agree that DPA shall replace any existing DPA the parties may have previously
entered into in connection with the Services.
2.2 Except for the changes made by this DPA, the Agreement remains unchanged and in full
force and effect. If there is any conflict between this DPA and the Agreement, the Agreement
shall prevail to the extent of that conflict.
2.3 Any claims brought under or in connection with this DPA shall be subject to the terms and
conditions, including but not limited to, the exclusions and limitations set forth in the Agreement.
2.4 Any claims against Laconciergery or its Affiliates under this DPA shall be brought solely
against the entity that is a party to the Agreement. In no event shall any party limit its liability
with respect to any individual's data protection rights under this DPA or otherwise. Customer
further agrees that any regulatory penalties incurred by Laconciergery in relation to the Customer
Data that arise as a result of, or in connection with, Customer’s failure to comply with its
obligations under this DPA or any applicable Data Protection Laws shall count toward and
reduce Laconciergery’s liability under the Agreement as if it were liability to the Customer under
the Agreement.
2.5 No one other than a party to this DPA, its successors and permitted assignees shall have
any right to enforce any of its terms.
2.6 This DPA shall be governed by and construed in accordance with governing law and
jurisdiction provisions in the Agreement, unless required otherwise by applicable Data
Protection Laws.
3. Scope and Applicability of this DPA
3.1 This DPA applies where and only to the extent that Laconciergery processes Customer Data
that originates from the EEA and/or that is otherwise subject to EU Data Protection Law on
behalf of Customer as Data Processor in the course of providing Services pursuant to the
Agreement.
3.2 Part A (being Section 4 – 8 (inclusive) of this DPA, as well as Annexe A of this DPA) shall
apply to the processing of Customer Data within the scope of this DPA from the Effective Date.
3.3 Part B (being Sections 9-12 (inclusive) of this DPA) shall apply to the processing of
Customer Data within the scope of the DPA from and including 25th May 2018. For the
avoidance of doubt, Part B shall apply in addition to, and not in substitution for, the terms in Part
A.
Part A: General Data Protection Obligations
4. Roles and Scope of Processing
4.1 Role of the Parties. As between Laconciergery and Customer, Customer is the Data Controller
of Customer Data, and Laconciergery shall process Customer Data only as a Data Processor
acting on behalf of Customer.
4.2. Customer Processing of Customer Data. Customer agrees that (i) it shall comply with its
obligations as a Data Controller under Data Protection Laws in respect of its processing of
Customer Data and any processing instructions it issues to Laconciergery; and (ii) it has provided
notice and obtained (or shall obtain) all consents and rights necessary under Data Protection
Laws for Laconciergery to process Customer Data and provide the Services pursuant to the
Agreement and this DPA.
4.3 Laconciergery Processing of Customer Data. Laconciergery shall process Customer Data only
for the purposes described in this DPA and only in accordance with Customer’s documented
lawful instructions. The parties agree that this DPA and the Agreement set out the Customer’s
complete and final instructions to Laconciergery in relation to the processing of Customer Data
and processing outside the scope of these instructions (if any) shall require prior written
agreement between Customer and Laconciergery.
4.4 Details of Data Processing
(a) Subject matter: The subject matter of the data processing under this DPA is the Customer
Data.
(b) Duration: As between Laconciergery and Customer, the duration of the data processing under
this DPA is until the termination of the Agreement in accordance with its terms.
(c) Purpose: The purpose of the data processing under this DPA is the provision of the Services
to the Customer and the performance of Laconciergery’s obligations under the Agreement
(including this DPA) or as otherwise agreed by the parties.
(d) Nature of the processing: Laconciergery provides an online service composed of tools
enabling the Customer to create its own Application(s) as described in the Agreement.
(e) Categories of data subjects: Any individual accessing and/or using the Services through the
Customer's account ("Users"); and any individual: (i) whose information is stored on or collected
via the Services, or (ii) to whom Users engage or communicate with via the Services
(collectively, "End Users").
(f) Types of Customer Data:
(i) Customer and Users: identification and contact data (name, address, title, contact details);
financial information (credit card details, account details, payment information, billing
information); IT information (IP addresses, usage data, cookies data, online navigation data,
location data, browser data);
(ii) End Users: identification and contact data (name, date of birth, gender, general occupation
or other demographic information, address, title, contact details, including email address),
personal interests or preferences (including marketing preferences and publicly available social
media profile information); IT information (IP addresses, usage data, cookies data, online
navigation data, location data, browser data).
4.5 Notwithstanding anything to the contrary in the Agreement (including this DPA), Customer
acknowledges that Laconciergery shall have a right to use and disclose data relating to the
operation, support and/or use of the Services for its legitimate business purposes, such as
billing, account management, technical support, product development and sales and marketing.
To the extent any such data is considered Personal Data under Data Protection Laws,
Laconciergery is the Data Controller of such data and accordingly shall process such data in
accordance with the Laconciergery Privacy Policy and Data Protection Laws.
4.6 Tracking Technologies. Customer acknowledges that in connection with the performance of
the Services, Laconciergery employs the use of cookies, unique identifiers, web beacons and
similar tracking technologies ("Tracking Technologies"). Customer shall maintain appropriate
notice, consent, opt-in and opt-out mechanisms as are required by Data Protection Laws to
enable Laconciergery to deploy Tracking Technologies lawfully on, and collect data from, the
devices of End Users (defined below) in accordance with and as described in the Laconciergery
Cookie Statement.
5. Subprocessing
5.1 Authorized Sub-processors. Customer agrees that Laconciergery may engage
Sub-processors to process Customer Data on Customer's behalf. The Sub-processors currently
engaged by Laconciergery and authorized by Customer are listed in Annex A.
5.2 Sub-processor Obligations. Laconciergery shall: (i) enter into a written agreement with the
Sub-processor imposing data protection terms that require the Sub-processor to protect the
Customer Data to the standard required by Data Protection Laws; and (ii) remain responsible for
its compliance with the obligations of this DPA and for any acts or omissions of the
Sub-processor that cause Laconciergery to breach any of its obligations under this DPA.
6. Security
6.1 Security Measures. Laconciergery shall implement and maintain appropriate technical and
organizational security measures to protect Customer Data from Security Incidents and to
preserve the security and confidentiality of the Customer Data, in accordance with
Laconciergery’s security standards described in Annex B ("Security Measures").
6.2 Updates to Security Measures. Customer is responsible for reviewing the information made
available by Laconciergery relating to data security and making an independent determination as
to whether the Services meet Customer’s requirements and legal obligations under Data
Protection Laws. Customer acknowledges that the Security Measures are subject to technical
progress and development and that Laconciergery may update or modify the Security Measures
from time to time provided that such updates and modifications do not result in the degradation
of the overall security of the Services purchased by the Customer.
6.3 Customer Responsibilities. Notwithstanding the above, Customer agrees that except as
provided by this DPA, Customer is responsible for its secure use of the Services, including
securing its account authentication credentials, protecting the security of Customer Data when
in transit to and from the Services and taking any appropriate steps to securely encrypt or
backup any Customer Data uploaded to the Services.
7. Data Center Locations
Laconciergery processes Customer Data in France where Laconciergery maintain data processing
operations. Laconciergery may transfer and process Customer Data anywhere in the world where
its Affiliates or its Sub-processors maintain data processing operations. Laconciergery shall at all
times provide an adequate level of protection for the Customer Data processed, in accordance
with the requirements of Data Protection Laws.
Part B: GDPR Obligations from 25 May 2018
8. Additional Security
8.1 Confidentiality of processing. Laconciergery shall ensure that any person who is authorized by
Laconciergery to process Customer Data (including its staff, agents and subcontractors) shall be
under an appropriate obligation of confidentiality (whether a contractual or statutory duty).
8.2 Security Incident Response. Upon becoming aware of a Security Incident, Laconciergery shall
notify Customer without undue delay and shall provide timely information relating to the Security
Incident as it becomes known or as is reasonably requested by Customer.
9. Changes to Sub-processors
9.1 Laconciergery shall (i) provide an up-to-date list of the Sub-processors it has appointed upon
written request from Customer; and (ii) notify Customer (for which email shall suffice) if it adds
or removes Sub-processors at least 10 days prior to any such changes.
9.2 Customer may object in writing to Laconciergery’s appointment of a new Sub-processor within
five (5) calendar days of such notice, provided that such objection is based on reasonable
grounds relating to data protection. In such event, the parties shall discuss such concerns in
good faith with a view to achieving resolution. If this is not possible, Customer may suspend or
terminate the Agreement (without prejudice to any fees incurred by Customer prior to
suspension or termination).
10. Return or Deletion of Data
10.1 Upon termination or expiration of the Agreement, Laconciergery shall (at Customer's
election) delete or return to Customer all Customer Data in its possession or control, save that
this requirement shall not apply to the extent Laconciergery is required by applicable law to retain
some or all of the Customer Data, or to Customer Data it has archived on back-up systems,
which Customer Data Laconciergery shall securely isolate and protect from any further
processing, except to the extent required by applicable law.
11. Cooperation
11.1 The Services provide Customer with a number of controls that Customer may use to
retrieve, correct, delete or restrict Customer Data, which Customer may use to assist it in
connection with its obligations under the GDPR, including its obligations relating to responding
to requests from data subjects or applicable data protection authorities. To the extent that
Customer is unable to independently access the relevant Customer Data within the Services,
Laconciergery shall (at Customer's expense) provide reasonable cooperation to assist Customer
to respond to any requests from individuals or applicable data protection authorities relating to
the processing of Personal Data under the Agreement. In the event that any such request is
made directly to Laconciergery, Laconciergery shall not respond to such communication directly
without Customer's prior authorization, unless legally compelled to do so. If Laconciergery is
required to respond to such a request, Laconciergery shall promptly notify Customer and provide
it with a copy of the request unless legally prohibited from doing so.
11.2 If a law enforcement agency sends Laconciergery a demand for Customer Data (for
example, through a subpoena or court order), Laconciergery shall attempt to redirect the law
enforcement agency to request that data directly from Customer. As part of this effort,
Laconciergery may provide Customer’s basic contact information to the law enforcement agency.
If compelled to disclose Customer Data to a law enforcement agency, then Laconciergery shall
give Customer reasonable notice of the demand to allow Customer to seek a protective order or
other appropriate remedy unless Laconciergery is legally prohibited from doing so.
11.3 To the extent Laconciergery is required under EU Data Protection Law, Laconciergery shall (at
Customer's expense) provide reasonably requested information regarding the Services to
enable the Customer to carry out data protection impact assessments or prior consultations with
data protection authorities as required by law.

Twilio California, USA
Annex B - Security Measures
Data Center Security
Laconciergery delivers millions of pageviews a month for thousands of users. We use multiple
ressources, placed in different world-class data centers in France.
Our data centers manage physical security 24/7 with mandatory personal identification, and
high tech security access control and access monitoring.
We have DDOS mitigation in place at all of our data centers, and aggressive use of firewalls
and network isolation in our infrastructure.
Access to our server systems is allowed only through secure connections by our trusted
administrators from the Laconciergery team.
Protection from Data Loss, Corruption
We implement multiple layers of application logic that prevent corruption of data from one user
account to another.
Account data is mirrored and regularly backed up off site. We secure the data in 3 different data
centers located in France.
Application Level Security
Laconciergery account passwords are hashed. Our own staff can't even view them. If you lose
your password, it can't be retrieved—it must be reset.
All login pages and all pages used to manage the Services (backend pages) pass data via
TLSv1.2.
Login pages and logins via the Laconciergery API have brute force protection.
We perform regular external security penetration tests throughout the year using different
vendors. The tests involve high-level server penetration tests, in-depth testing for vulnerabilities
inside the application, and social engineering drills.
Internal IT Security
Laconciergery offices are secured by badge access, and they are monitored with cameras
throughout.
Our office network is heavily segmented and centrally monitored.
We have a dedicated internal security team that constantly monitors our environment for
vulnerabilities. They perform penetration testing and social engineering exercises on our
environment.
Internal Protocol and Education
We continuously train employees on best security practices, including how to identify social
engineering, phishing scams, and hackers.
Protection Against Misuse
We can take all the measure to secure ourselves, but if your computer gets compromised and
someone gets into your Laconciergery account, that's not good for either of us.
We monitor and will automatically suspend accounts for signs of irregular or suspicious login
activity.
We monitor accounts and Application activity for signs of abuse.
In addition to our scalable algorithms, we employ another layer of human reviewers, who
monitor for anomalous account and Application activity 
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