Our contact details 

Name: Exupair France S.A.S. (Société par Actions Simplifiée, Simplified Joint-Stock Company)

Capital: 35.000 €

Address: 66 Av. des Champs-Élysées, 75008 Paris, France

Registered in the Register of Trade and Companies of Paris under the Reg. No. 920 421 963

Represented by Mr. Diego PAULO (General Manager) and Mr. Matias MAGNASCO (CEO)

Phone Number: +33 983856802

E-mail: info@exupair.com

The type of personal information we collect 

We currently collect and process the following information:

• Personal identifiers, contacts and characteristics (for example, name and contact details like phone numbers and emails), and in some cases, according to the type of services requested by the customer, passport details.
• Company name, location, VAT number and bank account details when a business operation is confirmed.

How we get the personal information and why we have it

Most of the personal information we process is provided to us through e-mail, directly by you for operational coordination purposes.

We use the information that you have given us in order to coordinate with you the operations you entitled us to support.

We may share this information with appointed suppliers/sub-contractors in case the urgency of a situation needs to do so.

Under the European General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

Legitimate interest.

How we store your personal information 

Your information is securely stored in Exupair’ corporate devices located at our premises, as well as servers within the European Union.

We keep names, emails, addresses, and phone numbers for an indefinite period of time, and your information is not sell to any Third-party.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information. 

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances. 

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances. 

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at info@exupair.com if you wish to make a request.

Google reCAPTCHA Privacy Policy

Our primary goal is to provide you an experience on our website that is as secure and protected as possible. To do this, we use Google reCAPTCHA from Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA). With reCAPTCHA we can determine whether you are a real person from flesh and bones, and not a robot or a spam software. By spam we mean any electronically undesirable information we receive involuntarily. Classic CAPTCHAS usually needed you to solve text or picture puzzles to check. But thanks to Google’s reCAPTCHA you usually do have to do such puzzles. Most of the times it is enough to simply tick a box and confirm you are not a bot. With the new Invisible reCAPTCHA version you don’t even have to tick a box. In this privacy policy you will find out how exactly this works, and what data is used for it.

What is reCAPTCHA?

reCAPTCHA is a free captcha service from Google that protects websites from spam software and misuse by non-human visitors. This service is used the most when you fill out forms on the Internet. A captcha service is a type of automatic Turing-test that is designed to ensure specific actions on the Internet are done by human beings and not bots. During the classic Turing-test (named after computer scientist Alan Turing), a person differentiates between bot and human. With Captchas, a computer or software program does the same. Classic captchas function with small tasks that are easy to solve for humans but provide considerable difficulties to machines. With reCAPTCHA, you no longer must actively solve puzzles. The tool uses modern risk techniques to distinguish people from bots. The only thing you must do there, is to tick the text field “I am not a robot”. However, with Invisible reCAPTCHA even that is no longer necessary. reCAPTCHA, integrates a JavaScript element into the source text, after which the tool then runs in the background and analyses your user behaviour. The software calculates a so-called captcha score from your user actions. Google uses this score to calculate the likelihood of you being a human, before entering the captcha. reCAPTCHA and Captchas in general are used every time bots could manipulate or misuse certain actions (such as registrations, surveys, etc.).

Why do we use reCAPTCHA on our website?

We only want to welcome people from flesh and bones on our side and want bots or spam software of all kinds to stay away. Therefore, we are doing everything we can to stay protected and to offer you the highest possible user friendliness. For this reason, we use Google reCAPTCHA from Google. Thus, we can be pretty sure that we will remain a “bot-free” website. Using reCAPTCHA, data is transmitted to Google to determine whether you genuinely are human. reCAPTCHA thus ensures our website’s and subsequently your security. Without reCAPTCHA it could e.g. happen that a bot would register as many email addresses as possible when registering, in order to subsequently “spam” forums or blogs with unwanted advertising content. With reCAPTCHA we can avoid such bot attacks.

What data is stored by reCAPTCHA?

reCAPTCHA collects personal user data to determine whether the actions on our website are made by people. Thus, IP addresses and other data Google needs for its reCAPTCHA service, may be sent to Google. Within member states of the European Economic Area, IP addresses are almost always compressed before the data makes its way to a server in the USA.
Moreover, your IP address will not be combined with any other of Google’s data, unless you are logged into your Google account while using reCAPTCHA. Firstly, the reCAPTCHA algorithm checks whether Google cookies from other Google services (YouTube, Gmail, etc.) have already been placed in your browser. Then reCAPTCHA sets an additional cookie in your browser and takes a snapshot of your browser window.

The following list of collected browser and user data is not exhaustive. Rather, it provides examples of data, which to our knowledge, is processed by Google.

• Referrer URL (the address of the page the visitor has come from)
• IP-address (z.B. 256.123.123.1)
• Information on the operating system (the software that enables the operation of your computers. Popular operating systems are Windows, Mac OS X or Linux)
• Cookies (small text files that save data in your browser)
• Mouse and keyboard behaviour (every action you take with your mouse or keyboard is stored)
• Date and language settings (the language and date you have set on your PC is saved)
• All Javascript objects (JavaScript is a programming language that allows websites to adapt to the user. JavaScript objects can collect all kinds of data under one name)
• Screen resolution (shows how many pixels the image display consists of)

Google may use and analyse this data even before you click on the “I am not a robot” checkmark. In the Invisible reCAPTCHA version, there is no need to even tick at all, as the entire recognition process runs in the background. Moreover, Google have not given details on what information and how much data they retain.

The following cookies are used by reCAPTCHA: With the following list we are referring to Google’s reCAPTCHA demo version at https://www.google.com/recaptcha/api2/demo.
For tracking purposes, all these cookies require a unique identifier.

How long and where are the data stored?

Due to the integration of reCAPTCHA, your data will be transferred to the Google server. Google have not disclosed where exactly this data is stored, despite repeated inquiries. But even without confirmation from Google, it can be assumed that data such as mouse interaction, length of stay on a website or language settings are stored on the European or American Google servers. The IP address that your browser transmits to Google does generally not get merged with other Google data from the company’s other services.
However, the data will be merged if you are logged in to your Google account while using the reCAPTCHA plug-in. Google’s diverging privacy policy applies for this.

How can I delete my data or prevent data storage?

If you want to prevent any data about you and your behaviour to be transmitted to Google, you must fully log out of Google and delete all Google cookies before visiting our website or use the reCAPTCHA software. Generally, the data is automatically sent to Google as soon as you visit our website. To delete this data, you must contact Google Support at https://support.google.com/?hl=en-GB&tid=111401120.

If you use our website, you agree that Google LLC and its representatives automatically collect, edit and use data.

You can find out more about reCAPTCHA on Google’s Developers page at https://developers.google.com/recaptcha/. While Google do give more detail on the technical development of reCAPTCHA there, they have not disclosed precise information about data retention and data protection. A good, basic overview of the use of data however, can be found in the company’s internal privacy policy at https://policies.google.com/privacy?hl=en-GB.

We use Google AdSense Advertising on our website.

Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

• Remarketing with Google AdSense
• Google Display Network Impression Reporting.
• Demographics and Interests Reporting.

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

You will be notified of any Privacy Policy changes: On our Privacy Policy Page

You Can change your personal information:

• By emailing us.
• By calling us.
• By logging in to your account.
• By chatting with us or by sending us a support ticket.

How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?
It’s important to note that we allow third-party behavioral tracking, primarily through search engine services.

COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

We do not specifically market to children under the age of 13 years old.

To the best of our knowledge, we do not let third-parties, including ad networks or plug-ins collect PII from children under 13.

Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via in-site notification within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.
• Process orders and to send information and updates pertaining to orders.
• Send you additional information related to your product and/or service.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

• Not use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can:
Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

Contacting Us
If there are any questions regarding this privacy policy, you may contact us using the information on our contact page.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at info@exupair.com, T: +33 983856802.

You can also complain to the CNIL, Commission Nationale Informatique & Libertés, the French Data Protection Agency, if you are unhappy with how we have used your data.

The CNIL’s address:

3 Place de Fontenoy

TSA 80715

75334 PARIS CEDEX 07

FRANCE

Helpline number: +33 1 53 73 22 22

CNIL website: https://www.cnil.fr/en/home