Privacy policy

Last updated: July 31, 2024

TELLUS, a public limited company with a capital of 37,012 euros, registered with the RCS of Antibes under number 448 560 847, whose registered office is located at 950 Route des Colles, 06410 Biot (“TELLUS”), pays particular attention to the protection of personal data and undertakes to protect it in accordance with the applicable regulations and in particular Regulation (EU) No. 2016/679 of 27 April 2016 known as the “General Data Protection Regulation” or “GDPR” and Law No. 78-17 of 6 January 1978 as amended, known as the “Data Protection Act” as amended (the “Applicable Data Protection Law”).

Within the framework of this privacy policy (the “Privacy Policy”), TELLUS collects personal data (the “Personal Data”) from users of the website www.joxko.com and the “Joxko” application (respectively the “Data Subjects” and the “Site”), and implements processing of this data for which it is qualified as “data controller”, within the meaning of the aforementioned texts.

Within the framework of the Privacy Policy, terms identified by an initial capital letter, if not defined herein, have the meaning given to them in the general terms and conditions of use and sale of the Site.

TELLUS undertakes to comply at all times with the requirements of the Applicable Data Protection Law and to process Personal Data only under the conditions set out below.

TELLUS processes the following Personal Data of the Data Subjects:

Whether providing Personal Data is mandatory or optional is indicated at the time of collection by the presence or absence of an asterisk. Providing certain Personal Data is mandatory for TELLUS to fulfill the purposes described above. Providing optional data allows TELLUS to better understand the Data Subject in order to provide services more tailored to their needs.

Beyond the aforementioned periods, Personal Data is archived by TELLUS, in a secure environment, for the legal limitation period for the purposes of proof for the establishment, exercise or defense of a right in court.

Regarding the creation of their Account, it is specified that the Data Subject has the option of using their personal Google, Facebook, or Apple accounts. In this case, the creation of their Account will be subject to the terms and conditions of the company concerned. TELLUS will therefore collect the following Personal Data: email address, first and last name, and telephone number.

Unless legally or judicially obligated to do so, TELLUS will never disclose, transfer, rent or transmit the Personal Data it processes to third parties other than the following recipients:

- The following service providers, it being understood that they act as "subcontractors" of TELLUS within the meaning of Applicable Data Protection Law, on the instructions of TELLUS, which provides them with the data strictly necessary for the performance of their tasks, under the contractual conditions signed with TELLUS, which cannot deviate from this article and which comply with Applicable Data Protection Law:

o The hosting provider for the Site and its databases, OVH, in its data centers located in France, for the purpose of performing technical hosting and database management services. For further information on the processing of Personal Data carried out by the hosting provider, the Data Subject is invited to read OVH's privacy policy, which can be viewed at the following address: https://www.ovhcloud.com/fr/personal-data-protection/ ;

o The service provider SCALEWAY for the IT implementation of the Business Continuity Plan (BCP) and backups. For any further information on the processing of Personal Data carried out by this service provider, the Data Subject is invited to read its privacy policy visible at the following address: https://www.scaleway.com/fr/politique-confidentialite/ ;

o The chat manager, the company FRESHWORKS, via its FRESHCHAT product, for the purposes of ensuring the proper execution of the chat service as part of customer service. For any additional information on the processing of Personal Data carried out by this service provider, the Data Subject is invited to read the confidentiality policy of the company FRESHWORKS visible at the following address: https://www.freshworks.com/gdpr/company/;

o The payment service provider, STRIPE, processes the following data for the purpose of providing the online payment service: the individual's identification data and banking data, in accordance with applicable banking regulations. For further information on the processing of Personal Data by this provider, the Data Subject is invited to read its privacy policy available at the following address: https://stripe.com/fr/privacy;

o The payment service provider, SOCIETE GENERALE, via its SOGENACTIF tool, for the purpose of executing the online bank card payment service. The following are processed: the person's identification data and banking data, in compliance with applicable banking regulations. For further information on the processing of Personal Data carried out by this provider, the Data Subject is invited to read its general terms and conditions available at the following address: https://entreprises.sg.fr/static/ent/Entreprises/Medias/PDF/Conditions-Generales/CG_Sogenactif2.0_25_juillet_2022.pdf;

o The payment service provider, PAYPAL, for the purpose of finalizing the order by payment. For further information on the processing of Personal Data carried out by this provider, the Data Subject is invited to read PAYPAL's privacy policy, which can be viewed at the following address: https://www.paypal.com/fr/webapps/mpp/ua/privacy-full;

o The cryptocurrency payment service provider, TRIPLE A, for the purpose of finalizing the order by cryptocurrency payment. For further information on the processing of Personal Data carried out by this provider, the Data Subject is invited to read TRIPLE A's privacy policy, which can be viewed at the following address: https://www.triple-a.io/privacy-and-terms-policy;

o The prepaid card payment service provider, PAYSAFE PREPAID SERVICES LIMITED, for the purpose of finalizing the order through payment. For further information on the processing of Personal Data by this provider, the Data Subject is invited to read the privacy policy of PAYSAFE PREPAID SERVICES LIMITED, available at the following address: https://www.paysafecard.com/fr/avis-de-confidentialite/.

TELLUS is committed to making its best efforts to:

- To ensure the physical and logical security of the servers hosting the Site and, in particular, the integrity of the network and servers against any external malicious act or known cyberattack. The servers are protected against intrusion by a firewall. Security updates for the operating systems and antivirus software are installed regularly;

- Implement and maintain Site security and confidentiality measures that take into account the principles of Personal Data protection and applicable banking security rules, and are adapted to the risk posed by their processing to the rights and freedoms of Data Subjects, in accordance with the requirements of Applicable Data Protection Law. These measures aim to (i) protect Personal Data against destruction, loss, alteration, or disclosure to unauthorized third parties and (ii) ensure the restoration of the availability of and access to Personal Data within appropriate timeframes in the event of a physical or technical incident. TELLUS also implements a procedure to regularly test, analyze, and evaluate the effectiveness of the aforementioned security measures.

Some of TELLUS's partners and/or service providers mentioned in Article 2 herein belong to groups of companies whose holding company is located outside the European Economic Area. Therefore, the personal data of the Data Subjects may be transferred to third countries (in particular the United States), notably for the purpose of maintaining the IT infrastructure and databases that these service providers process on behalf of TELLUS.

The Data Subject is also informed that these companies may be subject to legal, governmental or judicial obligations to disclose data, including personal data, regardless of where that data is hosted.

TELLUS ensures at all times that these transfers are carried out under appropriate and suitable security and confidentiality conditions to guarantee a level of protection of the Data Subject's personal data equivalent to the level required within the European Union, in accordance with the Applicable Data Protection Law, by concluding in particular with them the standard contractual clauses adopted by the European Commission.

Data subjects have the following rights over their personal data at any time:

- Right of access: to obtain confirmation of the processing of one's Personal Data as well as certain information about the processing, it being understood that this information is in any event provided in this document;

- Right to rectification: to obtain the rectification of one's Personal Data when it is inaccurate or incomplete;

- Right to erasure, also called "right to be forgotten": to obtain the erasure of one's Personal Data when it is no longer necessary for the purposes for which it was collected or when the Data Subject objects to the processing of his Personal Data;

- Right to restriction of processing: to obtain restriction of processing of his or her Personal Data when the Data Subject contests the accuracy of the data, when the period for retention of Personal Data has expired but the Data Subject still needs to retain this Personal Data for the establishment, exercise or defence of legal claims, or if the Data Subject has objected to the processing;

- Right to data portability: to obtain the Personal Data that the Data Subject has provided to TELLUS in a readable format, or to request that TELLUS transmit the Personal Data that the Data Subject has provided to another data controller;

- Right to object: to object at any time, for reasons relating to one's personal situation, to the processing of one's Personal Data, in particular where this objection concerns commercial prospecting, including profiling;

- Withdrawal of consent: withdrawing consent to future processing of Personal Data by TELLUS, where the processing is based on consent;

- Right to lodge a complaint: You may lodge a complaint with the French Data Protection Authority (the “CNIL”) if you believe that the processing carried out by TELLUS constitutes a violation of your Personal Data. The CNIL can be contacted:

• By telephone: +33 1 53 73 22 22;

• Via an online form available here: https://www.cnil.fr/webform/nous-contacter

Data Subjects' rights regarding their Personal Data can be exercised at any time with TELLUS by email at the following address: privacy[@]joxko.com.

The Site may contain hyperlinks to third-party websites. TELLUS has no control over the content of third-party websites referenced by hyperlinks. These websites are published by third-party companies independent of TELLUS. Consequently, TELLUS cannot assume any responsibility for the content, advertisements, services, or any other information or data available on or from these sites. Therefore, the Data Subject acknowledges being solely responsible for accessing and using these sites. TELLUS shall not be liable for any actual or alleged damages or losses arising from or related to the use of or reliance on the content, goods, or services available on these sites.

The Data Subject is not authorized to create a hyperlink to the Site. Creating links to the Site is only possible with the prior and express consent of TELLUS.

The Site uses plugins from the following social networks:

- Facebook®, operated by Meta Platforms Inc.;

- LinkedIn®, operated by Microsoft Corp.;

- Instagram®, operated by Meta Platforms Inc.;

- YouTube®, operated by YouTube LLC;

- X®, operated by X Corp.;

- TrustPilot®, operated by Trustpilot Group plc.

When the Data Subject interacts using these plug-ins, their browser establishes a direct connection with the servers of the corresponding social network. The plug-in content is immediately transmitted from the Data Subject's browser to the social network and stored on its servers. By integrating this plug-in, the social network is informed that the Data Subject has visited the Site. It can then associate the Data Subject's browsing activity on the Site with their user account on that social network, if applicable. If the Data Subject does not want the social network to collect data about them through the Site and link it to their account on the social network, the Data Subject must log out of the corresponding social network before visiting the Site. If the Data Subject is not a member of the social network, it is still possible for the network to collect and store their IP address.

In any event, TELLUS has no control over the exact content of the data thus collected. The use of the plug-ins is operated exclusively by the respective social networks and governed by their terms of service, available at the following addresses:

- For Facebook: https://fr-fr.facebook.com/help/581066165581870;

- For LinkedIn: https://www.linkedin.com/legal/user-agreement?

- For Instagram: https://fr-fr.facebook.com/help/instagram/581066165581870;

- For YouTube: https://www.youtube.com/static?template=terms&hl=fr&gl=FR;

- For X: https://x.com/fr/tos;

- For Trustpilot: https://fr.legal.trustpilot.com/for-reviewers/terms-of-use-for-consumers

Facebook® and Instagram® are registered trademarks and are the exclusive property of Meta Platforms Inc.

LinkedIn® is a registered trademark and is the exclusive property of Microsoft Corp.

YouTube® is a registered trademark and is the exclusive property of YouTube LLC.

X® is a registered trademark and is the exclusive property of X Corp.

TrustPilot® is a registered trademark and is the exclusive property of Trustpilot Group plc.

TELLUS uses cookies to ensure the proper functioning of the website www.joxko.com and to track and analyze website traffic. The "Joxko" application does not use cookies.

A "cookie" is a small data file sent to the user's browser by a web server and stored on their computer's hard drive or other storage device. Cookies do not pose any risk of damage to the storage device.

The information collected through cookies is solely and strictly intended for TELLUS, in compliance with applicable data protection law. Cookies from third-party publishers (Google, Facebook, Twitter) allow these publishers to access the information collected through their cookies, as detailed in the table below.

Cookie management is handled by the "Iubenda" tool implemented by the company HIMYDATA. The following cookies are used:

The Data Subject is free to consent to the use of all or some of the cookies (other than those strictly necessary for the operation of the Site) used on the Site. The Data Subject can make their choice upon their first connection by clicking on the categories of cookies they accept. The Data Subject is also free to withdraw their consent to the use of cookies at any time on the Site.

The Data Subject can also configure their browser to accept cookies or deactivate them. Cookie instructions for the most commonly used browsers can be found at the following links:

- Windows Internet Explorer®: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

- Mozilla Firefox®: https://support.mozilla.org/fr/kb/auteur-bloquer-cookies-preferences-sites

- Google Chrome®: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DiOS&hl=fr

- Apple Safari® (iPhone; iPad): https://support.apple.com/fr-fr/HT201265

- Apple Safari® (Mac): https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

- Deactivation of Google Analytics: https://tools.google.com/dlpage/gaoptout

TELLUS reserves the right to use the following tools on the Site:

- Google Firebase Analytics;

- Facebook SDK.

This Privacy Policy may be modified, supplemented, or updated at any time by TELLUS, in particular to take into account any legal, regulatory, jurisprudential, and/or technical developments, with the aim of continuously ensuring the best possible protection of the Personal Data of Data Subjects. Data Subjects are encouraged to consult the Privacy Policy regularly to stay informed about the processing carried out by TELLUS on their Personal Data. If a Data Subject does not agree with the terms of the new version of the Privacy Policy, they are free to request the deletion of their Personal Data under the conditions and in accordance with the procedures set forth herein.