Privacy Policy

COMPANY PRIVACY

Bien-être World Privacy policy

Dated: 8 May 2022.

This privacy policy (hereinafter referred to as the "Privacy Policy") sets out the legal framework for the collection, use and processing by T6 COSMOS Limited (hereinafter referred to as "T6 COSMOS") of personal data on behalf of its clients (hereinafter referred to as the "Client(s)") in the course of using the services offered through the "BEW User" and “BEW Pro” applications, designed, developed and operated by T6 COSMOS (hereinafter referred to as the "Platform").

Under the Privacy Policy, the controller of personal data is the Client. As the data controller, the Client retains full control over the personal data and determines the purpose, nature, aims, means and duration of the processing of personal data by T6 COSMOS under the subcontracting agreement between T6 COSMOS and the Client.

 

T6 COSMOS acts as a subcontractor and as such, collects, uses and processes on behalf of the Client the data entrusted to it by and on the instructions of the Client.

The personal data (hereinafter referred to as the "Personal Data"), that T6 COSMOS collects on behalf of the Client, concern mainly the employees of the Client making use of the “BEW User” Platform (hereinafter referred to as the "Users"), and more generally the Client himself, his representatives, his own customers, his service providers, suppliers or sub-contractors.

 

T6 COSMOS is also led to act as a data controller and as such, to collect, use and process data for its own account, in particular to provide a service adapted to the Client and to ensure the good functioning of the Platform. As such, T6 COSMOS collects data from practitioners who register on the website and use the dedicated platform (hereinafter referred to as "Practitioners").

The information of the Personal Data collected in the framework of the Privacy Policy, is mandatory and necessary for the processing and for the provision of the services offered by T6 COSMOS via the Platform (hereinafter referred to as the "Services"). The lack of information provided prevents the proper functioning of the proposed Services.

 

T6 COSMOS undertakes to comply with the applicable regulations on the protection of personal data and in particular the obligations arising from the European Regulation No. 2016/679 on the protection of personal data (hereinafter referred to as the "GDPR").

T6 COSMOS collects Personal Data only in accordance with the terms of this Privacy Policy and any reasonable and legal instructions given by the Client at any time.

ARTICLE 1: COLLECTED INFORMATION

The information of the collected Personal Data is compulsory and strictly necessary for the good functioning of the Platform and the Services. Otherwise, the Services cannot be provided.

 

1.1 Throughout the use of the Platform and Services, Bien-être World may collect or gather on behalf of the Customer and according to its instructions:

- Any information, directly or indirectly identifying the Users (hereinafter referred to as the "User Data") ;

- Any information, directly or indirectly identifying the Client and more particularly its representative or contact person (hereinafter referred to as "Client Data").

 

1.2 User Data is collected via the Customer. It can be collected directly when the User communicates it to Bien-être World for the purpose of providing the Services.

The Client communicates the data of the Users within the limit of a strictly necessary treatment for the good functioning of the Platform and the Services. The information of the personal data is compulsory to provide the User with an identifier and a password to access the Platform.

This includes Personal Data relating to the identity of the User and in particular: surname, first name, e-mail address).

1.3 Within the framework of the provision of its Services, Bien-être World also collects the following Customer Data:

- Name of the Company (corporate name, company name, logo);

- Legal form and Company registration number;

- Address of the head office;

- Name, first name and functions of its representative;

- E-mail address and telephone numbers of its representatives;

- Type of activity and beginning of accounting year;

- Invoicing address if it is different.

Bien-être World also collects under the Client Data, management data collected by the Client and transmitted to Bien-être World, or if necessary collected by Bien-être World on behalf of the Client and according to means determined by the Client. These data are anonymized for statistical purposes.

 

1.4 Bien-être World may also collect data from practitioners (hereinafter referred to as "Practitioner Data"), who register and/or use the Platform:

- The Practitioner's identity document;

- Data related to the Practitioner's specialties;

- Type of activity and start of activity;

- Degrees or certifications;

- E-mail address and telephone number;

- Bank account information;

- Photograph;

- Professional insurance.

 

ARTICLE 2: USE OF PERSONAL DATA COLLECTED (PURPOSES OF PROCESSING)

 

2.1  Bien-être World uses, stores and processes the Personal Data, for the following purposes determined by the Client:

Types of personal data

Purpose

Reponsible person

Legal basis of processing

Users’ data

 

Creation and management of an account on the Platform

The client

The treatment is necessary to the execution of the contract concluded between the User and the Client

User data

Access and use of the Platform by the User

The client

The processing is necessary for the performance of the contract concluded between the User and the Client

Client data

Provision to the Client of the Services on the Platform

The Client

The processing is necessary for the execution of the contract concluded between T6 COSMOS and the Client

Users’ data

Response to possible questions/complaints of the Users - Assistance

The Client

The processing is necessary for the execution of the contract concluded between the User and the Client

 

 Users’ data, client data and practitioners’

data

Management of requests for access rights, portability, deletion, rectification and opposition

The Client et T6 COSMOS

The Client and T6 COSMOS User Data: The processing is necessary for the execution of the contract concluded between the User and the Client

 

Customer Data : The processing is necessary for the execution of the contract concluded between T6 COSMOS and the Client

 

Practitioner Data : The processing is necessary for the performance of the contract between the Practitioner and T6 Cosmos

Users’ data

Litigation management

The Client

The processing is necessary for the performance of the contract between the User and the Customer

 

 

2.2 Bien-être World uses, stores and processes Personal Data, for the following purposes determined by T6 COSMOS:

Types of personal data

Purpose

Responsible person

Legal basis of processing

Users’ data ;

Practitioners’ data ; Client data

Development, improvement of the Platform, creation of a robust environment

T6 COSMOS

The processing is necessary for the purposes of the legitimate interests pursued by T6 COSMOS

 

Practitioners’ data

 

Creation and management of an account on the Platform

T6 COSMOS

The processing is necessary for the execution of the contract concluded between the Practitioner and T6 COSMOS

 

 

Practitioners’s data

 

Access and use of the Platform by the Users

T6 COSMOS

The processing is necessary for the performance of the contract between the Practitioner and T6 COSMOS

 

 

Practitioners’ data

 

Provision to the Practitioners of the Services on the Platform

T6 COSMOS

The processing is necessary for the performance of the contract between the Practitioner and T6 COSMOS

 

 

Practitioners’ data

 

 

 

Response to any questions/complaints from Users - Assistance / Management of disputes

T6 COSMOS

The processing is necessary for the performance of the contract between the Practitioner and T6 COSMOS + legal obligation

 

 

 

 

 

Practitioners’ data ;

Client data

 

Litigation management

 

T6 COSMOS

 

The processing is necessary for the execution of the contract concluded between T6 COSMOS and the Practitioner or the Client

 

           

Finally, T6 COSMOS grants itself the right to review, go through or analyze the Personal Data to comply with its legal obligations and, in particular for fraud prevention, risk assessment, compliance with regulations and investigation purposes.

 

ARTICLE 3: RETENTION OF PERSONAL DATA

The Personal Data are kept only for the time necessary to achieve the purpose for which Bien-être World holds this data, in order to meet the needs of the Customer or to fulfill its legal obligations.

 

At the end of the applicable periods and at the latest six (6) months after the end of the use of the Services by the User or the Practitioner or after the end of the commercial relationship between the Client and T6 COSMOS, the Personal Data will be destroyed or T6 COSMOS will proceed to their anonymization.

However, T6 COSMOS may keep certain Personal Data collected on separate storage spaces in order to comply with its legal or regulatory obligations. The data thus kept will be limited to what is strictly necessary.

ARTICLE 4 : SHARING AND DIVUGLATION OF PERSONAL DATA

  1. 1 T6 COSMOS may disclose Personal Data to administrative and judicial authorities, or to authorized third parties, if required or permitted by law, or if such disclosure is reasonably deemed necessary: (i) to comply with T6 COSMOS' legal obligations, (ii) to comply with legal process and to pursue claims against T6 COSMOS or Client, (iii) to respond to verified requests in connection with a legal investigation or alleged or suspected illegal activity or any other activity that may expose T6 COSMOS or Client to legal liability.

 

4.2 Subject to the authorization of the Client and the Practitioner, T6 COSMOS has the right to subcontract all or part of the execution of the Services in compliance with the legal provisions in force.

 

In this context, T6 COSMOS will not transfer Personal Data to third parties established outside the European Union that do not offer an adequate level of protection with regard to legal requirements for the protection of Personal Data.

 

This includes Bien-être World service providers that support Bien-être World’s business such as:

- The host of the Personal Data, acting as a subcontractor: T6 COSMOS uses the services of the company AWS acting as host of the Personal Data. The hosting servers are located in Europe;

- T6 COSMOS' technical service providers or its various suppliers such as payment solution providers, who will process Personal Data for the sole purpose of the proper performance of the Services.

Any subcontractor of T6 COSMOS (hereinafter referred to as the "Subcontractor") will be authorized to process on behalf of T6 COSMOS the Personal Data necessary to provide the Services to the Client and the Practitioners.

T6 COSMOS represents that:

Has delivered in writing any instructions regarding the processing of Personal Data by the Sub-contractors;

To ensure, in advance and throughout the processing, that the obligations under the European Regulation on the protection of Personal Data are respected by the Third Party Processor;

To supervise the processing, including carrying out audits and inspections of the Third Party Processor.

T6 COSMOS agrees that the Subcontractor will:

Processes Personal Data only for the sole purpose(s) for which it is sub-contracted;

Process the Personal Data according to the instructions of T6 COSMOS;

Guarantees the confidentiality of the Personal Data processed;

Has undergone the necessary training on the protection of Personal Data;

Takes into account, with regard to its tools, products, applications or services, the principles of protection of Personal Data from the design and protection of Personal Data by default;

Inform T6 COSMOS immediately if it considers that an instruction constitutes a violation of the European regulation on the protection of Personal Data or of any other provision of the law of the Union or of the Member States relating to the protection of Personal Data.

The Personal Data may also be transmitted to commercial partners that allow Bien-être World to properly execute the subscriptions, their management, processing and payment under the contractual conditions signed between the partner and T6 COSMOS that cannot derogate from the conditions of this Privacy Policy.

Only with the express consent of the Client and the Practitioners, Bien-être World may reuse the Personal Data or transmit them to partner companies for the purpose of sending commercial information by e-mail.

 

T6 COSMOS declares to receive from the Subcontractor all the necessary documentation allowing to demonstrate the respect of the obligations and allowing the realization of audits, including inspections, by T6 COSMOS or another auditor that it has mandated, and to contribute to these audits.

 

T6 COSMOS shall remain solely responsible to the Clients for the provision of the Services entrusted to a Third Party Contractor.

ARTICLE 5: PROTECTION OF PERSONAL DATA - RIGHTS OF USERS AND PRACTITIONERS

 

5.1 Bien-être World takes care to secure the Personal Data in an adequate and appropriate manner and has taken the necessary precautions to preserve the security and confidentiality of the data and in particular to prevent them from being distorted, damaged or communicated to unauthorized persons.

 

When Bien-être World notices a violation of rights within the framework of the treatment of the Personal Data, this violation will be notified to the CNIL within a time not being able to be higher than seventy-two (72) hours after having taken note of it.

 

Any breach relating to the processing of Personal Data will be notified by e-mail, within one (1) month, by Bien-être World to the Practitioner or the Client and the User concerned.

 

5.2 In all cases, the persons concerned benefit from a right of access, rectification, modification, opposition, portability and deletion of Personal Data. For Users, these rights must be exercised directly with the Client who will contact Bien-être World at the following address: cs@bienetreworld.com, indicating the name, first name and/or company name, address of residence or registered office, e-mail address, telephone number of persons concerned. Practitioners should also exercise their rights by contacting Bien-être World via this email address.

 

In accordance with the regulations in force, any request must be signed and accompanied by a photocopy of an identity document bearing the signature of the User, upon request by Bien-être World.

The concerned person will be able to recover his Personal Data in an open and readable format. The right to portability is limited to the data provided by the Client. It applies on the basis of the prior consent of the data subject. Bien-être World undertakes to transfer, on request, within one (1) month, any document of collection of the Personal Data to the Client in order to be able to implement the right to portability. The costs related to the recovery of the Users' data shall be borne by the Client.

ARTICLE 6: USE OF COOKIES

In accordance with the deliberations of the CNIL No. 2020-091 and No. 2020-092 of September 17, 2020, Bien-être World informs, moreover, that cookies record certain information that is stored in the memory of the hard disk of the User and the Practitioner. However, only Functional Cookies are collected by Bien-être World.

Functional Cookies are the cookies that help certain non-essential functionalities of the Platform, including the integration of content such as videos or the sharing of content on the Platform.

Users and Practitioners visiting the home page or another page of the Platform directly from a search engine will be informed:

  • The precise purpose of the cookies used;
  • The possibility of opposing these cookies and changing the settings by clicking on a link in the banner;
  • and the fact that continuing to browse the site implies consent to the deposit of cookies on the user's terminal.

To ensure the free, informed and unequivocal consent of Users and Practitioners on the Platform, the banner will not disappear until they continue browsing.

Unless prior consent is obtained, cookies will not be deposited or read.

 

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Contact Details of DPO

If you have any questions regarding the provisions of this Policy, your rights under this Policy or any other data protection issues, you can contact our Data Privacy Office at the email below:

cs@bienetreworld.com

In case of complaint or if you feel that our company has not addressed your concern in a satisfactory manner, you may contact the CNIL Commission Nationale de l’Informatique et des Libertés:

3 Place de Fontenoy
TSA 80715
75334 PARIS CEDEX 07
France

Tel: +33 (0)1.53.73.22.22

Fax: +33 (0)1.53.73.22.00