Privacy Policy

This Privacy Policy explains how AGO collects, uses, shares, and protects your personal data when you visit our website www.useago.com (the "Website" or the "Site"), subscribe to our newsletter, or send us emails.

AGO is the data controller for the processing of personal data of its customers, prospects, and website visitors (collectively referred to as "you" or "your" in this Privacy Policy).

This Privacy Policy does not cover the processing of personal data carried out through AGO's AI customer support services. When AGO provides AI customer support services to its clients, AGO acts as a data processor on behalf of those clients, who remain the data controllers. This processing is governed by a dedicated Data Processing Agreement signed directly between AGO and each client. More information is available at trust.useago.com.

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

1. Data Controller and DPO

The data controller responsible for the processing of your personal data is:

AGO SASU
75 Avenue Simon Bolivar, 75019 Paris, France
Website: www.useago.com
Email: [email protected]

AGO has designated a Data Protection Officer (DPO) in accordance with Article 37 of the General Data Protection Regulation (GDPR). You may contact the DPO for any question related to the processing of your personal data or the exercise of your rights at [email protected], or by writing to:

AGO SASU
Attn: Data Protection Officer (DPO)
75 Avenue Simon Bolivar, 75019 Paris, France

2. Categories of Personal Data

"Personal data" refers to any information that identifies, relates to, or could reasonably be linked to you, directly or indirectly. Please keep your personal data accurate at all times.

AGO may collect:

• name, surname, phone number, email address, and other similar contact information
• any additional information you choose to share on the Site
• payment information and invoices
• feedback, testimonials, inquiries, emails
• data relating to the management of our business relationship and invoices
• connection data (login, credentials) and information related to your interaction with our Website
• IP address

3. How We Collect Personal Data

AGO only collects personal data in compliance with this Privacy Policy and applicable data protection regulations.

We collect information about you from:

• your use of the Website;
• your subscription to AGO's newsletter;
• emails you send to AGO;

We use cookies and related technologies to collect information about your use of the Site. You can read more about cookies in Section 8 below.

The social media platforms, communities, or other methods of communication you use to interact with AGO or the Site may have their own specific privacy policies that govern the use of personal data related to that platform or app. You should find and carefully read those privacy policies, as our Privacy Policy does not apply to those platforms or apps.

We may receive additional personal data from third parties such as analytics providers. We may use this personal data to enhance other information we have about you to help us better understand our audience and improve the Site and our services.

4. Purposes and Legal Bases

We will only process your personal data when we have a lawful basis to do so. Below is an overview of our processing purposes grouped by their legal basis under Article 6 of the GDPR.

4.1. Contract performance (Art. 6.1.b)

We process your personal data as necessary to perform a contract with you or to take steps at your request before entering into a contract:

• managing our customer relationship;
• responding to requests or inquiries submitted through our contact form or other entry fields, to initiate business or perform a contract;
• maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying your information, and processing payments;

4.2. Legitimate interest (Art. 6.1.f)

We process your personal data based on our legitimate interest, balanced against your rights and freedoms:

• evaluating and improving the Website and our services;
• detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity;
• debugging and identifying errors that impair existing functionality;
• undertaking internal research for technological development;
• managing and developing our business and operations;
• administering surveys and promotional activities or events;

4.3. Consent (Art. 6.1.a)

When we rely on your consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before the withdrawal:

• our own marketing purposes;
• communicating newsletters, special offers, curated content, and announcements;
• sending you marketing information and advertisements through the Site, email messages, or other methods of communication;
• adding you to our contact database;

4.4. Legal obligation (Art. 6.1.c)

We process your personal data when required to comply with a legal obligation:

• site administration, enforcement of our Terms of Use, or compliance with the law;
• fulfilling our corporate reporting obligations;

5. How We Share Personal Data

We will not sell your personal data to any third party. We may share your personal data with your consent, at your request, or as follows:

• Affiliated companies (such as our subsidiaries and other companies owned by, controlled by, or affiliated with AGO) who may only use the personal data for the purposes described in Section 4 above;
• Third party service providers whom we rely on for services including fraud detection and prevention, billing, customer support, marketing, event organizing, security, analytics, and user experience. AGO has entered into data processing agreements with such service providers in accordance with Article 28 of the GDPR, limiting their use of and access to personal data to specific purposes;
• Authorized members of personnel (employees or contractors of AGO) when justified by their activity and subject to appropriate confidentiality obligations;
• to effect or evaluate a merger, acquisition, or otherwise support the sale or transfer of some or all of our business assets;
• to enforce our rights or protect our property;
• to protect the rights, property, or safety of others, investigate fraud, respond to a government request, or as needed to support auditing, compliance, and corporate governance functions;
• to defend ourselves in litigation or a regulatory action, and when required or advised to do so by law or legal counsel. This includes responding to subpoenas or similar legal proceedings, including to law enforcement agencies, regulators, and courts.

We encourage our third party partners to adopt and post their own privacy policies. The use of your personal data by third parties you can access through the Site, or who provide goods or information on or through the Site, is governed by their privacy policies and is not subject to ours.

6. Your Rights

Under the General Data Protection Regulation (GDPR), you benefit from the following rights regarding your personal data:

• Right of access (Art. 15): You may request confirmation of whether we process your personal data and, if so, obtain a copy of that data along with information about the processing.
• Right to rectification (Art. 16): You may request that inaccurate personal data be corrected or that incomplete data be completed.
• Right to erasure (Art. 17): You may request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or on other grounds provided by the GDPR.
• Right to restriction of processing (Art. 18): You may request that we limit the processing of your personal data in certain circumstances, such as when you contest the accuracy of the data.
• Right to notification (Art. 19): You have the right to be informed when rectification, erasure, or restriction of processing has been carried out, and we will communicate this to each recipient to whom the data has been disclosed, unless this proves impossible or involves disproportionate effort.
• Right to data portability (Art. 20): When the processing is based on consent or contract, you may request to receive your personal data in a structured, commonly used, and machine readable format, and to have it transmitted directly to another data controller where technically feasible.
• Right to object (Art. 21): You have the right to object at any time to the processing of your personal data when that processing is based on legitimate interest. AGO will then cease processing your data unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
• Right regarding automated decision-making (Art. 22): You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• Right to withdraw consent (Art. 7.3): When processing is based on your consent, you may withdraw that consent at any time. The withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

You have the right, at any time, to lodge a complaint with the French supervisory authority: the Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr.

To exercise any of these rights, please email us at [email protected].

7. Request Process and Response Timing

You may submit a data subject access request by emailing [email protected]. You will need to provide reasonable evidence of your identity so that we can verify your request.

AGO will acknowledge your request within 3 business days and respond within one (1) month of receipt, in accordance with Article 12.3 of the GDPR. If your request is particularly complex or if we receive a large number of requests, this period may be extended by two additional months. In that case, we will notify you of the extension and the reasons for the delay within the first month.

We will provide the information free of charge. However, if your requests are manifestly unfounded or excessive (in particular because of their repetitive character), we may either charge a reasonable fee taking into account the administrative costs, or refuse to act on the request.

We will select a format to provide your personal data that is readily usable and allows you to transmit the information from one entity to another without hindrance.

8. Cookies and Related Technologies

When you use the Site, we may collect certain information by automated or electronic means, using technologies such as cookies, pixel tags, web beacons, browser analysis tools, and web server logs.

A "cookie" is a small amount of information that a web server sends to your browser. It stores information about your account, your preferences, and your use of the Site. Some cookies contain serial numbers that allow us to connect your Site activity with other information we store about you or as related to your interactions with the Site.

Some cookies are temporary, whereas others may be configured to last longer. "Session" cookies are temporary cookies used for various reasons, such as managing page views. Browsers usually erase session cookies once the browser is closed. "Persistent" cookies are more permanent cookies stored on your device even after you close your browser. We use persistent cookies for purposes such as retrieving certain information you have previously provided and storing your preferences.

"Pixel tags" (also known as web beacons or clear gifs) are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed certain specific actions. These tools allow us to measure response to our communications and improve our web pages and promotions.

We collect many different types of information from the devices you use to access the Site, including your operating system type, browser type, domain and other system settings, the language your system uses, the country and time zone of your device, and your IP address.

8.1. Strictly necessary cookies

This category of cookies is necessary to enable you to navigate the Website and use its features, such as accessing secure areas. You may deactivate these cookies using your browser settings, but AGO informs you that their deactivation may lead to reduced performance of the Website.

8.2. Functionality cookies

This category of cookies allows AGO to remember the choices you have made while visiting the Website such as, where applicable, your user name, passwords, and other preferences.

8.3. Performance cookies

This category of cookies only collects information about the use of the Website for the benefit of AGO in order to manage the performance and design of the Website.

We use the services of PostHog and Google Analytics to help us analyze how the Website is used. The information generated by the cookies concerns the use of the Website, in particular your IP address. This data is used on behalf of AGO to evaluate your use of the Website and to compile reports on Website activity. You may refuse the use of cookies by selecting the appropriate settings on your browser or through the cookie consent banner.

8.4. Cookie Consent Management

AGO uses the Cookiebot consent management platform to collect and manage your cookie preferences. When you first visit our Website, a cookie consent banner allows you to accept or reject different categories of cookies. You can adjust your preferences at any time by clicking the cookie icon in the footer of the Website. Your consent choices are stored and respected across your browsing sessions.

9. Security of Personal Data

AGO has implemented an information security program that contains administrative, technical, and physical controls designed to reasonably safeguard personal data. For example, we use industry standard encryption technology (AES-256) to secure personal data when it is stored and when it is being transmitted over the Internet. We also use industry standard security strategies for password encryption, security certification, periodic vulnerability testing, and periodic service, database, and server security scanning. Despite our security program and procedures, you acknowledge and understand that we cannot guarantee that unauthorized access to your personal data will never occur.

10. Data Retention

We keep your personal data for as long as reasonably necessary for the purposes set out in this Privacy Policy, in accordance with the principle of data minimization.

10.1. Regarding AGO's customers, AGO will retain your personal data for a period not exceeding:

• Customer data (non personally identifiable): 3 years after the last interaction;
• Personally identifiable information: only as long as necessary for legitimate business purposes, typically no longer than 3 years after service termination;
• Audit logs: 30 days minimum;
• Backups: 14 days (operational backups);

10.2. Regarding prospects, the data collected on the Website are deleted 3 years after the last contact from the prospect or 3 years after their collection.

Upon reaching the end of the retention period or upon your request, data will be securely deleted in accordance with our Data Disposal Policy, ensuring that it is no longer recoverable.

11. International Transfers

Personal data we collect may be transferred to, used, and stored in the EEA, United States, or other jurisdictions in which AGO, our affiliates, or service providers are located. These locations may not guarantee the same level of protection of personal data as the one in which you live. AGO assesses the circumstances involving all cross-border data transfers and has suitable safeguards in place to require that your personal data will remain protected in accordance with this Privacy Policy.

AGO SASU is headquartered in France, with an affiliate in the United States. AGO has implemented the European Commission's Standard Contractual Clauses (SCCs) for transfers of personal data between our affiliated companies, which require all of our affiliates to protect personal data they process from the EEA in accordance with European Union data protection law. Where applicable, AGO also relies on the EU-U.S. Data Privacy Framework for transfers to certified U.S. based service providers.

We have implemented similar appropriate safeguards with all our third party service providers and partners where legally required. For additional details, please contact our DPO at [email protected].

12. AI Customer Support Services

AGO provides AI powered customer support services to its clients. In this context, AGO acts as a data processor on behalf of its clients, who remain the data controllers for the personal data processed through these services.

The processing of personal data through AGO's AI customer support services is governed by a dedicated Data Processing Agreement (DPA) signed directly between AGO and each client, in compliance with Article 28 of the GDPR.

If you are an end user whose data has been processed through AGO's AI services, please contact the relevant data controller (AGO's client) to exercise your data subject rights. For more information, visit trust.useago.com.

13. Third Party Practices

Websites and apps that may be accessible through links from the Site may have their own privacy statements and data collection, use, and disclosure practices. We are not responsible for and do not monitor the practices of any third parties. Our affiliates, business partners, or service providers may have their own privacy policies as well. We encourage you to read carefully the privacy policies provided by these other parties before providing them with any information or taking advantage of their offers or promotions. AGO is not responsible for the privacy or security of any information you provide to these third parties.

The Site may contain or be linked to online communities, social media platforms, and other areas where you may publicly post and share information (such as LinkedIn, Instagram, or discussion boards). All the information you post will be accessible to anyone with Internet access, and any personal data you include in your posting may be read, collected, and used by others. Please be careful about publicly posting your personal data. Please also refer to the privacy policies of each social media platform you use.

If you have questions about personal data posted in our communities, please contact [email protected].

14. Changes to This Policy

From time to time, we may update this Privacy Policy to clarify our practices, reflect new or different privacy practices, or comply with current laws and regulations. If we make any changes, we will post an "Updated on" date under the Effective Date at the top of this Privacy Policy. We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices.

Your continued use of the Site after we publish and/or send a notice about our changes to this Privacy Policy constitutes your acceptance of the updated Privacy Policy.