Privacy Policy
As the protection of your data is a major matter of concern for us, we want to take the time to inform you about what data we use during your visit and why we use it. If you still have questions on the way we work with your personal data, you can refer to our data protection officer (contact details below).
The meaning of “personal data” is defined in the General Data Protection Regulation (GDPR). According to the new regulation, personal data includes all information that refers to an identified or identifiable natural person. This can include for example, your rightful name, your address, your telephone number or your date of birth. Even information on how you can use this or other websites may contain personal data.
As soon as we have your consent to process personal data, Article 6.1(a) GDPR serves as the legal basis for processing your personal data.
When processing your personal data to perform a contract between you and TOWARD SAS, Article 6.1(b) GDPR serves as the legal basis. This also applies to processes required to conduct pre-contractual activities.
When processing personal data to perform a legal obligation to which our companies is subject, Article 6.1(c) GDPR serves as the legal basis.
Article 6.1(f) GDPR provides the legal basis for processing when the processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party and where such interests are not overridden by the interests or fundamental rights and freedoms of the data subject.
Your personal data will be deleted or the processing will be restricted as soon as the data has met the purpose for which it was stored. Storage of the data beyond this may be possible if this is stipulated by European or national legislators in EU directives, laws or other regulations to which the controller is subject. The data will be deleted or its processing will be restricted when a prescribed deadline expires, unless it is necessary to continue storing the data to conclude or perform a contract.
We use the information that we collect in a variety of ways in operating our business, including the following:
1. Improvements
We use the information to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the website, and to develop new products, services, feature, and functionality. Should this purpose require TOWARD to process Client Data, then the data will only be used in anonymized or aggregated form.
2. Communications
We may use a Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User for administrative purposes such as customer service or other.
3. Cookies and Tracking Technologies
We use automatically collected information and other information collected on the website through cookies and similar technologies to: (i) provide customized content, and information; (ii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iii) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (iv) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
4. Analytics
We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Site, and create user navigation reports for our Site administrators.
The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Site, and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users’ and Visitors’ activity on our Site.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
For more information, see Google Analytics Privacy and Data Sharing.
Purposes of the processing
On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services related to website and Internet use.
Legitimate interests
The legitimate interest in the data processing lies in the optimization of our website, the analysis of the use of our website and the adaptation of its contents. The interests of users are adequately protected by pseudonymisation.
Legal basis
The legal basis for the use of Google Analytics is Article 6.1 (f) GDPR.
Recipients or categories of recipients
The recipient of the collected data is Google.
Transfer to third countries
Personal data will be transferred to the USA under the EU-US Privacy Shield on the basis of the European Commission’s adequacy decision. You can download the certificate here.
Data storage – duration
The data sent by us and linked to cookies, user-identifiers (e.g. User IDs) or advertising-identifiers are automatically deleted after 14 months. Data whose retention period has been reached is automatically deleted once a month.
Objection
You can prevent the storage of cookies at any time by adjusting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser add-on. Opt-out cookies will prevent future collection of your data when you visit this website. To prevent Universal Analytics from collecting data across different devices, you need to opt-out of all systems used.
Active Campaign
TOWARD uses Active Campaign as a marketing tool to send part of its communications. By accepting the TOWARD Privacy Policy, you understand that the information you provide will be transferred to Mailrelay for processing according to its privacy policy.
We also collect your personal data when you yourself give your approval to do so – for example when you want us to contact you. Of course, personal data transferred in this manner is solely used for the purpose intended: establishing contact.
These details are provided voluntarily and, in these cases, are initiated by you yourself. Provided the details supplied are details of communication channels (such as email address, phone number), we will use these channels to contact you to deal with your concerns.
Purpose of the processing
The purpose of processing your data in this sense is to deal with and answer your concern.
Legitimate interests
The purpose described also represents the legitimate interest in processing your data.
Legal basis
The legal basis for processing the data you entered to establish contact with us is Article 6.1(f) GDPR.
Data storage – duration
We will delete the data we received from you in establishing contact either as soon as it is no longer required to fulfil the purpose for storing it, as soon as your concern has been dealt with in full and no further communication with you is necessary, or if you wish us to delete the data.
Objection
You can refer to our data protection officer at any time with respect to deleting the data to your query (see below for contact details). However, this might also mean that we cannot fully deal with your concern.
So-called social bookmarks (e.g. from Facebook, Twitter, YouTube, LinkedIn and GitHub) have been integrated on our website. Social bookmarks are internet bookmarks that allow users of such services to collect links and news messages. These are only included on our website as a link to the corresponding services. After clicking on the integrated graphic you will be forwarded to the page of the respective provider, i.e. only then will user information be transferred to the respective provider. For information on the handling of your personal data when using these websites, please refer to the respective data protection regulations of the providers.
Except as described in this Policy, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the website to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
1. Service Providers
We work with third party service providers who provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
2. Non Personally Identifiable Information
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the website.
3. Law Enforcement, Legal Process and Compliance
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the website and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
4. Change of Ownership
Information about Users and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or Visitor Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.
Client Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Service, and only if the recipient of the Client Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact us.
Gladly we will inform you whether and which of your personal data is processed by us and for what purposes (Article 15 of the GDPR). Furthermore, given the respective legal conditions, you have to the right to rectification (Article 16 GDPR), the right to restrict processing (Article 18 GDPR), the right to erasure (Article 17 GDPR), the right to object (Article 21 GDPS) and the right to data portability (Article 20 GDPR).
Irrespective of these rights and the possibility of asserting another administrative or legal redress, you also have the possibility at any time of asserting your right to complain to a supervisory authority, in particular, in the member state of your place of domicile, of your place of work or of the location of the alleged infringement if you are of the view that the processing of personal data affecting you infringes legal data protection regulations (Article 77 GDPR).
The controller within the meaning of the General Data Protection Regulation is
TOWARD SAS established in
55, Avenue Louis Breguet, La Cité,
Toulouse, Occitanie 31400, France
For contact us visit page: Contact TOWARD.
Amendments to this privacy statement
We reserve the right to amend this privacy statement at any time, taking account of applicable data protection regulations. Last updated: 2021.