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Privacy Policy

Latest update: April 2024

Wakam attaches the greatest importance to the protection of privacy and personal data collected in the course of its activities, as well as to compliance with applicable laws and regulations in this area.

This privacy policy (“Policy”) tells you how we collect, use, secure and share your personal information that we collect when you visit our websites (“Websites”) and use our Services (“Services”).

We may modify this policy from time to time. We always indicate the date of publication of the last modifications. If the changes are material, you will be notified before the change takes effect, either via a notice on our websites or by e-mail sent to the e-mail address we have on file for you .

We may provide “just-in-time” disclosures or additional information about our data collection, use and sharing practices for specific Services. These notices may supplement or clarify Wakam’s privacy practices or may provide you with additional choices about how Wakam treats your personal information.

If you are uncomfortable with any part of this policy, you should stop using our websites and services.

  1. SCOPE

We provide this policy to explain how we collect, use and share personal information about individuals who:

  1. ENTITY RESPONSIBLE FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA

Personal data is subject to processing by Wakam, a limited company with share capital of EUR 5 432 928, whose head office is located at 120-122 rue Réaumur, 75002 Paris, France, registered with the RCS of Paris, under number 562 117 085, whose intra-community VAT number is the following: FR59562117085 and Wakam UK Limited is a company registered in England and Wales with company number 14778827, having its registered office at 18th & 19th Floors 100 Bishopsgate, London, United Kingdom, EC2N 4AG. Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority under Firm Reference Number 995565..

For all of these processing operations, Wakam and Wakam UK Limited are the entities which determine the means and purposes, and thus act as data controllers, within the meaning of the regulations applicable to personal data and in particular EU Regulation 2016/679 relating to the protection of individuals with regard to the processing of personal data and the free movement of such data, and, for Wakam UK Limited ., the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 18).

  1. PERSONAL DATA COLLECTED AND PROCESSED BY WAKAM

Wakam and Wakam UK Limited collect and process various personal data when browsing websites and using services:

Personal data that you communicate to us, in particular:

  • Registration / profile: we collect the mandatory and necessary data to create your user account and give you access to our services, namely, your first name, last name, email address, telephone number and your password
  • Other: Any other information about you that you can give us

Data that we collect automatically in order to improve our services and navigation on our Websites, in particular:

  • Logs
    • As with most websites and services provided over the Internet, we collect certain information and store it in logs when you interact with our websites and services. This information includes Internet Protocol (IP) addresses as well as browser type, Internet service provider, referring/exit page URLs, operating system, date/time stamp, the information you searched for, language and regional preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information.
    • Occasionally, we connect personal information with other information collected in our log files as necessary to improve our websites and services. In such a case, we would treat the combined information in accordance with this policy.
  • Session replays
    • With regards to our Services, we may also use website analytics tools to better understand the needs of our users and optimise our services and user experience. These website analytics tools provide us with heat maps, session recordings of your website activities and service usage. We may also record your clicks, mouse movements, scrolling, form fills (keystrokes) in non-excluded fields and other metadata such as IP address or device type.
  1. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA

We collect and process your personal data to:

  • provide, operate, maintain and improve the Websites and Services;
  • allow you to access and use the Services;
  • process and complete transactions and send you related information, including purchase confirmations and invoices;
  • send transactional messages, including responses to your comments, questions and requests, provide customer service and support, and send you technical notices, updates, security alerts, and support and administrative messages ;
  • send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests and events; and provide other news or information about us and our partners;
  • monitor and analyse trends, usage and activities in connection with the Websites and Services and for marketing or advertising purposes;
  • investigate and prevent fraudulent transactions, unauthorised access to the Services and other illegal activities;
  • personalise the Websites and Services, including by providing features or advertisements that match your interests and preferences;
  • and comply with our legal obligations, including our obligations related to the protection of personal data.
  1. PERSONAL DATA RETENTION DURATION

Wakam and Wakam UK Limited retain your personal data only for as long as necessary to fulfill the purpose for which they holds the data in question, in order to meet your needs or to fulfill Wakam/Wakam UK Limited’s legal obligations.

Wakam and Wakam UK Limited may retain certain personal data in order to fulfill its legal and/or regulatory obligations and to exercise its rights (such as filing an appeal before a court) or for statistical or historical purposes.

In this case, all measures are put in place to ensure data security.

When Wakam and Wakam UK Limited no longer need to use your personal data, they will delete it from their systems and files or anonymise it so that it can no longer identify you.

  1. PERSONAL DATA IT SECURITY SYSTEM

Wakam and Wakam UK Limited undertake to protect personal data collected and/or processed against any loss, destruction, alteration, unauthorised access or disclosure.

To do this, Wakam and Wakam UK Limited implement appropriate technical and organisational measures, taking into account the nature of the data and the risks that their processing entails, to preserve the security and confidentiality of your personal data. These measures may in particular include practices such as limited access to data by staff of departments authorised to access it due to their functions, contractual guarantees in the event of recourse to an external service provider, impact studies on life privacy, regular reviews of our privacy practices and policies and/or physical and/or logical security measures (secure access, authentication process, backup copies, antivirus software, firewall, etc. ).

  1. RECIPIENTS OF PERSONAL DATA

Your personal data may be transmitted to the following recipients:

  • Wakam/Wakam UK Limited group entities, third parties and individuals acting within the framework of their usual business activities/employment functions, including but not limited to:
  • personnel responsible for the award, management and execution of contracts, including complaints;
  • management delegates, insurance intermediaries, insurance organisations responsible under a partnership contract for managing Wakam/Wakam UK Limited insurance contracts and their subcontractors;
  • courts, arbitrators, mediators;
  • supervisory and control authorities and all authorised public bodies;
  • internal and external auditors.

Wakam/Wakam UK Limited does not share your personal data with third party marketing companies. 

  1. EXERCICE OF YOUR RIGHTS

In accordance with current regulations and legislation, you have the right to access and rectify your personal data as well as the right to request their erasure (right to be forgotten), the right to object to their processing and to obtain limitation or portability to the extent that this is applicable, subject to compelling legitimate reasons that Wakam could justify for retaining your personal data.

Regarding the processing of your personal data that we collect/process, you can exercise the following rights:

  • a right to information: you have the right to obtain clear, transparent and understandable information on how we use your personal data and on your rights;
  • a right of access: you have the right to request access to the personal data that we hold about you, and you can request a copy of it;
  • a right of rectification: you can request rectification of any inaccurate personal data concerning you;
  • a right to erasure: you can request the deletion of your personal data in certain circumstances;
  • a right to portability: under certain conditions you can receive all the personal data concerning you that you have provided to us, in a structured format. You also have the right to demand that we transmit them, where possible, to another data controller;
  • a right to object to processing based on legitimate interests;
  • a right to withdraw consent at any time;
  • a right to restriction of processing: you have the right to restrict the processing of your personal data if:
    • you contest the accuracy of your personal data, until we verify their accuracy;
    • the processing is unlawful but you do not want us to delete your personal data;
    • we no longer need your personal data for the purposes of processing but you need this personal data in order to bring, assert or defend against legal claims;
    • you are opposed to the processing based on reasons linked to your particular situation, pending verification whether our legitimate and compelling reasons for continuing the processing override these interests

If such personal data is subject to such limitations, we will only process your personal data with your consent, or for the purposes of bringing, asserting or defending against legal claims.

When you send us a request to exercise rights, you are asked to specify as much as possible the scope of the request, the type of right exercised, the processing of personal data concerned, and any other useful element, in order to facilitate the examination of your request. In addition, you may be asked to provide proof of your identity.

When you exercise your rights, our Data Protection Officer processes your personal data for the purposes of managing your request (title, surname, first name, copy of identity document, nature of the request, response provided). This personal data is kept for a period of three (3) years, with the exception of the copy of your identity document, which is kept for one (1) year.

  1. ADDRESS TO EXERCISE YOUR RIGHTS

For any information or exercise of your rights regarding the processing of personal data managed by Wakam, you can contact our Data Protection Officer (DPO)

  • email : dpo@wakam.com
  • by postal mail to the following address: WAKAM S.A, For the attention of the data protection officer (DPO), 120 rue Réaumur, 75002 PARIS OR Wakam UK Limited, 18th & 19th Floors 100 Bishopsgate, London, United Kingdom, EC2N 4AG.

You also have the right to refer any complaint relating to the way in which Wakam S.A. collects and processes your data to the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, or, for Wakam UK Limited, to the Information Commissioner’s Office Making a complaint | ICO.