v 1.1 of 15.10.2018

This privacy policy defines and informs you of the way in which OCTOPUSH uses and protects the information that you transmit to us, if applicable when you use this site, is accessible from the following URL: octopush.com

These are an integral part and are subject to the General Conditions of Sale and Use of OCTOPUSH.

It defines OCTOPUSH’s commitments with regard to the protection of the personal data of its Users as required by the European regulations in force.

In addition to the articles of this undertaking, OCTOPUSH undertakes to comply in general with the clauses of L119 / 1 REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 relating to the protection of individuals when it comes to the processing of personal data and the free movement of such data, and repealing Directive 95/46 / EC (General Data Protection Regulation) (hereafter: GDPR).

Please note that this privacy policy may be amended at any time by OCTOPUSH, in particular in order to comply with any legislative, regulatory, jurisprudential, or technological developments. In such an instance, the date of its update will be clearly identified at the top of this policy. These modifications apply to the User from the moment they are landing on our website. The User should therefore regularly consult this confidentiality and use of cookies policy in order to be aware of any changes.

I. POLICY RELATING TO PERSONAL DATA

1. IDENTITY OF THE DATA CONTROLLER (DPO) Octopush has appointed a data controller (Data Protection Officer). Mail: dpo (arobase) octopush.com Tel: +33 (0) 4 13 41 50 70

2.PERSONAL DATA In general, you can visit the OCTOPUSH site without disclosing any personal information about yourself. In any event, you are in no way or form obliged to transmit this information to OCTOPUSH. However, if you decide not to provide personal data, you may not be able to benefit from certain information or services that you have requested.

3. TYPOLOGY OF DATA COLLECTED

3.1 Registration details When registering with OCTOPUSH, the User expressly consents to communicate personal data to OCTOPUSH. The data transmitted may include the user’s first name, last name, postal address, email address, telephone number, company name as well as his identification number and, where applicable, the intra-community VAT number.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

3.2 Cookies OCTOPUSH uses different types of cookies on its site, including: i. Strictly necessary/essential cookies: These cookies are essential in order to allow the User to move around the site and use its features, such as access to secure areas of the site, shopping cart, or billing pages. Without these cookies, the services that the User has requested cannot be provided. These cookies do not collect information that identifies a visitor. Accepting these cookies is a necessary condition for the use of the OCTOPUSH site, if the User refuses their use, OCTOPUSH cannot ensure optimal navigation on its site.

ii. Performance cookies: These cookies collect information about how visitors use a website, such as which pages visitors visit most, and error messages from OCTOPUSH pages. These cookies do not collect information that identifies a visitor. All the information collected by these cookies is aggregated and therefore anonymous. These cookies are used for statistical purposes as well as to improve the functioning of a website. Accepting these cookies is a necessary condition for the use of the OCTOPUSH site, if the User refuses their use, OCTOPUSH cannot ensure optimal navigation on its site.

iii. Functionality cookies: These cookies allow the OCTOPUSH site to remember the choices made by the User (such as their language) and to provide improved and more personal features. These cookies can also be used to remember the modifications that the User has made to the parts of their account that can be personalised. They can also be used to provide services requested by the User, such as watching a video or commenting on a blog. The information collected by these cookies may be anonymous and cannot track the User’s browsing activity on other websites. The User can choose to accept or reject these cookies, but refusing them could prevent OCTOPUSH from providing the User with certain features or support. It is also possible that this prevents OCTOPUSH from memorising the User’s refusal to use a specific feature.

iv. Targeting cookies: These cookies are used to deliver advertisements that are more relevant to the interests of the User. They are also used to limit the number of times a User is faced with an advertisement as well as to measure the effectiveness of advertising campaigns. They are usually placed by advertising networks with the permission of the site operator. They remember that the User has visited a website and that this information is shared with other organisations such as advertisers. Quite often, targeting cookies are linked to site functionality provided by third parties. The User can choose to accept or refuse these cookies, but refusing them could prevent OCTOPUSH from providing the User with certain functionalities. These cookies are placed by third parties, so the User can also choose to use their own tools to refuse these cookies.

4. PURPOSES OF THE PROCESSING

OCTOPUSH may process your Personal Information: i. For the purpose of providing you with the information or services that you have requested in the context of the commercial relationship established between the two parties; ii. For the purpose of collecting information allowing us to improve our site, our products and services (in particular by means of cookies); iii. For the purpose of contacting you about various events relating to OCTOPUSH; iv. In order to manage customers, manage the management of orders and SMS campaigns, after-sales service and commercial prospecting. 5. DURATION OF CONSERVATION Your personal information is kept by OCTOPUSH for the time corresponding to the purpose of the collection. This time must be included for the entire duration of the commercial relationship established between OCTOPUSH and the User. However, at the end of the contract, OCTOPUSH reserves the right to keep in its archives the data about which OCTOPUSH is subject to legal storage and/or archiving obligations provided for by European Union law or the law of a Member’s State. Access to the archives will be reserved only to persons authorised by OCTOPUSH.

6. COMPUTER RIGHTS AND FREEDOMS The User may contact the Data Controller (DPO) in order to express any request in connection with his rights as provided for by the GDPR. OCTOPUSH undertakes to respond as best as possible to the requests of its Users, as soon as possible and within the limits of its legal or regulatory obligations.

6.1 Right of access and communication of data You have the right to access Personal Information concerning you. However, because of the obligation of security and confidentiality in the processing of personal data which is incumbent on

OCTOPUSH, you are informed that your request will be processed provided that you provide proof of your identity, in particular by the production of ” a scan of your valid identity document or a signed photocopy of your valid identity document (in case of a request by post).

OCTOPUSH informs you that it will be entitled, if necessary, to oppose clearly abusive requests (by their number, their repetitive or systematic nature).

To help you in your process, in particular, if you wish to exercise your right of access by means of a written request to the postal address mentioned in the legal notices, you will find a model letter developed by the National Commission of Computing and Liberties (CNIL): https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces

6.2 Right to rectify data Under this right, the legislation empowers you to request the rectification, updating, blocking, or even erasure of your personal data which may prove to be inaccurate, erroneous, incomplete or obsolete.

Also, you can define general and specific directives relating to the fate of personal data after your death. Where applicable, the heirs of a deceased person may require the passing of their loved one to be taken into account and/or to carry out the necessary updates.

To help you in your process, in particular, if you wish to exercise, on your own account or on behalf of one of your deceased relatives, your right of rectification by means of a written request to the postal address mentioned in the legal notices, you will find below the link of a model of mail elaborated by the CNIL: https://www.cnil.fr/fr/modele/courrier/supprimer-des-informations-vous-concernant-dun-site-internet

6.3 Right of objection The exercise of this right is only possible in one of the following two situations: i. When the exercise of this right is based on legitimate reasons; ii. When the exercise of this right is intended to prevent the data collected from being used for commercial prospecting purposes.

To help you in your process, in particular, if you wish to exercise your right of opposition by means of a written request addressed to the address mentioned in the legal notices, you will find below a model letter prepared by the CNIL: https://www.cnil.fr/fr/modele/courrier/supprimer-des-informations-vous-concernant-dun site-internet

7. SECURITY In order to guarantee maximum security and optimum protection of the data of its Users, OCTOPUSH implements technical and organisational security measures appropriate to the possible risks to which the data may be exposed.

In accordance with GDPR directives, OCTOPUSH sets up means to guarantee the confidentiality, integrity, and availability of personal data and systems and services for processing such data.

OCTOPUSH ensures the proper functioning of the security measures put in place, and their regular updates, taking into account the evolution of practices in the sector as well as appropriate technologies. More specifically, the OCTOPUSH application is installed on redundant servers, ensuring the maintenance of the services offered, as well as the integrity of your data. A monitoring server is set up to launch alerts in the event of a system failure and/or an intrusion attempt. These servers are located in a French Datacenter certified ISO-27001.

A copy of the application data is also made regularly in order to recover the system in the event of a major failure. Access to these servers is secured by routing and firewall rules. To access the platform by a web browser, API, or third-party services, OCTOPUSH offers an HTTPS path benefiting from an AES 256 encryption certificate. Users’ passwords are also encrypted in a non-reversible manner. OCTOPUSH will not be able to know the clear passwords of the Users, who will therefore be the only ones to hold this information.

Finally, access to the service by API can be limited to particular IPs at the request of the User.

8. AUTHORISED SERVICE PROVIDERS AND TRANSFER TO A COUNTRY LOCATED OUTSIDE OF THE EUROPEAN UNION

OCTOPUSH informs you that it uses authorised service providers to facilitate the collection and processing of the data you have communicated to us. These service providers may be located outside the European Union and communicate the data collected through the various forms on the Site.

OCTOPUSH has previously ensured that its service providers have implemented adequate guarantees and that strict conditions of confidentiality, use, and data protection are observed. In particular, caution has been based on the existence of a legal basis for carrying out any transfer of data to another country.

The User accepts and authorises OCTOPUSH to enter into an agreement or to take all necessary measures to establish and ensure an adequate level of protection of personal data by a subcontractor.

9. COMPLAINT WITH THE COMPETENT AUTHORITY If you consider that OCTOPUSH is not fulfilling its obligations with respect to your Personal Information, you can address a complaint or request to the competent authority. In France, the competent authority is the CNIL to which you can send a request electronically by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet

10 – MEASURES IN CASE OF BREACH OF USER’S PERSONAL DATA In accordance with the requirements of the GDPR, OCTOPUSH undertakes to notify the CNIL of any personal data breach, as soon as possible after becoming aware of it.

Any notification to the CNIL will include the following information: i. The nature of the personal data breach; ii. The name and contact details of the Data Controller (DPO) within OCTOPUSH; iii. The likely consequences of the personal data breach; iv. The measures that have been taken or that the controller proposes to take to remedy the personal data breach, including, where applicable, measures to mitigate any negative consequences.

In the event that the violation of personal data is likely to generate a high risk for the rights and freedoms of a User, as a natural person, OCTOPUSH undertakes to notify the User as soon as possible.

11. CONFIDENTIALITY OF YOUR PASSWORD You are responsible for the confidentiality of the password you have chosen to access your account on OCTOPUSH.

You agree to keep this password secret and not to communicate it to anyone.

II. COOKIES POLICY

When you first connect to the OCTOPUSH site, you are warned by a banner located at the bottom of your screen (below) that related information may be saved in files called “cookies”:

“By continuing to use this site you consent to the use of cookies which allow us to personalise content and ads, provide social media features, and analyse our traffic. We use a Google Analytics script which places cookies. To learn more, please see our privacy policy. “

This cookie use policy informs you about the provisions we implement in terms of web browsing.

We invite you to read this document carefully to know and understand our practices regarding the processing of your personal data that we implement.

1 – GENERAL INFORMATION ON COOKIES OCTOPUSH, as the publisher of this website, may install a cookie on the hard drive of your terminal in order to guarantee you smooth and optimal navigation on our site.

“Cookies” are small text files of limited size which allow us to recognise your computer, tablet, or mobile device in order to personalise the services we offer you (content, ads, features, etc.).

“Cookies” do not allow you to be identified. They are used for the sole purpose of improving the interactivity and performance of our site and to deliver relevant content to you. This information is not communicated to third parties except when OCTOPUSH has obtained your prior consent or when the disclosure of this information is required by law, by order of a court, or any other authorised administrative or judicial authority.

2. SOCIAL NETWORK COOKIES Social network sharing cookies are issued and managed by the publisher of the relevant social network. Subject to your consent, these cookies allow you to easily share part of the content published on the OCTOPUSH Site, in particular through a sharing application button depending on the network concerned.

Three types of social networks sharing cookies are present on the OCTOPUSH site: i. Facebook, whose cookie policy can be consulted by clicking on the following link: https://fr-fr.facebook.com/policies/cookies/ ii. LinkedIn, whose cookie policy can be consulted by clicking on the following link: https://fr.linkedin.com/legal/cookie-policy policy? | = fr FR iii. Twitter, whose cookie policy can be consulted by clicking on the following link: https://support.twitter.com/articles/20170518#

3. SETTING THE COOKIES The vast majority of web browsers provide the default configuration so that the deposit of cookies is authorised. However, you have the option to modify this default setting so that all or some of the cookies are systematically rejected.

You must understand that the refusal of cookies may alter your user experience as well as compromise certain features of the site offered by OCTOPUSH. Where applicable, OCTOPUSH declines all responsibility for the consequences related to the degradation of your browsing conditions and your user experience. These consequences do not constitute damage and you cannot claim any compensation for it.

Your browser also allows you to delete existing cookies on your terminal or to notify you when new cookies are likely to be placed on your terminal. These settings have no effect on navigation but will make you lose all the advantages of using cookies.

4. CONFIGURATION OF THE INTERNET BROWSER To help you change your cookie preferences, you will find below the links to help you access your browser menu:
   (i) Chrome: https://support.google.com/chrome/answer/95647?hl=fr
   (ii) Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies
   (iii) Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet explorer-delete-manage-cookies # ierie-11
   (iv) Opera: http://help.opera.com/ (v) Windows / 10.20 / en / cookies.html (vi) Safari: https://support.apple.com/kb/PH27411?viewlocale=fr

For more information on the tools you may need for controlling cookies, you can consult the CNIL website: https: /www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.

5. USE OF THIRD-PARTY COOKIES Please note that OCTOPUSH uses the services of third parties to learn about your use of its site, in order to optimise your user experience. These third parties (such as web traffic analysis services) may also use cookies that we have no control over.

CONTACT: For any question relating to this privacy policy or for any request relating to your personal data, you can contact us by: (i) Sending an email to our data protection officer at the following email address: dpo (at) octopush.com (ii) Or by writing to us at the following address: 131 av du Prado – 13008 Marseille – France.