Tusky

Privacy Policy

Last updated 11 November 2024

The Privacy Policy is intended to inform the users of the Site and the clients of the Services (hereinafter “You”) about the use of their Personal Data by TUSKY (hereinafter “TUSKY”), owned by ZERO KNOWLEDGE COLLECTIVE SAS a simplified joint stock company under French law, entered on the Paris Trade and Companies Register under number 893 172 429 and whose registered office is located at 59, rue de Ponthieu, Bureau 562, 75008 Paris, when TUSKY acts in the capacity of data controller.

For processing where TUSKY acts in the capacity of data processor as defined by the applicable regulations with regard to the protection of personal data, please refer to the T&Cs, which are available by clicking here.

The Privacy Policy is intended to indicate to you:

  • how Your Personal Data are collected and processed;
  • the applicable rules in terms of security and Your rights over Your Personal Data.

By using the Website and the Services, You represent that You are aware of and accept the terms of the Privacy Policy.

1. Definitions

Capitalised terms and expressions have the meaning given in the T&Cs, whether they are used in the singular or the plural, with the exception of the terms listed hereinafter:

Cookies. Refers to a small computer file, which is deposited and read when You browse the Website, read an email, or install or use the Application regardless of the terminal used (computer, tablet computer, smartphone connected to the Internet, etc).

Applicable Law. The Privacy Policy is governed by French law No. 78-17 of 6 January 1978 and its application legislation, the General Data Protection Regulation of 27 April 2016 (“GDPR”), and any legislation and/or regulation of French law or European law applicable in France that may amend the aforementioned legislation and regulations.

Data Controller. Refers to the legal person who determines the purposes and means of the processing. In the context of the Services, the Data Controller is TUSKY of which the full identity is specified in the introduction to the Privacy Policy.

2. How are Your Personal Data collected and processed?

TUSKY may collect and process Personal Data regarding You, in its capacity as Data Controller, either when You visit the Website or when You use the Services.

TUSKY undertakes to take all necessary measures to ensure that the collection of Your Personal Data is always fair, transparent and strictly necessary for the purpose for which they are collected. TUSKY undertakes to inform of You of the existence and conditions for this collection and shall, where applicable, obtain Your consent.

Request for product updates and promotions

Personal Data collected: Email

Data retention period: 3 years after the last contact and/or from the request for the deletion of the Personal Data.

Request for support

Personal Data collected: Email

Data retention period: Throughout the full duration of the request for support.

Exercising your rights

Personal Data collected: Email. Where applicable: a copy of Your identity card.

Data retention period: Throughout the whole duration of the examination of the request then for 1 year in an archived database (with the exception of the copy of the identity card).

3. For what purposes and on what legal basis are Your Personal Data collected?

TUSKY mainly uses Your Personal Data to enable You to use the Website and the Services, but also to fulfil its legal or regulatory obligations. In particular, TUSKY collects and processes Your Personal Data for the following purposes.

Purpose: Managing Subscriptions
Legal basis: Performance of a contract (article 6.1 b) of the GDPR)

Purpose: Providing and maintaining the Services
Legal basis: Legitimate interest (article 6.1 f) of the GDPR)

Purpose: Processing requests for support
Legal basis: Performance of a contract (article 6.1 b) of the GDPR)

Purpose: Managing and responding to requests to exercise rights
Legal basis: Complying with a legal obligation (article 6.1c) of the GDPR)

Purpose: Sending electronic communications
Legal basis: Consent (article 6.1a) of the GDPR)

Purpose: Sending information about the Services, including confirmations, technical manuals, updates, security alerts, etc.
Legal basis: Consent (article 6.1a) of the GDPR)

Purpose: Complying with French legal and regulatory obligations
Legal basis: Complying with a legal obligation (article 6.1c) of the GDPR)

4. How long are your personal data kept for?

TUSKY only keeps your Personal Data for the duration strictly necessary for the purposes for which they were collected in accordance with the Applicable Law. Personal Data are not kept beyond the duration necessary for the processing purposes in question. The retention periods are specified in Article 2 above.

5. Who does TUSKY share your personal data with?

The Personal Data collected and processed are intended for:

  • TUSKY's in-house departments with the exclusive aim of providing You with Services by means of the Platform. Any people who may have cause to access the Personal Data are bound by a confidentiality obligation and undertake to take strict confidentiality and protection measures with regard to the Personal Data;
  • technical service providers that are bound to TUSKY by a subcontracting agreement pursuant to the provisions of article 28 of the GDPR.

TUSKY may transfer your Personal Data to its subcontractor technical service providers in the context of the following operations:

6. What security measures have been put in place?

TUSKY implements appropriate technical and organisational measures to protect Personal Data against accidental or illegal destruction, loss, alteration, distribution or unauthorised access, and to maintain the confidentiality of Your Personal Data.

7. What are Your rights and how can You exercise them?

Other than in the event of limitations imposed by the Applicable Law and subject to their applicability, You have the following rights:

  • the right to be informed of and access the Personal Data collected and processed by TUSKY by means of the Website. You can be sent a copy of Your Personal Data, as well as specific information about the nature of the processing to which Your Personal Data is subject;
  • the right to the correction of Your Personal Data. You can correct and complete Your Personal Data in the event that they are inaccurate or incomplete;
  • the right to request the deletion and limitation of Your Personal Data. You can request the deletion of Your Personal Data when (i) the Personal Data are no longer required for the purposes for which they were collected, (ii) You intend to exercise Your right to object or (iii) Your Personal Data have been subject to illicit processing. This right does not however apply when TUSKY must retain Your Personal Data to comply with legal obligations or to defend its rights before the competent jurisdictions;
  • the right to the portability of the Personal Data recorded on the Website, this can be exercised by requesting a copy of the Personal Data in electronic format and the right to send these Personal Data to be used by a third party service (article 20 of the GDPR);
  • the right to object to the processing of Your Personal Data in the following situations:
    • the right to object at any time to the processing of Personal Data for reasons related to a specific situation;
    • the right to object to the processing of Personal Data for marketing purposes;

      TUSKY will no longer process Your Personal Data, unless TUSKY demonstrates that there are legitimate and overriding reasons for the processing;
  • the right to define conditions for use, retention and communication after Your death.

You can exercise Your rights via email at support@tusky.io or by making a request with proof of Your identity:

  • by email to the following address: support@tusky.io
  • by traditional mail to the following address: 59, rue de Ponthieu, Bureau 562, 75008 Paris

You also have the right to file a claim with the competent control authority, i.e. the French Data Protection Authority (CNIL): https://www.cnil.fr/

8. Amendments to the Privacy Policy

The Privacy Policy may be amended at any time, in particular to ensure its compliance with legislative and regulatory developments. You will be informed and/or asked to accept such changes if necessary by means of the Website.

Personal Data are collected and processed according to the Privacy Policy in force at the time when they are collected, unless an essential legal requirement provides otherwise with retroactive application.

TUSKY advises you to consult the Privacy Policy whenever you visit the Website to be aware of any modifications or updates that have been made.

9. Analytics

Fathom Analytics

We use Fathom Analytics (https://usefathom.com/), a privacy-focused alternative to Google Analytics, to understand how our users engage with our website. We will never sell this data to third parties.

Fathom Analytics collects information about your use of the website, while protecting your privacy, to help create reports and statistics on the performance of the website.

Fathom Analytics' technology doesn't actually use Cookies. You can read about it here: https://usefathom.com/data

10. Contact

If you have any doubts or questions about the confidentiality and use of Personal Data by TUSKY through the Website, You may send Your request to the following email address: support@tusky.io

For any information on the protection of Personal Data, You can consult the website of the French Data Protection Authority (CNIL): www.cnil.fr