Privacy Policy
Updated on January 31, 2023
The Website https://bluegpt.app (hereinafter the “Website”) is the property of InspireLabs, a french SAS, société par actions simplifiée, with a share capital of 100 euros, registered with the Toulouse R.C.S, under number 948 309 059, headquartered in: InspireLabs - 5 chemin de Gramont - 31200 TOULOUSE (hereinafter referred to as “BlueGPT“) which, in its capacity as the person responsible for processing personal data, attaches great importance to the protection and respect of privacy.
The purpose of this privacy policy is to inform, while browsing the Website, any person using the Website
and its services (hereinafter the “Users”; or “User”) of BlueGPT practices regarding the conditions of collection, use and sharing of information that Users are required to provide as well as their rights.
The Website comply with French and European legal standards regarding the protection of privacy and personal data, and in particular with the French law n°78-17 of January 6, 1978, named “Loi informatique et Libertés”, and the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR"), regarding the protection of individuals with regard to the processing of personal data and the free circulation of such data.
IMPORTANT: NOTE TO USERS
ANY NAVIGATION ON THE WEBSITE AFTER THE PUBLICATION OF THIS PRIVACY
POLICY CONSTITUTES ACCEPTANCE OF THIS POLICY WITHOUT RESERVE.
If the User wishes to withdraw his/her consent to the processing of his/her data, he simply needs to request it directly by email at the following address: [email protected]
Furthermore, assuming that it is required by law and/or in certain circumstances, the User’s consent will be collected, or a possibility of refusal will be provided before any data is transmitted.
- Person responsible for processing the personal data collected
The person responsible for processing personal data is BlueGPT.
- Nature of the data collected
The data collected on the Website in the context of the use of the services are those enabling BlueGPT to identify Users directly or indirectly and to provide the services.
This may include the following categories of data concerning its Users
- data of civil status, identity, identification such as name, first name, postal address, e-mail address, telephone number;
- data relating to personal life such as delivery address;
- economic and financial data such as payment data;
- security data such as passwords; and
- connection data such as IP address and navigation data such as cookies.
The compulsory or optional nature of the personal data collected and the possible consequences of a failure to reply are indicated at the time of their collection on the associated forms.
Users who communicate the personal data of a third party will have to confirm that they have the consent of this third party for the use of the personal data of the latter by the Website.
- Purpose and legal basis of processing activities
a. Purpose of processing activities
The personal data collected on the Website are used only for and during the execution of services for the
following purposes:
- management of the commercial relationship:
- processing and management of the User's orders;
- communication with the User;
- customer testimonies;
- commercial prospecting on all the offers of BlueGPT;
- sending newsletters on products, services and new features;
- good functioning and continuous improvement of the Site and its functionalities:
- general administration of the Site;
- general management of the security of the Site;
- collection of information by means of cookies and other tracers;
- commercial evaluation of the services of BlueGPT:
- data analysis;
- identification of usage trends;
- determining the effectiveness of promotional campaigns;
- monitoring performance of the Site;
- evaluating services, products, marketing and customer experience.
In addition, BlueGPT may use and/or keep the data to meet, where appropriate, its legal and/or regulatory obligations.
b. Legal basis of processing activities
The processing activities and the personal data collection are authorized based on the following legal bases:
- The execution of contractual obligations, for the management of the commercial relationship;
- The consent of the User, for:
- commercial prospecting ;
- sending of newsletters;
- commercial evaluation of services; and
- deposit of cookies and other tracers.
- The legitimate interest to guarantee the best level of operation and quality of the Site for the proper functioning and continuous improvement of the Site.
c. Aggregation with non-personal data
BlueGPT reserves the right to publish, disclose and use aggregated information (information about Users or specific groups or categories of Users combined so that an individual User can no longer be identified or mentioned) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes, and other commercial purposes.
d. Timing of data collection
The data collected by BlueGPT is freely communicated by the Users during the registration procedure on the Site, during the order procedure or during the registration to the newsletter on the Site.
Data, such as connection data, can also be collected automatically while using the Website; in particular when the User:
- browses the pages of the Website;
- subscribes to the newsletter;
- registers on the Site;
- and/or subscribes to services.
These automatically collected data only the use of the services exclusive from the identity of the User. This collection is necessary to maintain and operate BlueGPT's services and for its internal analysis and reporting.
This information includes:
- information about how the services are used (frequency, traffic data, how the User reached the Site);
- information about the device used to access the services (device name, country, location, IP address, browser and device characteristics, operating system, language preferences, referring URL).
In any case, the personal data collected:
- will be obtained and processed fairly and lawfully;
- will be recorded for determined and legitimate purposes;
- will be used in accordance with these purposes;
- is adequate, relevant, and not excessive in relation to these purposes; and
- will be treated with caution to ensure its security and confidentiality in order to prevent it from being damaged, modified, destroyed, or communicated to unauthorized third parties.
e. Recipients of personal data
The recipient of personal data collected on the Website is first and foremost BlueGPT.
The personal data are not communicated to third parties with the exception of the partners of BlueGPT whose communication of personal data is necessary within the framework of the realization of the services proposed by BlueGPT (execution, treatment, management and payment of the orders), with the analysis and the follow-up of the data.
However, the partners undertake to scrupulously respect the provisions of the “Loi Informatique et Libertés” and the GDPR as well as future new provisions.
However, other recipients may have access to personal data. These are, where appropriate, the service providers in charge of the Website of BlueGPT (administration, sales, marketing, legal etc.) and its external service providers (technical service providers, access providers, communication agencies, etc.).
In the event of a change of control of BlueGPT or a merger, an acquisition, a collective procedure or any other form of transfer of assets, the data collected by BlueGPT may be transferred to third parties. Nevertheless, BlueGPT will ensure the confidentiality of the personal data collected and to inform the Users before such data is transferred or subjected to new confidentiality rules.
If required by law, User's consent will be obtained, or a possibility of refusal will be arranged before any data is transferred.
Data collected may also be transferred if vital interests are at stake and BlueGPT believes it is necessary to investigate, prevent or take action to prevent potential violations of its policies and more broadly in situations involving suspected fraud, potential security threats and illegal activities or may be used as evidence in litigation involving BlueGPT.
f. Rights of Users
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April
2016 known as the “GDPR” relating to the protection of individuals with regard to the processing of personal data and to the free circulation of such data and with Law no.78-17 known as the “Informatique et Libertés” law of 6 January 1978, amended by Law 2004-801 of 6 August 2004 relating to information technology, files and liberties, the User has the right to access, modify, correct and delete any personal data:
- the right of access to his/her personal data;
- the right to modify his/her personal data;
- the right to rectify his/her personal data;
- the right to delete and erase his/her personal data;
- the right to object to the use of his/her personal data;
- the right to limit the processing of his/her personal data; and
- the right of portability of his/her personal data, when the data is subject to automated processing based on consent or contract;
- a right to withdraw consent at any time; anda right to determine what happens to his or her data after his or her death.
Users wishing to exercise their rights may send their request via the form for exercising their rights, by e-mail or by post to the following addresses:
- Postal mail: InspireLabs - 5 chemin de Gramont - 31200 TOULOUSE
- Electronic mail: [email protected]
In the event of exercising one of these rights, the Users must send BlueGPT the elements necessary for his/her identification: surname, first name, email, and possibly postal address.
Moreover, in accordance with applicable regulations, User’s request must be signed, accompanied by a photocopy of an identity document bearing their signature, be clear and specify in detail the right they wish to implement and the address in which they wish to receive the reply in the event of implementation of one of the rights listed above.
BlueGPT then undertakes to reply within a maximum period of one (1) month following receipt of the User’s complete request.
Due to the complexity of the request and/or the number of requests, this deadline may be extended to two (2) months on condition that BlueGPT informs the User within one (1) month of receipt of the request of the reasons for the postponement.
BlueGPT informs Users of their right to lodge a complaint with the National Commission for Information Technology and Civil Liberties (hereafter the "CNIL") in one of the ways indicated below:
- By phone: +33 1 53 73 22 22
- By fax: +33 1 53 73 22 00
- Via the CNIL website : www.cnil.fr/fr/plaintes ou www.cnil.fr
- By postal mail:
Commission Nationale de l'Informatique et des Libertés - CNIL
3 Place de Fontenoy
TSA 80715 - 75334 PARIS CEDEX 07.
g. Data retention period
g.1 Retention of data for the duration of the contractual relationship
The personal data of the Users collected is not kept beyond the time necessary for the execution of the obligations of BlueGPT defined at the time of the conclusion of the contract or the predefined duration of the contractual relationship, except for the data that BlueGPT would need to keep as evidence, for legal, administrative needs or in accordance with the legislation in force.
Personal data whose collection is not necessary for the performance of the services of BlueGPT, will be deleted and if necessary, anonymized or stored in a secure manner preventing any further processing pending their deletion.
g.2 Retention of anonymized data after deletion of the User's account
BlueGPT keeps the personal data of Users collected for the duration strictly necessary to achieve the purposes described in this privacy policy.
In case of termination of the contract or closure of the User's account, BlueGPT will keep for three (3) years from the date of the commercial relationship the information provided by the User, namely:
- the name and surname or the company name;
- postal addresses;
- e-mail addresses; and
- telephone numbers.
The navigation data will be kept for a maximum of six (6) months in accordance with the recommendations of the CNIL
Beyond this period, they will be anonymized and kept exclusively for statistical purposes and will not be used in any way whatsoever.
h. Transfer of personal data abroad
To the extent possible, BlueGPT processes User data only within the European Union and does not transfer such data outside of the European Union.
Nevertheless, in case of international transfer of the Users' data outside the European Union, it is necessary to distinguish:
- countries that have been granted an adequacy decision by the European Commission: in this case, the data is transferred to a country that provides a level of protection deemed sufficient and adequate to the provisions of the European data protection regulations; and
- countries whose level of data protection has not been recognized as adequate: in this case, in order to guarantee a transfer in conformity with the European regulation, and in particular to ensure the security of the data, BlueGPT will base its transfer on protection mechanisms adapted to each service provider and subcontractor, such as the conclusion of standard contractual clauses approved by the European Commission, the application of binding company rules or under an approved certification mechanism.
i.Security
BlueGPT undertakes to implement the appropriate technical and organizational measures that are reasonably necessary regarding the regulations applicable to the protection of personal data, including protection against unauthorized or illicit processing and against accidental loss, destruction, or damage, in order to guarantee a level of security adapted to the risks incurred for the rights and freedoms of natural persons in the context of the processing referred to in this privacy policy.
When personal data is transferred to third parties for processing, BlueGPT ensures that these third parties implement all appropriate technical and organizational measures to ensure the protection of personal data in accordance with applicable laws.
These measures are defined considering the state of knowledge, the costs of implementation and the nature, scope, context, and purposes of the processing as well as the identified risks.
Depending on the needs, risks, costs and purpose of processing, these measures may include pseudonymization and encryption of data.
This protection can be ensured by the mention of "https" in the URL of the browser as well as by the representation of a closed padlock at the bottom of the screen.
Finally, in the event of a violation of the rights concerning personal data that may create a high risk for the rights and freedoms of the User, BlueGPT undertakes to inform the User of this violation within a maximum period of seventy-two (72) hours.
j. Links
On the Website, Users may have access to various links directing them to third-party sites.
BlueGPT will not be responsible for the information that is sent to these third parties or collected by them.
This privacy policy does not govern third party sites or third-party content accessed by the User.
BlueGPT has no control over hypertext links and/or other promotional formats.
Consequently, BlueGPT gives no guarantee concerning the personal data protection practices of the indexed websites and cannot be held liable in the event of a dispute arising between a website indexed on the Website and one of the Users, in particular due to losses or damage suffered, the operators of the indexed websites being solely responsible for their personal data protection practices.
k. Tracers
A tracer is a text file that may be stored in a dedicated space on the hard disk of the User's computer when he consults an online service through his browser.
In practice, tracers are small text files that are placed on the User's computer by the Websites the User visits. They are used to make the Websites work and improve the usability of the Websites.
The tracer is transmitted by a website's server to the User's browser. Each tracer is assigned an anonymous identifier. A tracer cannot be traced back to a physical person.
When consulting the Website, Users are informed that tracers or other means of recording navigation data are used by the Website or by third parties, service providers for the Website and deposited on the User's terminal (computer, mobile or tablet).
BlueGPT or its partners can be brought to install, subject to the acceptance of the User, various tracers and in particular:
- session tracers, which disappear as soon as the User leaves the Website;
- persistent tracers, which remain on the User's terminal until the end of their lifetime or until the User deletes them; and
- statistical tracers (allowing to measure the audience of the Site).
Only the sender of a tracer can read or modify the information contained therein.
In accordance with the recommendations of the CNIL, when connecting to the Site for the first time, the User will be asked to expressly accept the Site's tracers.
k.1 Purpose of tracers
The tracers used by BlueGPT or its partners make it possible to identify the Users, to recognize the browser of the latter when they connect to the Website, to record their access frequencies (traffic measurement) and their display preferences of the terminal of the Users, to adapt and/or personalize the presentation of the Site to improve the experience of the Users and to optimize the Website with the sole aim of providing the services requested by the User.
In addition, the tracers used on the Site are based on the International Chamber of Commerce guide by categories:
- strictly necessary tracers;
- performance tracers;
- functionality tracers;
- advertising targeting tracers.
Strictly necessary tracers
Strictly necessary tracers allow the User to browse the Website.
These tracers do not collect any information about the User that could be used for marketing purposes.
BlueGPT uses these tracers to:
- ensure the functioning of the Website;
- secure the forms and protect them from malicious scripts.
BlueGPT does not use these cookies to:
- collect information that could be used to promote products or services to the User; or
- remember the User's preferences or name after the visit.
Performance tracers
These tracers are used to improve the performance of the Website, such as error handling, tracking response rates or improving the design of the Website.
Functionality tracers
These tracers are used to provide services or to keep track of the User's settings in order to improve their visit to the Website.
Targeting or advertising tracers
These tracers are used to promote products or services for the User on other sites. They may also be used to limit the number of times the User sees a particular advertisement on the Website and to measure the effectiveness of a particular campaign.
Tracers retention period
In accordance with the recommendations of the CNIL, the maximum retention period for tracers is thirteen (13) months after they are first deposited in the User's terminal, as is the duration of the validity of the User's consent to the use of these tracers. The life of the tracers is not extended with each visit. The User's consent must therefore be renewed at the end of this period.
User's right to refuse tracers
During the User’s first time browsing the Website, a banner explaining the use of tracers appears. It allows the User to activate or deactivate certain tracers. It will only disappear once the User has accepted the use of tracers to continue browsing.
The registration of a tracer remains subject to the will of the Users. In accordance with legal and regulatory provisions, BlueGPT obtains prior consent to the use of tracers.
Users also have the possibility of configuring their browsing software so as to oppose, totally or partially (in particular depending on the issuer), the recording of tracers. The configuration also offers the possibility of accepting or refusing tracers on a one-off basis, before they are recorded in the User’s terminal.
Therefore, Users who wish to prevent the recording of cookies can follow the procedure specific to each browser and described in the browser's help menu.
- Chrome
- Internet Explorer
- Edge
- Safari
- Firefox
- Opera
However, in case of opposition to the registration of tracers or the uninstallation of a tracer, Users are informed that certain services may no longer function correctly.
l. Modification de la politique de confidentialité
BlueGPT reserves the right to modify and update, at any time, the present privacy policy, in order to take into account any legal and/or jurisprudential evolution and to meet the requirements of the regulation applicable to the protection of personal data.
The version that prevails is the one that is accessible online on the day of the consultation of the Website.
Any consultation of the Website after publication of the modified confidentiality policy implies unreserved acceptance of the new confidentiality policy by the latter.
m. Contacts
For any request for information or to find out more about the processing of his/her personal data, including the exercise of his/her rights indicated above, the User may contact BlueGPT from his/her account by email or post at the following address:
- Postal mail: InspireLabs - 5 chemin de Gramont - 31200 TOULOUSE
- Electronic mail : [email protected]
For any complaint or dissatisfaction in connection with the use of their personal data by BlueGPT, the User may contact BlueGPT by email or post at the following address:
- Postal mail: InspireLabs - 5 chemin de Gramont - 31200 TOULOUSE
- Electronic mail : [email protected]
When the User contacts BlueGPT, they will be asked to identify themselves.
Version updated on 31.01.2023