Privacy

As of April 22, 2023

Privacy and security are of utmost importance to tocco (hereinafter known as “Vuvei Ventures”, “Provider,” “us”, “we”, “the App” or “the Site”) and we strive to ensure that our technical and organizational measures in place respect your data protection rights.

This Privacy Policy describes how we manage, process, and store personal data submitted in the context of providing our services. “Personal data” refers to any information relating to an identifiable individual or his or her personal identity.

Tocco is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal information when you use our www.tocco.earth and www.app.tocco.earth ("Website" and "Application" collectively referred to as "Platform").

SECTION 1 - INFORMATION COLLECTION

We may collect personal and company information from you, such as your name, email address, and other contact information, as well as information about your company (e.g., company name, address, and contact information) when you voluntarily provide it to us, for example, when you sign up for our newsletter, submit a contact form, or create an account on our Application. Additionally, when you use the chatbot or interact with our Application, we may collect information about your preferences, needs, and usage patterns.

SECTION 2 - USE OF INFORMATION

Data Collected:

When you subscribe to our services, we collect and manage the following data, which is not aggregated:

• Access tokens and resume tokens (from Google, Microsoft, LinkedIn)
• Passwords (for Tocco applications, SMTP/IMAP)
• Confidential data: email address, first name, last name, company name, Intra-community VAT number (if applicable), login, password, mailing address, country, phone number, IP address(es) and domain name, user application notifications, campaign data, campaign leads, email templates, graveyard email list, user tasks, team activity logs, order history, complaints, incidents, information on subscriptions, and messages on our site. Some data is collected automatically due to your activity on the site (see paragraph on cookies below).
• Internal data: page templates
• Public data: None

Sensitive Personal Data:

The data submitted must not include any sensitive personal data, such as government identifiers (i.e., social security, driving license, or taxpayer-identification numbers), complete credit card or complete personal bank card numbers, medical records, or particulars connected with applications for care or treatment associated with private individuals.

Data Handling:

The chart below summarizes the requirements for handling information based on classification. Information that is mixed with multiple classifications must always be handled with the highest applicable classification (e.g., public information that is stored or transmitted along with confidential information may be encrypted to simplify the use of encryption solutions).

Confidential Data

Distribution:

Not shared with third parties

Customer information is never included in reports, regardless of accompanying data

Labeling:

Documents, spreadsheets, presentations, and text files labeled “Confidential”

All paper documents labeled “Confidential”

Paper Documents:

• Only printed when there is a legitimate business need and no reasonable alternative, with management approval
• Stored in a locked cabinet
• Placed in a destruction bin for shredding immediately after use

Electronic Files:

• Collected or stored when there is a legitimate business need and no reasonable alternative, with management approval
• Stored and transmitted encrypted
• Wiped from electronic media immediately after use

Internal Data

Distribution:

Redistributed to anyone within Vuvei Ventures

Labeling:

Not labeled

Paper Documents:

• Only printed when there is a legitimate business need and no reasonable alternative
• Stored on Vuvei Ventures premises or in a locked cabinet
• Placed in a destruction bin for shredding immediately after use

Electronic Files:

• Stored and transmitted in clear text on Vuvei Ventures corporate systems
• Deleted or wiped from electronic media immediately after use

Public Data

Distribution:

Shared with anyone internal or external to Vuvei Ventures

Labeling:

Not labeled

Paper Documents:

Recycled conventionally when no longer needed

Electronic Files:

Stored and transmitted in clear text

Deleted or wiped from electronic media immediately after use

Purposes of Processing and Legal Basis:

Your personal data is processed to meet one or several of the following purposes. Each purpose is associated with a legal basis, which can be found below.

On the basis of our legitimate interest in offering you a safe, optimum, efficient, and personalized experience, we carry out processing operations for the following purposes:

• To solve problems and improve the use of our Platform and services
• To personalize, assess, and improve our services, content, and materials
• To analyze the volume and history of your use of our services
• To inform you about our services, as well as our partners’ services and/or promotional offers
• Respond to your inquiries and provide customer support.
• Provide a personalized user experience, including the display of relevant products, materials, and suppliers based on the information you provide.
• Facilitate communication between users, suppliers, and brands within the Application.

On the performance basis of a contract to which you are a party, we carry out processing operations for the following purposes:

• To provide our services
• To facilitate performance, including verifications relating to you

On the basis of your consent or legitimate interest, we carry out processing operations for the following purposes:

• To sign up for our newsletters, use case studies, and marketing material

On the basis of compliance with our legal and regulatory obligations, we carry out the processing for the following purposes:

• To prevent, detect and investigate any activities that are potentially prohibited, unlawful, or contrary to good practices, and to ensure compliance with our terms of use and sending policy

We use the personal data submitted to us only in accordance with applicable data protection legislation.

Newsletter and Marketing Emails:

If you have opted in to receive our newsletters, you can easily unsubscribe by following the “unsubscribe” links included in every email sent.

Email Statistics:

Without systematically doing so, we may analyze and track the various rates (e.g., click, open, bounce rates) and the number of emails sent with Tocco, which you open to assess performance rates on your emailing campaigns.

SECTION 3 - INFORMATION SHARING

Personal data relating to you collected on our website is intended for Tocco’s use and may be forwarded to Tocco’s partner companies so that we may obtain assistance and support in the context of carrying out our services. Tocco ensures that it has clear data protection requirements for all of its third-party providers.

We may share your personal information with third-party service providers to help us operate our business, such as email service providers, analytics providers, and payment processors. We require these third parties to maintain the confidentiality of your information and to use it only for the specific services they provide.

Tocco does not sell or rent your personal data to third parties for marketing purposes.

Additionally, Tocco does not disclose your personal data to third parties, except if:

• You (or your account administrator acting on your behalf) request or authorize disclosure thereof
• The disclosure is required to process transactions or supply services which you have requested (i.e., to check that you are employing best practices in your mailings or for the purposes of processing an acquisition card with credit-card issuing companies)
• Tocco is compelled to do so by a government authority or a regulatory body, in the case of a court order, a summons to appear in court, or any other similar requisition from a government or the judiciary, or to establish or defend a legal application
• The third party is a subcontractor or sub-processor of Tocco in the carrying out of services (e.g., Tocco uses the services of an Internet provider, a telecommunications company, a host provider, CRM tools, customer support client tools, invoices tools, payment tools, analytics tools)

SECTION 4 - COOKIES AND TRACKING TECHNOLOGIES

Our Application uses cookies and other tracking technologies to improve your browsing experience, analyze usage patterns, and understand where our users come from. By using our Application, you consent to our use of cookies and other tracking technologies.

SECTION 5 - DATA SECURITY

We take reasonable precautions to protect your personal information from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee the absolute security of your information.

Data Retention and Deletion: We retain Google user data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Users may request the deletion of their Google account data at any time by contacting us at contact@tocco.earth. Upon such a request, we will delete the data promptly, except where retention is required by law or necessary for legitimate business purposes, such as dispute resolution or enforcement of our agreements.

SECTION 6 - THIRD-PARTY LINKS

Our Application may contain links to third-party websites. We are not responsible for the content, privacy policies, or practices of any third-party websites. By clicking on a third-party link, you will be directed to that website, and we encourage you to review its privacy policy before providing any personal information.

SECTION 7 - CHILDREN’S PRIVACY

Our Application is not intended for use by individuals under the age of 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information, please contact us, and we will take steps to remove such information from our systems.

SECTION 8 - GDPR RIGHTS FOR EU USERS

In accordance with French Data Protection Laws and the European General Data Protection Regulation 2016/679 (GDPR), you have several rights related to the collection of your personal data:

• Right to be informed: This is why we have drafted this privacy policy.
• Right of access: You have the right to access all your personal data at any time.
• Right to rectification: You have the right to rectify your inaccurate, incomplete, or obsolete personal data at any time.
• Right to restriction of processing: You have the right to restrict the processing of your personal data in certain cases stated in art.18 of the GDPR.
• Right to erasure (‘right to be forgotten’): You have the right to demand that your personal data be deleted and to prohibit any future collection.
• Right to file a complaint to a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a breach of applicable regulations.
• Right to define instructions related to the retention, deletion, and communication of your personal data after your death.
• Right to data portability: You have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
• Right to object: You have the right to object to the processing of your personal data. Please note, however, that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

To exercise any of these rights, please contact us at the contact information provided below. We may require that your request be accompanied by a photocopy of proof of identity or authority.

SECTION 9 - GOOGLE COMPLIANCE

The platform’s use and transfer to any other app of information received from Google Accounts will adhere to Google API Services User Data Policy, including the Limited Use requirements.

SECTION 10 - INTERNATIONAL DATA TRANSFERS

If you are a user located within the European Union (EU), please be aware that your personal information may be transferred to, processed, and stored in countries outside of the EU. By using our Application and providing your personal information, you consent to such transfers, processing, and storage in accordance with this Privacy Policy.

SECTION 11 - CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our Application. It is your responsibility to review the Privacy Policy periodically for any changes.

SECTION 12 - PUBLISHER

If you have any questions or concerns about our Privacy Policy or the handling of your personal information, please contact us at:

Publisher:

The website https://tocco.earth/ is published by:

The company Vuvei Ventures

Simplified joint stock company with a capital of 1 000,00 euros

Registered with the RCS of Paris under the number 911 864 817

Head office: 229 rue Saint-Honoré - 75001 Paris - France

Intra-community VAT number: FR75911864817

E-mail address: contact@tocco.earth

Director of the publication: Mr Dongliang Ge, President of Vuvei Ventures company