This Privacy Policy explains how TAWL Solutions Sarl-S (“we”, “our”, or “us”) collects, uses, and protects your personal data. TAWL Solutions is the parent company of Topcho, a platform dedicated to pet health and wellness. This policy applies to all personal data collected in connection with our services, website, and any related interactions.
1- What data do we collect?
To provide its services, TAWL Solutions needs to collect and process information about you. The data we collect depends on the context of your interactions with TAWL Solutions and the choices you make, including the services provided to you.
Please note that you can choose which data you allow us to collect. When you are asked to provide personal data, you may refuse. If you choose not to provide the data necessary to provide the service, we may not be able to provide the service.
2- Categories of data processed
The data we collect and process may include, but is not limited to, the following:
- Identification data: we collect data about you such as your first and last name, e-mail address, postal address, telephone number and similar contact data, date and place of birth, gender, country and preferred language;
- Electronic identification data: we use cookies to collect data on how you use our website and consult our marketing e-mails. This may include, for example, information on which pages of the TAWL Solutions website you have visited, how long you stayed or which items you clicked on;
- Business details: we collect data about you, such as job title, department, organization name, size and location, and whether or not you are acting on behalf of a customer;
- Financial information: we collect your financial information, such as financial account information, if necessary to accept payment or fulfill contractual obligations or for related purposes;
- Contractual information: any information provided by the data subject that enables TAWL Solutions to perform its contractual obligations.
In addition to the above categories of data, TAWL Solutions warrants that, except to the limited extent that may be necessary in the course of employment and in the performance of a contract with a customer, we do not request or collect special categories of data (i.e. , personal information specifying criminal offences/convictions, medical or health conditions, biometric or genetic data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the individual's sex life).
3- How do we collect your data?
This privacy notice applies to personal data, which is information that TAWL Solutions collects from you and other third parties that specifically identifies you as an individual.
TAWL Solutions may collect your personal data in different ways.
We collect your personal data when you consent to the use of various categories of cookies by visiting our website. Cookies are small pieces of text that are downloaded to your computer or other Internet-enabled device when you visit a website. They enable TAWL Solutions to collect information about the use of a website in order to improve the overall user experience.
Cookies can be classified in two different ways, by “lifetime” and by “domain”. There are two types of cookies classified by lifetime:
- Session cookies, which are deleted once the browser is closed and are therefore not saved on the user's device.
- Persistent cookies remain stored on the user's terminal for a certain period of time. They are not automatically deleted. Your browser sends these cookies back to the website each time you visit it again, so that it can remember your preferences and personalize what you see on the screen.
As far as the domain is concerned, a distinction is made between:
- Proprietary cookies, which are cookies set by the website you are visiting. No other website can read them.
- Third-party cookies, which are set by websites when they use external services, which deposit their own cookies.
4- Data collection method
By visiting our website and accepting the use of certain categories of cookies, certain data may be transmitted to us (this data will depend on the categories of cookies that have been accepted). However, regardless of which cookies you agree to use, all data transmitted is anonymised.
Personal data we collect when you do business with TAWL Solutions: we may collect and process your data when you do business with us. “Personal data” means information relating to an identified or identifiable natural person that TAWL Solutions receives on behalf of the customer itself. Examples of categories of such personal data can be found in the previous section.
Personal data we obtain from other sources: we may also periodically obtain personal and non-personal information about you from TAWL Solutions' subsidiaries, affiliates, business partners or other third party sources where they are legally permitted to share such information with us, and add it to the information we already hold about you, such as, but not limited to:
- Updated business address information;
- Identification data;
- financial information;
- Contractual information.
5- Purpose of collecting, using and processing personal data
For any processing of personal data to comply with the General Data Protection Regulation (the “GDPR”), a lawful basis must be identified prior to its implementation.
We use or may use your personal data for the following purposes (or as otherwise described at the point of collection) in accordance with the legal basis under the GDPR:
- To provide you with the service you have requested;
Processing is necessary for the performance of a contract with the data subject.
- To provide you with information, access to resources or other services you have requested from us on behalf of your organization;
The processing is necessary for the performance of a contract with the data subject.
- To send you customer service-related communications (marketing);
Processing is necessary for the purposes of the legitimate interests pursued by the data controller.
- To process communications, you send to TAWL Solutions and respond to your questions, requests and complaints;
Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract;
Processing is necessary to comply with a legal obligation.
Processing is necessary to comply with a legal obligation.
- To carry out the recruitment process;
Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.
- To promote our events and conferences via photos and videos posted on our social networks;
Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.
- To manage TAWL Solutions’ infrastructure and business operations and to comply with internal policies and procedures;
Processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party.
- To comply with all applicable rules, laws and regulations, codes of practice or guidelines or to assist law enforcement and investigations by competent authorities.
Processing is necessary to comply with a legal obligation.
We may contact you by mail, telephone, fax, video conference, e-mail or other electronic messaging service to inform you of special events, new features or other information that may be of interest to you in accordance with your interaction with TAWL Solutions. Where required by applicable law, your prior consent will be obtained before we send you direct marketing and you may object or refuse to receive marketing messages from TAWL Solutions.
TAWL Solution does not sell or rent your information to third parties under any circumstances.
6- Sharing your personal data
TAWL Solutions shares your personal data if necessary to provide any service you have requested or authorized.
TAWL Solutions may also share your personal data with your consent for the following purposes in particular:
- Recruitment;
7- Disclosure of your personal data
Service providers: we may disclose/transfer your data to third parties whom we refer as service providers only to the extent necessary to enable such service providers to provide services to TAWL Solutions and to assist us in providing services to you.
TAWL Solutions' policy is to maintain contracts with all third parties with whom we disclose/transfer personal information that restrict their access, use and disclosure of personal data.
Service providers must, in fact, comply with our confidentiality and data security requirements and are not permitted to use the personal data they receive from us for any other purpose.
- Third parties: we may disclose/transfer your data to third parties such as public administration and authorities, banking institutions, notaries, domiciliation agents and TAWL Solutions' professional advisors and auditors.
- Affiliated companies/branches/subsidiaries: we may disclose/transfer your data, as provided for in our terms and conditions, to other companies owned or controlled in common with TAWL Solutions who will process your information in accordance with this privacy policy.
- Safety, security and legal compliance: we will access, transfer, disclose and retain personal data to comply with applicable law or respond to subpoenas, court orders or other valid legal process, for national security reasons, to defend against legal claims, to protect the rights and safety of TAWL Solutions customers, TAWL Solutions employees or others. This may involve sharing your data with law enforcement, government agencies, courts and other organisations.
- Consent: we may share your data in other ways and for new purposes if you have requested and consented to such sharing.
Recipients may be located inside or outside the European Union. Your personal data will not be transferred to any country outside the European Union that does not offer an equivalent level of protection, unless:
- You have given us prior authorisation to do so;
- If specific measures, such as standard contractual clauses, have been signed, or if the companies concerned have adopted binding corporate rules, guaranteeing that the provisions of the applicable data protection law have been complied with.
Where personal data is transferred/disclosed to TAWL Solutions’ affiliates/branches/subsidiaries, this transfer is based on specific measures, in particular the standard clauses issued by the European Commission regarding the transfer of personal data outside the European Union.
If you wish to consult the latter, please inform us by contacting us using the details provided in the “HOW TO CONTACT US” section of this policy.
8- Access to personal data
TAWL Solutions ensures that you can exercise your rights at any time. TAWL Solutions will process any request within the limits of its technical and organisational resources.
These include:
Right of access to your personal information: if you wish to see the data we hold, collect and process about you, please let us know by contacting us using the details provided in the “HOW TO CONTACT US” section of this policy.
Right of rectification: if the data we hold, collect and process about you is inaccurate or incomplete, you have the right to update this data at any time by contacting us using the contact details provided in the “HOW TO CONTACT US” section of this policy.
Right to erasure: If, at any time, you decide that you do not wish us to retain the personal data we have collected from you, you may request that we delete your data by contacting us using the contact details provided in the “HOW TO CONTACT US” section of this policy. We will take reasonable steps to comply with your request in accordance with applicable law.
Right to restrict processing: if you wish to exercise this right, please contact us using the details provided in the “HOW TO CONTACT US” section of this policy. You should only obtain the right to restrict processing if this is in accordance with applicable laws.
Right to object: if you wish to exercise this right, please contact us using the details provided in the “HOW TO CONTACT US” section of this policy. We will consider your objection and comply with it unless we have a compelling legitimate reason as permitted by applicable law.
Right to data portability: you may have the right to have your personal data transferred directly from us to another data controller only where you have asked us to do so and have consented to such sharing, and where technically possible. If you wish to exercise this right, please contact us using the details provided in the “HOW TO CONTACT US” section of this policy.
Right to lodge a complaint with the supervisory authority: you have the right to lodge a complaint with the Commission Nationale pour la Protection des Données (the “CNPD”), if you believe that your data is being processed in a manner that does not comply with the RGPD.
Please note that these rights are not always absolute and that there may be situations in which, technically or legally, TAWL Solution may not be able to respond to your request.
9- How do we protect your data?
TAWL Solution recognises your trust and is committed to protecting the data you provide to us.
TAWL Solution pays particular attention to the ethics of working from home. We avoid taking hard copies home, and require our employees to perform any task requiring the use of hard copies from the office.
We maintain appropriate organisational, physical and technical security measures (including personnel, facilities, hardware and software, storage and networks, access controls, monitoring and logging, vulnerability and breach detection, incident response, encryption of personal data) to protect against unauthorised or accidental access, loss, alteration, disclosure or destruction of personal data.
10- Notification of personal data breach
TAWL Solutions will inform its customer of any personal data breach by it, its subcontractors or any other third party acting on its behalf, as soon as possible, only when the personal data breach is likely to result in a high risk to the customer's rights and freedoms.
11- Retention period for personal data
TAWL Solutions will keep your personal data only :
- For as long as is necessary for the purpose or purposes for which it was intended;
- For the purposes of performing or fulfilling a contractual obligation with you or the organization you represent and, therefore, for legitimate business purposes;
- As long as required or permitted by law.
12- What we expect from you
We expect you to inform us in writing as soon as possible of any changes to the information you have provided, so that we can keep it up to date.
If you provide us with personal information that does not relate to you (for example, information about your respective representatives, members of staff and agents, beneficial owners, shareholders, etc. or any third parties), you must first inform them and ensure that they acknowledge that we may use such information as set out in this Privacy Policy.
In particular, you must provide them with information about their rights as data subjects. We assume that such third parties are aware of the processing of any personal information about them that we may carry out and of the disclosure thereof to third parties and countries as described herein and that, to the extent necessary, you have obtained such data subjects' prior written consent.
13- Changes to this privacy policy
We reserve the right to modify this Privacy Policy from time to time to reflect changes in the law, our data collection and practices, and to ensure that it is accurate, complete and up-to-date. You are advised to check this privacy policy from time to time.
14- How to contact us
If you have any questions or concerns about our use of your information or about our privacy policy, you can contact us by sending an e-mail to support@topcho.io.