Privacy policy
Our website address is :
https://flexibility-unlock.com
Last update : 01/01/2024
Our website address is : https://flexibility-unlock.com
Last update : 03/03/2025
1. PREAMBLE
This Privacy Policy governs the manner in which this website collects, uses, maintains and discloses information collected from users (individually referred to as a "User") of the website (referred to as the "Site").
Personal information : "information which allows, in any form whatsoever, directly or indirectly, the identification of the natural persons to whom it applies" (article 4 of law no. 78-17 of January 6, 1978).
This privacy policy applies to the Site and to all products and services offered by the company. It supplements the provisions applicable to the relationship between the company and the User, and must therefore be read in conjunction with the other applicable conditions, and in particular with the terms and conditions accessible from the Site.
The purpose of this policy is to present to users of the Site :
- The procedure for collecting and processing their personal data ("PCD"), it being understood that PCD is any data likely to identify a User, such as surname, first name, date of birth, postal address, phone number, e-mail address or IP address.
- The various rights of Users in relation to this data
- The person responsible for processing this data
- The Site's policy on "cookies"
The collection of personal data of its prospects and customers is limited to what is strictly necessary, in accordance with the principle of data minimization, and indicates the purposes pursued by the collection of this data, whether providing this data is optional or mandatory to manage requests and who may see it.
This policy for the use of personal data is made in accordance with the provisions of Law no. 78-17 of January 6, 1978 (known as the "Loi informatique et libertés" or "LIL"), and the General Regulation on the Protection of Personal Data ("GDPR") no. 2016/679.
2. Data controller
A "data controller" is the person who, alone or jointly with others, determines the purposes and means of processing, and a "data processor" is the person who processes personal data on behalf of the data controller.
The person responsible for processing the personal data referred to herein is KIVENCORP, a company registered with the Registre du Commerce et des Sociétés under number 940 218 514 00013 RCS PARIS (FRANCE) and whose registered office is located at 60 Rue François 1er, 75008, Paris.
The Company is responsible for processing the data of its customers and more generally of Internet users (hereinafter "you") browsing the websites it operates as part of its business, such as https://flexibility-unlock.com.
We undertake that the collection and processing of personal data will be carried out lawfully, fairly and transparently, in accordance with the General Data Protection Regulation ("GDPR").
The data controller will notify the User of any rectification or deletion of DCP unless this would entail disproportionate formalities, costs and steps for the User.
3. Gathering information
We collect certain information when you register on our site https://www.flexibility-unlock.com, log in to your account, make a purchase on said site, register to participate in a challenge, participate in private or group coaching, register on a program waiting list, download free documents and/or when you log out.
The information collected includes your first name and e-mail address when you subscribe to our newsletter so that you can receive free content on a regular basis, be informed of our updates, receive occasional commercial offers and be notified of the release of our new course programs.
The company reserves the right to collect nominative information and personal data concerning you. This information is required to manage and send your order by e-mail, and to improve the services and information we send you.
Pursuant to the provisions of Article 5 of European Regulation 2016/679, DCP are collected and processed :
- Only after obtaining the consent of the User, the owner of the DCP
- In pursuit of one or more purposes determined in this document
- Concerning only the DCP necessary for the pursuit of the objectives
- Kept for a limited period of time
- By guaranteeing the integrity of the data collected
Processing is lawful only if, and insofar as, at least one of the following conditions is met :
- The data subject has consented to the processing of his/her personal data for one or more specific purposes;
- The processing is necessary for the performance of a contract to which the data subject is a party, or for the performance of pre-contractual measures taken at the data subject's request;
- The processing is necessary to comply with a legal obligation to which the data controller is subject;
- The processing is necessary to protect the vital interests of the data subject or of another natural person;
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data prevail, in particular where the data subject is a child.
4. Personal identification data
We may collect personally identifiable information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, subscribe to informational e-mail messages, and in connection with other activities, services, features or resources we make available on our Site.
Users may be asked to provide an e-mail address where appropriate. Users may, however, visit our Site anonymously. We collect certain personally identifiable data from Users only if they voluntarily provide it to us (such as first name, last name, e-mail address, postal address, phone number). Users can always refuse to provide personal identification data, in the knowledge that this refusal may prevent them from accessing certain activities linked to the Site.
You must not provide any false nominative information and must not create an account for another person without that person's authorization. The contact details you provide must always be accurate and up to date.
All account holders who access a virtual space (course, viewing, etc.) have access rights that are strictly personal, confidential and non-transferable. All account holders must take the necessary security measures to preserve the integrity of their access rights (login, password) to prevent third parties from connecting to their account. The holder of access rights shall be liable for any fraudulent or abusive use of his/her access codes, where this is the result of his/her own negligence. In any event, the holder of access rights must inform us without delay of the loss or theft of his or her access codes.
5. Non-personal identification data
We may collect non-personal identification data about Users whenever they interact with our Site. Non-personal identifying information may include browser name, computer type and technical information about the means by which Users connect to our Site, such as the operating system and Internet service providers used, as well as other similar information.
6. Usage data
We may also collect information about how you access and use the Service ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (i.e., IP address), browser type, browser version, the pages of our Service that you visit, the date and time of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data such as tracking course progress or viewing modules when the User has purchased a course.
7. Web browser cookies
Your device's technical data is automatically collected and recorded by the Site for advertising, commercial and statistical purposes. Our Site may use "cookies" to improve the User's experience. The User's web browser places cookies on his or her hard disk for record-keeping purposes, which may sometimes make it possible to track information about the User.
We automatically collect your IP address and information relating to the use of our Site. Our site can thus remember your identity when a connection has been established between the server and the web browser. Information previously provided in a web form may also be stored.
Cookies are strictly necessary for the operation of our site. They enable you to use the main functions of our members' area (e.g. access to your account). The User may choose to configure his or her web browser to refuse cookies, or to warn him or her when cookies are being collected. In this case, please note that some parts of the Site may not function properly.
The cookies used on the Site are :
- "Temporary" cookies : this type of cookie is active in your browser until you leave our platform, and expires if you do not access the Site for a given period of time.
- Permanent" or "tracker" cookies: this type of cookie remains in the cookie file of your browser for a longer period of time, depending on your browser settings. Permanent cookies are also known as tracker cookies.
In this respect, Systeme.io has its own privacy policy, and the Company invites you to read Systeme.io's privacy policy : https://systeme.io/fr/privacy-policy
We do not collect or store any personal data (surname, first name, address, etc.) that may be linked to technical data. This data may be sold to third parties by the suppliers of the cookies used to collect it.
In accordance with European recommendations, cookies may be stored for a maximum of 13 months after they are first placed on the User's terminal, as is the period of validity of the User's consent to the use of these cookies. The lifetime of cookies is not extended with each visit. The User's consent must therefore be renewed at the end of this period.
Cookies may be used for statistical purposes, in particular to optimize services rendered to the User, based on the processing of information concerning access frequency, page personalization, operations carried out and information consulted. You are informed that the cookie supplier may place cookies on your terminal.
The cookie records information relating to navigation on the service (the pages you have consulted, the date and time of consultation, etc.) which we can read during your subsequent visits. Some of the site's functions, such as video players and interactive content, may use third-party services and deposit cookies that enable them to identify your viewing of the content.
If you do not wish cookies to be used on your terminal, most browsers allow you to disable cookies via the settings options :
- Chrome : https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=fr
- Safari : https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
- Firefox : https://support.mozilla.org/fr/kb/protection-renforcee-contre-pistage-firefox-ordinateur
- Internet explorer : https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
Further information on how the User can configure his browser and limit the action of cookies is available on the CNIL website (www.cnil.fr).
8. Exercise of rights
In accordance with the law of January 6, 1978, you have the right to access data concerning you, to rectify or delete it, to ask questions, to limit the processing of your data, to portability, and to erasure, within the limits set by regulations and in particular the GDPR.
We use the e-mail address you provide to send you information and updates relating to your order, occasional company news, information on related products, etc.
You also have the right to object at any time, for reasons relating to your particular situation, to the processing of personal data whose legal basis is our legitimate interest, as well as the right to object to commercial prospecting by clicking on the newsletter unsubscribe link. Furthermore, THE SELLER undertakes not to communicate its customer details to third parties, whether free of charge or in exchange for payment.
Requests to exercise your rights should be sent electronically to kvnroulandsw@gmail.com. The request must indicate the surname and first name, e-mail or postal address of the person concerned, and must be signed and accompanied by valid proof of identity. In order to respect the aforementioned rights, you must receive a reply within fifteen (15) days.
If you are not satisfied with our response, you may lodge a complaint with the personal data protection and control authority to which you belong (for example, in France, the CNIL). Visit cnil.fr for more information on your rights.
For all intents and purposes, it is hereby specified that upon exercising the right to erasure, to object to processing, or to withdraw consent, the proper functioning of the site and/or course services may be disrupted or even interrupted. For example, if these rights are exercised at the time of ordering services, the said order may not be carried out.
If you have an account or have filled in any form, you may request to receive a file containing all the personal data we hold about you, including that which you have provided to us. You can also request the deletion of your personal data. This does not include data stored for administrative, legal or security purposes.
The age or consent of the User in the case of a minor under the age of 15 may be verified by any means available to the Site editor. Indeed, pursuant to Article 8 of European Regulation 2016/679 and to the French Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data.
9. Retention period of personal data
Data used to manage commercial prospecting is kept for a maximum of three years from the last contact from the prospect or the end of the contract with the customer, and for 10 years for accounting purposes. If you have not authenticated yourself on the Site, or if you have not behaved actively (for example, by clicking on a link) for a period of three years, you may receive an e-mail inviting you to log in as soon as possible, failing which your data will be deleted from our databases.
Means of effective deletion of data are put in place as soon as the retention or archiving period necessary for the fulfillment of the determined or imposed purposes is reached, in particular after deletion of your account with our company.
In accordance with our legal obligations, certain documents relating to our internal operations and containing personal information (purchase orders, contracts, invoices, etc.) will be archived. Similarly, we may archive documents until the expiry of the statute of limitations/forclosure periods applicable to legal proceedings, in order to defend our interests before the courts in the event of subsequent litigation.
In any event, personal data that is processed will not be kept beyond the time required to fulfill the obligations defined when the contract was concluded, or as required by current legislation. Beyond this period, the data may be anonymized and stored exclusively for statistical purposes.
Site user account management :
- Data is kept for 3 years from the date of collection or the last click by the user.
To enable the execution of the service offered by the Site :
- Data is kept for the duration of the contractual relationship, then for 3 years for commercial prospecting purposes from the date of collection or the last contact by the person concerned
Constitution and management of customer files:
- Data is kept for the duration of the contractual relationship, then for 3 years for commercial prospecting purposes from the date of collection or last contact by the person concerned
Creation and management of User files :
- 3 years from collection
Constitution and management of Prospects and business network files :
- 3 years from collection
Management of newsletters :
Until unsubscription by the person concerned
Management of customer and user credit card numbers :
- Data is deleted once the transaction has been completed, and no later than 30 days after collection
Sending (emailings) of company news and personalized solicitation information :
- 3 years from the date of collection or last contact with the data subject
Management of an opposition list :
- 3 years from registration on the list
Protection of online services against infringement of intellectual property rights and unfair competition :
- 3 years from creation of site user account or last click
Customer identity data must be kept for the duration of the contractual relationship, then for 5 years.
In the event of exercising the right of access or rectification, data relating to identity documents may be kept for one year.
10. Use of collected data
The company may collect and use Users' personal data :
The information you provide enables us to respond more effectively to your requests and support needs.
We may use data in aggregate form to understand how categories of Users use the services and resources provided on our Site.
We may use the e-mail address provided to send the User information and updates regarding his/her order or subscription. It may also be used to respond to requests, questions and other queries. If the User decides to subscribe to our mailing list, he/she will receive electronic mailings that may include company news, updates, information about related products or services, etc.
If, at any time, the User wishes to unsubscribe from receiving future e-mails, we include detailed unsubscribe instructions at the bottom of each e-mail.
If you reside in the European Economic Area (EEA), the company's legal basis for collecting and using the personal data described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
The company may process your Personal Data :
- Because we need to perform a contract with you
- Because you have authorized us to do so
- Because we have a legitimate interest in doing so and your rights do not override this legitimate interest
- For payment processing purposes
- To comply with the law
11. How we protect your data
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal data (User name, password, transaction information and data stored on our Site).
12. Disclosure and procedures in the event of a data breach
The DCP of Users may be disclosed in the event that current laws and regulations oblige us to do so.
In the event of data leakage, you will be immediately notified by e-mail.
13. Sharing your personal data
We do not sell, trade or rent any personally identifiable information about Users to outside third parties. We may share generic, aggregated demographic information, independent of any personally identifying data, about Site visitors and Users with our business partners, trusted affiliates and advertisers for the purposes described above.
The first point listed does not include trusted third parties who assist us in operating our website or conducting our business, so long as such parties agree to keep such information confidential, such as :
- Paypal and Stripe : payment management
- Systeme.io : management and hosting of our online products / management of our e-mail lists
- Goddady : domain name hosting
In this respect, we check that any processor provides sufficient and appropriate contractual guarantees to respect your rights, so that processing meets the requirements of the GDPR and to comply with the GDPR provisions applicable to data transfers.
They may also be transmitted to companies that contribute to these relationships, such as those responsible for the execution of services and orders for their management, execution, processing and payment. This information and data is also stored for security purposes, in order to comply with legal and regulatory obligations.
We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or when we are required to do so by law.
We undertake to comply with the applicable regulations relating to the transfer of data to countries outside the European Union, and in particular with the following terms and conditions :
- We will transfer the data of visitors, prospects and customers to countries recognized as offering an adequate level of protection. In the case of transfers to the United States, to organizations that have signed up to the Privacy Shield;
- When the destination country does not offer an adequate level of protection, we use transfer tools that comply with regulations (notably the European Commission's standard contractual clause).
14. Third-party websites and social networks
Users may find advertisements or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these third-party websites, and we are not responsible for the practices employed by websites linked to or from our Site.
In addition, these websites, including their content and links, may be constantly evolving. These sites and services may have their own privacy and customer service policies. Your browsing and interaction on any other website, including websites linked to or from our Site, are subject to their own terms and policies.
This policy applies only to the activities of the company, which shall not be held liable for the failure of any third party to comply with its obligations regarding the protection of personal data.
The information about you that you have sent us may be enriched for commercial, prospecting, communication, solicitation or marketing purposes, by means of other sources of information such as social networks (so-called "public" information or information to which we may have access as page administrator).
We may also contact you or answer your questions via social networks, if you have first contacted us in this way. You are informed that the use of social networks involves the processing of personal data by the providers of these networks (see their privacy policy).
In the event that your member area can be connected to another service (e.g. a social network) for cross-mailing purposes, the third-party service may provide us with information that you have authorized to be disclosed. You are informed that publishers of third-party services may also collect information concerning your consultation and/or use of the Site, in accordance with their own personal data processing policies.
15. Computer security
We undertake to implement all appropriate technical and organizational measures using physical and logistical security measures to guarantee a level of security appropriate to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of your personal data.
Only those persons who need to perform a specific job (for example, billing or customer service) have access to personally identifiable information. Computers and servers used to store personally identifiable information are kept in a secure environment. However, since no mechanism offers maximum security, an element of risk is always present when using the Internet to transmit personal information.
The security of personal data also depends on Users. Users undertake to keep their login and password confidential. Members also undertake not to share their account and to report to the company any unauthorized use of said account as soon as they become aware of it.
We invite you to be careful about what you decide to make public on the Internet. With regard to personal data, including data relating to your private or sensitive life, made public at your initiative or deduced from your contributions, comments and statements of any kind whatsoever on the Site, or on social networks in groups and/or conversations with other users of the Site.
Certain messages or solicitations received may come from ill-intentioned persons seeking to obtain personal information concerning the User with a view to fraudulent use (phishing). If the User receives a message which appears to be an attempt at phishing, he/she is invited not to reply to it and not to open any attachments, images or links contained in the message. The User may report this by e-mail to kvnroulandsw@gmail.com.
All transactions carried out on our Site are secure. Credit card payments are handled by our partner STRIPE, a trusted payment service provider. We use SSL encryption to protect your personal data and the means of payment used. Thanks to this process, we are never in direct possession of your bank details.
The address of the payment page begins with "https" and is accompanied by a closed padlock or key in the bottom right-hand corner of your browser. This allows you to check that you are in a secure payment zone when you are asked for your credit card number. Stripe automatically checks that this connection is secure before sending your banking and transaction data.
Their privacy policy is available at : https://stripe.com/us/privacy
In the event that we become aware of unlawful access to your personal data stored on our servers or those of our service providers, or of unauthorized access resulting in the risks identified above, we undertake to :
- Notify you of the incident as soon as possible if this is required by law;
- Examine the causes of the incident;
- Take all reasonable measures to mitigate the negative effects and damage that may result from the incident.
Under no circumstances may the commitments defined in the above point be assimilated to any recognition of fault or responsibility for the occurrence of the incident in question.
In the event of any breach of security or any incident likely to affect the integrity of your personal data or that of others, we would be grateful if you would inform us immediately by e-mail to kvnroulandsw@gmail.com.
You have the right to lodge a complaint with a data protection authority about our collection and use of your Personal Data. For further information, please contact your nearest data protection authority in the European Economic Area (EEA).
16. Mandatory or optional nature
On the Site, you are informed of the compulsory nature of the answers by the presence of an asterisk or any other type of mention. In the event of an incomplete request (e.g. on-line registration or order), the Company reserves the right to request additional information or to prevent validation of the form concerned by any technical means.
17. Changes to this Privacy Policy
KIVENCORP may update this privacy policy at any time. When we update it, we will revise the update date at the bottom of this page. Changes and clarifications will take effect immediately upon posting on the Website.
We encourage Users to consult this page frequently to take note of any changes, and thus remain informed of our contribution to the protection of the personal data we collect. The date of the update is indicated in the header and we invite you to consult it regularly. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and to be aware of any changes.
Any modifications shall not affect purchases previously made on the site, which shall remain subject to the Policy in force at the time of purchase and as accepted by the user when validating the purchase.
If the Site is acquired by or merged with another company, the DCP may be transferred to the new owners so that the Site can continue to sell its products.
18. Your acceptance of these conditions
By using this Site, you signify your acceptance of this privacy policy, in particular with regard to the collection and processing of personal data, as well as the use of "Cookies".
If you do not accept this policy, please do not use our Site. If you use the Site after this Privacy Policy has been modified, you will be deemed to have accepted such modifications.
19. Language, applicable law and attribution of jurisdiction
This privacy policy is written in French. In the event of translation into one or more languages, the French text shall prevail in the event of litigation. The temporary or permanent non-application of one or more clauses of the present policy shall not constitute a waiver of the other clauses of the present policy, which shall continue to have full effect.
The present policy is not exhaustive and we reserve the right to supplement it by any means.
Any dispute arising in connection with the use of the https://www.flexibility-unlock.com website is subject to French law. The competent courts of Paris shall have exclusive jurisdiction.
20. The main laws concerned
Law no. 78-17 of January 6, 1978, as amended by law no. 2004-801 of August 6, 2004 on data processing, data files and individual liberties.
Law no. 2004-575 of June 21, 2004 on confidence in the digital economy.
General Data Protection Regulation (" GDPR ") n°2016/679.r
Contact information
For any questions relating to this privacy policy or, more generally, to the protection of their Data, Users may contact the data controller at the following address : kvnroulandsw@gmail.com.