At JOE, protecting your personal data is our priority.

When you use the application JOE (hereinafter the "Application") we may collect personal data about you. 

The purpose of this policy isto inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons withregard to the processing of personal data and on the free movement of such data(hereinafter the "GDPR"). 

1. Who is the data controller?

The data controller is JOE, SAS registered with the Registry of Trade and Companies of Lille under the number 884156605 and whose head office is located at 165Avenue de Bretagne – 59000 Lille (hereinafter “Us” or “We”). 

Regarding payment services provided on the Application, we may also act as processor of our financial partners asidentified below. Our financial partners have their own privacy policies, which can be accessed through the link below.

 2. What personal data we collect?

Personal data is a data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name. 

We may collect the following personal data:

- Identification data (e.g. full name, email and postal addresses, telephone number, position, job, ID card, your photo, video in the context of competition);

- Authentication data when you access theApplication, in particular your identifiers, access codes and passwords, or when you exercise your rights of access or rectification, in particular photos and information appearing on the ID documents that you provide for this purpose;

- Data relating to your lifestyle habits or consumption;

- Data relating to your transactions with merchants;

- Login data (e.g. logs, IP address);

- Location data;   

- Data related to recordings from telephone calls with our customer care service (e.g. content of the calls, dates of the calls);

- Economic and financial data (e.g. bank details,RIB, IBAN, range of income, bank account balance);

- Data related to your credit cards (card account and payment card details)

- Any other information that you decide to provide by any means. We may ask you to connect us with your bank. In the context of our obligations of vigilance with regard to our customers (obligations known as "Know Your Customer" or"KYC"), we may ask you to provide us with proof of identity (for example your driving license, national ID, passport). We inform you, when collecting your personal data, whether some of these data are mandatory or optional. Mandatory data are indicated with an asterisk.

3. On what legal basis, for what purposes andfor how long do we keep your personal data?
Purposes Legal basis Data retention period
To provide you with our services available on our Application Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract When you have created your account: personal data are retained for the duration of your account. If your account is inactive for a period of 2 years, it will be deleted. In addition, personal data may be archived for probationary purposes for a period of 5 years.
Perform the services offered on the Application (pre-purchase fractional payment with our partner Solaris or post-purchase with our partner Floa Bank), and monitoring the contractual relationship with our customers Performance of a contract to which you are party Personal data are retained for the duration of our business relationship.
To create a database of customers and prospects Our legitimate interest in developing and promoting our business For our customers: their personal data are retained for the duration of our business relationship. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action).
To send newsletters, requests and direct marketing mailings For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news For our prospects: your consent Personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action).
To improve our services Our legitimate interest in improving our services Recording of telephone calls: 6 months from the date of collection Telephone call content analysis documents: 1 year from the date of collection
To answer to your information request and other inquiries Our legitime interest in responding to your inquiries Personal data are retained during the processing of your request and is deleted once the request has been processed
To comply with our legal and regulatory obligations To perform the KWC process Legal and regulatory obligations Invoices are archived for a period of 10 years. Data relating to ID documents are retained only for the time necessary for identity verification. In the event of refusal to provide you with split payment, KYC documents shall be retained for a period of one year from the provision of the said elements. If permitted, the KYC documents shall be retained for a period of five years from the closure of the customer account.
To process your applications Taking steps at your request prior to entering into a contract The data are retained for the necessary time to process your application. If your application is unsuccessful, we may wish to retain your data and will inform you if so. If you do not object to the retention of your data, they will be retained for 2 years after your last contact with us.
To organize contests and promotional operations Our legitimate interest in winning clientele loyalty and offering them gifts The personal data is kept for the duration of the contests or promotional operations and may be archived for 5 years for evidential purposes.
To elaborate analytics of audience Our legitimate interest in analyzing the composition of our customer base and improving our services The personal data are retained for the duration of our business relationship.
To process data subjects’ requests to exercise their rights Our legitimate interest in responding to your requests and keeping records of them If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted. If you exercise your right to object to direct marketing: we keep this information for 3 years. The information allowing the management of your requests to exercise your rights under the GDPR will be kept for 2 (two) years from the date of the request.
4. Who are the recipients of your personal data?

Will have access to your personal data:

(i) The staff of our company;

(ii) Our processors: hosting provider, secure payment provider, financial services provider, bank aggregator, analytics provider, social network advertising provider, customer support provider, newsletter sending provider, referencing provider, customer support provider, provider in charge of KYC, provider in charge of bank transfers);

(iii) Our financial partner necessary for the execution of the services, the company Floa Bank (T&C accepted at the time of your registration) improving its own processing, as described in their privacy policy;

(iv) Our financial partner necessary for the execution of the services, the company Solaris (T&C accepted at the time of your registration) improving its own processing, as described in their privacy policy

Your personal data may also be sent to public bodies, exclusively in order to perform our legal obligations, to judicial officers, to ministerial officers and to recovery services.

5. Are your personal data likely to be transferred outside the European Union?

Your personal data is hosted for the duration of the processing on the servers of the company Amazon Web Services located in Ireland, within the European Union. 

As part of the tools, we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

· Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or

· The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR: in this case these transfers are based on appropriate safeguards indicated in article 46 of theGDPR, adapted to each provider, including but not limited to the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or under an approved certification mechanism; or

· The personal data are transferred under the any appropriate safeguards described in Chapter V of the GDPR.

6. What rights do you have regarding your personal data?

You have the following rights with regard to your personal data:

 - Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.

 - Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR. 

Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.

Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR. 

Right to erasure (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR. 

Right to file a complaint to a competent supervisory authority (in France, the CNIL), under GDPR article77, 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 (article 40-1 of French law “informatique et libertés”). 

Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal. 

Right to data portability: under specific conditions defined in article 20 of the GDPR, 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 as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.You can exercise these rights by writing us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.

7.     Cookies

For more information on cookie management, please see our Cookie Policy.

8. Contact information for data privacy matters

Contact email: yohan@getjoe.co  
Contact address: 165 Avenue de Bretagne – 59000 Lille (France)

9.     Modifications

We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

Entry into force: December 16, 2021