Last updated on: 22/09/2021
Tech-Lab offers a Site (as defined below) on which users can create an account to access discount offers (the “Offers”), either via free plans or paid plans (hereinafter the “Plan(s)”), that can be used on products sold by third-party affiliates (the “Partners”) - (altogether the “Service(s)”).
All personal data collected on the website www.joinsecret.com (hereinafter the “Site”) are processed by Tech-Lab (hereinafter “Tech-Lab” or “we”), acting as the data controller, in accordance with legal requirements and, in particular, the “Data Protection Act” of 6 January 1978 as amended and the European Regulation n°2016/679/EU of 27 April 2016.
In particular, we provide you with information about the personal data we collect from you, how we use, disclose and protect it and, finally, how you can exercise your rights over this data.
Tech-Lab processes personal data concerning you and which you have provided to us in the following contexts:
- When you browse the Site;
- When you register on the Site / create an account;
- When you subscribe to one of our paid Plans and make a payment on the Site;
- When you want to access an Offer subject to eligibility conditions by a Partner and have to fill a questionnaire with us in this regard;
- When you do not object to receiving our newsletters and other commercial information from us;
- When you wish to get in touch with us to ask us a question or make a complaint (including via our online chat bot).
In this context, Tech-Lab collects and processes the following personal data:
- Your identity and contact details: surname, name, e-mail address, country;
- The address of your website;
- Your identifiers: email address and password;
- Your payment information (i.e. expiration date and 4 last numbers of the credit card);
- Any eligibility requirement to which an Offer is subject: URL of your website, business model, date of creation of your company,
- The content and history of your subscriptions;
- Any other information you directly and voluntarily provide to us in the course of your use of our Site and of the Service.
The mandatory or optional nature of any information to be completed by you is typically marked by an “optional” statement (asterisk) in the corresponding forms at the time such information is collected. Any failure to complete that information may result in Tech-Lab refusing to process your request.
You agree that the personal data you provide about yourself to Tech-Lab will be current, accurate, complete and unequivocal.
The main objective of collecting personal data by Tech-Lab is to offer you a secure, optimal, effective and personalized experience.
Tech-Lab undertakes to collect and process your personal data lawfully and fairly. The processing implemented by Tech-Lab pursues specified, explicit and legitimate purposes.
The purposes associated with each legal basis are listed below:
- Based on the performance of the contract with you, we process your personal data for the following purpose:
- - To provide you the Service, i.e. manage your account, your subscription to our Plans, your payments, your access to our Offers, your compliance with any eligibility requirements to which an Offer may be subject, the communications/follow-up exchanges with you.
- Based on your consent, we process your personal data for the following purpose:
- Based on our commercial legitimate interests (to ensure quality customer service and provide you with a secure and optimal Service), we process your personal data for the following purposes:
- - To send you commercial information by e-mail (on the e-mail address you provided on the form dedicated to newsletters on the Site or at the time of creating your account) about our Service, Offers and news.
- - To carry out satisfaction surveys;
- - To handle any information request you may have and deal with any complaint;
- - To ensure the proper functioning of the Site (via essential cookies non-submitted to prior consent);
- - To prevent and fight against fraud, including the management of the consequences of this fraud;
- - To establish any evidence necessary to defend our rights and manage pre-litigation and litigation;
- - To carry out statistics and analysis to improve our Service;
- - To manage a merger or acquisition of all or part of Tech-Lab.
- Based on our legal obligations, we process your personal data for the following purposes:
- - To manage our accounting and keep any document mandatory in this context;
- - To manage responses to official requests from public or judicial authorities;
- - To handle data subjects’ rights.
Tech-Lab will keep your personal data for the following periods:
- For data used to provide you the Service and manage our relationship with you:
- - For all data relating to your account and subscription (except payment data), including our exchanges with you in this context: 5 years after the end of the contractual relationship (we will delete your account after 2 years of inactivity on it, unless you object).
- - For your payment details: until the end of your subscription to a paid Plan (including the initial term of one year and any automatic extension term), i.e until the last payment due date. Your data may be kept for an additional period of 13 months after the debit date or 15 months in the case of deferred debit cards to be able to face any claim.
- When cookies or other tracers not necessary for the functioning of the Site are placed on your device, they are used/read for 6 months following your consent.
- For data used for marketing purpose: 3 years following the last contact with you.
- For data used in the context of your requests or complaints: 5 years following the request / 5 years following the closing of the complaint.
- For data used to prevent and fight against fraud: 1 year or 5 years in case of fraud.
- For data necessary to establish any evidence in case of litigation: 5 years after the end of the contractual relationship and/or until the end of the proceeding in case of ongoing litigation.
- For data used to carry out statistics and analysis to improve our Service: 3 years after the last contact with you.
- For data used for satisfaction surveys: 3 years after the last contact with you.
- For data used in case of merger/acquisition: until the end of such merger/acquisition.
- For data used to manage our accounting: 10 years.
- For data used to manage responses to official requests from public or judicial authorities: until the end of the procedure initiated by the authority.
- For data used to handle data subjects’ rights: between 1 year and 5 years depending on the data and the right involved.
Tech-Lab will provide access to your personal data to its internal services on a need-to-know basis.
Tech-Lab may also provide access to your personal data to service providers to perform services related to the Site (hosting, maintenance, payment processing, risk and fraud protection, chat bot) and to perform data analysis and marketing campaign services. These service providers will only have access to your data to perform these services and are bound to the same security and confidentiality obligations as Tech-Lab which remains responsible for the processing of your data.
Tech-Lab may also share your data to comply with its legal obligations, to prevent, detect, investigate and take action against any prohibited or illegal activities, any situation threatening the security or any other right and interest of Users, Tech-Lab or any individual, and any violation of the Site’s Terms & Conditions. Tech-Lab may also transmit your personal data to respond to legal or administrative proceedings of any kind, court orders or enforcement measures requested by the competent authorities. In all these cases, your data may be transmitted to lawyers, advisors and authorities. Tech-Lab may finally share your data to third-party company in the context of a merger or acquisition of all or part of Tech-Lab by such third-party company.
The recipients listed above to whom Tech-Lab may communicate your personal data may be domiciled abroad, including outside the European Economic Area (in the United States). In such case, Tech-Lab will require them to take, in accordance with the applicable legislation on the protection of personal data, all organisational and technical measures that permit ensuring an adequate level of protection of your data - by a decision of adequacy of the European Commission or by the signature of the standard contractual clauses drafted by the European Commission - a copy of these documents is available on request.
You have the following rights over your personal data:
- The right of access: You have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof.
- The right to rectification: You have the right to obtain the rectification of inaccurate personal data concerning you. You also have the right to have incomplete personal data completed.
- The right to erasure: In some cases, you have the right to obtain the erasure of personal data concerning you. However, this is not an absolute right and Tech-Lab may have legal or legitimate grounds for keeping such data.
- The right to restrict processing: you have the right to ask us to temporarily stop using your personal data, in particular if you are questioning our right to use that data;
- The right to portability: you have the right to receive your personal data in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another company without hindrance from Tech-Lab. This right only applies when the processing of your personal data is based on your consent or on a contract (see section 2 above).
- The right to object to processing: you have the right to ask us to stop processing your personal data when such processing is based on the legitimate interest of Tech-Lab (see section 2 above). Tech-Lab may, however, invoke valid reasons for continued processing or keep the data (in particular when the data is necessary for the establishment, exercise or defense of legal rights). When your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of such data.
- A right to give instructions concerning the use of your data after your death: you have the right to give Tech-Lab instructions concerning the use of your personal data after your death.
To exercise one or more of these rights, please contact Tech-Lab at the following postal address 1 rue de Stockholm, 75008, Paris, France or by email at [email protected]
You also have the right to lodge a complaint with the CNIL.
Feel free to send us any questions or concerns regarding this Policy by sending us an email at [email protected]
If we decide to change this Policy, we will post the changes on this page and update the date of the change indicated below. In the event of a material change, we will inform you by any means deemed appropriate.