(last update july 2018)

By using www.ToWebOrNotToWeb.com, you are accepting the practices described in the below privacy policy, including our use of cookies and similar online tools. If you do not agree to the terms of this privacy policy, please do not use www.ToWebOrNotToWeb.com.

Introduction
The General Data Protection Regulation (GDPR) seeks to enhance the safeguarding of Personal Data, the protection against the unlawful processing of Personal Data and the movement of Personal Data within the European Union. The GDPR does not apply to information already in the public domain.
This document explains how ToWebOrNotToWeb processes Personal Data (the “Personal Data” or “PD”), which is defined as the information concerning any person and any company (the “Data Subject” or “DS”) that is not in the public domain.

Personal Data
Through www.ToWebOrNotToWeb.com ToWebOrNotToWeb collects and processes Personal Data from Data Subjects that is necessary to perform its consultancy Services (“Services”) for the following purposes:
• To provide access to marketing information and specific content on www.ToWebOrNotToWeb.com
• To sell Services
• For ToWebOrNotToWeb marketing and statistical purposes
• To improve www.ToWebOrNotToWeb.com browsing experience
• To post user generated content and comments on www.ToWebOrNotToWeb.com
• To respond to any DS inquiries or requests by email or telephone
• For compliance with ToWebOrNotToWeb Terms of Service
• To verify financial transactions where relevant and to protect, enforce, or defend ToWebOrNotToWeb rights, assets and interests
• To comply with the law and to prevent or respond to a violation of any law, regulation, and to protect ToWebOrNotToWeb network security
• For any corporate change such as the acquisition of or the merging with another company, the partial or total sale of assets
ToWebOrNotToWeb only collects Personal Data to provide the Services and does not use PD for other purposes than those described above. ToWebOrNotToWeb does not sell, exchange or give away PD.
The PD that ToWebOrNotToWeb collects and stores may include but is not limited to the following types of information:
• Contact information, including first and last name, email address, phone number
• Occupation information, including company name, company website, company type, company address, title, and any other information directly provided via the registration forms on www.ToWebOrNotToWeb.com.

PD are stored and managed by ToWebOrNotToWeb in accordance with the GDPR.
In making initial contact with ToWebOrNotToWeb, Data Subject consents to ToWebOrNotToWeb maintaining a marketing dialogue with him until he either opts out, which he can do at any time, or ToWebOrNotToWeb stops promoting the Services.
DS can make initial contact with ToWebOrNotToWeb in many ways including, but not limited to:
• By signing up or registering in any of the sections of www.ToWebOrNotToWeb.com
• By buying and subscribing to a Service
• By completing a contact forms on the website
• By contacting ToWebOrNotToWeb by telephone
• By using our third-party Services, such as the Service providers ToWebOrNotToWeb uses for sending newsletter/email, for producing, hosting and distributing webinars and other online presentations, for download whitepaper or guides, for analytics about website usage such as Google Analytics, for social networking such as Twitter, Facebook, Instagram, for government and law requirements
Whenever indicated with an asterisk (*) or in other ways, the Data will be required, without which ToWebOrNotToWeb will not be able to provide the corresponding requests.

ToWebOrNotToWeb can also act on behalf of its Clients as Data collector or as Data manager during the performance of the Services, in which cases ToWebOrNotToWeb will do its best to ensure that the Clients are fully GDPR compliant.
Some Personal Data may be collected from the forms and surveys on www.ToWebOrNotToWeb.com, from emails and phone calls, or from visiting the website. ToWebOrNotToWeb may use such information, including but not limited to Internet Protocol (IP) addresses, to identify its DS and to analyze the statistics of their behavior on the website.

Non-Personal Data
When DS use www.ToWebOrNotToWeb.com and subscribe for Services, ToWebOrNotToWeb collects additional non-personally identifiable information. This may include, but is not limited to, Data about device, browser, operating system, IP address, social network pages, date and time.
This non-Personal information may be collected through various technologies, including but not limited to server logs and cookies.

Cookies
ToWebOrNotToWeb’s website uses its own and third-party cookies. Cookies are pieces of information that a website transfers to a computer to know how a person uses the website and to improve the user’s navigation whenever he returns to the website within a certain period of time.
www.ToWebOrNotToWeb.com uses cookies to help ToWebOrNotToWeb identify Data Subjects and their website preferences. Data Subjects who do not want to use ToWebOrNotToWeb’s or third-party cookies should set their browsers to refuse cookies before visiting www.ToWebOrNotToWeb.com. However, by doing so DS may not be able to take full advantage of www.ToWebOrNotToWeb.com. Although cookies do identify a user’s computer, they do not personally identify users or passwords and do not store credit or debit card details.
Specifically, the cookies ToWebOrNotToWeb uses and their purposes are:
• Session Cookies: to manage sessions of registered Data Subjects. It facilitates their navigation, access to specific content, Services and pages, keeping the session open on the Service. This cookie will expire soon after the corresponding session is closed. Additionally, ToWebOrNotToWeb may use a Facebook cookie for those Data Subjects that access www.ToWebOrNotToWeb.com through this social network.
• Social network cookies, such as Facebook, Twitter, Instagram, etc.: to share some content through social networks. The cookie in this case redirects the Data Subject to log in into his social network account to share the content in his own account and it requires the Data Subject to have an account with such social networks.
• Google Analytics: to record access, navigation and visit information on www.ToWebOrNotToWeb.com through the Service of Google Inc.
The treatment of the Data corresponding to third-party cookies are subject to the responsibility of the indicated third-party. ToWebOrNotToWeb has only anonymized Data and can not therefore associate such Data to a specific person. Neither this website nor its legal representatives are responsible for the content or the veracity of the third-party cookies privacy policies. Data Subjects’ web browsers are the only tools through which cookies are stored, managed, disabled and removed. Neither this website nor its legal representatives can guarantee or be responsible for the handling of cookies by the mentioned browsers. In the case of Google Analytics cookies, this company stores cookies on servers located in the United States and does not share them unless it is necessary for specific system operations or required by the law. For further information about Google policy, DS can refer to https://policies.google.com/?hl=en for full details.

Disclosure
ToWebOrNotToWeb may occasionally disclose Personal Data to third parties to perform the Services on its behalf. ToWebOrNotToWeb requires these third parties to agree to use any Personal Data following this Privacy Notice’s and the GDPR’s requirements. ToWebOrNotToWeb may disclose Personal Data for legal obligations, regulations or governmental request. ToWebOrNotToWeb may also enforce its Terms and Conditions or investigate potential violations of its Terms and Conditions to detect, prevent or mitigate fraud, security, technical issues, or protect against harm to the rights, property or safety of ToWebOrNotToWeb, its Clients and/or the wider community.
ToWebOrNotToWeb may disclose aggregate website statistics to describe the Services to prospective Clients and other business partners, but these statistics will not include personally identifying information.
If ToWebOrNotToWeb undergoes reorganization or is sold to a third party, Data Subjects agree that any Personal Data ToWebOrNotToWeb holds may be transferred to that reorganized entity or third party.

Retention Policy
ToWebOrNotToWeb will process Personal Data during the duration of any contract and will continue to store only the Personal Data needed after the contract has expired to meet any legal obligations.

Data storage
Data is held in the European Union using multiple servers. Where Data is transferred to countries outside the European Union, we will ensure the appropriate safeguards are in place.

Data Subjects’ rights
At any time whilst ToWebOrNotToWeb is in possession of Personal Data, all Data Subjects have the following rights:
• Access: the right to request a copy of their Personal Data that ToWebOrNotToWeb holds
• Rectification: the right to correct their Personal Data that ToWebOrNotToWeb holds, if they are incorrect or incomplete
• Deletion: the right to ask ToWebOrNotToWeb to delete their Personal Data hold by ToWebOrNotToWeb
• Restriction: the right to restrict the processing of their Personal Data by ToWebOrNotToWeb whenever that doesn’t prevent the performance of the Services
• Portability: the right to have their Personal Data that ToWebOrNotToWeb holds transferred to another organization
• Object: the right to object to certain types of processing of their Personal Data by ToWebOrNotToWeb
• Object to automated processing: the right to object to automated processing of their Personal Data by ToWebOrNotToWeb
• Information: the right to ask the details of their Personal Data that ToWebOrNotToWeb holds and how ToWebOrNotToWeb is processing it. The details that can be asked are the following:
 -Identity and the contact details of the person at ToWebOrNotToWeb that has determined how and why to process the Personal Data
 -The purpose of the processing
 -The types of Personal Data collected, stored and processed
 -Recipient(s) to whom the Data may be disclosed
 -How long the Data will be stored
 -Information about your rights
 -How to lodge a complaint with ToWebOrNotToWeb
 -Whether the processing of Personal Data is a contractual requirement, or necessary to enter into a contract and the possible consequences of failing to provide such Data
 -The source of Personal Data if it wasn’t collected directly from you
 -If applicable, the information, the reasons for, and the consequences of automated processing

To access the Personal Data that ToWebOrNotToWeb holds, identification of the Data Subject will be required. ToWebOrNotToWeb will accept the following forms of identification when information on Personal Data is requested by Data Subjects: valid national identification document, company full address with official registration number, VAT number, business title and responsibilities within the company. If ToWebOrNotToWeb is dissatisfied with the quality of the identification information provided, ToWebOrNotToWeb may ask further information before releasing the Personal Data.

In case ToWebOrNotToWeb refuses a Data Subject’s request for one of the above rights, ToWebOrNotToWeb will provide the reason, which Data Subject can legally challenge.

Security
While ToWebOrNotToWeb places great importance on the security of Personal Data associated with Data Subjects, it cannot ensure or guarantee that loss, misuse or alteration of Personal Data will not occur. In the unlikely event of a Data breach, ToWebOrNotToWeb will work to inform the Supervisory authority and concerned Data Subjects within 72 hours of becoming aware of the breach, in accordance with Articles 33 and 34 of the GDPR.

Data Subjects should bear in mind that transmission of information over the internet is never entirely secure. ToWebOrNotToWeb cannot therefore guarantee the security of information transmitted to www.ToWebOrNotToWeb.com which transmission remains at the Data Subjects’ own risk.

ToWebOrNotToWeb has no control of third-party websites linked to www.ToWebOrNotToWeb.com and is not responsible for their contents.

Complaints
If Data Subjects want to make a complaint about how their Personal Data is being processed by ToWebOrNotToWeb or its partners, Data Subjects can do so by contacting directly ToWebOrNotToWeb. If Data Subjects do not get a response within 30 days, they can complain to the Data Protection Regulator.

The contact details are:
ToWebOrNotToWeb, 52 rue Mouffetard 75005 Paris France
Telephone +33 (0)9 53 34 96 32or email contact@winlocal.in
French Data Protection Authority : CNIL (Commission Nationale de l’Informatique et des Libertés)
www.cnil.fr/english/

Consent
Through agreeing to this privacy notice, Data Subjects are consenting to ToWebOrNotToWeb processing their Personal Data for the above specified purposes. Data Subjects can withdraw such consent or object PD processing at any time by emailing to ToWebOrNotToWeb.
For that, they can refer to https://winlocal.in/toweb/contact/ page for full contact details.

Data Controller
TO WEB OR NOT TO WEB, SAS, 52 rue Mouffetard, 75005 Paris France
The person responsible for Personal Data and the Data protection through www.ToWebOrNotToWeb.com is Silvia Carter, CEO of ToWebOrNotToWeb.
Contacts:
silvia.carter@winlocal.in
+33 (0)9 53 34 96 32
Please email any questions, concerns or comments you have about this privacy policy or any requests concerning your Personal Data to contact@winlocal.in

Information about the website
In accordance with art. 6 of the French law n° 2004-575 of June 21st, 2004 for the full confidence in the digital economy, users of www.ToWebOrNotToWeb.com are hereby provided the information regarding the management of the website and its content.
Owner:
ToWebOrNotToWeb SAS, 52 rue Mouffetard 75005 Paris France, with a registered capital of 10 000 €, business registration number Paris RCS 792 671 653, VAT number FR 25 792671653.
Contact:
contact@winlocal.in
+33 (0)9 53 34 96 32
Responsible for the website:
Silvia Carter
CEO of ToWebOrNotToWeb SAS
Web hosting:
1&1 Internet AG
Brauerstr. 48
76135 Karlsruhe
Allemagne
https://www.1and1.de/
+49 (0)2 602 969 708

Liability limitations
ToWebOrNotToWeb shall not be liable for damages related with the use of www.ToWebOrNotToWeb.com. It’s the user’s responsibility to make sure he’s using updated virus free equipment and the latest browser version before using www.ToWebOrNotToWeb.com.
Likewise, ToWebOrNotToWeb does not guarantee the absence of interruptions or of issues to access www.ToWebOrNotToWeb.com or its content, nor that it is permanently updated, without inaccuracies, which ToWebOrNotToWeb will try to repair as soon as possible.

Intellectual property
Without prejudice to the website’s content individual rights, the set of www.ToWebOrNotToWeb.com contents, in terms of design, programming, structure, indexing and presentation, is protected in accordance with the international laws on intellectual property and are owned exclusively by ToWebOrNotToWeb. Any reproduction, modification, publication, adaptation of all or part of the website is forbidden, unless a previous written authorization is provided by ToWebOrNotToWeb. Unauthorized use of www.ToWebOrNotToWeb.com or part of it will be considered illegal and pursuable in accordance with art. L.335-2 and following of the French Intellectual Property Code.
Failure to comply with the above conditions will constitute an unlawful activity, which may lead to corresponding civil or criminal sanctions in accordance with the applicable legislation. The third-party contents of the website, whether texts, images, animations, multimedia, software, computer applications, trademarks, trade names or patents belong to the mentioned companies, organizations or persons. The use of such third-party content in www.ToWebOrNotToWeb.com is done for illustration only or as a reference to products, Services and companies, in accordance with the rules on intellectual property.