Politique de confidentialité
Introduction
The CYGOGN company offers a solution enabling the creation of a self-supporting universal email address, capable of pre-qualifying incoming emails and automatically routing them to the competent recipients. The solution also enables the analysis and forwarding of emails received in generic mailboxes to the competent recipients.
In the context of using the Solution, users are required to communicate emails, documents, confidential files, and personal data concerning them. CYGOGN places the utmost importance on the confidentiality and security of these personal data.
This Privacy Policy was established in compliance with current laws, regulations, and standards. It explains which personal data are concerned, how they are collected, processed, disseminated, stored, and for what purposes.
1. Definitions
CYGOGN
Refers to CYGOGN company, as a French SAS ("societe par actions simplifiee"), with a capital of 298,840 EUR, registered in the Lyon-France Trade and Companies Register under number 902237494, represented by Olivier Berger, hello@cygogn.com, +33 4 65 84 69 02. CYGOGN is the publisher of the Solution and provides the Service.
Recipient
Refers to any legal entity that has subscribed to CYGOGN's offer and benefits from a self-supporting universal email address, the configuration of their incoming email flow, and access to the Service according to the subscribed rights.
Solution
Refers to the artificial intelligence software solution that allows for the automation of the email routing system via a universal email address through artificial intelligence.
Service
Refers to the entirety of services and performances provided by CYGOGN. The Service allows a User, depending on their role as a recipient, to subscribe to an offer to obtain a self-supporting universal email address and benefit from an automated email reception flow. It also allows a sender to send emails without needing to identify a specific contact to target the designated recipient.
Refers to an electronic mail, that is, a written message sent electronically through a computer network. An email is sent from one electronic mailbox to another. It may include an attachment, that is, Content.
Content
Refers to any document, file, image, in any format that can be transmitted as an attachment or within the body of an email.
Sender
Refers to the person who sends an email to a recipient via a CYGOGN address.
Generic mailbox
Refers to any generic email mailbox such as contact@mycompany.com that the company subscribing to the Cygogn offer wishes to have sorted by the Solution.
User
Refers to any person who uses the CYGOGN Service. They can be an Administrator User when subscribing to the Service on behalf of a recipient or sender organization, a Sender User when they send an email to a CYGOGN email address, or a Recipient User when they receive an email via the CYGOGN routing Solution.
Site
Refers to the website published by CYGOGN, available at www.cygogn.com.
2. Collected Data and Purposes of Processing
CYGOGN ensures that the collection and processing of data are strictly necessary for the purpose of providing the Service, in accordance with the rules and instructions given by the Users.
2.1 Personal data processed when CYGOGN acts as a data controller or data processor
The processing carried out by CYGOGN, whether as a data controller or a processor, serves a clear, legitimate, and defined purpose. Data is primarily processed for the following purposes:
| Category | Collected Information | Purposes | Legal Basis | Retention Period |
|---|---|---|---|---|
| Data related to emails exchanged through or filtered by CYGOGN. | Emails (subject, message, attachments, sender, recipients, and email metadata). |
| Contract | For traceability reasons, emails are retained for a maximum duration of 12 months from their date of handling. Moreover, emails are kept for no longer than 12 months following the end of the commercial relationship. |
| Data related to the deliverability of emails. | Email opening detection data and user feedback on email deliverability, including receipt acknowledgment and the correct final recipient email address in case of distribution error. |
| Contract | 12 months from the end of the commercial relationship. |
| Data related to recipient organizations. | Distribution rules of organizations, including distribution conditions and email addresses of final recipients. |
| Contract | 6 months from the end of the commercial relationship. |
| Data related to user accounts. | Name, first name, email address, and telephone number of the preferred contact at CYGOGN. |
| Contract | 6 months from the end of the commercial relationship. |
| Web browsing data such as cookies. | Please refer to section 2.2 below. |
| Consent | No more than 13 months from the initial placement of the cookies. |
The personal data collected in this context are in no case transferred to a third party for commercial purposes.
In the event of an impact analysis conducted by the data controller, CYGOGN commits, in its capacity as a processor, to provide all necessary information. Furthermore, CYGOGN commits to informing the recipient within a maximum period of 72 hours from the observation of a security breach that caused a violation of personal data subject to notification to the competent authorities.
2.2 Website Navigation Cookies
The website uses several types of cookies for different purposes:
Functionality cookies
Essential for using the site. They enable core functionalities such as maintaining identification throughout navigation, adapting the site's presentation to the user's display preferences, and securely managing and accessing the user's personal space. These cookies are necessary for providing services during site navigation and cannot be disabled without impairing the site's functionality.
Analytical and audience measurement cookies
These non-individualized cookies help understand site usage, identify the most visited pages, and measure performance in order to improve site operation. They are not essential for navigation but help measure performance, identify navigation issues, facilitate searches, analyze viewed content, and optimize the site.
| Category | Cookie Publisher | Purpose |
|---|---|---|
| Functional | Cygogn | Management of user sessions, authentication, and personalization of the service. |
| Analytics | Tracking the user's interaction with the site, distinguishing between users, and remembering them over time and during repeated visits. |
It is considered that the User of the Site has given consent to the placement of cookies if the User continues navigation by clicking on the acceptance button on the cookie banner, by interacting with an element of the Site, or by visiting another page after their first connection. This consent remains valid for thirteen (13) months from the first placement of a cookie, after which consent will be requested again.
Users may oppose or limit the recording of cookies at any time by configuring their browser software such as Internet Explorer, Google Chrome, Safari, or Firefox. Browsers can also be configured to notify the user of cookies and request acceptance on a case-by-case basis or refuse them systematically.
Refusing cookies may deprive the user of access to certain content or significantly disrupt browsing and the services expected from the Site. If the browser is configured to refuse all cookies, some essential site functions may no longer work correctly.
For more information on the use, management, and deletion of cookies, please consult the CNIL guide.
3. Recipients
Data may be collected, transmitted, and processed by third parties on behalf of and for CYGOGN within the strict limit of the reasons stated above. CYGOGN ensures that all service providers with whom it works maintain the confidentiality and security of the data.
CYGOGN may use subcontractors, including partner structures that carry out part of the service, IT maintenance providers, technical support for databases, software, and applications that may contain data concerning CYGOGN users or prospects, as well as marketing and web agencies that create websites, advertising, marketing, and commercial campaigns for CYGOGN.
Data may also be shared with recipients or joint controllers such as lawyers, auditors, accountants, and competent public authorities when requested.
4. Retention Period
Personal data is retained only for the duration necessary to achieve the purposes mentioned above or to enable CYGOGN to meet its legal obligations. Once data is no longer useful, it is deleted or anonymized.
5. Transfer of Personal Data Abroad
The processed data is hosted by Amazon Web Services and Microsoft Azure on the territory of the European Union. CYGOGN does not transfer data outside of the European Union.
6. User's Rights
- The right of access and rectification of personal data. Before implementing this right, CYGOGN may request proof of identity to verify its accuracy.
- The right for the User to withdraw consent at any time to the processing of personal data for processes carried out on this basis.
- The right to request the deletion of personal data, except where retention is necessary to comply with a legal obligation. Data necessary for the execution of the contract will be deleted after a notice period of thirty (30) days, and such deletion may prevent CYGOGN from fulfilling the contract.
- The right to object to the processing of personal data for a legitimate reason. Exercising this right may lead to CYGOGN's inability to perform all or part of the Service when the data is necessary for its execution.
- The right to restrict processing, allowing the User to temporarily freeze the use of some of their personal data by CYGOGN.
- The right to data portability under Article 20 of Regulation (EU) 2016/679 ("GDPR"), allowing the data subject to receive the personal data they provided to CYGOGN in a structured, commonly used, and machine-readable format, and to transmit those data to another data controller.
- The right to define the fate of personal data after death and choose whether CYGOGN may communicate these data to a previously designated third party. In the absence of instructions, CYGOGN commits to destroying these data unless retention is necessary for evidential purposes or to meet a legal obligation.
GDPR-related rights can be exercised by mail or email with the Data Protection Officer or their representative:
CYGOGN
20, boulevard Eugene Deruelle, 69003, France
Email: fr.90223749400015@cygogn.com
If you believe, after contacting CYGOGN, that your data protection rights are not respected, you can file a complaint with the CNIL services.
7. Security and Privacy
CYGOGN implements organizational, technical, and software measures regarding physical and computer security to protect personal data against alteration, destruction, and unauthorized access.
CYGOGN uses the collected data with the goal of offering an efficient Service and Solution. In particular, the data is used to provide the Service, update and secure it, troubleshoot issues, offer support, improve and develop the Solution and Service, analyze performance, comply with legal obligations, and improve artificial intelligence.
The processing of personal data for these purposes includes both automated and manual processing methods. When manual review is required for emails, support, analysis, or process improvement, it is entrusted to authorized and trained CYGOGN personnel who are bound by confidentiality.
The entire system and data are hosted on Amazon Web Services and Microsoft Azure clouds. The data is fully encrypted, and only authorized CYGOGN teams bound by confidentiality can have access to the encryption keys.
8. CYGOGN Account
When a User wishes to take advantage of the Service and organize the routing of their emails or sort their generic mailboxes, they subscribe to the CYGOGN offer and provide their instructions for routing and the list of email addresses of the concerned individuals. In doing so, they act as the Recipient.
The User is responsible for the processing of data transmitted in this context and ensures that concerned individuals are informed and that the routing instructions remain up to date, so that CYGOGN's Service remains effective and functional.
9. Changes to the Privacy Policy
CYGOGN reserves the right to make any modifications or updates to this Policy at any time and without notice.