Introduction:

The spunky.dev website operated by EI SPUNKY DEVELOPMENT places great importance on the confidentiality and protection of personal information of its clients, prospects, partners, suppliers, and visitors. This privacy policy explains how we collect, use, share, and protect the personal data you provide to us. Please read this policy carefully to understand our practices regarding privacy.

This policy aims to ensure strict compliance with the principles of transparency and fairness in the processing of personal data. As the controller of this personal information, SPUNKY DEVELOPMENT fully assumes its responsibility to provide clear and easily accessible information regarding how we use the information we collect or that you provide to us.

Please also note that we may update this privacy policy to continue serving your best interests.

This policy was last updated on: 07/06/2024 at 16:28.

Legal Basis:

The processing described below is necessary for the execution of services and contracts provided and concluded by SPUNKY DEVELOPMENT (Article 6.1b of the GDPR).

Personal data collected:

When you use our website or the services offered by SPUNKY DEVELOPMENT, and more generally, during any interaction with our company, you may provide us with a range of information about yourself, some of which may identify you (hereinafter referred to as 'Personal Data'). This may occur when you browse our website, fill out online forms, attend our events, subscribe to one of our contents (e.g.: Newsletter), or register and/or log in via one of the user interfaces offered by SPUNKY DEVELOPMENT.

The nature and amount of data collected vary depending on your relationship with our services:

* Your name and contact information: That is, all personal information you yourself entered through one or more forms on our website. This includes: your name, first name, address, email address, and phone number.

* Data related to your project: To get in touch with our teams, we ask you for certain information about your digital project. This includes: The name of your project/company, the service offered by SPUNKY DEVELOPMENT you wish to use, your budget for the realization of this project, and a description of your project in your own words.

* Login credentials: Refers to all the information you need for authentication and access to your personal spaces.

* Information related to your browsing: By using our website, you interact with our servers. During this interaction, we collect some of the public information provided by your web browser regarding your activity: browser preferences, language, and configuration.

Use of cookies:

What is a cookie?

Cookies are text files containing small amounts of information that are downloaded to your computer or mobile device when you access our services. We use both session cookies and persistent cookies to identify you more easily. A session cookie is used to identify a particular visit to our site. These cookies expire after a short time, or when you close your browser after using our site. A persistent cookie, on the other hand, will remain on your device for a period defined in the cookie. We use these cookies when we need to identify you over a longer period. For example, when you ask us to keep you logged in.

Cookies used:

The vast majority of cookies we use are used to identify you, secure your session, and facilitate the use of our services.

Here is a list of the main cookies used by SPUNKY DEVELOPMENT:

* sdev-csrftoken: Cookie to protect our site's forms against CSRF attacks.
* sdev-session-id: Cookie containing your session identifier.
* sdev-token: Cookie containing the string identifying your session.
* sdev-cookies-policy: Cookie added to your browser when you accept/refuse SPUNKY DEVELOPMENT’s privacy agreement.
* sdev-auth-page: Cookie containing your login status.
* $SDEV-FINGERPRINT (Local Storage): Cookie containing a unique identifier to prevent any session hijacking.

If any of these cookies are deleted, access to most features of our services would be compromised.
Other cookies may be used on the site, but we solemnly certify that none are used for advertising tracking or similar purposes.

How do I manage my cookie preferences?

You have the option to accept or refuse cookies, except for strictly necessary cookies listed above. Currently, SPUNKY DEVELOPMENT only uses cookies strictly necessary for the website’s operation, so you don't need to worry about configuring them.

You can also block the storage of all cookies and other trackers by configuring your browser's privacy and/or security options. To do this, we invite you to consult the detailed explanations available on the website of the French data protection authority: the CNIL (click here)

However, please note that blocking all cookies via browser settings may lead to changes or loss of certain settings or information and may hinder your browsing experience on our website.

Use of your personal data:

We may use your personal data for the following purposes:

* Perform our contract with you : Whether you are a client or partner of SPUNKY DEVELOPMENT, we process your data as part of creating service contracts between both parties.

* Marketing/communication operations : We may use your personal data to send you communications related to our activities, according to your expressed interest. This may include newsletters, event invitations, etc. You can request to stop receiving such communications at any time by writing to the following address: stop@spunky.dev.

* Resolve a dispute : We may process your personal data to respond to legal requests or defend our rights in the context of legal proceedings.

* For statistical, quality monitoring, accreditation, and ranking purposes : To improve the quality and performance of our services in general, we may process your personal data and submit surveys to generate statistics or global reports.

* Security : SPUNKY DEVELOPMENT may also process your data to ensure the safety of people and property.

* Security of SPUNKY DEVELOPMENT's information system : Your activity on the information system is logged. These logs may be analyzed for various purposes:

- Producing statistics to optimize, monitor, and improve information systems.
- Detecting and analyzing anomalies or security incidents.
- Making logs available in response to legal requests.
- Detecting abuse and fraud (uses contrary to regulations or that could involve SPUNKY DEVELOPMENT’s liability).

For all these purposes, your data may be processed to be completed and updated in compliance with Article 5 of the GDPR.

For purposes not listed above, your data may be fully anonymized before being used for these new purposes.

Sharing your data with third parties:

SPUNKY DEVELOPMENT is committed to not sharing your personal data with any third party except:

* Our subsidiaries and trusted partners who share our values.

* Legal and administrative authorities. To comply with our legal obligations, in case of emergency or crisis, we may need to share some of your data with legal, regulatory, or administrative authorities.

Legal basis for processing your personal data:

SPUNKY DEVELOPMENT only collects, uses, and shares your personal data in accordance with what is permitted by the current General Data Protection Regulation (GDPR).

We may process your data either:

* Because you have given your consent. For certain operations such as marketing activities, we use your data because you have authorized us to do so.

* To perform our contract with you. We process your data to execute the contract we have with you and to provide the services specified.

* To comply with a legal obligation. In some cases, we need to collect or retain certain information about you to fulfill our own legal obligations, for example, in matters of taxation or security. Because the processing is necessary for the performance of a task carried out in the public interest.

* Because this processing is in our legitimate interest. Sometimes it is in the legitimate interest of SPUNKY DEVELOPMENT to process certain personal data of yours.

* Because this processing is necessary to protect the vital interests of a person.

Retention of your data:

Your personal data is retained for as long as necessary to fulfill the purpose for which it was collected or in accordance with legal requirements.

The retention period varies depending on several factors, including:

* The needs of SPUNKY DEVELOPMENT's activities.
* Contractual requirements
* Legal obligations (Insurance, Taxation, Human Resources, etc.)
* Recommendations from regulatory authorities

Your data may be retained beyond our contractual relationship, for example to defend our rights in court, to provide you with documents you no longer have, or to meet our legal obligations.

Beyond the intended retention period, your personal data will be permanently deleted.

Security of your data:

We regularly assess and review the technical and organizational measures in place to ensure the security of our information system. This approach aims to prevent any risk of loss, alteration, or unauthorized disclosure of your personal data.

Your rights:

Your personal data belongs to you, and as such, you have a number of rights. In accordance with applicable data protection laws and regulations, you have the right to:

* Access: You have the right to know what personal data we hold about you, to consult it, and to obtain a copy.

* Rectification: If you notice an error, you can request at any time that we correct incorrect information.

* Deletion: Under certain conditions, you may ask us to erase your personal data. Please note that we may retain some information about you where required by applicable laws and regulations, or where we have a legitimate reason to do so (e.g. contract execution or legal defense).

* Restriction: Under certain conditions, you may ask us to restrict our use of your personal data, for example, during the time needed to review a rectification request.

* Portability: You have the right to ask us to send you or another data controller the personal data you provided to us, in a structured, commonly used and machine-readable format.

* Objection: In some cases, you may object to the use of your personal data for certain processing (e.g. direct marketing operations).

Depending on your request, we may ask you to verify your identity.

Contact and complaints:

You may withdraw the consent you have given us to process your data for a specific purpose at any time. For any questions regarding this policy or to exercise your rights, you can contact us at the following address: contact@spunky.dev

If you believe your rights have not been respected, you may file a complaint with the competent supervisory authority: Commission Nationale de l’Informatique et des Libertés.

Via the URL: https://www.cnil.fr/fr/plaintes
Or
Via postal mail: 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07