PRIVACY POLICY AND LEGAL NOTICE

This Privacy Policy applies to any person who creates an account on the mobile app named “Shared Resources” (the “Mobile App”) hosted and operated by HUMANITARIAN LOGISTICS COOPERATIVE (HULO), a European Cooperative Company, having its registered office at 89 rue de Paris 92110 Clichy, France and registered under number 903 751 154 RCS Nanterre (“hulo”, “you”, “your”).

When you are using the Mobile App and services offered through it (the "Services"), we may collect and process your personal data.

The purpose of this Privacy Policy (the "Privacy Policy") is to inform the users of the Services and the Mobile App ("User(s)", "you", "your") about how we collect and process your personal data, in compliance with the applicable French and European legislation, notably French Law No. 78-17 of 6 January 1978 on information technology, data files and civil liberties, Regulation (EU) No. 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR") and Directive 2002/58/EC of 12 July 2002 as amended by Directive 2009/136/EC ("ePrivacy Directive"), and any national transposition text or any subsequent text that may follow them (together, "Applicable Regulations").

It is very important to us to respect your privacy and protect your personal data.

It is important that you read this Privacy Policy so that you know how and why we process and use your personal data.

We regularly update the Privacy Policy in order to comply with any legislative, regulatory, jurisprudential, editorial or technical changes. The date of the latest update is 12/08/2024.

1. Definitions

   The terms "personal data", "process/processing", "data controller", "processor", “data subject”, "recipient(s)" and "consent" have the same meaning as given in Article 4 of GDPR.

2. Scope

   This Privacy Policy applies to our processing of your personal data where we act as a data controller with respect to the Services and the Mobile App. This Privacy Policy does not apply to our processing of your personal data on behalf of third party services providers (providing services to You through the Mobile App ("Third Parties"), where we act as a data processor. For the latter, please refer to privacy policies of Third Parties who act as data controllers for the processing of certain of your personal data.

   The Mobile App include links to Third Parties' websites, plug-ins and applications. Clicking on these links may allow Third Parties to collect your personal data. We do not control these Third Party websites and are not responsible for their processing of your personal data.

3. Data Controller

   The data controller for processing your personal data collected on our Mobile App and/or when you are using our Services is HUMANITARIAN LOGISTICS COOPERATIVE (HULO), a European Cooperative Company having its registered office at 89 rue de Paris 92110 Clichy, France and registered under number 903 751 154 RCS Nanterre, and the contact details of which can be found in Article Contact information.

4. What personal data is collected?

   We may collect, use, store and transfer various types of personal data from following categories (the list of examples of data for each category may not be exhaustive) regarding users of the Mobile App:

• Identification data: name(s), surname, pseudonym;
• Contact data: professional email address of the humanitarian organisation or partner of hulo;
• Professional information: name of the humanitarian organisation or partner of hulo; position and department, professional email address, country of intervention;
• Authentication data: professional email address of the humanitarian organisation or partner of hulo, password;
• Communications data: messages sent to us via contact forms or emails, any correspondence from you that may be sent to us or to other users of the Services via the messaging service or the publication of ads, or any exchanges with us;
• Content data: your personal data such as your full name or contact information (i) that may transit through our Services (for example, as part of an ad, a research, the contact list or messaging service) or (ii) may be hosted by us for the purpose of providing them and providing support for such Services.

We do not intentionally collect any special categories of data (such as health, sexual orientation, religious beliefs, etc.). If the Content data contains any special categories of data, we do not have any knowledge of it.

We also collect non-personal data.

5. Why do we collect your personal data?

The table below describes why we use your personal data for which we are data controller, and what is the legal basis for such use.

Purpose	Legal basis	Categories of personal data
Establish and manage our contractual relationship with users of the Mobile App	Necessary for performance of the contract	Identification data Contact data Professional information Authentication data Communications data
Provide You with the Mobile App’s functionalities (including creating an Account and answering to your requests)	Necessary for performance of the contract	All categories
Operate and secure our network and prevent fraud	hulo's legitimate interest in securing our network in particular by evaluating the volume of data transiting through our network at any given time, in order to manage this data hulo's legal obligations, in particular relating to security, fraud detection and management	All categories
Perform our legal obligations in assisting law enforcement and other government authorities and regulators, in performing court decisions	hulo's legal obligations as described in the purpose (for example, providing data or implementing an interception upon request from law enforcement authorities)	All categories




6. Who are the recipients of your personal data?

   6.1. Data transferred to the authorities and/or public bodies

   In accordance with the regulations in force, personal data may be forwarded upon request to the competent authorities, courts, officers of the law, ministerial officers, debt collection or public bodies, exclusively for hulo to satisfy its legal obligations.

   6.2. Use of data by hulo and its partners/subcontractors

   Your personal data may be used by hulo, its subcontractors, affiliates and/or, if applicable, by its business partners, for the purposes described in Article 5 above.

   • hulo’s staff, auditors and hulo’s subcontractors may have access to your personal data as part of providing the Mobile App and/or the Services;
   • Third Parties that may receive your personal data as independent data controllers. In this case, any such processing would be subject to privacy policies of such providers;
7. Security of your personal data

hulo undertakes to take all the necessary precautions and organizational and technical measures in order to preserve the security, integrity and confidentiality of your personal data, and, in particular, to protect such data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to this data.

We require that third parties with whom we contract to respect the security of your personal data and to process it in accordance with Applicable Regulations.

8. Retention periods of your personal data

hulo undertakes not to keep your personal data beyond the period strictly necessary for the purposes for which it was collected, and in accordance with the Applicable Regulations, as well as any laws and regulations, including taxing and accounting.

hulo undertakes to anonymize or delete your personal data as soon as the purpose and/or the duration of their established retention expire.

After having served its main purpose, personal data may be archived for auxiliary purposes, such as of researching, investigating and prosecuting criminal offenses, ligation, or accounting and tax purposes. Archiving implies that this personal data will be subject to limited access restrictions.

In order to determine retention periods of your personal data, we take into account the following:

• Volume, origin and category of personal data;
• Potential risks arising from fraudulent use or unauthorized disclosure of personal data; and
• Purposes for which the personal data has been processed.

As an example, please find below some established retention periods:

• Identification data and Contact data: as long as the account is valid or until the user to whom they belong requests deletion.
9. What are your rights regarding your personal data?

In accordance with the Applicable Regulations, you have the right to:

• access to your personal data, 
• rectification of your personal data;
• Erasure or deletion of your personal data (subject to any hulo’s needs that should be justified, to retain personal data, for example with respect to its legal obligations). You can delete your account by going to your profile / my settings / delete your account ;
• restriction of processing of your personal data (subject to limitations provided in Applicable Regulations);
• object to processing of your personal data (subject to limitations provided in Applicable Regulations);
• withdraw your consent, if the processing of your personal data was based on your consent;
• portability of some of your personal data (subject to limitations provided in Applicable Regulations);
• provide hulo with instructions regarding the use of your personal data after your death;
• lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés) or the supervisory authority of the Member State of the European Union in which you normally reside.
• Delete your account by going to your profile modification area, ticking the deactivate box and confirming your choice.

To exercise the rights mentioned in this Article, you may contact hulo at dpo@hulo.coop or at HUMANITARIAN LOGISTICS COOPERATIVE (HULO), 89 rue de Paris 92110 Clichy, France.

10. Contact information

For any questions concerning the processing of your personal data, you can address your request directly to hulo by contacting it at dpo@hulo.coop or at HUMANITARIAN LOGISTICS COOPERATIVE (HULO), 89 rue de Paris 92110 Clichy, France.

hulo will endeavour to find a satisfactory solution to ensure compliance with the Applicable Regulations.