Data Processing Policy

Data Processing Policy

Introduction

This policy outlines the data processing practices of revzper SAS for the Euphile platform, including its products such as Solon, Vauban, Nassau, Leonardo, Atlas, Plutus, Tzu and Richelieu.

1. Lawful Bases for Data Processing

Personal data is processed on the following lawful bases: (a) contract performance for subscription management, billing, and service delivery; (b) legitimate interest for platform security, fraud prevention, and usage analytics; (c) legal obligation for tax and commercial record keeping.

2. Categories of Data Processed

The following categories of personal data are processed: identity provider subject references, subscription states, usage metadata, and billing records.

3. Processing Activities Register

A processing activities register is maintained as required by applicable regulations.

Ref: GDPR Art. 30

Data Subject Rights

revzper SAS ensures compliance with data subject rights under applicable regulations.

1. Overview of Rights

Data subjects have the following rights regarding their personal data:

Enumerated Rights

• Request confirmation of whether personal data is processed and access to such data.
• Request correction of inaccurate or incomplete personal data.
• Request deletion of personal data under specific conditions (e.g., when no longer necessary for the purposes for which it was collected).
• Request limitation of processing in certain circumstances (e.g., during verification of data accuracy).
• Receive personal data in a structured, commonly used, and machine-readable format, and transmit it to another controller where technically feasible.
• Object to processing based on legitimate interests or direct marketing, including profiling.
• File a complaint with the competent supervisory authority. For data processed in France, the authority is the Commission nationale de l'informatique et des libertés (CNIL). Contact details for the CNIL are provided below.

2. Exercising Rights

To exercise any of these rights, contact revzper SAS at contact@revzper.com or via the contact details provided in our privacy policy. Responses will be provided without undue delay and in any event within one month of receipt, subject to applicable legal exceptions.

3. CNIL Contact Details

Address: 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France

Website: https://www.cnil.fr

Email: cnil@cnil.fr

Categories of Personal Data Processed

The following table details the categories of personal data processed for the Euphile platform and its products (Solon, Vauban, Nassau, Leonardo, Atlas, Plutus, Tzu, Richelieu).

1. Data Categories Overview

revzper SAS processes the following categories of personal data for the Euphile platform. The processing purposes and legal bases for each category are detailed below.

2. Data Minimization Principle

This table demonstrates compliance with the principle of data minimization by ensuring that only necessary data is processed for each purpose.

Ref: GDPR Art. 5(1)(c)

3. Detailed Data Categories