Last Updated: September 21, 2022

Launchmetrics Hackathon Privacy Policy

This Privacy Policy (“Privacy Policy”) is aimed at illustrating the means and purposes of the processing of personal data carried out by Launchmetrics for the “Beauty Hacks: The Data Hackathon by Launchmetrics” taking place from the 17th - 21st November 2022 (“ Hackathon”), and it is applicable to all the participants to the Hackathon (“Participant”, “you” or “your”).

When we refer to “Launchmetrics”, “we”, “us” or “our”, we mean Launchmetrics France SA having its principal offices at 16-18 rue de Londres, 75009 Paris, France (“Controller”, “Business” or “Launchmetrics”) as part of the Launchmetrics Group. For the purposes of organizing, managing or otherwise performing any activities related to or connected with the Hackathon, the Controller may share or disclose Participant’s Personal Data to its affiliates. In such events, and on a case by case basis, each affiliate will be considered a Processor for the purposes of GDPR. A full list of Launchmetrics affiliates can be found here.

The Processing of the Personal Data carried out by Launchmetrics for the Hackathon is made in compliance with the applicable laws, and is based on the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and accountability. Any term indicated in capital letters shall have the meaning attributed to it within the GDPR or in the CCPA, or otherwise provided hereto.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it, and in case of doubts or questions please feel free to contact us at dpo@launchmetrics.com.

What Does This Privacy Policy Covers?

This Privacy Policy covers the processing of Participants’ Personal Data collected for the purposes of participating in the Hackathon as well as navigating the Hackathon’s Website (“Website”).

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services and applications (“Third-Party Services”) that you elect to use to participate to the Hackathon or to individuals that we do not manage or employ. We cannot take responsibility for the content or privacy policies of those Third-Party Services.

What Data Do We Collect and Receive?

The Personal Data that will be processed are necessary to register and attend the Hackathon. In particular, with your consent, we will collect the following types of information from Participants:

Personal Data Directly Provided by You

To register and attend the Hackathon we will ask you to provide us with some of your Personal Data. In particular you will be asked to provide your name, surname, contacts’ details, age, occupation, institution or company affiliation and sector.
Before completing the registration process you will be asked to tick a checkbox providing your consent so we are sure that you understand the reason why we may collect such information and you will also be provided with a link to this Privacy Policy.

Usage Information

In addition to the Personal Data provided directly by you, we may also collect usage information.

In particular we collect:

IP Address Information and Other Information Collected Automatically. We automatically receive and record information from your web browser when you interact with the Website, including your IP address and cookie information. Generally, the Website automatically collects usage information, such as the number and frequency of visitors to the Website. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally, and in any case these information are not made public. Indeed, this type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Website so that we can analyze and improve them. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.
Aggregate Information. Without prejudice to the above, we also collect statistical information about how, collectively, users use the Website (“Aggregate Information”). Some of this information is derived from Personal Data. This statistical information cannot be tied back to you or your web browser. We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use the Websites and their services or websites, which facilitates improving both their services and how the Websites interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Data about you that they have independently developed or acquired.
Device Identifiers. When you access the Websites by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Website. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Website. Some features of the Website and Website may not function properly if use or availability of device identifiers is impaired or disabled.
Location Data. When you access the Website by or through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device. Location data may convey to us information about how you browse and use the Website and Website. Some features of the Website, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled. Implementation of Location-based services may vary depending on where you are accessing the Website from.

Cookies

The Website uses first and third parties cookies and similar tracking technologies (including web beacons to analyze which emails are opened, or links clicked), which may collect information about you via the Websites and across other websites and online services. For more details about how we use these technologies, please see our Cookies Policy.

Why We Collect Personal Data and Lawful Basis to Do So

Your Personal Data will be processed electronically or manually by Launchmetrics as required by any applicable laws.

In particular, we will process your Personal Data,

to register you to attend the Hackathon, by granting your freely and informed consent, according to Art. 6.1, a) of GDPR;
for our legitimate interest, to prevent frauds, ensure cyber security of the Website, or to defend ourselves in case of disputes or claims, pursuant to Art. 6.1, f) of GDPR, and provided that your interests do not overridden ours;
to comply with obligations set forth by applicable laws and regulations and to ascertain responsibilities in case of any computer crimes against the Website or Launchmetrics. As this processing is mandatory by law, Participant’s consent is not required according to Art. 6.1, c) of GDPR.

Is Information About Me Secured?

We work hard to secure your Personal Data from any unauthorized access to, or unauthorized processing, alteration, disclosure or destruction of, Personal Data we hold by taking appropriate technical and organizational security measures, having regard to the state of the technological development and the cost of implementing any measures. Where appropriate, for example, we might implement pseudonymization and encryption of Personal Data.

Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

Please consider that we store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Data or otherwise.

Where it is likely that a breach results in a risk to the rights and freedoms of individuals, we will notify the relevant supervisory authority within seventy-two (72) hours of becoming aware of it. This information can be provided in phases to facilitate fast and efficient reporting. Where a breach is likely to result in a high risk to the rights and freedoms of individuals, we will notify those concerned directly.

How Long Do We Conserve Your Data?

Launchmetrics will retain your Personal Data in accordance with applicable laws and only for the period of time necessary to organize and manage the Hackathon.

What Happens When There are International Data Transfers?

We are a global organization, as such, we may share information about you within Launchmetrics offices and with affiliates and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Privacy Policy.

In some cases, we use suppliers located in various countries to collect, use, analyze, and otherwise process information on its behalf. It is our practice to require such suppliers to handle information in a manner consistent with our policies and applicable laws. Overall, we commit to comply with any legal requirements provided under any applicable law to transfer Personal Data to third countries.

In particular, for transfers of Personal Data outside of the EEA falling within the scope of application of GDPR, we are making sure that any of these transfers are supported by the strict legal compliance of our suppliers to the GDPR. In particular, depending on the concrete case, we rely on European Commission Adequacy Decisions, or EU Standard Cont r actual Clauses (also called Model Clauses) to meet the GDPR requirements.

Notice for Participants located in the People’s Republic of China

The content of this section is intended exclusively for the benefit of Participants that are residing and/or are nationals (“Chinese Participants”) of the People’s Republic of China (“China”), and it must be construed in addition and not in lieu of the full Privacy Policy.

In particular, the purpose of this section is to inform Chinese Participants that for the purposes indicated in section “Why We Collect Personal Data and Lawful Basis to Do So”, we might transfer Chinese Participants’ Personal Data outside China. Provided that, we will consider to have received Chinese Participants explicit consent to the data transfer at the time of the registration to the Hackathon.

For the sake of clarity, Chinese Participants’ Personal Data might be transferred among the companies affiliated to Launchmetrics, as well as to its service provider, and to the Hackathon partners or sponsors. We will not sell any Chinese Participants’ Personal Data to third parties. Any Chinese Participants’ wishing to know which entities received their Personal Data, can contact Launchmetrics at privacy@parklu.com

Who can access my Personal Data?

As a general principle, your Personal Data will be shared and made available or otherwise processed in strict compliance with the principle of the “need to know”. Unless upon your specific consent or as otherwise required by applicable laws, your Personal Data shall not be shared with any other organizations.

Without prejudice to the above, Your Personal Data might be shared with:

Entities affiliated to Launchmetrics, which will act as data processor pursuant to GDPR. The complete list of the entities affiliated to Launchmetrics can be found here.
Analytical Services. We use certain analytics providers (including but not limited to Google Analytics, Inspectlet, Google Optimize, Hotjar) in order to better understand how the Website is used and how it can be improved. Your IP address information may be accessed by one or more of such analytics providers. In addition, information regarding the usage activity of a certain portion of users of the Website may be shared, but such information is shared on an anonymous basis and does not reveal the identity of any individual Participant. These providers do not collect any personal information or store IP addresses locally on their websites.
Service provider. We might share your Personal Data with our service providers (e.g. cloud providers, Website providers) for the purposes of managing your requests/interactions with the Websites.
Hackathon Partners or Sponsors. Launchmetrics Hackaton’s partners and/or sponsors may receive your Personal Data for the purpose of the Hackathon to allow you to attend the Hackathon and/or to access or use certain tools or features, and they may process it for other purposes. For the sake of clarity, such data sharing will entail the creation of a joint-controllership relationship among Launchmetrics and each Hackathon partner or sponsor. You hereby acknowledge that such data sharing may occur. If you wish to receive additional information on this, please do not hesitate to contact us at dpo@launchmetrics.com, and please remember that you have the right to object to such processing at any time by emailing us at dpo@launchmetrics.com.

Please also consider that we reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Notice for California Residents

The content of this section is aimed solely at providing California residents with relevant information under the CCPA and only applies to Personal Information for which Launchmetrics is a Business (as defined in the CCPA). It must be construed in addition and not in lieu of the full Privacy Policy.

Information we may collect

California law requires us to disclose certain information regarding the Personal Information we collect in the twelve (12) months prior to the effective date of this Privacy Policy. We have collected Personal Information from you, your devices, our partners, third parties, and from categories of sources otherwise described above in this Privacy Policy.

Although we do not sell personal information in exchange for any monetary consideration, the CCPA defines a sale in a way that may include allowing third parties (website analytics companies, providers of email services, and security vendors and event sponsors/partners) to receive certain combined Personal Information such as, identifiers and commercial information that are collected directly from you and Internet or other electronic network activity (e.g. cookies) collected from your usage of the Website.

We do not sell personal information in exchange for any monetary consideration. We share Personal Information as necessary for certain business purposes, as defined by the CCPA (Cal. Civ. Code 1798.140(d)) and described in the section “Why We Collect Personal Data and Lawful Basis to Do So” of this Privacy Policy. California residents may opt out of the sale of their Personal Information. While Launchmetrics does not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the CCPA. In order to provide you with control over how your Personal Information is collected and shared, if you would like to opt out of Launchmetrics’ use of your Information for such purposes (when considered as a sale), you may do so by contacting us directly. With respect to cookies, you can customize your settings when you access the Website and change them at any time.

Please note that these requests apply only to information that Launchmetrics holds as a Business. If your request relates to the Personal Information collected through a third party’s website or services, you should direct your request to the owner of that website or service.

If you have additional questions about this section or how to exercise your rights under the CCPA, please contact us at dpo@launchmetrics.com. The CCPA allows California consumers to designate an authorized agent to exercise their rights under CCPA. If we receive a request from an agent, then we have the right to verify that you indeed want to take the action requested by the agent and will do so by contacting you directly.

California’s Shine the Light Law

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Data that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following email address: dpo@launchmetrics.com. The request should attest to the fact that you are a California resident, and provide a current California address.

Your Rights Under The Applicable Data Protection Laws

Pursuant to the applicable data protection laws, you have a number of rights concerning the Personal Data that We hold about you, including but not limited to the right (i) to be informed on the processing operations; (ii) of access of your Personal Data processed by us; (iii) to rectification and/or erasure of your Personal Data; (iv) to restrict and/or object the processing; (v) to data portability; (vi) to lodge a complaint; (vii) to withdraw your consent to the processing operations (provided that consent was the lawful basis used for the processing); (viii) to not be subject to automated individual decision making; (ix) to equal service.

You can exercise any of these rights, by contacting us at dpo@launchmetrics.com providing a description of your request. Your requests will be handled within a maximum of 30 (thirty) working days.

English Version Controls and Changes

Non-English translations of this Privacy Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls. We reserve the right to modify the present Privacy Policy where appropriate, we will notify you of any changes.