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Privacy policy - App

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Mantra, which manages the platform Mantra, attaches great importance to the protection and confidentiality of your personal data, which represent for us a pledge of seriousness and trust.

The Privacy Policy specifically reflects our willingness to enforce compliance with applicable data protection rules and, in particular, with the General DataProtection Regulation ("GDPR").

In particular, the privacy policy aims to inform you about how and why we process your data in connection with the services we provide.

Who is this policy for?

The policy applies to you, regardless of where you live, as long as you are users of our Mantra service.

Why do we process your data?

To provide our services, we have to process yourpersonal data:

●   To use and benefit from ourservice and all its features on the basis of our general terms of use.
●   To provide user account management (e.g., account creation, service access, and account deletion) based on our Terms of Service.
●   To receive our technical emails (e.g. modification of passwords, etc.) essential to the proper functioning of our service on the basis of our general conditions of use.
●   To ensure and enhance the security and quality of our services on a day-to-day basis (e.g., statistics, data security, etc.) based on our legal obligations, our terms and conditions of use and our legitimate interest in ensuring the proper functioning of our services.

Your data is collected directly from you when you use our website and we undertake toprocess your data only for the reasons described above.

For cookies, please consult our dedicated CookiePolicy accessible on our website.

What data do we process and for how long?

We have summarized the categories of personal data that we collect and their respective duration of retention.

If you wish to obtain further details on the retention periods applicable to yourdata, you can contact us at: dpo@mantra.ms.

●   Professional identification data (e.g. last name, first name, position, company, etc.) and contact data (e.g. email address and business phone number, etc.) kept for the entire duration of the provision of the service, plus the legal statute of limitations, which is generally 5 years.
●   Email address to receive our technical messages kept until your account is deleted.
●   Connection data (e.g. logs, IP address, etc.) kept for a period of 1 year.

Once the retention periods described above have expired, the deletion of your personal data is irreversible and we will no longer be able to provide it to youafter this period. At most, we may only retain anonymous data for statistical purposes.

Please also note that in the event of litigation, we are required to retain all of your data for the duration of the processing of the case even after the expiration of the retention periods described above.

What rights do you have to control the use of your data?

The applicable data protection regulations give you specific rights that you can exercise, at any time and free of charge, to control how we use your data.

●   Right of access and to obtain a copy of your personal data as long as this request is not in opposition with business secrecy, confidentiality, or the secrecy of correspondence.
●   Right of rectification of personal data that are incorrect, obsolete or incomplete.
●   Right to request erasure ("right to be forgotten") of your personal data that are not essential to the proper functioning of our services.
●   Right to the restriction of processing your personal data which allows you to freeze the use of yourpersonal data in case of dispute about the lawfulness of a processing.
●   Right to ask for the portability of your data which allows you to download part of your personal data in order to store it or transmit it easily from one information system to another.
●   Right to provide guidelines on the fate of your data in the event of your death either by you, a trusted third party or an heir.

To be considered, your request has to be done by you only at the address dpo@mantra.ms. Any request that does not follow this process cannot be treated.

Requests cannot be made by anyone other than you.Therefore, we may ask you to provide proof of identity if there is any doubt about your identity.

We will respond to your request as quickly as possible, within one month of receipt, unless the request is complex or repeated. In this case, the response time may be up to three months.

Please note that we may always refuse to respond to any excessiveor unfounded request, especially if it is repetitive.

Who can access your data?

WE NEVER TRANSFER OR SELL YOUR PERSONAL DATATO THIRD PARTIES OR BUSINESS PARTNERS. ALL OF YOUR PERSONAL DATA ARE USED EXCLUSIVELY BY OUR STAFF OR BY OUR IT SERVICE PROVIDERS.

More specifically, we only share your data with people who are duly authorized to use it to provide you with our service, such as ourIT department or our customer relations department.

Your personal data can also be transferred to our service providers for the sole purpose of technically operating our service (e.g. data host).

We specify that we audit every service provider before recruiting them in order to verify that they are strictly complying with the applicable rules regarding personal data protection.

How do we protect your data?

We implement all the technical and organizational means required to guarantee thesecurity of your data and, in particular, to fight against any risk ofdestruction, loss, alteration or unauthorized disclosure of your data (e.g.training, access control, passwords, etc.).

Can your data be transferred outside the European Union?

Unless strictly necessary and on an exceptional basis, we never transfer your data outside the European Union and your data is always hosted on European soil. In addition, we undertake to do our best to recruit only service providers whohost your data within the European Union.

In case we are using service providers that need to transfer your personal data outside the European Union, we undertake to verify that they are implementing appropriate safeguards to ensure the confidentiality and protection of your personal data.

Who can you contact for more information?

We have officially appointed an outsource and independent Data Protection Officer ("DPO") to our supervisory authorityin order to ensure the safety and confidentiality of your personal data.

You can contact our DPO at any time and free of charge at dpo@mantra.ms in order to obtain more information or details on how we process your personal data.

How can you contact the CNIL?

You may at any time contact the "Commission nationale de l'informatique et des libertés"or "CNIL" at the following address: CNIL Complaints Department, 3 place de Fontenoy - TSA 80751, 75334Paris Cedex 07 or by phone at 01.53.73.22.22.

Can the policy be modified?

We may change our Privacy Policy at any time to adapt it to new legal requirements as well as to new processing that we may implement in the future.

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