Privacy Policy

We are JL PARTNER SAS, with a share capital of 1,000 euros, headquartered at 30 rue Renoir, 78960 Voisins-le-Bretonneux, registered with the Versailles Trade and Companies Register under number 984 584 755 and identified for VAT purposes under number FR02984584755 ("We"). We publish and operate the Ember platform, accessible after authentication from the website www.ember.do (the "Website"), which allows You to use an AI-based strategic co-pilot to structure, manage and develop your professional activity (the "Platform"). We are committed to protecting your personal data and respecting your privacy when You use the Platform ("You"). This privacy policy describes how We collect, use, retain and protect information that directly or indirectly identifies You ("Personal Data"), in the context of: browsing the Website, creating and managing your user account, using the Platform's features, managing your subscription and payment methods, your communications with our support and all data generated or processed as part of your use of the Platform. The processing of your Personal Data is based on Regulation (EU) 2016/679 of April 27, 2016 (GDPR) and the amended French Data Protection Act. For any questions regarding this policy or the exercise of your rights, You may contact Us at: support@ember.do.

We only process the Personal Data necessary for browsing the Website, managing the forms made available to you, operating the Ember Platform and managing your subscription, as listed in Article 3. We never ask You to provide so-called "sensitive" data within the meaning of GDPR (for example: health data, political opinions, religious beliefs, ethnic origin, sexual orientation). If You voluntarily transmit this type of information on the Platform or in your communications with Us, this data is only processed to respond to your one-time request and is immediately deleted once it is resolved. All Personal Data processed as part of the Platform comes from information that You choose to enter. When registering, only your email address is required. You can then complete your profile or add information according to the features you use. You are free to provide only the data you wish; however, the absence of certain information may limit access to or quality of certain features. Personal Data is processed internally by authorized persons, within the limits of their respective duties.

The table below summarizes, for each purpose, the categories of Personal Data concerned, the specific data processed, the applicable legal basis and the retention period.

Your Personal Data is accessible only to the following recipients, within the limits of their duties:

• Our authorized internal teams, strictly within the scope of their duties (support, billing, maintenance, security)
• Our technical subcontractors, acting on our behalf and under GDPR-compliant contracts (hosting, security services, payment tools, analytics tools, emailing, support)
• Administrative or judicial authorities, when required by law or upon formal request
• Ministerial officers or legal auxiliaries, in the context of debt collection
• A potential acquirer or buyer, in the event of a transfer, merger or restructuring operation

The majority of our subcontractors and service providers are established within the European Union, which guarantees a high level of protection for your Personal Data. However, certain technical services essential to the operation of the Platform may involve transfers of Personal Data outside the European Union, particularly when We use service providers located outside the EU or companies whose parent company is established in a third country (for example for hosting, sending emails, performance analysis or certain advanced features). When such transfers take place, We ensure that they are governed in accordance with current regulations, by means of one of the following guarantees: the signing of Standard Contractual Clauses adopted by the European Commission; the service provider's adherence to the Data Privacy Framework approved by the European Commission (for transfers to the United States); any other appropriate guarantee provided for by the GDPR. We only work with partners presenting strong guarantees in terms of security and confidentiality. You can obtain more information about our subcontractors and applicable guarantees by contacting Us at: support@ember.do.

We implement technical and organizational measures designed to ensure the security and confidentiality of your Personal Data. These measures aim to prevent any loss, destruction, unauthorized access, disclosure or alteration of your data.

• encryption of data in transit (HTTPS/TLS)
• separation of technical environments according to access levels
• strict management of internal authorizations, limited to only those whose duties require it
• enhanced access controls for Platform administration
• continuous monitoring of the infrastructure to detect any anomalies or suspicious activities
• regular backups to ensure service continuity
• GDPR-compliant subcontracting agreements, including security and confidentiality guarantees

We also carry out regular updates of our systems and security tools to maintain a high level of protection. In the event of a security incident, identified threat or vulnerability situation, We may take the following measures: quickly identify the problem using our monitoring tools; temporarily suspend all or part of the service to avoid greater damage; correct technical flaws and strengthen our systems; inform You if your Personal Data is directly affected by the incident; cooperate with the competent authorities if necessary to manage the situation. We are committed to responding quickly and appropriately to protect your Personal Data and limit the consequences of any security incident. In the event of a Personal Data breach presenting a high risk to your rights and freedoms, We undertake to inform You as soon as possible and to notify this breach to the CNIL within 72 hours of its discovery, in accordance with the GDPR.

You have, under the conditions provided for by the applicable regulations, the following rights over Your Personal Data:

You may also define directives regarding the fate of Your Personal Data after Your death (retention, erasure and, where applicable, communication of this data).

You may exercise Your rights at any time by contacting Us at: support@ember.do. We process Your requests free of charge, except in the case of manifestly unfounded or excessive requests. We will respond to You within a maximum period of one month from their receipt. This period may be extended by two months in the case of complex requests or a multiplicity of requests; in this case, We will inform You of this extension and the reasons for the postponement. When We have reasonable doubt about Your identity, We may ask You for additional information or proof of identity to verify that the request indeed comes from the data subject or their authorized representative. When the processing of Your Data is based on Your consent, You may withdraw this consent at any time by contacting Us at the same address. The withdrawal of Your consent does not affect the lawfulness of processing carried out before this withdrawal. If You believe, after contacting Us, that Your rights are not being respected, You may file a complaint with the CNIL (www.cnil.fr) or seize a competent court.

When You delete Your account from Your user area, all of Your Personal Data and Your content are permanently deleted from the Platform.

Yes, We reserve the right to modify or update this privacy policy at any time. We will inform Platform users by email and by publishing the updated version directly within the Platform. Any modification will take effect as soon as it is published online. Your continued use of the Platform after the publication of a new version constitutes acceptance of this policy as modified. In certain situations (for example, if We wish to use your Personal Data for purposes different from those indicated at the time of collection), when necessary, We will inform You personally and/or seek your agreement before proceeding with the processing.