June 2025
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1. DEFINITIONS

SUBSCRIPTION: service provision contract entered into between the CLIENT and NAVLEAD which has as its purpose the use of the APPLICATION under the conditions described in these GENERAL TERMS OF SERVICE AND USE.

‍APPLICATION: the Navlead website and/or the Navlead internet and/or mobile application, edited and marketed by the company NAVLEAD, which allows the organization, management, storage, modification, sharing, operation and/or downloading in a readable and portable format, professional contact details of individuals, coming from (i) data entered by the CLIENT, (ii) reconstructions of professional email addresses made by the APPLICATION from information publicly available on the internet and/or (iii) the EXTENSION.

‍TARGETS: natural or legal person whose professional data, publicly accessible on the internet, are processed by the CLIENT via the APPLICATION.

‍CLIENT: natural or legal person acting exclusively within the framework and/or for the needs of their professional activity and who has an active and valid SUBSCRIPTION to the APPLICATION.

‍ACCOUNT: private online space of the CLIENT on the APPLICATION, accessible after subscribing to a SUBSCRIPTION and which allows the CLIENT to use and manage their SUBSCRIPTION.

‍GENERAL TERMS: the hereby general terms of services and use.

‍DATA: as the case may be, either the professional information that the CLIENT provides to NAVLEAD at the time and/or during his/her SUBSCRIPTION, or the professional information relating to the TARGET listed in Article 5 below.

‍EXTENSION: the Navlead software in the form of a compatible internet browser extension, edited and marketed by the company NAVLEAD, which allows the retrieval, storage and download in a readable and portable format, of search results of professional contact details of individuals, carried out by the CLIENT via the Linkedin website or similar sites.

‍NAVLEAD: simplified joint-stock company with a share capital of €1,000, registered with the Paris Trade and Companies Register under number 943 508 945, with its registered office at 61 rue Emeriau 75015 Paris, represented by its President.

‍CONTROLLER: NAVLEAD in what concerns the DATA of the CLIENT; the CLIENT in what concerns the DATA of the TARGET.

‍GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, the latest applicable version of which on the date hereof can be consulted here.

‍PROCESSOR: NAVLEAD, which acts on behalf of the CLIENT with regard to the DATA of the TARGET in accordance with the "Contractual Clauses" appearing in Appendix 1 of the hereby GENERAL TERMS.

‍USER: natural person, member of the CLIENT’s company and/or team, to whom the CLIENT gives access to the APPLICATION as part of a “multi-USER” SUBSCRIPTION. The CLIENT is the USER in the case of an individual SUBSCRIPTION.

2. GENERAL CONSIDERATIONS

‍This Personal DATA protection Charter (hereinafter the “Charter”) explains who is the data controller, in what capacity and how the company NAVLEAD processes your DATA when you use the APPLICATION or when you enter into a contract with NAVLEAD as a client or supplier, as well as your rights and obligations regarding the processing of the DATA of the TARGET.

In its capacity of data controller of CLIENT DATA, NAVLEAD can be contacted either by mail at the address of its registered office, or by email at the address privacy@navlead.com

In its capacity as data controller of regarding the DATA of the TARGET, the CLIENT must ensure its compliance with the rules set by the GDPR data protection regulations. The examples of rules applicable to the CLIENT in its capacity of controller, contained in this Charter and in the GENERAL TERMS, are not exhaustive and their respect by the CLIENT is not enough to consider that the CLIENT complies with all of its obligations regarding the personal data protection. Therefore, it is in the CLIENT'S responsibility to inquire for and implement, under his/ her sole responsibility, mechanisms allowing to ensure compliance with his/her obligations as data controller within the personal data protection.

The use of the APPLICATION implies full and unreserved acceptance of the Charter. NAVLEAD may modify the Charter at any time. In the event of a substantial modification, NAVLEAD undertakes to inform you via the email address you provided when contracting the SUBSCRIPTION.

‍3. PRINCIPLES
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‍When processing DATA, NAVLEAD ensures compliance with the following principles.
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‍Principle of fairness: DATA is processed fairly. Only DATA that is freely accessible and clearly made visible to the public by its holders is processed. DATA for which the person has expressly limited visibility is not processed.
‍Principle of transparency: the information that NAVLEAD must provide to the persons concerned by the processing of their DATA under its legal obligations is listed in this Charter.
‍Principle of minimization: NAVLEAD limits the type of DATA processed to what is strictly necessary with regard to the purpose of processing and the collection criteria, defined below. For each of the processing implemented, NAVLEAD undertakes to process only DATA that is adequate, relevant and limited to what is necessary with regard to the purposes and the criteria set out below.

‍4. WHAT DATA, WHY AND HOW IT IS PROCESSED

‍NAVLEAD is only likely to process DATA in the following cases. 

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‍5. DATA EXCLUDED FROM PROCESSING

‍The APPLICATION does not allow the CLIENT to process DATA for which the TARGET has expressly refused processing, has limited public access, or has made non-visible to third parties on the internet.If, despite the measures taken, NAVLEAD processes incidentally and residually DATA that should have been excluded, it applies mechanisms to delete this DATA immediately or as soon as it is identified as such.

‍6. DATA RECIPIENTS

‍DATA of the CLIENT

The recipients of the DATA of the CLIENT are exclusively NAVLEAD and any person acting on behalf of NAVLEAD for the purposes of the performance of the SUBSCRIPTION contract or of the operation of the APPLICATION or of NAVLEAD's activity (such as NAVLEAD personnel, hosting service providers, etc.).

NAVLEAD applies an authorization policy which allows to ensure that the DATA processed is only shared with authorized persons.

When NAVLEAD uses a service provider, it communicates DATA to it only if this is necessary for the operation of the APPLICATION and after having obtained from the latter a commitment and guarantees on its ability to meet these security and confidentiality requirements regarding the DATA.

NAVLEAD may share certain CLIENT DATA in order to respond to requests for information from investors, accountants or any auditor of NAVLEAD, in particular in the context of possible fundraising or verification of the use of raised funds, or for the purposes of NAVLEAD's legal, fiscal or regulatory compliance.

DATA of the TARGET

The recipients of the DATA of the TARGET are determined by the CLIENTS in compliance with their obligations as data controller within the meaning of the GDPR data protection regulations.

‍‍7. DATA SHARING‍

‍SHARING OF THE DATA OF THE CLIENT BY NAVLEAD

‍NAVLEAD may share CLIENT DATA with its third-party service providers for the operation of its websites, products, and services. These providers offer services related to data hosting, application development, marketing, sales support, and customer service. This may include removing duplicate data, analyzing data or performing statistical analysis on the CLIENT's use of the APPLICATION or of his/her interactions with other websites, providing marketing assistance, processing credit card payments, supplementing the information the CLIENT provides to NAVLEAD to offer higher quality services, developing and improving products and services, and providing customer service. These third-party service providers are prohibited from using the DATA for any other purpose, and they are required to maintain its confidentiality.

NAVLEAD reserves the right to use or disclose DATA in circumstances required by law or if the company has reasonable grounds to believe that use or disclosure is necessary to protect its rights, protect its safety or the safety of others, investigate a case of fraud, or ensure compliance with a law, court order, or legal process.

NAVLEAD may share DATA with its parent companies, affiliates, subsidiaries, and other current or future entities under common control and ownership to the extent necessary to respond to CLIENT requests or for other purposes authorized by this Charter.

‍SHARING OF DATA OF THE TARGET BY THE CLIENT
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‍THE CLIENT may share DATA with USERS and/or other CLIENTS under the conditions and limits provided in the GENERAL TERMS. In the event of sharing, the CLIENT undertakes to ensure that the beneficiaries of the sharing comply with this Charter and remains responsible for the use of the DATA by the beneficiary of the sharing.

‍8. DATA STORAGE PERIOD AND METHODS‍

‍DATA of the CLIENT

‍DATA of the CLIENT is stored and kept on servers located in France and/or within the European Union, for the entire duration of the SUBSCRIPTION and for a period of up to 3 (three) years from its termination for any reason whatsoever. By way of exception, in accordance with NAVLEAD's legal obligations, billing DATA is kept for a period of 10 years after the expiry of the SUBSCRIPTION.

In the event of an inactive SUBSCRIPTION, meaning a SUBSCRIPTION that the CLIENT does not pay for and has not been using for at least 1 (one) year, the DATA will be stored for a period of up to 2 (two) years after the date on which the SUBSCRIPTION became inactive.

Without prejudice to the foregoing, NAVLEAD may store DATA if it deems it reasonably necessary to comply with any legal or regulatory obligation, legal proceeding or administrative request, to protect the safety of a threatened person, to address any problem of a fraudulent, security or serious technical nature, or to protect the rights or property of its CLIENTS against imminent danger.

DATA of the TARGET
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‍At the CLIENT's option, the DATA of the TARGET is stored and kept on the APPLICATION's storage platform on servers located in France and/or within the European Union, and/or on the CLIENT's personal computer media (such as a computer) where he/she can download the DATA.THE CLIENT ensures that the DATA is kept in accordance with the GDPR data protection regulations for a period compatible with these regulations.

‍9. TRANSFER OF DATA

‍DATA of the CLIENT may be transferred to and processed in countries other than their country of residence. These countries may have data protection laws that differ from those in your country (and in some cases, may be less protective). Where this is the case, we have taken appropriate safeguards to ensure that your DATA remains protected in accordance with this Charter. These measures include the implementation of the standard contractual clauses of the European Commission for data transfers, in contracts with our service providers and third-party partners.

Any transfer of the DATA of the TARGET is under the sole responsibility of the CLIENT, acting as the controller. In such cases, the CLIENT must ensure compliance with its obligations under the GDPR data protection regulations and he/she guarantees, under his/her sole responsibility, that the transferred DATA benefits from adequate protection in accordance with this Charter.

‍10. USE OF THE DATA

‍The DATA shall be used in accordance with each respective processing purpose indicated in the table in Article 4 hereinabove.

‍11. SECURITY OF THE DATA

‍Various security technologies and procedures are used to protect the DATA against unauthorized access, use, or disclosure. NAVLEAD stores the DATA on computer servers in a controlled, secure environment protected against unauthorized access, use, or disclosure. All DATA is protected by adequate physical, technical, and organizational measures. Details of the protective measures implemented by NAVLEAD are provided in Appendix 1 of the GENERAL TERMS.

‍12. UPDATING PROCESSED DATA

‍NAVLEAD periodically ensures that DATA of the CLIENTS is up to date. However, it is also your responsibility to ensure that your DATA is as accurate, complete, and up-to-date as possible by informing NAVLEAD as soon as possible of any modification or error.

NAVLEAD reminds its CLIENTS of the need to verify the updating of the DATA of the TARGETS.

‍13. YOUR RIGHTS

‍You have the following rights regarding your DATA processed by NAVLEAD:
- Right to access DATA,
- Right to object to the processing of DATA,
- Right to request the restriction of the processing of DATA,
- Right to request access, rectification, erasure, or portability of this DATA,
- Right to withdraw consent given concerning the processing of all or some of your DATA,
- Right to give instructions on the becoming of your DATA after your death.

To exercise these rights, you must contact NAVLEAD at privacy@navlead.com or via the form on the NAVLEAD website, enclosing a photocopy of an identity document certified as a true copy of the original, dated and holding your signature.

Any request that does not observe with this forma will be considered potentially fraudulent and NAVLEAD will not be obliged to respond, the absence of a response in this case never be a source of liability for NAVLEAD, this being expressly accepted by the concerned perso as part of NAVLEAD's security policy with regard to DATA in the interest of the CLIENTS and TARGETS themselves.

When the request concerns DATA of the TARGET, NAVLEAD undertakes to transfer it to the concerned CLIENT without delay, in order to allow him/her to respond to the request.

‍14. LINKS TO THIRD-PARTY WEBSITES

‍The APPLICATION may contain hyperlinks to websites owned and operated by third parties. These websites have their own privacy policies, and we encourage you to consult them. They govern the use of DATA you submit during your visit. NAVLEAD disclaims any responsibility for the privacy practices of these third-party websites, and you use them at your own risk.

‍15. CLARIFICATIONS, QUESTIONS - COMPLAINTS

‍If you would like clarification or have any questions regarding this Charter, you can contact us at the following address: privacy@navlead.com or via the form on the NAVLEAD website.

If you have not received a response within three (3) months of receipt of your request or if the response is not satisfactory, you may lodge a complaint with the CNIL - Commission Nationale de l’Informatique et des Libertés ( French National Commission for Information Technology and Civil Liberties) by any means available on its website.

‍16. GOVERNING LAW

‍This Charter, its conclusion, performance, interpretation, termination, and any related matters are governed by French law.

This Charter has been drawn up in compliance with the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (the “GDPR”), the CNIL's practical guidelines on the processing of data accessible on the internet (“Fiche focus sur les mesures à prendre en cas de collecte des données par moissonnage” [Focus sheet on measures to be taken in the event of data collection by web scraping] dated June 10, 2024, “Recommandations pour les l’utilisation de données publiées sur Internet” [Recommendations for the use of data published on the Internet] dated June 12, 2024, “IA : Mobiliser la base légale de l’intérêt légitime pour développer un système d’IA” [AI: Mobilizing the legal basis of legitimate interest to develop an AI system] dated June 10, 2024) as well as the guide set by the CADA and the CNIL in association with ETALAB “De la publication en ligne et de la réutilisation des DONNEES publiques (« open data »)” [The online publication and reuse of public data (“open data”)] in 2019.