PERSONAL DATA PROTECTION POLICY

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MOMJI, SARL with capital of €50,000 - RCS PARIS 511 779 738 - Head office: 38 rue Blomet 75015 PARIS collects and processes personal data in the context of its at-home childcare business. Personal data refers to any information that may relate to an identified or identifiable individual, directly or indirectly. The automated processing of personal data is governed by:

•  Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, hereinafter referred to as "RGPD". The RGPD requires the data controller (MOMJI) to provide the data subject with a certain amount of information,
•  Law n°78-17 of January 06, 1978 relating to data processing, files and freedoms, modified by the law of August 6, 2004, hereinafter referred to as the "Data Processing and Freedoms Law",
•  Law n°2018-493 of June 20, 2018, hereinafter referred to as the "New Data Protection Act".

This "Personal Data Protection Policy" is intended to inform all individuals concerned and applies to all websites, extranets and applications.

Identity and contact details of the data controller:

The data controller is Mr. Hervé LECAT, President of MOMJI - 38 rue Blomet 75015 PARIS.

Contact e-mail: rt@kinougarde.com

Publisher: MOMJI - 38 rue Blomet 75015 PARIS.

Host : MAKHEIA GROUP - 125 rue de Saussure 75017 PARIS.

Contact details of the Data Protection Officer:

MOMJI has appointed a Data Protection Officer (DPO), whose contact details are:

By post: DPO MOMJI - 38 rue Blomet - 75015 PARIS
By e-mail: postmaster@momji.fr

Data collected:

MOMJI collects directly or indirectly all or part of the following data:

•  Identification of prospects/customers/candidates/employees (surname, first name, date of birth, social security number of instructors, CAF/MSA benefit number of customers concerned), 
•  Identification of beneficiaries whether or not they are minors under the age of 15 (surname, first name, date of birth, class, address of school or extracurricular activities),
•  Postal, e-mail and telephone contact details,
•  Log in information (IP address, web pages consulted, connection logs, password),
•  Tracking of babysitting hours (history of childcare requests),
•  Payment (payment methods and history),
•  Reviews on services offered by MOMJI,
•  Complaints,
•  Identification of third-party partner companies (surname, first name, postal, e-mail and telephone contact details).

In any event, the personal data collected will be limited to that necessary for the purposes set out in the paragraph below.

Information for minors under 15:

The MOMJI website is intended for parents and applicants over the age of 18. The personal data of minors under the age of 15, collected as part of the monitoring of their custody, benefit from the same security measures as any other personal data.

Purpose of the data processing:

The purpose of a data processing operation corresponds to the objective pursued, the need to which it responds for the data controller. Personal data is processed electronically for the purposes and under the conditions specified below:

For candidates and employees:

•  Gather the information required for a recruitment interview,
•  Preparing the information needed to draw up employment contracts, monitoring assignments,
•  Execution of employer obligations (URSSAF declarations, etc.),
•  Supply and management of a secure online personal space,
•  Referral: MOMJI identifies a referring family and a referred family to determine the associated benefits,
•  Recording of telephone conversations for training purposes and to improve service quality. Calls are kept for a maximum of 21 days. Individuals may object to any recording by contacting the person they are talking to,
•  Optional dispatch from time to time of information on MOMJI's activities,
•  Updating of customer knowledge, personalization of our offers,
•  Carrying out satisfaction, opinion and recommendation surveys, processing complaints, site performance statistics.

Pour les prospects et les clients :

•  Carrying out financial simulations on MOMJI offers: MOMJI uses the contact details provided to contact the prospect and assist them in carrying out simulations,
•  Suggest other service offers,
•  Handling of requests and customer accounts: monitoring of childcare requests, handling of worker assignments, identification of benefits linked to the partner employer company, accounting operations linked to payments, handling of any unpaid bills,
•  Supply and management of a secure online personal space,
•  Enactment of administrative formalities stipulated in the contract (PAJE certificates, tax certificates),
•  Referral: MOMJI identifies a referring nanny and a referred friend to determine the associated benefits,
•  Recording of telephone conversations for training purposes and to improve service quality. Calls are kept for a maximum of 21 days. Individuals may object to any recording by contacting the person they are talking to,
•  Optional dispatch from time to time of information on MOMJI's activities,
•  Updating of customer knowledge, personalization of our offers,
•  Carrying out satisfaction, opinion and recommendation surveys, processing complaints, site performance statistics.

Length of conservation:

For candidates and employees:
Unsuccessful candidate: 2 years from date of interview
Selected candidate: 3 years from date of interview 
Employees who have worked: 5 years from end of activity

For prospects and clients:
Prospect: 3 years from date of last contact
Client: 5 years from last activity
After this period, data may be anonymized for statistical purposes.

Recipients:

Personal data may be transmitted to the following recipients:

•  Employees in charge of managing job applications, trainee follow-up, payroll, declarations to the relevant administrative authorities, prospecting, customer relations and marketing operations,
•  Service providers (subcontractors) used by MOMJI to provide its services within the scope of the above-mentioned purposes, such as, for example, the management of banking transactions, the processing of customer reviews or marketing operations,
•  Legally authorized administrative, tax and judicial authorities.

Rights:

MOMJI has implemented appropriate personal data protection measures to ensure that personal data is used in accordance with the purposes described above and to ensure that it is accurate and up-to-date.

•  Right to be notified of personal data kept or not by MOMJI,
•  Right to access personal data, their purposes, recipients and retention periods,
•  Right to request modification, updating, limitation or deletion of personal data,
•  Right to object to specific processing of personal data,
•  Right to data portability,
•  Right to be kept informed of the appropriate safeguards provided if personal data is transferred to a third country outside the European Union,
•  Right to obtain a paper or electronic copy of personal data processed by MOMJI through one of its subcontractors,
•  Right to give instructions concerning personal data after death,
•  Right to withdraw consent at any time,
•  Right to know the consequences of refusing to collect personal data,
•  Right not to be the subject of an automated decision,
•  Right to demand that the necessary security measures be taken for the storage of personal data,
•  To exercise these rights, please contact MOMJI's DPO, with proof of identity:

1.  By post: DPO MOMJI- 38 rue Blomet 75015 PARIS
2.  By e-mail: postmaster@momji.fr MOMJI has one month to reply.

•  Right to lodge a complaint with the CNIL, 3 place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.
•  Right to lodge a complaint with a supervisory authority following the discovery of a personal data breach.

Measures taken to protect personal data:

It is essential for MOMJI to ensure the security of the personal data entrusted to it. To this end, MOMJI has taken the following measures:

•  Raising team awareness of personal data protection,
•  Information system security and intrusion audits,
•  Redaction of a Personal Data Protection Policy,
•  Informing the CNIL within 72 hours of any data breach.

Changes to this Personal Data Protection Policy:

MOMJI may need to modify this Personal Data Protection Policy in order to meet the requirements of applicable regulations. Should significant changes be made, MOMJI will clearly indicate them on the website or by other means such as e-mail.