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📅 Revised policy dated 29/05/2024
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Processing manager
Kwit
SAS with share capital of €50,010
31 Rue du Fossé des Treize
67000 STRASBOURG
N° RCS Strasbourg 819 528 597
Phone: (+33) 637 868 460
E-Mail : [[email protected]](mailto:[email protected]?subject=Privacy%20Policy)
DPO
Maitre Apolline SCHMITT : [[email protected]](mailto:[email protected]?subject=Privacy%20Policy)
Person concerned
Any user of the Kwit application or website
Purposes for which data is processed, legal basis for processing, data collected, and retention period.
The data of users of the Kwit application or website that may be subject to personal data processing includes all data directly entered by users (direct collection) and the indirectly collected data specified in the table below.
The button "Invite" friends to recommend Kwit opens user-sharing applications without transferring any data to Kwit.
Purposes
Purpose |
Legal basis |
Data collected indirectly |
Data retention period |
Comments |
Create an account and authenticate on the application by e-mail or via an SSO platform (Apple, Google, Facebook) to use the application securely |
Kwit's legitimate interest in securing the use of the application |
• Account creation date |
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• Dates and times of connection and/or sessions |
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• Technical information about phone and computer system |
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• Regional Settings |
Data is kept for the duration of account use and up to 36 months from the last session (excluding regional settings, which are retained only for the time of the session). |
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Ensure that the Kwit user is over 15 years of age |
Legitimate interest |
• Year of birth |
Data is stored for a maximum of 36 months from the last session. |
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Use the Kwit application to enable the user to combat his or her cravings to smoke and participate in the cessation of smoking/nicotine: |
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- Build a user profile and personalize the application experience
- Self-assessment of smoking/nicotine cessation criteria
- Track progress and program data
- Unlock your goal | Consent | • Data entered by the user (in particular when creating a user profile)
• UUID
• History of data entered by the user
• Date and time of sessions | Data is deleted when users withdraw their consent or, if not, for the duration of the account and up to 36 months from the last session. | Data processing for this purpose is only carried out locally on the phone. |
| To enable us to respond to any "contact" requests via website forms | Legitimate interest in responding to any request | • E-mail
• Messages exchanged | Data is kept for the duration of exchanges and in intermediate archives for a maximum of 5 years for evidentiary purposes. | |
| Manage paid subscriptions to Kwit (excluding subscriptions taken out via the AppStore and Google PlayStore) | Contract execution | • Subscription data (Last name, First name, Address, Mail, Subscription chosen)
• Payment cookies
• Authentication cookies | Data is kept for the duration of the subscription and, in intermediate archives, for up to 5 years, except for financial data, which is held for 10 years. | |
| Provide technical support for the application and produce statistics on the application's functionality on the various software packages | Legitimate interest for Kwit to respond to all technical support requests | • UUID
• Phone technical information (including model)
• Operating system technical information (including version and regional settings)
• Application technical information
• Date and time of connection | Data is kept for the duration of the technical support and, in intermediate archives, for up to 5 years for evidentiary purposes. | |
| Ensure the security and stability of the application | Legitimate interest of Kwit in ensuring the security and stability of the application | • UUID
• Phone technical information (including model)
• Operating system technical information (including version and regional settings)
• Application technical information
• Connection date and time
• Technical information about the bug (stack trace) | Data deleted after a maximum period of 3 months. | |
| Compile statistics on user typologies and behaviors to improve the effectiveness of smoking cessation assistance, and conduct anonymous scientific studies (data are aggregated and anonymized) | Kwit's legitimate interest in improving the effectiveness of its smoking cessation aid | • Usage data excluding data directly identifying the user | Data is anonymous. | |
| Compile statistics on visits to Kwit websites | Consent | • Anonymized usage data | Data is kept for a maximum of 13 months. | |
| Send offers | Consent | • UUID
• E-Mail
• Quit date
• Gender
• Year of birth
• Username
• Last session
• Regional parameters | Data is kept for a maximum of 3 years since the last contact. | |
| Ensure compliance with the RGPD and, in particular:
- Delete account inactive for more than 36 months
- Respond to any request to exercise rights | Legal obligation | • UUID
• Login and/or session dates
• Identification (only in case of doubt as to the identity of the person making the request) | Data is kept for the duration of the response provided and in intermediate archives for up to 5 years for evidentiary purposes (except for identification documents - immediate deletion after presentation). | |
| Collect user feedback on the application's functionalities to improve it, and in particular :
- Provide feedback on the various stages of the quit smoking/nicotine program | Consent | • UUID
• The date and time article was read
• The date and time the review is left | Data is deleted when users withdraw their consent or, if not, for the duration of the account and up to 36 months from the last session. | |
| Participate in the user community and enable peer assistance | Consent | • UUID
• Messages (anonymized when leaving Kwit if the Kwitter does not delete them)
• The date and time of the message
| Data is deleted when users withdraw their consent or, if not, for the duration of the account and up to 36 months from the last session. | |
| Contact Kwit experts for specific advice | Kwit's legitimate interest in responding to any request made to a Kwit expert | • UUID
• The date and time of the message | Data is kept for the duration of the account and up to 36 months from the last session | |
| Share data with the healthcare professional of the user's choice | Consent | • Data entered by the user | Data is deleted after a maximum of 48 hours, and the access link is not indexed. | |
| Obtain feedback on the application, new features or partnerships envisaged | Consent | • Data entered by the user
• Satisfaction feedback date | Data will be kept for a maximum of 12 months from the date of completion of the questionnaire. | |
| Respond to any contact requests sent via "A problem, contact us" or "Suggest a feature" | Legitimate interest of the Data controller in responding to any requests made | • UUID | Data is kept for the duration of the response and in intermediate archives for a maximum of 5 years from the last contact for evidentiary purposes. | |
| Inform users of legal updates | Legal obligation | • E-Mail | Data is kept for the duration of the response and in intermediate archives for a maximum of 5 years from the last contact for evidentiary purposes. | |
| Track website traffic | Consent | • Analytic and performance cookie | Data is stored for a maximum of 13 months. | |
Mandatory or optional nature of answers