Privacy Policy

Our Privacy Commitment

The purpose of this privacy policy (“Privacy Policy“) is to inform persons whose personal data is processed by Early Metrics SAS, a simplified joint-stock company, located at 86-90 Rue Notre Dame de Nazareth, 75003 Paris, registered with the RCS under the number 804 356 525 (“Early Metrics” or We“), of the conditions under which this data processing is performed, the data involved, the reasons for this processing, the ways in which We use the data and the rights of the subjects whose data is being processed.
The Privacy Policy is accessible from our website (the “Website“) and is also made available to you during all exchanges with Early Metrics, upon the conclusion of a contract and upon request.
It may be modified to take into account, in particular, the evolution of the data processing operations implemented and the applicable legislation. Any significant change will be brought to your attention by email, for example during exchanges with our services, or via pop-ups upon your visit to the Website.

1. Processing Your Personal Data

Early Metrics is responsible for Data processing as a professional entity offering ratings, analyses and studies related to companies such as startups, in particular to achieve or obtain investments or to conclude commercial partnerships with our clients. In this capacity, Early Metrics is subject to the obligations imposed by the regulations in force in France and across the European Union regarding the protection of personal data, in particular Regulation (EU) 2016/679, enacted on 27 April 2016, concerning the protection of individuals with regards to the processing of personal data and the free movement of such data in addition to any applicable national legislation (the “Regulation“).
The Privacy Policy applies to Early Metrics’: clients; suppliers and service providers; prospects, whether they are potential clients subscribing to the services offered by Early Metrics, prospects requesting a quote, or startups, whether startups that Early Metrics identifies via public and/or
internet databases (“Sourced Startup“), those that make themselves known to Early Metrics by completing an online survey or application form created on behalf of a client (“Indexed Startup” or “ScaleX Startup”), or those that are specifically identified by a customer for rating (“Rated Startup“) which Early Metrics rates; and users browsing the Website (the “People” or “You“). The Privacy Policy covers personal data, including any information that could identify People directly,such asfirst, last names and contact details, or indirectly, such as an IP address, social security number or a registration number (the “Data”).
Data processing refers to any operation that is performed or considered directly or indirectly with the Data, such as collection, registration, organisation, storage, modification, consultation, use, transmission or any other form of provision, reconciliation or interconnection, limitation, or
destruction, etc.
Data processing always has a purpose, i.e. a reason justifying the Data processing. For example, Early Metrics asking You to enter your email on the Website is a form of Data processing of which the goal is the response to a request for a quote or for information.
Only Data necessary to the processing purposes for which it is collected is processed.
Furthermore, Data processing must be founded on a legal basis,such as the performance of a contract between You and Early Metrics, the legitimate interest of Early Metrics, the performance of a legal obligation or your consent.
Moreover, Data whose collection is mandatory is identified as such (i.e. by an asterisk in the forms).

2. Collected and Processed Data

2.1 Data that You provide us

Early Metrics collects Data directly from You through the forms accessible on the Website, by telephone, or by an online survey, within the context of commercial discussions or exchanges of any kind with Early Metrics, from your mobile terminals or through interviews in particular conducted in person, and through questionnaires as part of the rating, indexing or ScaleX process. You must notify us of any update of this Data without delay.

2.2 Data obtained from third parties

Data can also be provided indirectly, in particular that which is available online, from public databases (Infogreffe, LinkedIn, etc.), professional data providers, banking organisations or credit institutions or from search engines, via cookies and/or tracers but also via clients and/or incubators and startup accelerators. For more information about cookies, we invite you to read the Cookie Policy which can be found here. We update your Data in our database on a regular basis.

2.3 Data regarding third parties that You provide us

In the event that You send us Data relating to another person due to the need for reference contacts (such as an investor, customer, etc.) or in the context of our relations, You guarantee that You have the authority/authorization to consent to the processing of Data on their behalf, You receive on their behalf all correspondence relating to their Data, and, if necessary, You consent on their behalf to the transfer of their Data abroad.

3. Summary Table of Purposes

The tables below summarise all Data processing by specifying for each purpose: the Data concerned, the basis and the persons with access, for each type of person concerned.

3.1 Prospects

Purpose of the Processing	Type of data	Legal/Judicial Basis	Person/Service with Access to the Data
Analysis of the prospect’s needs, answering questions and sending quotes	First and last name	Consent	Commercial service
Sending commercial offers	Email address		Marketing service
Sending information regarding research and ratings in progress	Phone number		Service providers (AirTable for organising and exchanging files; Google, Pardot and Salesforce for sending emails and newsletters)
Invitation to events	Navigation data (cookies)

3.2 Clients

Purpose of the Processing	Type of data	Legal/Judicial Basis	Person/Service with Access to the Data
Providing services, notably rating	Data of the contact of the client requesting the rating: First and last names Email address Phone number Job title	Contract fulfilment	Commercial service Person in charge of the assignment
Contract signature Management of client relations and service follow-up	See above	Contract fulfilment	Commercial service Financial and accounting service
Litigation (e.g., recovery of invoices)	See above	Legitimate interest	Legal service Third parties (e.g., bailiffs, collecting companies, lawyers, etc.)

3.3 Startups

Purpose of the Processing	Type of data	Legal/Judicial Basis	Person/Service with Access to the Data
Research/sourcing of the startup Identification of startup and qualification of relevance according to client project	Data of the directors/founders of the startup according to information available on public databases (e.g., Infogreffe, LinkedIn, startup’s website, etc.) and/or provided by the client: First and last names Email address Phone number Job title CV Gender Age	Consent	Internal services Clients External audit provider (e.g., financial auditor, lawyer, etc.) Service providers (e.g., AirTable for organising and exchanging documents, Google and Mailchimp for sending emails and newsletters)
Conducting the index ranking or ScaleX service	Data of the directors/founders of the Startup according to information provided by the startup through completion of the online survey: First and last names Email address Phone number Job title CV Gender Age Salary	Consent Contract fulfilment	Internal services Service in charge of conducting index ranking or ScaleX service Clients External audit provider (e.g., financial auditor, lawyers, etc.) Service providers (e.g., AirTable for organising and exchanging documents, Google and Mailchimp for sending emails and newsletters)
Conducting the rating/audit	Data of the directors/founders of the Rated Startup: First and last names Email address Phone number Job title CV Gender Age Salary	Contract fulfilment	Service in charge of conducting ratings/audits Client External audit (e.g., financial auditor, lawyer, etc.) Service providers (e.g., AirTable for organising and exchanging documents, Google and Mailchimp for sending emails and newsletters)

3.4 Suppliers and service providers

Purpose of the Processing	Type of data	Legal/Judicial Basis	Person/Service with Access to the Data
Delivery of the service and follow- up of the service provider	First and last name of staff of the supplier or service provider Contact details Contract Invoice and purchase order form	Contract fulfilment	Commercial service Financial and accounting service
Payment	Bank details (e.g., name of bank, bank address, BACS number, etc.)	Contract fulfilment	Accounting service
Follow-up and handling of disputes relating to supplier/provider contacts	See above	Legitimate interest	Legal service Third parties (e.g., bailiffs, lawyers, etc.) Every service of the company in relation with the supplier concerned

4. Who Can Access Your Data?

The Data collected is accessible within Early Metrics by the services charged with managing the different processes concerned.
Access to the Data is strictly reserved to those persons who need to have access in the scope of their assignment within Early Metrics and who are linked to Early Metrics by a commitment of condifentiality.
The tables above specify for each purpose the persons and services of Early Metrics likely to have access to the Data concerned by the processing in question.
In addition, certain subsidiaries of the Early Metrics group located within the European Union or in countries considered to ensure an adequate level of Data protection may also have access to the Data in within the scope of an intra-group Data transfer agreement.

5. The Recipient and Transfers of This Data

For certain purposes identified above, Early Metrics makes use of service providers or subcontractors (e.g. those in charge of monitoring the premises or charged with providing administrative services like archiving) such as IT service providers (e.g. web hosting service providers), solutions in the form of software-as-a-service (SaaS) which need to access the Data to carry out the assignment entrusted to them by Early Metrics (e.g. AirTable for startup documents), including certain providers outside France
(see point 8 below).
In this case, Early Metrics imposes strong obligations on these contracting parties regarding the processing, the condifentiality and the security of the Data to which these providers have access.
Early Metrics may also be required to disclose the Data to third parties in certain specific cases:

If Early Metrics plans to sell any business or assets (including by selling the business which carries out that activity or owns those assets), the Data may be disclosed to potential acquirers as part of an audit, including their advisors;
If all or part of Early Metrics’ assets are acquired by a third party, the Data will be one of the transferred assets and will be therefore processed by the acquirer who will act as the new Data controller and its data policy will govern the Data processing;
If Early Metrics must communicate or give access to the Data to comply with a legal or regulatory obligation, a court decision or a request from an administrative authority;
If the law or You yourself authorises this transfer by Early Metrics.

In any eventuality, Early Metrics does not sell the Data to third parties other than our clients.
The Data of the companies which are the object of a service, notably rating, will be shared with the client(s) who ordered the service or who would be interested in receiving the report, as well as the clients linked to Early Metrics by the contracted subscription to the ratings. The transmission of your Data is based on the fulfilment of the contract between You and Early Metrics in the scope of this assignment.

6. Length of Data Storage

The Data (in particular, the startup rating report) is kept for a period of five years from the completion of the service, whether as a contract with a client or as the completion of a service (notably startup rating) for the completion of a service by a supplier. However:

The Data of prospects, Sourced Startups or Indexed Startups is deleted within three years of its collection or the last contact with You;
In pre-litigation matters, the Data is stored until the conclusion of a settlement agreement or, if not, until the presciption of the corresponding legal action;
In matters of judicial litigation, the Data is stored until the decision has the force definitive of res judicata.

In addition, anonymous data and data relating to Startups may be kept indefinitely as long as it does not contain any Data.

7. Actions Carried Out on the Data

The following actions are carried out on the Data:

Collection and saving
Organisation and structuring
Hosting or storing in third-party software
Consultation
Sorting (via a solution published by a third party)
Archiving externally
Communication by transmission, disclosure, or in other form made available to the services concerned
Modification/consultation by the account management service or marketing service
Deletion or destruction

8. The Location of the Data and Security Measures in Place

Your Data is hosted within the European Union but is is accessible, in particular, to certain subcontractors in the United States.
Early Metrics takes all necessary precautions to ensure the confidentiality of the Data and to prevent its alteration, corruption or access by unauthorised persons with repsect to the Data concerned. For example, acces to your Data is limited and restricted to only those persons/services that need to access it. This Data is stored on sercure servers and bank data is also encrypted. Access to the data requires the use of a username and password.
Nevertheless, the Data transmission via the internet is not without risk. Therefore, Early Metrics does not guarantee the security of Data transmitted via the internet once Early Metrics has fulfilled its commitments to security.
In the event that transfers of Data takes place outside the European Union, they comply with the General Data Protection Regulation (GDPR) and, in particular, are subject to the signature of standard contractual clauses, as laid out by the European Commission, or are carried out only in countries that have been the object of an adequacy finding by a competent authority,such as subcontractors located in the United States certified under the Privacy Shield Framework, or that provide an equivalent level of protection to that provided by the GDPR.

9. Rights of Those Concerned and the Exercise of Rights

As part of the Data processing carried out by Early Metrics, You have the right:

To obtain access to the Data processed and and a copy of said Data;
To obtain rectification of the Data;
To obtain deletion of all or part of the Data when the Data (i) is no longer necessary for the purposes for which it was collected, (ii) is based exclusively on consent, (iii) is the subject of an opposition request;
To oppose the processing of your Data for legitimate reasons and to obtain the limitation/restriction of the processing, temporarily, when the accuracy of the Data is contested or when the Data is no longer necessary for Early Metrics but is still necessary for the exercise or defence of legal rights;
To unsubscribe or oppose the receipt of business prospecting messages at any time by clicking on the “unsubscribe” link in any email or communicaiton sent by Early Metrics;
To withdraw, at any moment, your consent to any Data processing based on consent;
To obtain portability of the Data when the processing is based on consent and the processing is carried out using automated procedures;
To provide guidance on the fate of Data post-mortem; and
To file a complaint with the CNIL.

You can read more about your rights in details here. To exercise your rights or for any issue relating to the Privacy Policy, please address your question to the following address: data@earlymetrics.com

If You intend to exercise any of your rights, We reseve the right to verify your identity before accessing your request and in particular to obtain a copy of your identification documents.