LOGO GINO 2021 RVB

Gino Legaltech Privacy Policy

Gino LegalTech (“Gino LegalTech” or “we”) is aware of its duties to protect personal data. The purpose of this Privacy Policy (the “Policy”) is to explain to you how we process your personal data and how you can exercise your rights in relation to it.

In order to comply with the purposes of the General Data Protection Regulation n°2016/679 of 27 April 2016 and the Law known as “Informatique et Libertés” n°78-17 of 6 January 1978 (hereinafter together referred to as the “Regulation”), we undertake to inform you in full transparency of our processing and to operate processing only in relation to the services we offer.

The collection, use and storage of your information is necessary for us to provide Gino LegalTech’s products and services to you. Products and services include websites, applications, software, and servers of our providers.

For more information, please read the product and service specific details in this Policy. This Policy applies to all interactions between Gino LegalTech and you and to the products and services listed below.

01 – Who are we?

The Policy governs the products and services offered by Gino LegalTech, a limited liability company with a share capital of 200,000 euros, represented by Philippe Ginestié, whose registered office is located at 10, Place des Etats-Unis in Paris 75116, registered with the Paris Trade and Companies Register under number 830 029 211 and intra-community VAT number: FR63830029211.

In order to comply with the purposes of the General Data Protection Regulation n°2016/679 of April 27, 2016 and the Law known as “Informatique et Libertés” n°78-17 of January 6, 1978 (hereinafter referred to together as the “Regulation”), we undertake to inform you in full transparency of our processing and to operate processing only in relation to the services we offer.

The collection, use and storage of your information is necessary for us to provide Gino LegalTech’s products and services to you. Products and services include websites, applications, software, and servers of our providers.

For more information, please read the product and service specific details in this Policy. This Policy applies to all interactions between Gino LegalTech and you and to the products and services listed below.

02 – What personal data do we collect?

Gino LegalTech processes personal information that you provide directly to us in the course of our interactions with you and through our products and services. Some of this information is obtained indirectly, by collecting data about your interactions with and uses of our products and services. Such information may relate to choices you make, including your privacy settings.

You may refuse to provide your personal data. However, most of our products and services require certain personal data to be provided. If you choose not to provide us with the necessary data to enable us to provide you with a product or service, you will not be able to use it.

The personal data collected by Gino LegalTech is as follows:

  • Identity and identification data (title, surname, first name, telephone number, email address)
  • Professional information (job title, department or service, company name)
  • Login data
  • Information about your needs regarding our products and services

03 – What we use your data for?

The personal data processed by Gino LegalTech is based on your consent, the performance of contractual obligations or pre-contractual measures, or our legitimate interest in soliciting potential customers and improving and developing our products and services.

You have the right to withdraw your consent at any time, in which case we will immediately stop processing your data for the purposes based on that consent. However, withdrawal of your consent will not render previous processing operations unlawful.

The purposes for which we process your personal data include:

  • The provision of our products and services, including security and problem resolution
  • The improvement, development and security of our products and services
  • Communication between Gino LegalTech and you
  • Advertising or marketing communications, such as promotional communications or presentations of offers that may be of interest to you

The data collected indirectly through cookies and similar technologies is necessary for us to improve and ensure the proper administration and improvement of our products and services. In addition, this data also serves our legitimate interest in ensuring the security of our products and services, including the prevention and detection of fraud and security incidents.

04 – Who can access your personal data?

We share your personal data upon your consent or in order to fulfill our contractual obligations to provide a product or service you have requested. Data is shared internally only with personnel who are authorized to communicate and provide our products and services, and with personnel responsible for their development and security.

Your personal data may be stored with our hosting providers for the necessary operation of our products and services. We explicitly require that these service providers recognize and adhere to the European Privacy Principles when sharing this information.

Gino LegalTech may also share your personal information with consultants who assist in the drafting of your contract with us, or with government agencies, solely to meet our legal and regulatory obligations.

*Unless you object, by providing your personal data you agree to receive marketing emails from Gino LegalTech. In accordance with the French Data Protection Act of 6 January 1978, you have the right to access, modify and delete your personal data by contacting us by email at contact@ginolegaltech.com

05 – Do we transfer your personal data outside France?

In connection with the use of our products and services through Microsoft Word Online, your personal data will be hosted on Microsoft Corporation’s servers located in France. You can find more information about the location of the data hosted at Microsoft Corporation at the following address: https://www.microsoft.com/fr-fr/trust-center/privacy/data-location

06 – Do we use cookies and web beacons?

Gino LegalTech uses cookies to enhance your user experience of its products and services and to ensure that they are improved and protected. Cookies are small text files placed on your device that store data that can be recalled by web servers in the domain that placed them. They allow us to connect you to our products and services, to fight fraud and to analyze the performance of our products and services.

You can refuse cookies using the information banner on the home page of our site and the settings of your browser.

The period of validity of your consent to the use of these cookies will not exceed thirteen months, pursuant to Deliberation No. 2013-378 adopted by the CNIL on December 5, 2013, and may be extended by a new manifestation of consent.

Session ID cookies

Session cookies are used to maintain user data during browsing. These cookies are necessary for us to log you into your personal session in order to access our products and services.

Audience measurement cookies

Our website uses Google Analytics, which is owned by Google LLC. We inform you that the information obtained from the cookie about your use of the website may be transmitted to a Google LLC server in the USA and stored there. Google LLC processes the information obtained in this way in accordance with its own privacy policy, which can be viewed at this address: https://policies.google.com/privacy?hl=fr.

We use Google Analytics in particular for audience measurement and traffic analysis purposes, so that you can benefit from a better user experience.

Cookies related to advertising operations

We also use DoubleClick, a marketing solution from Google LLC. These cookies enable the provision of advertising and advertising-related services, such as data collection, behavioral analysis or “retargeting”. The information obtained from these cookies may be transmitted to a Google LLC server in the United States where it is stored. Google LLC’s privacy policy is also applicable to its DoubleClick tool. 

Social network cookies generated by their sharing buttons

Social network sharing buttons automatically generate cookies that are deposited on your device. These third-party cookies collect information that is processed through the privacy policies of Facebook, Linkedin and Twitter.

Cookies related to “Call-to-Action” generated by the CRM

Gino LegalTech uses Hubspot, a marketing solution from HubSpot. The information collected is subject to HubSpot’s privacy policy and is described here: https://legal.hubspot.com/fr/privacy-policy

07 – How long will your data be kept?

The data collected is kept only for as long as is necessary for the purposes for which you have consented or for the performance of our contractual obligations. In order to comply with a legal obligation, Gino LegalTech may keep your personal data for a longer period of time, but this period is determined and proportionate to the purposes for which the data is being retained. Our clients’ personal data is deleted after 5 years from the end of the contract, or at the end of the contract for Gino’s application data if reversibility is implemented, to allow us to retain the necessary elements until the end of the statute of limitations in commercial law. At the end of these periods, we are obliged to delete your data, subject to legal or regulatory obligations to archive it.

08 – Details specific to Gino LegalTech products and services?

Role of Gino LegalTech and its clients

Gino LegalTech’s mission is to provide you with a computer application and to assist you in the creation of your first anonymous document drafting robots. In this respect, Gino LegalTech is considered a subcontractor under the RGPD, responding to your instructions as a data controller.

The personal data recorded by your robots is stored in a database located on the servers of our hosting provider. You may be required to register personal data of customers, providers, suppliers or staff members in our products and services in order to draw up acts concerning them.

We would like to remind you that it is your responsibility to store only the data that is strictly necessary for the purposes you are pursuing, in accordance with the principle of minimization provided for by the GDPR. Depending on your input, Gino LegalTech may store any type of personal data, including:

  • Identification data
  • Information relating to personal life
  • Information relating to professional life
  • Economic and financial information
  • The social security number

Given the potential presence of sensitive data as defined by the regulations, Gino LegalTech is particularly vigilant about its security and confidentiality obligations. Our products and services incorporate security measures to protect this information. Security and traceability of the data recorded by the robots. Access to personal data in our products and services is controlled by a user authentication process to ensure that users only have access to the data they are authorized to access.

The Gino platform consists of the following modules:

– Admin : to manage the application (e.g. user access and profiles as well as the groupings of robots and documents produced (the ‘Domains’) by the Client)

– Gindex : to store the created robots;

– Lab : to create contractual robots (“Robots”);

– Writer :to use robots to produce acts (“Acts”);

– Dab :to produce reports and monitor dashboards;

– Sign :to sign the draft contracts;

– Flux :to validate the acts produced;

– Nego :to negotiate draft contracts;

Depending on the subscribed offers and the status of the authorized persons, the access to the recorded personal information will be more or less extended. The actions of the platform’s users are stored in an application log. You have access to this action log. We remind you that you are responsible for the security of your identifiers, including passwords and one-time codes sent by SMS.

Subcontractors of Gino LegalTech

For the use of our platform via Microsoft Word, Gino LegalTech collaborates with Microsoft as a subcontractor through its Azure data hosting offering. The implementation of the RGPD is governed by a contract that complies with the regulation. For more information, you can find the privacy policy of our provider at the following addres: https://privacy.microsoft.com/fr-FR/privacystatement

For the electronic signature, Gino LegalTech uses the partner Universign, a French company, whose security policy is described at the following address: https://www.universign.com/fr/politique-protection-donnees/

09 – What are your rights under the Data Protection Regulation?

You have the following rights regarding your personal data:

  • Request access to your data
  • Request the correction of your data
  • Request the deletion of your data
  • Request to limit the processing of your data
  • Request the transfer of your data in a usable format
  • Oppose the processing of your data, if there is a legitimate reason
  • Define directives concerning the fate of your data after your death


Due to legal or regulatory obligations, Gino LegalTech may not be able to respond favorably to your request. If this is the case, we will explain the reasons why.

10 – Is the personal data processed in an automated way?

Gino LegalTech does not use any automated decision making systems. As such, we do not process your personal data automatically.

11 – Is the personal data processed in an automated way?

This version was last updated on October 28, 2020. We reserve the right to make changes to the Policy at any time. Therefore, we urge you to review this Policy regularly.

12 – How can I exercise my rights and make a complain?

If you wish to exercise your rights regarding your personal data or file a complaint, you can contact us by filling out our contact form available at https://www.ginolegaltech.com/contact/

or by mail to Gino LegalTech – Legal Department – 10, Place des Etats-Unis, 75116 Paris.

All requests must be accompanied by proof of identity. We will respond to your request within one month of receipt. Depending on the complexity or number of requests, we may extend this period to two months, in which case we will inform you of the extension within one month.

If you believe that Gino LegalTech is processing your personal data in a manner contrary to the Regulations, you may file a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL). This is the supervisory authority responsible for matters relating to the processing of personal data. The CNIL can be contacted at 3, Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, by telephone at 01 53 73 22 22, and on its website: www.cnil.fr

Thank you for reading this Privacy Policy.