Privacy Policy

Privacy and personal data protection policy of the Website and the “CitizenWave” Application

(Version in force as of August 31st, 2023)

CitizenWave takes the respect of privacy and protection of personal data very seriously. That is why, CitizenWave, as the data controller, is committed to protecting the privacy and personal data of the Users in accordance with legal requirements and in particular with the Regulation n°2016/679 of April 27, 2016 regarding the protection of individuals with regard to the processing of personal data and the free circulation of such data, hereinafter « General Data Protection Regulations » ou « RGPD ») and the Law n°78-17 of January 6, 1978 relating to data processing, the files and the liberties (known as the « Data Protection Act »), (global the « Applicable Regulations »).

CitizenWave can be contacted by e-mail at the following address: but also by mail to the following postal address: 86 rue Voltaire, 93100 MONTREUIL, France.

This Privacy Policy (hereinafter the « Privacy Policy ») aims at informing the Users of the Application as well as possible about the way CitizenWave protects the personal data it collects in the context of downloading and using the Application and about the commitments made by CitizenWave in order to ensure the respect of the Users’ personal data.

By providing personal data in the context of the use of the Application, the User acknowledges having read the terms of this Privacy Policy.

Terms beginning with a capital letter and not defined herein shall have the meaning given to them in the TOS.


The Privacy Policy applies to any natural person who is of legal age, registered and holds a valid account on the Application (hereinafter the « User(s) »).


CitizenWave processes the personal data of the Application Users in the following situations:

When creating and managing the User Account on the Application;
When using the Services offered on the Application;
When participating in promotional offers or contests;
When the User contacts CitizenWave’s customer service or any other CitizenWave contact point (e-mail, telephone).


As data controller, CitizenWave collects the Users’ personal data in a lawful, fair and transparent manner. The main purpose of collecting personal data is to provide the Services by offering the Users a safe, optimal, efficient and personalized experience.

The purpose of the table below is to inform the User (i) of the different categories of personal data collected by CitizenWave, (ii) of the use that is made by CitizenWave of such personal data and (iii) of the legal basis and exceptions that allow justifying the processing and consequently making it lawful and fair.

The information that the User must provide when creating his account in order to benefit from the Services is indicated with an asterisk.

How does CitizenWave use this data? On what legal basis and/or exception is the processing of personal and sensitive data based?
Manage the User account creation procedure, the process of connecting to the Application and more generally the User account Such processing is necessary for the execution of the contract between CitizenWave and the User, i.e. it is necessary to provide the User with the service offered by CitizenWave.
Provide Users with a collaborative platform on which they can interact with the entire community of other Users and disseminate and share User Content on their personal profile This processing is necessary for the execution of the contract between CitizenWave and the User, i.e. it is necessary to provide the User with the Services offered by CitizenWave.
Manage the Application and its operational functions, improve and develop new functionalities according to use (service customization), optimize the display on the Application according to the preferences chosen by the UserCustomize the display of Contents within the Application Such processing is for some necessary for the execution of the contract between CitizenWave and the User, i.e. necessary to provide the User with the service offered by CitizenWave and for others necessary to pursue CitizenWave’s legitimate interests in order to ensure that the User is offered an Application that works properly, to solve any technical problem, to ensure the protection and security of the Application and to offer him personalized and adapted content. The processing thus benefits both the User and CitizenWave without harming the interests, rights and fundamental freedoms of the Users.
Prospecting (including sending information related to the launch of new Services, the organization of promotional events and marketing activities of all kinds) This processing is necessary to pursue CitizenWave’s legitimate interests, to promote its Services, to understand their efficiency, to ensure that the User benefits from the most appropriate experience. The processing thus benefits both the User and CitizenWave without infringing on the Users’ interests, rights and fundamental freedoms.
Responding to and communicating with Users and measuring the level of satisfaction and quality of servicesEstablish statistics and follow up on audience measurements


Such processing is necessary to pursue CitizenWave’s legitimate interests (economic interests) in order to improve the Services offered to the User, to better understand the needs and expectations of the Users. The processing thus benefits both the User and CitizenWave without infringing on the Users’ interests, rights and fundamental freedoms.
Security management and incident detection and resolution The processing related to security management is based on CitizenWave’s legitimate interest to secure its Services and Application. The processing thus benefits both the User and CitizenWave without infringing on the interests, rights and fundamental freedoms of the Users.
To apply the legislation and regulations in force and to ensure its defence and/or defend its interests in the event of litigation. The processing related to the application of the laws and regulations in force is based on the legal obligations that may rely on CitizenWave.



 Generally applicable retention periods

CitizenWave keeps the personal data for the entire duration of the activation of the User’s personal account. The User has the possibility to close his personal space at any time by sending an email request to CitizenWave at the following address:

In case of inactivity of the account for a period of three years, the User’s personal data will be automatically deleted.

In case of litigation, CitizenWave reserves the right to keep the data that could be useful for the duration of the litigation and to place them in a separate archive for a period of 5 years after the exhaustion of the legal remedies.


In accordance with the Applicable Regulations, the User has the following rights to his personal data:

  • a right to information: the User has the right to obtain clear, transparent, understandable and easily accessible information on the way CitizenWave uses his personal data and on his rights. That is why CitizenWave has drafted this Privacy Policy.
  • a right of access: the User has the right to access the personal data CitizenWave has about him/her (provided that the request is not manifestly unfounded or excessive, in particular due to its repetitive nature), and to obtain a copy thereof.
  • a right of rectification: the User has the right to demand that his/her personal data be rectified if they are inaccurate or out of date and/or that they be completed if they are incomplete (provided that the request is not manifestly unfounded or excessive, in particular due to its repetitive nature).
  • a right to erasure: in certain cases, the User has the right to obtain the deletion or suppression of his personal data. This is not an absolute right, as CitizenWave can be compelled to keep the User’s personal data for legal or legitimate reasons.
  • a right to limitation of processing: the User has the right to request that the processing of his personal data be limited, so that CitizenWave can keep such data, but can neither use nor process it. This right applies in particular circumstances, namely:
  •           In cases where the accuracy of personal data is disputed by the User. The processing is then limited for a period of time that allows CitizenWave to verify the accuracy of the personal data;
    In cases where the processing is unlawful and the User opposes their deletion and demands instead the limitation of their use ;
    In cases where CitizenWave no longer needs the personal data for the purpose of the processing, but the User still needs them to establish, exercise or defend his rights in court;
    In cases where the User has opposed the processing based on the legitimate interests pursued by CitizenWave during the verification whether the legitimate reasons pursued by CitizenWave prevail over those of the person concerned or not.
  • a right to object to the processing of his personal data when the processing is based on the legitimate interest of CitizenWave (see above the table in Section 3 to identify said processing and data): the User can at any time oppose the processing of his personal data for reasons related to his particular situation, unless CitizenWave has legitimate and compelling reasons for the processing of such data that prevail over the User’s interests, rights and freedoms, or when such data is necessary to ascertain, exercise or defend a right in court.
  • a right to data portability: the User has the right to receive the personal data concerning him/her that he/she has provided to CitizenWave and that are present in CitizenWave’s database, in a structured, commonly used and machine-readable format. This only applies to data that the User has provided directly or indirectly, when the processing is based (i) on the User’s consent or on the execution of a contract and (ii) is performed using automated processes.
  • a right to define special guidelines for the storage, deletion and disclosure of your personal data after his or her death.
  • a right to lodge a complaint with a supervisory authority: the User has the right to seize and file a complaint with the data protection authority of his country (in France the CNIL) to contest CitizenWave’s practices in terms of personal data protection and privacy.

The User may, at any time, exercise the aforementioned rights by sending a request to the following e-mail address but also by mail to the following postal address: 86 rue Voltaire, 93100 MONTREUIL, France.


The User undertakes to ensure, as far as necessary, the updating of personal data concerning him/her. The User also undertakes to ensure that the personal data concerning him/her is accurate, complete and sincere.

In addition, the User agrees not to disseminate his personal data, nor those of others, in the User Content that he will publish as part of the Application Services.


CitizenWave undertakes to keep all personal data collected through the Application and to share them only under certain circumstances and in accordance with the provisions of the Applicable Regulations.Communicating the Users’ personal data internally: Some of the Users’ personal data are accessible to CitizenWave’s employees if they need to have access to them in order to carry out the mentioned purposes, i.e. to provide the Users with the Services in an appropriate manner.
The communication of the Users’ personal data to third party service providers: CitizenWave can notably give access to the Users’ personal data to third party service providers, acting as subcontractors to perform services related to the Application and notably hosting, storage, analysis, communication, data processing, database management or computer maintenance services. These service providers only act upon instructions from CitizenWave and will only have access to the Users’ personal data to perform the aforementioned services and will be bound by the same security and confidentiality obligations as CitizenWave.

In addition, the User’s personal data may be shared with third parties for the following reasons:

In the context of a merger, acquisition or sale of all or part of the company’s assets, which the User acknowledges having been informed of;
In response to a judicial or administrative procedure of any kind or to law enforcement measures requested by the competent authorities ;
To comply with legal obligations, to protect the rights and/or safety of an individual, to protect the rights and property of CitizenWave, including the need to see this Privacy Policy and the Terms of Use respected, and to prevent fraud, security or technical problems.


CitizenWave may transfer the Users’ personal data to its subcontractors located outside the European Union. The subcontractors are the following:

  • – Twilio – Which complies with the new European Union (EU)-United States (US) Data Privacy Framework (DPF) RGPD regulation (August 2023)
    – Sentry – Which follows a Data Processing framework providing Standard Contractual Clauses.


CitizenWave may update this Privacy Policy at any time to adapt it to new practices and service offerings. In such case, the date of the Privacy Policy update will be updated and will indicate the day on which the changes were made. If CitizenWave updates the Privacy Policy, the Users will be notified through the Application.


In general, if the User has any questions or comments regarding this Privacy Policy, the use CitizenWave makes of his data, or if he wishes to exercise any of his rights, he can contact CitizenWave by email at the following email address or by postal mail at the following postal address : CitizenWave, 86 rue Voltaire, 93100 MONTREUIL, France.


  • What is a cookie?

A cookie is a small text file sent to the User’s browser by the website visited, and stored on the User’s computer or mobile device. Cookies allow the website to collect information about the User’s visit, such as the User’s path through the website or the User’s language preference, in order to improve the User’s browsing experience as well as the content and functionality of the website.

A cookie does not allow the User to be identified, but is only used to record information relating to his or her browsing on the site or application. A cookie generally contains the name of the website or application from which the cookie originated, the duration of the cookie (i.e., the length of time the cookie will remain on your device) and a value, which is usually a randomly generated unique number.

Cookies are secure; they can only store information that is placed there by the browser, which is information that the User has previously entered into the browser or that is included in the page request.

There are two types of cookies, with different uses and content:

temporary cookies, which contain information that is used during the browsing session. These cookies are automatically deleted when the User closes his/her browser. Nothing is kept on the computer once the User has finished browsing the site;
persistent cookies, which are used to store information that is used between visits. This data allows the sites to recognize the User when he returns and to react accordingly.

  • What cookies does CitizenWave use on the website

The User is informed that during his visits to the Website or the Application, certain cookies necessary for technical reasons to operate our Websites are deposited. We refer to these as “essential” or “strictly necessary” cookies.

These cookies enable the Website to function properly. Thanks to these cookies, the User does not need to provide certain information each time he visits the Site (e.g. choice of language). These cookies also allow the Site to follow his movements from one page to another so that it does not ask him for the same information he has already provided on the Site. These cookies allow the User to move easily and quickly from one page to another of the Site without having to identify himself or herself or to reprocess each new page of the Site that the User visits.

These cookies are necessary for the operation of our Site and are considered non-confidential intrusive cookies that enhance the Internet experience and therefore do not require consent. The User cannot accept or refuse their use.

In addition, CitizenWave uses certain analysis and personalization cookies. Audience measurement cookies collect information about the way the User uses and moves on our Website. For example, they make it possible to know which pages are most visited, IP (Internet Protocol) addresses, browser type, Internet Service Provider (ISP), referring and exit pages, operating system, date and time and click stream data. These cookies generate statistics on the number of visits and use of our Site. Statistics on traffic, content and page views may be collected. These statistics allow us to analyze trends, administer the Site, track Users’ movements on our Site, and gather demographic information about our overall user base.

These cookies are as follows:

  • Google Tag Manager
  • Google Analytics
  • LinkedIn Analytics
  • Hubspot
  • Facebook

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