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.
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“).
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
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).
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.
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.
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.
Purpose of the ProcessingType of dataLegal/Judicial BasisPerson/Service with Access to the DataAnalysis of the prospect’s needs, answering questions and sending quotesFirst and last nameConsentCommercial serviceSending commercial offersEmail addressMarketing serviceSending information regarding research andratings in progressPhone numberService providers (AirTable for organising and exchanging files; Google, Pardot and Salesforce for sending emails and newsletters)Invitation to eventsNavigation data (cookies)
Purpose of the ProcessingType of dataLegal/Judicial BasisPerson/Service with Access to the Data
Data of the contact of the client requesting the rating:
Purpose of the ProcessingType of dataLegal/Judicial BasisPerson/Service with Access to the Data
Data of the directors/founders of the startup according to information available on publicdatabases (e.g., Infogreffe, LinkedIn, startup’s website, etc.) and/or provided by the client:
Data of the directors/founders of the Startup according to information provided by the startup through completion of the online survey:
Data of the directors/founders of the Rated Startup:
Purpose of the ProcessingType of dataLegal/Judicial BasisPerson/Service with Access to the DataDelivery of the service and follow- up of the service provider
PaymentBank details (e.g., name of bank, bank address, BACS number, etc.)Contract fulfilmentAccounting serviceFollow-up and handling of disputes relating to supplier/provider contactsSee aboveLegitimate interest
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.
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:
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.
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:
In addition, anonymous data and data relating to Startups may be kept indefinitely as long as it does not contain any Data.
The following actions are carried out on the Data:
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.
As part of the Data processing carried out by Early Metrics, You have the right:
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.
The website https://earlymetrics.com/ (the « Website ») is edited by Early Metrics, a simplified joint stock company with €5,480 in capital, whose corporate office is located at
216 Rue Saint Denis, 75002 Paris
and registered at the Paris RCS under the number 804 356 525 (“Early Metrics”).
Phone number: 06 85 10 40 40
Email address: firstname.lastname@example.org
Intra-Community VAT number: EM FR n° FR 05 804356525
1&1 Internet SARL
7, place de la Gare
BP 70109 57201 Sarreguemines Cedex
Phone number: 0970 808 911
During the visit or use of the Website and/or Early Metrics (the “Website”) applications, cookies are placed on the User’s computer, mobile or tablet. The purpose of these cookies is to inform users browsing the Website (the “User”) of the processing of their personal data and their related rights.
The term “cookie” encompasses the different tracers that are deposited or read on a computer, tablet, or mobile, for example when consulting a website, an application, an advertisement, or when using software. A cookie is intended to collect information regarding the user’s browsing. This information can be used for various purposes such as: identifying users and allowing them to access their account or performing statistics including the use of the Website or other sites and applications.
List of cookies Early Metrics has access to on its Website (they are not necessarily all used):
Name of cookies and the editor (if it’s a third-party)Purpose/UseNature of the cookies(necessary for Website use or not)GoogleDetermine the language of the WebsiteNot necessaryGoogle AnalyticsMesure the audience and use of the WebsiteNot necessaryTwitter and LinkedinShare buttonsNot necessary
Use of the Website may lead to the installation of certain cookies issued by third parties (for example communication agencies, audience measurement companies, social networks, YouTube, Facebook, etc.) to identify the users’ interests and possibly customise the advertising offers sent to them on and off the Website.
They can be deposited when the User navigates the Website or when they click on the Website’s advertising spaces. However, these third-party cookies are not controlled by Early Metrics. The issuing and use of these cookies are subject to the privacy policies of these third parties.
The cookies (identified above) and the third-party cookies are installed as of the User’s first visit on the Website. Most cookies are intended to allow or facilitate navigation of the Website and are necessary for the operation of said Website. Therefore, as indicated in the table above, the Website uses “essential” cookies that do not require the consent of the User and other cookies that require the express consent of the User prior to their installation.
By clicking on the button “Ok accept all” of the Website’s information banner, the User agrees to the placement of cookies on their device. The User also has the option to select the “Personalise” button which then allows them to disable/enable all or some of the “non- essential” cookies at any time.
The User’s consent to the placement of cookies on their device is valid for a period of thirteen (13) months. Therefore, cookies requiring the User’s consent are deleted or rendered ineffective thirteen (13) months after their deposit, upon which the consent of the User must be reobtained.
the cookies’ purpose as described above when configurating their browser.
Furthermore, the User is informed that the refusal of a cookie will be taken into account by the installation of a “refusal cookie” on the concerned terminal. We must therefore be careful not to delete this refusal cookie if the User’s choice is to be taken into account.
The following links explain how to configure the various internet browsers in order to deactivate cookies:
Google Chrome: https://support.google.com/accounts/answer/61416?hl=fr
The User may also use a cookie management software to configure them according to their wishes, such as for example the TarteAuCitron or TagCommander software. A list of software (non-exhaustive) is also available on CNIL’s website (link).
Early Metrics commits to allowing access and use of the Website as part of an obligation of means. The information available on the Website is provided “AS IS” without warranty of any kind, including the integrity, accuracy, timeliness, availability, reliability or completeness of information, products, accessories or services appearing on the Website or their suitability for the User’s intended use.
Early Metrics’ liability is limited to direct damage, thus excluding indirect damage of any kind. Early Metrics cannot be held liable for any damage suffered by the User or by a third party resulting directly or indirectly from: the non-compliance by the User of any of its obligations, negligence, use of the Website that is non-compliant, in particular for purposes other than those indicated by Early Metrics or its suppliers, or in case of delay or failure to fulfil its obligations due to a cause beyond its control such as a fortuitous event or a force majeure.
In all cases and within the limits authorised by law, the total amount of compensation and of any amount charged to Early Metrics with regards to the Website may not exceed the total sum of €500. Any claim against Early Metrics must be made within one month of the event subject of said claim.
Early Metrics holds all commercial rights to exploit the Website’s elements (text, graphics, logos, computer developments, photographs, images, brands, creations, etc.) including intellectual property rights related to them, which the User expressly acknowledges, with the exception of the elements provided by Users related to the Service.
The User is prohibited from infringing the property rights relating to the elements of the Website protected by intellectual property rights. This includes reproducing, representing, modifying, adapting, translating, extracting and/or reusing a qualitatively or quantitatively substantial part of them.
Any User, website owner or not, who wishes to use a hypertext link directing users to the Website must request permission from Early Metrics beforehand, using the contact email address mentioned herein. All links must be removed at the simple request of Early Metrics.