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Measures for the protection of your personal data


Last updated on 23/03/2018

Sarbacane Software attaches great importance to the protection of your personal data.

With this document, we wish to inform our customers and prospects ("You") of the means implemented and the purposes pursued in relation to the collection of your personal data, in accordance with the regulations in force in France and within the European Union.

This charter applies to all services offered by Sarbacane Software ("We"). For any product or service offered by Sarbacane Software additional rules may apply.

At any time, You can contact us at the following email address:

1. Definitions

Personal data or data of personal nature

Personal data, or data of personal nature, is any information that directly or indirectly identifies a natural person.

Data controller

The person responsible for the data as the 'data controller', is anyone who determines the purposes and means of processing of the personal data.

Data processor

The 'data processor' is a subcontractor processing the data on behalf of a data controller. It is a separate legal entity from the data controller and is subject to an obligation of security and confidentiality regarding the personal data in order to protect it.

The data processor must be in a position to provide sufficient technical and organizational guarantees to ensure the protection of personal data.


Processing is any transaction (or set of transactions) involving personal data, and includes the collection, recording, organization, preservation, adaptation or modification, extraction, consultation , use, communication by transmission, broadcast or any other form of provision, reconciliation or interconnection, and the locking, erasure or destruction of data.

2. Security measures for protection of personal data

The personal data is collected by Sarbacane Software which, depending on the situation, is acting either as a data controller or a data processor.

When We act as the data processor, especially with regard to the processing of your recipient databases, We only act on your instructions and under your responsibility. As such, You agree to respect the amended version of the Data Protection Act of 6 January 1978, and as such, not to use sensitive data

- We are transparent:

In the performance of our services, We may collect your following personal data and other data:

  • - Your contact details (surname, first name, address, telephone number, email address);
  • - Transaction history, orders, payment IP address;
  • - Bank details (within the framework provided by law);
  • - The identifiers of the devices when using our software; IP connection address, activity log;
  • - The information collected via cookies;
  • - Data on the performance of our products and information on how You use them;
  • - Your interactions with us;
  • - Your data used in the context of the services;
  • - The statistics resulting from your campaigns;
  • In most cases, the collection of your personal data is required for the execution of the contract. Failure to provide this information would result in the impossibility or difficulty of carrying out the services. When necessary, your consent is requested.

    The collection and processing of personal data is justified, in particular with regard to:

  • - Resolution No. 2016 amending a simplified standard concerning the automated processing of personal data relating to the management of customers and prospects.
  • - Article 133-24 of the French Monetary and Financial Code.
  • - Article 123-22 par. 2 of the French Commercial Code.
  • - We only collect what is strictly necessary:

    We collect your personal data to fulfill one or more of the following purposes:

  • - the creation of your customer account;
  • - the management of your orders and the payment;
  • - the management of your subscriptions;
  • - monitoring of the customer relationship such as satisfaction surveys, claims management and technical support;
  • - evaluate and improve the quality of our products, services and websites;
  • - respond to your instructions when We act as a data processor, allowing the provision of the services;
  • - carry out operations relating to direct marketing;
  • - management of technical direct marketing operations (which includes technical operations such as standardization, enrichment and deduplication);
  • - the selection of people to carry out loyalty, direct marketing, survey, product testing and promotion actions;
  • - the performance of requested operations; Send You newsletters, informative messages and promotional offers by email or SMS, to keep You informed of news;
  • - the development of business statistics; know and manage your preferences in order to offer You products that meet your expectations;
  • - the organization of contests;
  • - the management of requests for right of access, rectification and opposition;
  • - management of unpaid bills and litigation;
  • - assert our rights; ensure compliance with the terms and conditions, the anti-spam policy, and laws and regulations;
  • - comply with the legal requirements.
  • - We only keep your data for the necessary amount of time:

    We retain your personal data as long as necessary to fulfill the purposes for which it was collected. We also keep your personal data during the retention period required by law, particularly in civil and commercial matters.

    Unless you expressly request otherwise, your campaign data is retained for a maximum of six months from the end of your subscription. This allows You to, within this time, recover your data in case of new subscription.

    The data necessary for commercial prospection is kept for a period of three years from the end of the commercial relationship. If You are a prospect, your data is kept for a maximum of 3 years from the collection or last contact with You.

    - Your personal data is confidential:

    Your personal data, including your databases and campaign content, is not sold, rented or disclosed to third parties.

    In order to be able to carry out the above actions, unless you consent, only our staff, the services in charge of the audit (notably the auditor) and our subcontractors (secure payment platform in particular) will have access to your personal data, according to their abilities. They may also be communicated to any legally authorized authority (particularly in the case of judicial requisition or the right of communication).

    - We focus on securely storing your personal data

    Our internal measures:

    Within the framework of our best effort undertaking, We inform You we take organizational and technical measures to preserve the security, integrity and confidentiality of personal data and, above all, ensure that they are not damaged, modified or that no unauthorized person has access.

    You can contact us for a presentation of these measures.

    Our staff is subject to an obligation of confidentiality through their employment contract and a computer charter attached to our rules of procedure. We also educate our staff about privacy and security measures.

    The measures of our data processors (subcontractors)

    When We use a subcontractor, it is subject to an obligation of security and confidentiality of your personal data to ensure its protection. At any time, upon our request, our subcontractors must provide evidence of sufficient technical and organizational security measures to ensure the protection of your personal data.


    Your personal data, with some exceptions, are hosted in France and/or within the European Union. More particularly:

  • - In the context of email and SMS campaigns, your recipient databases, campaign content and statistics are hosted in France;
  • - In the context of SMS campaigns, these data are also hosted within the European Union.
  • - As part of the support and in our capacity as controller, we use the Freshdesk solution (e-mail and live chat). The Company Freshworks Inc. based in the USA, is recipient of the following data: Last name, first name, e-mail address, telephone, and the contents of the messages exchanged.
  • To protect your Personal Data, We have taken the following guarantees to ensure You have a sufficient level of protection of Your Personal Data: Freshworks Inc is a member of PrivacyShield. The data transfer is also governed by the standard contractual clauses established by the European Commission.

    In any case, We guarantee, in case of transfer of your data outside the European Union, to implement all the appropriate measures to guarantee a sufficient level of data protection, such as:

  • - Give priority to the so-called "safe" countries, in order to provide significant protection of your personal data;
  • - Obtain guarantees of security and confidentiality from subcontractors by imposing strict contractual clauses while reserving the possibility of inspecting them regularly.
  • - We respect your rights:

    In accordance with the provisions of the Data Protection Act of 6 January 1978 (amended by the law of 6 August 2004 on the protection of individuals with regard to the processing of personal data), you benefit from:

  • - A right of access to your personal data;
  • - The rectification or erasure of these for legitimate reasons;
  • - A right to oppose the processing of your personal data for legitimate reasons;
  • - The right to define the guidelines relating to the fate of your personal data after your death. In the absence of these, your heirs may exercise their right to your personal data.
  • These rights can be exercised, in support of a valid identification document, by contacting us at the following email address:

    3. Cookie policy

    Our websites use "cookies" which are small text files placed on your device in order to operate the websites and collect information about the online activity.

    There are different types of cookies:

    Cookies necessary for navigation

    These cookies are essential for the operation of our sites and allow access to secure areas such as your shopping cart, your account etc. Without these cookies, it would be difficult to use the sites under normal conditions.

    Analytical or performance cookies

    These cookies enable us to know the use and the performances of our sites and to improve their functioning.

    Functional cookies

    These cookies are used to personalize your navigation.

    Advertising cookies

    These cookies collect information in order to offer relevant advertising based on your interests. They are usually placed by third parties with our permission.

    Which cookies are dropped and why?




    Identifies the user on the chat


    Number of pages viewed on the site (unidentifiable user)

    _ga, _gu,

    _gs, _gw

    And any cookie starting with « _ »


    Google analytics


    Prevents repeated posting of a pop-in on the blog


    Promotions management during commercial operations


    Cookie used to establish profitability statistics

    Userlog et encrypt

    Allows the user to access his space


    View the personalized information of the user


    View the personalized information of the user


    Prevents some computer attacks


    Check if the user has accepted the storage of cookies on his browser


    Identifies the origin of a users visit


    Affiliation management


    Check whether cookies are enabled or not

    What are third party cookies?

    Our websites contain cookies issued by third parties that allow them to collect browsing information related to the terminals that visit our websites.

    Google Analytics standard audience measurement cookies are used to collect information about the user and to reconstruct their journey on the site.

    The so-called "social networks" cookies are collected via application buttons and are likely to identify You, even if You have not used this button, when consulting our site, especially if You are connected to a social network platform.

    We invite You to consult the privacy policies of these third parties to learn about the purposes for use and navigation information they can collect through these tools. You can also refuse these cookies by adjusting the respective setting of your browser, as shown below.

    Among the third-party cookies, one can find so-called "affiliation" cookies which are cookies related to an affiliation program.

    How can You accept or refuse cookies?

    You can accept cookies or in some cases choose to disable them at any time. Nevertheless, some cookies are essential to your general navigation. These include cookies related to:

  • - The shopping cart;
  • - Identification;
  • - Authentication;
  • - Sessions created by a media player;
  • - Load balancing sessions;
  • - Solutions for analyzing and measuring the audience;
  • - Customization of the interface.
  • You can set your browser to tell You which cookies are on your device and ask You to accept them.

    You can also use a platform for managing cookies, sharing cookies and advertising cookies.

    How to change my browser settings?

    Access this feature via the "Options" or "Preferences" menu of your browser. The modification method is described in the help menu of your browser:

  • - For Internet Explorer:
  • - For Safari:
  • - For Chrome:
  • - For Firefox:
  • - For Opera:
  • Some browsers also offer the option "Do Not Track" that You can select to prohibit the deposit of cookies on your device.

    4. Amendment of this document

    This document may be modified at any time. We advise You to consult this page regularly to be aware of any changes or updates.

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