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Personal data - Account creation

The use of the account creation form is associated with the service of personal data processing managed by Sarbacane Software, whose contact details are as follows:

 Sarbacane Software

 3 Avenue Antoine Pinay

 ZA des 4 vents

 59510 Hem

 France

Purpose of the data processing

The purpose of processing is to create a user account that allows the person performing the creation to connect to the software application.

Objectives

It allows Sarbacane Software to:

· create a unique account and allow the access and the use of the products and services

· identify users who connect to their accounts and access to the products and services so as to offer a customized background

· communicate with users via email

· communicate with users on the phone

· communicate with users via SMS

· collect and analyse your recipients’ behaviour for statistical purposes, for targeted reminders and to determine the best time to send future communications in order to deliver them during the actual time slots people habitually check their email.

Legal basis

The data subject has consented to the processing of their personal data for one or more specific purposes. Therefore, the general contractual conditions apply and govern the processing necessary for the performance of the contract.

Processed data

Categories of processed data

· ID details

· Personal or professional data

· Behaviour and software environment

· Country and town of location

Data source

• This information is collected from users of the publicly accessible account creation form. Thereafter, the personal data can be completed or corrected in the application, from the user account preferences.

• The behavior of the recipients of e-communications, their software environment, are reckoned based on their interaction with the message (openings, clicks, image display).

• The geolocation of the town is calculated from the recipient's public IP connection address when interacting with the message (accuracy rate around 85%).

Mandatory nature of data collection

The form provides for the mandatory collection of an email address and a password to enable the authentication of the person. To proceed with the validation of the form, it is necessary to accept the terms and conditions and the anti-spam policy by ticking the dedicated checkbox. The associated documents are freely accessible by clicking on the referencers link, so that it is possible to read them before the validation of the form. Other data is optional, all of which can be modified or added later in the application from the user account preferences.

Automated decision making

This processing does not involve automatic decision-making.

Persons concerned

The data processing concerns:

· Natural and legal persons using the form

· The Sarbacane Software staff in charge of helpdesk requests

· The Sarbacane Software staff in charge of customer relationship topics

· The Sarbacane Software staff in charge of sales requests

Data Recipients

Categories of recipients

According to their respective needs, the recipients of all or part of the data are:

· Authorized Sarbacane Software staff

· Subcontractors solicited when sending SMS:

  · SINCH (previously CLX Communication) Lindhagensgatan 112 18 Stockholm - Sweden

  · CM (previously CM Telecom) 110 Rue de Réaumur 75002 Paris - France

Transfers of data outside the European Union

No transfer of data outside the European Union is carried out unless the subsequent subcontractor processes services outside the EU/EUE (see subsequent providers list). In this case, Sarbacane Software has ensured that the transfer is carried out in accordance with the standard contractual clauses approved by the European Commission for the transfer of personal data or that other appropriate legal data transfer mechanisms are applied.

Data retention period

The entered data that is the subject of the creation of a commercial status is kept for 3 years after the last exchange or till the end of the commercial relation.

Raw data from interactions with the electronic communications sent shall be saved for a maximum of 12 months. The consolidated data are saved within the corresponding communication campaign until they are manually deleted by the Sarbacane Software’s staff in charge of carrying out periodic communications.

Security

Please consult our document describing our technical and organizational security measures.

Your rights to your data

You can access and obtain a copy of the data concerning you, oppose the processing of it, have it rectified or have it erased. You also have a right to limit the processing of your data.

Furthermore, Sarbacane Software provides a charter dedicated to the protection of personal data.

Exercise your rights

The Data Protection Officer (DPO) at Sarbacane Software is your contact for any request to exercise your rights on this treatment.

Send your requests:

By email to : dpo@sarbacane.com

By post to:

Attn: Data Protection Officer

Sarbacane Software

3 Avenue Antoine Pinay

ZA des 4 vents

59510 Hem

France

Complaint to the data protection authority

If, after contacting us, you believe that your rights to your personal data are not respected, you can submit a complaint to the data protection authority. To find the contact information for the authority on which you depend, please visit this page.

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