Version effective on 03/05/2022
Sarbacane Software, located at 3 Avenue Antoine Pinay, Parc d'activité des 4 vents in Hem (59510) - RCS Lille Métropole 509 568 598, acting as a data processor as defined by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 applicable since 25 May 2018 and by the amended Law No. 78-17 of 6 January 1978, relating to data processing, files and freedoms (hereinafter, together, the "Regulation"), attaches great importance to the protection of personal data.
This policy (hereinafter the "Policy") applies to all websites and services (hereinafter the "Services") offered by Sarbacane Software (hereinafter "We"). Any product or service offered by Sarbacane Software may be supplemented by specific mentions.
Through this Policy, We wish to inform the users of our Services (hereinafter "You") of the means used and the purposes pursued for the collection of any information that directly or indirectly identifies a natural person (hereinafter "Personal Data"), in accordance with the Regulation, when We act as data processor, i.e. when We determine the purposes and means of the processing.
It is understood that processing means any operation (or series of operations) relating to Personal Data, by any process and in particular the collection, recording, organization, storage, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of distribution, merging or interconnection, as well as blocking, erasure or destruction (hereinafter referred to as "Processing").
When using our Services, You may be asked to provide Personal Data, directly or indirectly. The compulsory or optional nature of the Personal Data requested and the possible consequences of a lack of response are specified to you during the collection.
Thus, We collect Personal Data that You provide to Us, Personal Data that We obtain from third party sources, and Personal Data that We obtain through Your use of the Services.
Thus, the following Personal Data and other data may be collected and processed:
Regarding data collected from other sources, We may also obtain your contact details and other personal information from companies which are part of the Group to which We belong and from other third parties, including companies with which We offer shared services and which warrant to Us that they have obtained your data lawfully; and/or from publically available sources and/or from the data providers from whom We obtain data.
We collect and process Your Personal Data under the following legal bases:
We may process your Personal Data for the following purposes:
Your Personal Data are processed by Us, but We may also share your Personal Data (i) with different appropriate departments of the companies within the Sarbacane Group to which We belong (ii) and/or with external service providers, duly authorized. The departments of our Group and our external subcontractors operate on our instructions and within the strict limits of their tasks (e.g.: to process your payment or to create your invoice). In this context, your Personal Data are neither sold nor rented to third parties.
When these service providers use servers outside the EU, We have made sure that they have signed contracts on the protection of personal data and in particular the standard clauses of the European Commission to regulate the transfer of personal data. This is for example the case with the company Freshworks Inc - USA, a tool that We use to provide you with support, customer relations or sales.
In any case, We ensure that the persons authorized to process your Personal Data (staff, partners, subcontractors, etc.) are committed to respect the confidentiality of Personal Data or are subject to an appropriate legal obligation to confidentiality. Thus, We ensure in particular that our employees who may have access to your Personal Data as part of their tasks are made aware of the protection of Personal Data.
As part of our obligation of means, We inform you that appropriate organizational and technical measures are taken to preserve the security, the integrity and the confidentiality of your Personal Data and in particular, to prevent that they are distorted, damaged or accessible to unauthorized third parties.
Furthermore, We are committed to keep the Personal Data confidential, not to disclose it, in any form whatsoever, except (i) for the purposes of the execution of the Services and the purposes of the Processing; (ii) in application of a legal or regulatory provision; (iii) to fulfill communication requests from judicial and/or administrative authorities; (iv) to exercise our rights or those of our partners and third parties (iv) with your prior consent or upon your request.
We keep your Personal Data for the time necessary to fulfill the purposes for which it was collected. We also keep your Personal Data for the period of time defined by the law, especially in civil and commercial matters.
For example, the Personal Data required for commercial prospecting, in particular name, first name, postal address, e-mail address and telephone number are kept for a period of three years after the end of the commercial relationship. If you are a prospect, your Personal Data is kept for a maximum of three years from the date of collection or the last active contact with You.
Likewise, as an example, if You are a candidate for a recruitment, if your application is rejected and if You do not request the destruction of your application, your Personal Data are kept for a maximum of two years after the last contact. Only your express consent allows a longer retention.
In accordance with Regulations, You have the following rights:
These rights can be exercised by contacting Us at the following e-mail address: firstname.lastname@example.org
Or contact our Data Protection Officer directly at the following address email@example.com
We may change this Policy from time to time, in order to comply with legal, regulatory, case law, or technical developments.
We recommend that you check this page regularly for any changes or updates made to this Policy.
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