Version applicable from May 25, 2018
Sarbacane Software attaches great importance to the protection of your personal data.
This charter applies to all services offered by Sarbacane Software ("We"). For any product or
service offered by Sarbacane Software additional rules may apply.
This charter can be modified at any time to meet legal, regulatory and technical changes.
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 personal data when
we act as the controller, in accordance with the regulations in force. In particular this applies
to when We process the contact details of a person in your company, when You contact us
for support or assistance, when You browse our Websites, or when You use our forms to
When we process personal data for your account and under your instructions, we act as a
subcontractor. This is particularly the case when we are processing your campaign recipient
databases. This relationship is governed by this Agreement in compliance with GDPR Article
For the purpose of this document, the following terms are defined as:
Personal data, or data of personal nature, is any information that directly or indirectly
identifies a natural person, that is treated by Sarbacane Software in its capacity as
Refers to Sarbacane Software SAS. The person responsible for the data as the 'data
controller', is anyone who determines the purposes and means of processing of the personal
The 'data processor' is a subcontractor processing the data on behalf of a data controller
and acting under their instructions. 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, regardless of
the processing method applied. In particular this 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
Identity of the controller
The controller is:
Sarbacane Software SAS. 3 Avenue Antoine Pinay, Parc d’activités des 4 vents, 59510
HEM, RCS Lille Métropole 509 568 598, represented by SASU KALOMA CAPITAL as
The collection and processing of Personal Data by Sarbacane Software is governed by the
GDPR and by Regulation (EU) 2016/679 of the European Parliament and the Council of 27
April 2016 on the protection of individuals with regard to the processing of personal data and
on the free circulation of such data.
- We are transparent:
All Personal Data about you is collected directly from You.
The legal grounds for the collection of your Personal Data are:
- The execution of our contractual relations. The non-provision of these would result in
impossibility or difficulty of carrying out the Services;
- Our legitimate interest in ensuring the best possible quality of service;
- When necessary, your consent is requested. This consent can be withdrawn at any time
We are required to process your Personal Data for the following purposes:
- the creation of your customer account;
- the management of your orders and the payment;
- the management of your subscriptions and services;
- 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 including the
development of sales statistics
- management of technical direct marketing operations (which includes technical operations
such as standardization, enrichment and deduplication);
- carry out operations relating to direct marketing;
- the performance of requested operations; Send You newsletters, informative messages
and promotional offers by email or SMS, to keep You informed of news;
- the organization of contests;
- the management of the exercise of your rights with regard to the rules on the protection of
- management of unpaid bills and litigation;
- assert our rights;
- assert our rights; ensure compliance with the terms and conditions, the anti-spam policy,
and laws and regulations;
- comply with the legal requirements.
Type of Personal Data
The mandatory or optional nature of the Personal Data requested and the possible
consequences of a lack of response are specified to you during the collection.
We may collect your following Personal Data and other data: - your contact information
(name, surname, function, address, telephone number, email address); - transaction history,
orders, payment IP address; - bank details (within the framework provided by law); -
machine identifiers when using our software, connection IP address, log of activities; -
information collected via cookies; - the performance data of our products and the information
on how You use them; - your exchanges with Us; - the data collected as part of our affiliate
- 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.
The data necessary for commercial prospection, notamment nom, prénom, adresse postale,
adresse électronique, téléphones 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.
Sarbacane Software commits to maintain the confidentiality of Personal Data, not to disclose
it, in whatever form, except (i) for the purposes of the Services and performance of it; (ii)
pursuant to a legal or regulatory provision; (iii) to respond to communication requests from
judicial and/or administrative authorities; (iv) to enforce our rights or those of our partners
and third parties; (iv) with your prior agreement or at your request.
We use services provided by specialized companies, including our subcontractors, the list of
which can be communicated to you by contacting our DPO. When these companies use
servers outside the EU, we have taken care to conclude contracts with them 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 within our support department (i.e.
support request form by email and live chat).
In all cases, Sarbacane Software ensures that the persons authorized to process your
Personal Data (personnel, partners, subcontractors, etc.) guarantees to respect the
confidentiality of the Personal Data or are subject to an appropriate legal obligation to
-Your Personal Data is secure:
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.
-We respect your rights:
In accordance with the GDPR and other rules, You have the following rights:
- the right of access to your Personal Data (article 15 of the GDPR);
- the right to rectify your Personal Data in the event that it is inaccurate (Article 16 of the
- the right to have your Personal Data erased (Article 17 GDPR) in some cases;
- the right to a limitation of the Processing of Your Personal Data (article 18 of the GDPR)
and the right to the portability of your Data (article 20 of the GDPR), within the limits fixed by
the applicable regulations;
- the right to withdraw Your consent at any time when the Processing is based on it (Article
13 of the GDPR);
- the right of opposition to the Processing of your Personal Data (article 21 of the GDPR);
- the right to define the guidelines regarding the fate of your Personal Data after your death.
In the absence of this, your heirs may exercise their rights to your Personal Data.
These rights can be exercised, in support of a valid identification document, by contacting us
at the following email address: email@example.com.
You can contact us at any time - Contact details of our DPO:
You can contact us at the following email address: firstname.lastname@example.org
Or contact our Data Protection Officer directly at email@example.com