NOTICE: Protection of personal data
Contents
Purposes – Objective – Definitions – Legal basis of processing
❖ Wabel Network offers, within the framework of this document, a service for collecting and retransmitting testimonials from its customers to its prospects. Wabel Network also offers a service to connect its customers and prospects who wish to directly collect testimonials from their peers who have already benefited from Wabel Network’s services.
We inform you that for the proper execution of the services indicated above, some of your Personal Data are processed by and on behalf of Wabel Network whose head office is located at 10 rue du Colisée, 75008, Paris, France (France).
❖ This GDPR information notice aims to inform you of the management of your Personal Data by Wabel Network as well as the means available to you to exercise your rights. We invite you to read it carefully and keep a copy.
This notice may be subject to updates depending on regulatory and legal developments and developments in our processing. The latest version of this document will be communicated to you.
❖ Terms beginning with a capital letter have the meaning given to them below:
– Personal data or Personal Data or Data: any information relating to a natural person (hereinafter referred to as “data subject”) identified or identifiable directly or indirectly, in particular by reference to an identifier, such as a name, a identification number, location data, an online identifier, or one or more specific elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity;
– Data subject: any identified or identifiable natural person, whose personal data is processed herein. The Persons concerned by this notice are the contacts, natural persons, of Wabel Network among its clients and prospects interested in the services indicated above;
– Regulations applicable to the protection of Personal Data: means the General Data Protection Regulation (otherwise known as the “GDPR”), any other European law or regulation, as well as any national law or regulation of the Member States of the Union European, relating to the processing of Personal Data;
– Data controller: legal entity which, alone or jointly with others, determines the purposes and means of the processing; in this case Wabel Network;
– Subcontractor: natural or legal person who processes Personal Data on behalf of the Data Controller;
– Processing (S): any operation or set of operations carried out or not using automated processes and applied to personal data or sets of data, such as collection, recording, organization , structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation , erasure or destructions.
❖ The legal basis for the processing carried out is your consent.
Personal data collected
When you are a customer of Wabel Network, we collect your personal data at the time of your request to participate in the collection of your testimony (verbatim, video, collection of contact references).
When you are a prospect of Wabel Network, we collect your Personal Data when you first contact Wabel Network and when you access the services offered hereunder.
Whether you are our client or our prospect, we collect, for the purposes of the services offered, directly from you, the Data indicated below:
– Your first and last name(s)
– Your email address and professional telephone number
– Information about your company (its sector of activity, its name) and your position within your company
We also collect:
- a) for our customers only:
– when you opt for a video testimonial, the video of your presentation and that of your company;
– the size of your company.
- b) For our prospects only: a Token link allowing you to be identified and to trace your activity in the computer systems.
Recipients of your Personal Data
The Data collected will be communicated only to the following recipients:
– Employees of Wabel Network responsible for implementing these services and monitoring the commercial relationship with the customer or prospect ;
– Our subcontractor, the company CLAYM SAS, whose head office is located at 6 place bérault, 94300 Vincennes France as well as its subcontractors listed below:
- The company Videoask by Typeform: whose head office is located in Barcelona (Spain), i.e. in the European Union,
- The Mailjet company: whose head office is located in Paris (France), i.e in the European Union,
- The company Bubble.io: whose head office is located in New York (USA)
Security of your Personal Data and Transfer to third countries
In accordance with the Regulations applicable to the protection of Personal Data and good practices in terms of Data security, we pay the greatest care to the security of your Data that we process.
In order to protect your Data, we put in place appropriate organizational and technical measures, adapted to the sensitivity of your Data collected and the risks induced by their processing.
We implement all useful means to guarantee the confidentiality, integrity, availability and resilience of your Personal Data. We take care to store Personal Data concerning you in information systems offering an appropriate level of security, access to which is protected, restricted and recorded and we provide in our contractual documentation a strict confidentiality commitment for all persons involved in processing Personal Data on our behalf.
We also ensure that all members of staff and all persons involved in the processing of Personal Data comply with all rules on the protection of Personal Data and undertake to keep the Personal Data processed confidential.
In this regard, we ensure that our Subcontractor, the company CLAYM SAS whose head office is located within the European Union and which is itself subject to the Regulations applicable to the protection of Personal Data, ( i) respects its regulatory and contractual obligations in terms of Data protection, and (ii) only uses Subcontractors presenting at least the same guarantees as it in terms of Data security and compliance with the Regulations applicable to the protection of Personal Data.
Our Subcontractor has guaranteed to us that it has selected its Subcontractors involved in these services, taking into account GDPR compliance criteria, ISO certifications and advanced security standards. Thus, its two (2) Subcontractors (The company Bubble io and Videoask by Typeform) who transfer your Data outside the European Union, implement appropriate guarantees, in particular through the conclusion of Standard Contractual Clauses (SCC) to ensure the compliance of transfers of said Data with the Regulations applicable to the protection of Personal Data.
Below you will find the guarantees and security measures implemented by each Subcontractor:
- Videoask.com by Typeform
➔ hosts its data in Virginia in the USA
➔ Here is their DPA with SCC (choice D) and Privacy policy (Choice C)
➔ certification: ISO 27001, SOC2, HIPAA, GDPR
➔ security standards: secured by multiple levels of encryption and access control and by penetration tests.
- Bubble.io
➔ hosts the data at AWS in Oregon in the USA
➔ here is their: DPA & SCC and Privacy Policy
➔ certification: built on Amazon Web Services, which itself complies with certifications such as SOC 2, CSA, ISO 27001, and more
➔ security standards: RDS AES-256 encryption
➔ hosts its data with Google Cloud Platform in Frankfurt (Germany) and St. Ghislain (Belgium).
➔ Here is their DPA and their Privacy Policy
➔ certification: SOC 2, ISO 27001, and ISO 27701
➔ security standards: data is encrypted and is copied and placed in real time in three separate locations
We guarantee that none of your Data will be transferred to third parties for purposes other than those stated above without your consent.
________________________________
1 Standard contractual clauses are model personal data transfer contracts adopted by the European Commission and on the basis of which companies can transfer personal data to countries outside the European Union. To find out more: https://www.cnil.fr/fr/transfert-de-donnees-les-clauses-contractuelles-types-cct-de-la-commission-europeenne#:~:text=Les%20clauses%20contractuelles%20types%20sont,europ%C3%A9enne%20le%204%20juin%202021.
Duration of retention of your Data
Your data will be kept for a period of 10 years.
You can, at any time, withdraw your consent to the processing of your Data by notifying us of your decision by mail to the following address:
DPO Wabel Network
10 rue du Colisée, 75008, Paris, France
or by email to: privacy@wabel.com
Exercise of your rights
In accordance with current regulations, you have:
– a right of access allowing you to access the Data concerning you,
– the right to request the rectification of your Personal Data when they are inaccurate or incomplete,
– the right to request the erasure of your Data unless it is necessary for the establishment, exercise and defense of our rights in court.
In the context hereof, and we will consider your request to erase your Data as a withdrawal of your consent to the processing of your Data for the purposes of the services offered,
– a right to portability of Personal Data concerning you in order to obtain a copy,
– a right to object to the processing of your Personal Data or to limit their processing for legitimate reasons. In this case, we invite you to notify us of the withdrawal of your consent to the processing of your Data following the procedure indicated above.
You can also send us your instructions for the conservation, deletion or communication of your Personal Data in the event of death and designate the person who will be responsible for this.
Visit the cnil.fr website for more information on your rights.
To exercise your rights, you can contact us by mail at the following address:
DPO Wabel Network
10 rue du Colisée, 75008, Paris, France
or by email to: privacy@wabel.com
We inform you that no profiling or decision-making concerning you is carried out on the basis of the processing of your Personal Data.
Other important information
For any questions or additional information on the processing of your Data, your rights and the means to exercise them, you can contact us using the following contact details:
DPO Wabel Network
10 rue du Colisée, 75008, Paris, France
or to the following email: privacy@wabel.com
If you consider, after contacting us, that your rights under the Regulations applicable to Data protection are not respected, you can send a complaint to the CNIL.