This is a temporary automatic translation, only the French version is valid regarding the law.
The company SocialBuddy SAS, hereinafter referred to as "SWELLO" or "We", is concerned about the protection of the personal data of visitors and users, hereinafter referred to as the "User", of its website https://swello.com, hereinafter referred to as the "Site", and is committed to protecting them in compliance with the applicable regulations, in particular Regulation (EU) No. 2016/679 of April 27, 2016, known as the "General Data Protection Regulation" or "GDPR," and Law No. 78-17 of January 6, 1978, as amended, known as the "Data Protection Act" (together hereinafter referred to as the "Applicable Regulation on the Protection of Personal Data").
SWELLO carries out data processing for which it is qualified as a "joint controller of processing," jointly responsible with its professional Clients. In this sense, SWELLO provides a service to Clients for which the usage will be carried out by Users. SWELLO also carries out personal data processing as the sole Data Controller. These processing activities are indicated by the abbreviation "RT" in the table presented in Article 1 of this Policy.
It is specified that SWELLO conducts an activity entirely aimed at professional clients (B2B activity). Social media accounts that may be linked to the use of the User's Account (the "Account") are not intended to be personal accounts. It is also specified that the Site is not intended for minors.
|Purposes of processing||Personal data collected||Legal basis|
|Manage the creation and use of the User's account||Last name, first name, email address, phone number, social network accounts, information contained on the accounts and in particular LinkedIn (profile picture, employer, position, professional experience, training)||Execution of the contract between the User/Client and SWELLO|
|Manage the subscription and provision of the Service, in accordance with SWELLO's terms and conditions of sale and use||Name, first name, email address||Execution of the contract between the User/Client and SWELLO|
|Manage the billing for the Service in accordance with SWELLO's Terms and Conditions of Sale and Use||Name, first name, email address, phone number, payment method, estimate, invoice||Execution of the contract between the User/Client and SWELLO|
|Manage refunds (RT)||Name, first name, email address||Execution of the contract between the User/the Client and SWELLO|
|Organize demonstrations of the platform, and prospecting (RT)||Name, first name, email address, employer||Legitimate interest of SWELLO, according to the rules of commercial prospecting in B2B|
|Provide assistance and support to the User through his Account, the chatbot and/or the contact form available on the Site, and/or any other means of communication (telephone, email) transmitted by the User (ST)||Name, first name, phone number, call history, employer||Legitimate interest of SWELLO to be able to respond to requests made at the initiative of the User|
|To inform the User about SWELLO's services and activities (RT)||Name, first name, email address, phone number, employer||Consent of the User to receive the newsletter of SWELLO|
|Participate in webinars organized by Swello (RT)||Name, first name, email address||Legitimate interest of SWELLO to process your personal data to organize the webinar you registered for|
|Manage the contests (registration, selection of the winner(s), sending the prize) (RT)||Name, first name, email address||User's consent to participate in the contest|
|Track and analyze Site traffic (RT)||Country of origin, connection medium used, operating system used, version of the operating system used, origin of the connection, all or part of the IP address, trackers||Consent of the User to the deposit of cookies and other tracers on his browser|
|For statistical purposes via cookies or reduced links (RT)||Country of origin, connection medium used, operating system used, version of the operating system used, origin of the connection, all or part of the IP address||Consent of the User to the deposit of cookies and other tracers on his browser|
|Publication of customer reviews and testimonials (RT)||Name, first name, position, employer, various comments, photograph||Customer's consent to have his opinion or testimonial published on Swello's website, and shared on Swello's social media pages|
|Affiliate and Referrer management (RT)||Referrer ID||Consent of the User to the deposit of cookies and other tracers on his browser|
The compulsory or optional nature of the data entry is specified at the time of collection, by an asterisk next to the data to be filled in compulsorily. The compulsory communication of certain personal data is necessary for SWELLO to implement the above-mentioned purposes. The optional data allow SWELLO to better know the User.
The User's personal data collected within the framework of the subscription to the Service, including the data used for the creation of the Account, will be kept by SWELLO for the duration necessary for the proper management of the contractual and commercial relationship between the User and SWELLO. Generally, the information is kept for a period of 10 years for accounting information, 5 years from the end of the contract for commercial data, 3 years for data processed in the context of prospecting, 13 months for data from cookies and other tracers, and 6 months for data from the online chat.
The User's personal data is strictly confidential and intended exclusively for SWELLO.
Unless required by law or court order to do so, SWELLO will never disclose, assign, rent or transmit the User's personal data to third parties other than:
SWELLO may call upon subcontractors to carry out a range of operations and tasks on our behalf, including but not limited to:
SWELLO ensures the compliance of the selected subcontractors based on the information provided by them.
SWELLO does not intend to transfer data to countries located outside the European Economic Area (EEA). If necessary, SWELLO ensures that appropriate safeguards are implemented to guarantee compliance and the security of the processing.
If the Client intends to provide non-occasional access to Users located outside the EEA, they must request the use of standard contractual clauses from SWELLO.
These policies can be consulted at the following addresses:
As part of providing its services, SWELLO uses third-party services such as Google's YouTube API. We retrieve video metadata (title, description, and thumbnail) and may store them for up to 30 days. We do not share this data with external clients, and this data is exclusively used to display this information in your interface.
You can manage your Google security settings from their dedicated page for this purpose (Google Security settings page).
SWELLO is committed to ensuring the security and integrity of the User's personal data. In this regard, SWELLO implements and maintains technical and organizational security measures for the Site, the Account, and, more generally, its information system, adapted in view of the nature of the personal data processed and the risks posed by their processing.
These measures aim to (i) protect personal data against their destruction, loss, alteration, disclosure to unauthorized third parties, and (ii) ensure the restoration of the availability of personal data and access to them within appropriate timeframes in the event of a physical or technical incident.
The User has, at any time, the following rights on his personal data:
If the user wishes to assert any of the aforementioned rights, he or she may contact the data protection officer of SWELLO in writing at the following email address dpo [@] swello [dot] com, within the limits of the legal obligations and compelling reasons to which SWELLO would be subject, if the processing is necessary for the performance of a contract, for the exercise of a public service mission, for archival, scientific, historical or statistical research purposes, for the exercise of the right to freedom of expression and information, for the establishment, exercise or defense of legal claims.
If your identity is not proven, you may be asked to provide a copy of an ID.
Finally, SWELLO users may file a complaint with the relevant supervisory authority, the CNIL (https://www.cnil.fr/fr/plaintes).
For any question concerning SWELLO's management of Users' personal data, the User may at any time contact SWELLO's Data Protection Officer (DPO) at the following email address: dpo [@] swello [dot] com.
This Policy may be regularly updated to reflect changes in the Applicable Regulation on the Protection of Personal Data.
Last Update Date: September 2023