This is a temporary automatic translation, only the French version is valid regarding the law.
The company SocialBuddy SAS, (hereinafter "SWELLO" or "We") is concerned about the protection of the personal data of visitors and users (hereinafter the "User") of its site https://swello.com (hereinafter the "Site") and undertakes to protect them in accordance with the applicable regulations and in particular Regulation (EU) No. 2016/679 of 27 April 2016 known as the "General Data Protection Regulation" or "GDPR" and Law No. 78-17 of 6 January 1978, as amended, known as the "Data Protection Act" (together hereinafter the "Applicable Personal Data Protection Regulations").
SWELLO implements data processing for which it is qualified as a "data controller", within the meaning of the aforementioned texts. SWELLO also acts as a "subcontractor" in the context of the supply of its product. The processing operations marked "ST" in the table referred to in paragraph 1 are carried out by SWELLO as a subcontractor As such, SWELLO undertakes to comply at all times with the requirements of the Regulations applicable to the protection of personal data and to carry out processing on the personal data of the Users only under the conditions provided for hereinafter.
It is to be specified that SWELLO carries out an activity entirely for professional clients (B2B activity). The social network accounts that may be linked to the use of the User's Account (the "Account") are not intended to be personal accounts.
|Purposes of processing||Personal data collected||Legal basis|
|Manage the creation and use of the User's account (ST)||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 and SWELLO|
|Manage the subscription and provision of the Service, in accordance with SWELLO's terms and conditions of sale and use (ST)||Name, first name, email address||Execution of the contract between the User 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 and SWELLO|
|Organize demonstrations of the platform, and prospecting||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||Name, first name, email address, phone number, employer||Consent of the User to receive the newsletter of SWELLO|
|Participate in webinars organized by Swello||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)||Name, first name, email address||User's consent to participate in the contest|
|Track and analyze Site traffic||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||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||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||Referrer ID||Consent of the User to the deposit of cookies and other tracers on his browser|
|Platform error check for each user||IP address, email address||Legitimate interest of Swello to control errors that have occurred|
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 is likely to call upon the following subcontractors: the company STRIPE which manages the security of subscription payments, WHEREBY for videoconferencing operations, MANDRILL and MAILCHIMP for emailing operations, STANDARD FACILE for the management of telephone calls, HELPSCOUT for the organization of webinars and ZAPIER for the automation of Instagram publications. SWELLO ensures the compliance of the selected subcontractors according to the elements provided by them.
SWELLO does not intend to transfer data to countries outside the European Economic Area (EEA). Where applicable, SWELLO ensures that appropriate safeguards are implemented to guarantee the compliance and security of the processing.
SWELLO undertakes to ensure the security and integrity of the User's personal data. In this respect, SWELLO implements and maintains technical and organizational security measures for the Site, the Account and, more generally, its information system adapted to the nature of the personal data processed and the risks presented by their processing.
Thanks to the different APIs and its partnerships, SWELLO is a secure platform. The site is protected by an SSL certificate. The infrastructure and the code are validated by security audits, the team is aware and trained. Most of the data is hosted in France, on SecNumCloud servers or if necessary, in Europe (more information). In addition to that, SWELLO offers several features to increase the security level of each Swello account (including multi factor authentication).
These measures are designed to (i) protect personal data against destruction, loss, alteration, disclosure to unauthorized third parties, (ii) ensure the restoration of availability of and access to personal data in a timely manner 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.
In providing its services, SWELLO uses third-party services such as Google's YouTube API.
We collect the metadata of the videos (title, description and thumbnail) and can store them for up to 30 days.
We do not share this data with external clients and this data is used exclusively to display this information in your interface.
You can manage your Google security settings from their Google Security settings page.