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Privacy policy

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.

1. Processing purposes, collected personal data, and legal bases

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.

2. Retention periods of the User's personal data

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.

3. Recipients of the User's personal data and transfers

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:

  • Social networks for the purpose of executing the contract between SWELLO and the User.
  • Duly authorized public authorities (judicial, regulatory...)
  • Regulated professions (lawyers, bailiffs, etc.) that may be involved in implementing guarantees, recovery, or litigation.

SWELLO may call upon subcontractors to carry out a range of operations and tasks on our behalf, including but not limited to:

  • Managing the security of subscription payments;
  • Handling phone calls;
  • Managing the chat system;
  • Hosting User data;
  • Conducting email campaigns;
  • Organizing webinars.

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.

It is understood that within the scope of using the services, SWELLO cannot be held responsible for personal data sent or captured by the Platforms to which SWELLO is associated. The Client and the User are advised to refer to the Terms of Use and Privacy Policies of the various associated Platforms for more information about the processing of data by these Platforms.

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.

Here are the terms of use of YouTube (YouTube Terms of Service) as well as the privacy policies and terms of use of Google (Google Privacy Policy).

You can manage your Google security settings from their dedicated page for this purpose (Google Security settings page).

4. Security measures implemented

Certainly, here's the translation with the HTML tags:

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.

5. Rights of the User on his personal data

The User has, at any time, the following rights on his personal data:

  • right of access (Article 15 GDPR) and rectification (Article 16 GDPR), updating, completeness of user data right of deletion of user data (Article 17 GDPR), when they are inaccurate, incomplete, equivocal, outdated, or whose collection, use, communication or storage is prohibited;
  • right to withdraw consent at any time (Article 13-2c GDPR);
  • right to restrict the processing of user data (Article 18 GDPR);
  • right to object to the processing of user data (Article 21 GDPR);
  • right to portability of data provided by users, when such data are subject to automated processing based on their consent or on a contract (Article 20 GDPR);
  • the right to define the fate of the users' data after their death and to choose to whom SWELLO shall communicate (or not) their data to a third party that they have previously designated;

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.

6. Updating of this Policy

This Policy may be regularly updated to reflect changes in the Applicable Regulation on the Protection of Personal Data.

Last Update Date: September 2023