Privacy policy

Spinergie respects the right to privacy and recognizes the importance of protecting personal data.


In this respect, Spinergie undertakes to process personal data transmitted by the persons browsing its website and interacting with Spinergie through such website, accessible at the following address <https://www.spinergie.com>; (hereinafter the "Site"), in accordance with the provisions of Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR"). "), of the law N° 78-17 of 6 January 1978 relating to data processing, files and freedoms (hereinafter the "Law N° 78-17") as well as this Privacy Policy of Spinergie (hereinafter the "Privacy Policy").


The purpose of the Privacy Policy is to detail the origin and use of personal data collected and processed by Spinergie as well as the measures it implements to best protect said data.

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ARTICLE 1 - SCOPE OF THIS POLICY

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Spinergie, whose registered office is located at 49 rue Notre-Dame de Nazareth 75003 Paris, registered with the Paris Trade and Companies Register under number 821 352 317, collects and processes personal data transmitted to it by people browsing the Site (hereinafter the "Visitor(s)").

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ARTICLE 2 - TREATMENTS OPERATED BY SPINERGIE

2.1 Legal basis for processing

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As part of the browsing by Visitors, it is in the legitimate interest of Spinergie to be able to process certain data relating to the use of the said website in order to improve its operation.
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2.2 Description of Processing


Processing Operations:
Collection; access; use; matching; transmission; organization


Purpose(s) of the Processing(s):
Allowing visitors to browse the website, providing a demo of the solution offered by Spinergie; commercial prospecting, improvement of the website.


Category(ies) of Data Subjects:
Visitors
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Category(ies) of Personal Data processed:
Identification data, contact data, connection data

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Categories of Data Recipients:
Spinergie, HubSpot, Google Advertising, Meta, LinkedIn, Mouseflow
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Categories of personnel with access to Personal Data (e.g. security, operational, legal personnel):

Marketing, Sales, Account teams.
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Unless the consent of the persons concerned is obtained under the conditions provided for in accordance with the provisions in force, these operations must not lead to the establishment of profiles likely to reveal sensitive data (racial or ethnic origins, philosophical, political, trade union, religious opinions, sexual life or health of individuals).
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ARTICLE 3 - DATA RETENTION PERIOD

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Visitors’ personal data are kept by Spinergie for a period of three (3) years from the date of their collection.


Audience measurement statistics are not kept for a period exceeding six (6) months.


Certain data may be archived beyond the periods provided for (i) in the event of litigation in order to establish the reality of the disputed facts; and/or (ii) for the purposes of investigating, detecting and prosecuting criminal offences for the sole purpose of allowing, as necessary, the communication of such data to the judicial authority.


Archiving implies that this data is no longer available online but is extracted and stored on an autonomous and secure medium.


After the deadlines set out in the Privacy Policy, the personal data of the Visitors are deleted.


Spinergie keeps Visitors’ data only for the periods specified above and will delete them at the expiry of the aforementioned periods.
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ARTICLE 4 - SPINERGIE’S COMMITMENTS

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Spinergie undertakes to take and maintain all necessary measures, including appropriate technical and organizational measures, to preserve the security and confidentiality of the personal data of Visitors.
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In the context of the processing of personal data, Spinergie may involve subcontractors. In this case, Spinergie ensures that the subcontractor complies with its obligations under the GDPR and that it provides sufficient guarantees as to the implementation of appropriate technical and organizational security measures.
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ARTICLE 5 - RIGHTS OF VISITORS


Visitors have the following rights:

  1. A right of access: this right allows Visitors to obtain information regarding the processing
    of their personal data as well as a copy of such data;
  2. A right to rectification: this right allows Visitors to request that personal data they consider inaccurate or incomplete be amended accordingly;
  3. A right to object: it allows Visitors to object to the processing of their personal data for reasons related to their particular situation. The right to object is absolute with regard to the processing implemented for commercial prospecting purposes;
  4. A right to restrict processing: it allows Visitors to suspend the processing of personal data to which they are subject while retaining the processed data;
  5. A right to data portability: it allows Visitors to obtain that the personal data they have provided be retained or, where technically possible, transferred to a third party. The information requested by Visitors will be provided to them in electronic form, unless expressly requested otherwise;
  6. The right to define guidelines relating to the fate of their data after their death;
  7. A right to erasure: it allows Visitors to obtain the deletion of their personal data. With regard to the right to delete personal data of Visitors, this will not be applicable in cases where the processing is implemented to meet a legal obligation. Visitors may do so by sending an email to privacy@spinergie.com and type "My personal information: delete" in the email title.

Visitors are informed that they have the right to lodge, at any time, a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), if they consider that the processing subject to the Privacy Policy constitutes a violation of the applicable legislation on the protection of personal data.

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ARTICLE 6 - CHANGES TO THE PRIVACY POLICY

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Spinergie reserves the right to make, at any time, any changes to the Privacy Policy that it considers necessary and useful.
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In the event of a change to the Privacy Policy, Spinergie undertakes to make the Visitors accept the new Privacy Policy again when they access the Site again.

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ARTICLE 7 - COOKIES

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Spinergie collects information about the use of the Site by Visitors using cookies. Cookies are text files that may be deposited by Spinergie on the hard drive of the computer of Visitors or any other access device they use, when consulting the Site. Cookies help Spinergie remember Visitors when accessing the Site as well as various information about previous visits.

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Here is a list of these cookies:

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Functional cookies: These cookies allow Visitors to browse Spinergie’s services and use functions
such as connecting to secure areas.

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Non-functional cookies: These cookies make it possible to obtain attendance statistics useful for
optimizing its ergonomics and content. They also allow the user to view multimedia content of third-
party services directly on the site.

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Cookies used: