Skello SAS
Privacy Policy

1. Definition and nature of personal data

• When you use the Skello software solution (hereinafter: the "Solution"), we may ask you to provide us with personal data about yourself.
• The term "personal data" refers to all data that can be used to identify an individual directly or indirectly, by aggregating several data, which includes your name, surname, e-mail address, postal address, telephone numbers, data relating to your transactions through the Solution, data entered by our customers (hereinafter : the "Clients") in the context of their use of the Solution, in particular your date and place of birth, nationality, gender, place of work, seniority, nature of the employment contract, job held, remuneration elements, social security number, as well as any other information that we may request from you and that you may choose to communicate to us about yourself.

2. Purpose of this Charter

• The purpose of this charter is to inform you about the means we use to collect and process your personal data, in strict compliance with your rights.
• In this respect, we would like to inform you that we comply, in the collection and processing of your personal data, with the current version of Law No. 78-17 of 6 January 1978, as amended, relating to information technology, files and freedoms.
• We draw your attention to the fact that we are only responsible for our use of your personal data, to the exclusion of any other collection and processing carried out directly by our Clients in the context of their use of the Solution. Clients are solely and exclusively responsible for complying with their legal and declaratory obligations in the context of the processing of your personal data that they carry out themselves, with their own means and for their own needs.

3. Identity of the person responsible for collecting and processing the data

• The company responsible for collecting and processing your personal data is Skello, SAS, registered in the Paris Trade and Companies Register under number 820 275 956, with its registered office at 112, Avenue de Paris - CS 60002 94306 Vincennes Cedex (hereinafter referred to as "we").

4. Collection and processing of personal data

• (i) Manage your access to and use of certain services accessible on the Solution,
• (ii) Carry out operations relating to the management of customers concerning contracts, orders, deliveries, invoices, loyalty programmes, follow-up of customer relations,
• (iii) Constitute a file of registered members, users, customers and prospects,
• (iv) To send newsletters, solicitations and promotional messages. In the event that you do not wish to do so, we give you the option of expressing your refusal in this respect when your data is collected;
• (v) To compile commercial and traffic statistics on our services,
• (vi) Organise competitions, lotteries and all promotional operations, excluding online gambling games subject to approval by the Online Gaming Regulatory Authority,
• (vii) Manage the management of people's opinions on products, services or content,
• (viii) To manage any outstanding payments and disputes relating to the use of our products and services,
• (ix) To meet our legal and regulatory obligations.
• Your national insurance numbers will be collected and processed on behalf of Customers for the sole purpose of managing your remuneration. In this regard, we act as a subcontractor for the processing of your national insurance numbers, with the Clients being solely responsible for their processing.
• When collecting your personal data, we inform you whether certain data must be provided or whether they are optional. We also inform you of the possible consequences of failing to reply.

5. Recipients of the data collected

• Only the staff of our company, the services in charge of control (auditor in particular) and our subcontractors will have access to your personal data.
• Clients guarantee that only their administrative and payroll staff will have access to your national insurance numbers.
• Your personal data may also be sent to public bodies, exclusively in order to meet our legal obligations, to judicial officers, to ministerial officers and to bodies responsible for debt collection.

6. Transfer of personal data

• Your personal data will not be transferred, rented or exchanged to third parties.

7. Duration of storage of personal data

• Concerning data relating to the management of customers and prospects:
• Your personal data will not be kept beyond the time strictly necessary to manage our commercial relationship with you. However, the data enabling us to establish proof of a right or a contract, or which must be kept in order to comply with a legal obligation, will be kept for the period provided for by the law in force.
• With regard to any prospecting operations aimed at customers, their data may be kept for a period of three years from the end of the commercial relationship.
• Personal data relating to a prospect, who is not a customer, may be kept for a period of three years from the date of their collection or the last contact from the prospect.
• At the end of this three-year period, we may contact you again to find out whether you wish to continue receiving commercial solicitations.
• Concerning identity documents: In the event of exercising the right of access or rectification, data relating to identity documents may be kept for the period provided for in Article 9 of the Code of Criminal Procedure, i.e. one year. In the event of exercising the right of opposition, these data may be archived for the limitation period provided for in Article 8 of the Code of Criminal Procedure, i.e. three years.
• Concerning the management of the lists of opposition to receive canvassing: The information allowing to take into account your right of opposition is preserved at least three years as from the exercise of the right of opposition.
• Concerning audience measurement statistics: The information stored in the users' terminal or any other element used to identify users and allowing their traceability or frequentation will not be kept beyond thirteen (13) months.

8. Security

• We inform you that we take all necessary precautions and appropriate organisational and technical measures to preserve the security, integrity and confidentiality of your personal data and, in particular, to prevent it from being distorted, damaged or accessed by unauthorised parties.

9. Cookies

• Cookies are text files, often encrypted, stored in your browser. They are created when a user's browser loads a particular website: the website sends information to the browser, which then creates a text file. Each time the user returns to the same site, the browser retrieves this file and sends it to the website's server.
• There are two types of cookies, which have different purposes: technical cookies and advertising cookies.
• Technical cookies are used throughout your browsing experience to facilitate your browsing and to perform certain functions. A technical cookie may, for example, be used to remember the answers entered in a form or the user's preferences regarding the language or layout of a website, where such options are available.
• Advertising cookies may be created not only by the website on which the user is browsing, but also by other websites displaying advertisements, announcements, widgets or other elements on the page displayed. These cookies can be used for targeted advertising, i.e. advertising based on the user's browsing habits.
• We use technical cookies. These are stored in your browser for a period of thirteen (13) months.
• We do not use advertising cookies. However, if we were to use them in the future, we would inform you in advance and you would be given the opportunity to deactivate these cookies.
• We use Google Analytics which is a statistical audience analysis tool that generates a cookie to measure the number of visits to the Solution, the number of pages viewed and visitor activity. Your IP address is also collected to determine the city from which you are connecting. The length of time this cookie is kept is mentioned in article 7 (v) of this charter
• We would like to remind you that you can refuse to accept cookies by configuring your browser. However, such a refusal could prevent the proper functioning of the Solution

10. Consent

• When you choose to provide your personal data, you expressly give your consent to the collection and processing of your personal data in accordance with the provisions of this charter and the legislation in force

11. Access to your personal data

• In accordance with the French law n° 78-17 of 6 January 1978 relating to information technology, files and freedoms, you have the right to obtain the communication and, if necessary, the rectification or deletion of data concerning you, through online access to your file. You may also contact:
  - e-mail address: contact@skello.io
  - postal address: 112, Avenue de Paris - CS 60002 94306 Vincennes Cedex

• You are reminded that any person may, for legitimate reasons, object to the processing of data concerning him or her.

12. Modifications

• We reserve the right, at our sole discretion, to change this policy in whole or in part at any time. Such changes will be effective upon publication of the new policy. Your use of the Solution following the entry into force of these modifications will constitute recognition and acceptance of the new policy. If you do not agree with the new policy, you should no longer access the Solution.

13. Entry into force

• This charter came into force on 21 March 2017.

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