privacy

Data Protection Policy (privacy policy)

What is the purpose of this document?

This document aims to succinctly present why and how we collect and process your personal data.

It will be updated if there are any changes in the processes of handling your data.

What data do we collect?

The personal data collected depends on your use of our website.

If you are a simple visitor (not registered)

During your visit to our website, your browser executes a script provided by the Google Analytics service. This script collects anonymized data to generate statistics about website traffic. These data are: your IP address and its geographical location, the time of connection, the duration of the connection if applicable, and the last page visited before arriving on the site. They are stored on Google servers in Ireland and the United States for a duration of 26 months.

Similarly, we use Hubspot services which generate a cookie when you connect. A cookie is a small file containing a string of characters that is sent to your computer when you visit our website. When you visit our site again, the cookie allows this site to recognize your browser. Cookies can store user preferences and other information. Cookies provide a convenient feature to save you time or tell the web server that you have returned to a specific page. Cookies set by the website owner (in this case, Softcorner) are called "first-party cookies." Cookies set by parties other than the website owner are called "third-party cookies." Third-party cookies allow third-party features or functionalities to be provided on or through the website (e.g., analytics). The parties that install these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites. The information is stored and managed on our service providers' servers. These data are stored in Germany (via Google) for a duration of 26 months. HubSpot, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. HubSpot is committed to complying with the applicable principles of the frameworks regarding the transfer of personal data received from the European Economic Area (EEA) based on each Privacy Shield framework.

If you create an account to register a company

When registering, you must complete several forms that are sent to Softcorner.

The first form concerns the individual who is registering. The collected data are as follows: first name, last name, phone number, position within the company, company name, email address.

The second form is about the company for which the registration is made. The collected data are as follows: company name, legal form, VAT number, contact email address, website address, headquarters postal address, registration number (SIREN/SIRET), registration proof (file to be provided via a form), statutes (file to be provided via a form), bank account details to receive sales revenue (IBAN and BIC).

The third form concerns the legal representative of the company for which the registration is made; the personal data related to this legal representative are as follows: first name, last name, email address, nationality, date of birth, postal address. A copy of an identity document (ID card or passport or, for British citizens, driver's license) is also requested.

The fourth form is about the company's partners for which the registration is made, who hold at least 25% of the capital. For each partner, the collected data are as follows: first name, last name, date of birth, city of birth, country of birth, nationality, postal address.

How do we collect your data?

We collect your data in two ways:

• During your visit to the website, certain connection data are automatically collected for statistical purposes. The collection of these data is carried out by executing JavaScript code and by recording cookies. You can refuse cookie recording and disable JavaScript execution to prevent data collection;
• When registering, you are asked to fill out several forms containing personal data that are necessary for us to provide our services. It is your responsibility to fill out these forms, and it is manually and directly from you that we collect these personal data.

Why do we use your data?

The data collected during your visit to our website allows us to obtain statistics on its traffic. This enables us to provide you with better services. These data are anonymized and not used for profiling purposes. The legal basis for processing is your consent (Article 6.1.a GDPR), which you can withdraw.

The data collected when you register on our site and become our client are necessary for the provision of the services we offer you. It is indeed essential that we have these data to execute the contract we conclude with you. The legal basis for processing is therefore the contract (Article 6.1.b GDPR).

Finally, clients' contact data may be used for informational and marketing purposes. You have the right, as a client, to object to the use of your data for these purposes. The legal basis for processing is legitimate interest (Article 6.1.f GDPR).

How do we use your data?

Connection data are collected during your visit to our website by Google Analytics. We then use these data to obtain anonymous statistics on the traffic of our website.

Similarly, we use the services of HubSpot, which keeps track of the websites and pages you visit on our website to determine which part of the website or platform is most popular or most used. These data are used to provide personalized content and promotions on the Softcorner website and platform to customers whose behavior indicates interest in a particular area. Third parties serve cookies through our website for advertising, analytics, and other purposes.

The other data, which are collected directly from you when you fill out the registration forms, are used to provide you with our services. This means that these data enable us to contact you, inform you, verify the regularity of the transactions you perform, and process payments.

Some data are subject to automated processing when they are necessary for service execution: for example, your bank details (IBAN and BIC) are automatically used to issue a transfer order to your account.

Other data are not subject to automated processing and are used when needed: for example, the contact phone number is only used if it is necessary to reach your company by phone.

Finally, some data may be used both automatically and "manually": for example, the contact email address can be used to send you a newsletter (automated processing) and to contact you if necessary (manual processing).

How do we store your data?

Some connection data are transmitted to our subcontractors and retained by them in a minimized or anonymous form. Some subcontractors store data outside the European Union, particularly in the United States.

The data collected through the registration forms are stored on our servers, located within the European Union and subject to European data protection law.

How long do we keep your data?

The statistical data collected during your visit to our website are retained for:

• Google Analytics: 26 months;
• Hubspot: 26 months;

The data collected during your registration, which are used for informational and marketing purposes, are retained for a maximum of 3 years after your last activity.

The data collected during your registration, which are necessary for the provision of our services, are retained for the duration of the contract, plus 5 years (general statute of limitations).

To whom do we transmit your data?

The connection data are transmitted to:

• Google, for the use of Google Analytics service, and stored in Ireland and the United States,
• Hubspot, for the use of Hubspot Marketing service, and stored in Germany and the United States,

The bank data collected during registration are transmitted to our payment subcontractor, MangoPay (https://www.mangopay.com/en/).

The other data collected during registration are used exclusively by our collaborators and are not transmitted to subcontractors.

Finally, all the data we collect may be transmitted to French administrative and judicial authorities.

What are your rights?

As a person concerned by personal data processing operations, you have certain rights under:

• The law n°78-17 of January 6, 1978, amended, relating to data processing, files, and freedoms ("Data Protection Act") and;
• The Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, relating to the protection of individuals with regard to the processing of personal data and to the free movement of such data, and repealing Directive 95/46/EC ("GDPR").

These rights are as follows:

The right of access allows you to obtain confirmation that your data are being processed and to know the list of data collected and processed and their uses.

The right to be informed of modifications and deletions of data.

The right of rectification allows you to correct erroneous data and complete incomplete data.

The right to restriction allows you, under certain conditions, to have the processing of your data limited to certain purposes or processes.

The right to object allows you, under certain conditions, to object to the processing of your data. You can exercise this right in particular to refuse any processing based on your consent or the legitimate interest of the data controller.

The right to erasure allows you, under certain conditions, to obtain the erasure of your personal data.

The right to data portability allows you, under certain conditions, to receive a copy of your data in a structured and machine-readable format.

The right not to be profiled allows you to object to data processing that aims to "profile" you or make automated decisions about you.

You can obtain more information and exercise these rights by contacting us (see below).

What use do we make of cookies?

Cookies (https://en.wikipedia.org/wiki/HTTP_cookie) are small files stored on your computer during your visit to our website. They allow certain information to be saved that will be reused during your future visits.

We make two distinct uses of cookies:

• Technical cookies save login information to prevent you, for example, from having to fill out the same forms at each visit. These cookies are not essential for using our website, but they improve its ergonomics;
• Statistical cookies provide statistical data on the traffic of our website. They are not essential for its use.

How can you act on cookies?

During your first visit to our website, a message appeared on your screen asking for your consent to the use of cookies. If you refused, we did not store any cookie on your computer. If you accepted, you can withdraw your consent at any time.

The cookies we store on your computer are not essential for using our website. You can, therefore, disable them if you wish.

The best way to disable cookies is to change your browser's preferences. As there are many competing browsers, we cannot provide a comprehensive guide, and we invite you to consult your browser's manual or online help.

The CNIL provides a guide for Google Chrome and Firefox: https://www.cnil.fr/en/cookies-tools-for-controlling-them.

Furthermore, some browsers allow extensions designed to give you greater control over the use of cookies. There are also extensions that allow you to disable JavaScript code execution on your browser.

How can you contact us?

For any information request and complaint, and to exercise your rights over your data, you can contact us:

• By email at: privacy@softcorner.eu
• By postal mail by writing to Softcorner SAS, 11 rue de Provence, 75009 Paris.

To exercise your rights over your data, we invite you to attach a copy of an identity document to your mail.

You can also contact the CNIL using the information on this page: https://www.cnil.fr/en/contacting-the-cnil-standard-and-phone-permanences