This Privacy Policy has been updated on 24 June 2021.
As a result of your use of the software solution, ViaSay (hereinafter the “Solution“), we may require you to provide us with your personal data so that you have the possibility to use the services provided through the Website.
The word “personal data” means any data that enables a person to be identified, which includes your first name, family name, email address, telephone numbers, data relating to your use of the Solution as well as any other information about you that you choose to provide us with.
The purpose of this privacy policy is to inform you of the means that we use to collect and process your personal data with the strictest respect for your rights.
In this regard, we inform you that we collect and process your personal data in compliance with French law N° 78-17 dated 6 January 1978 on Information Technology, Data Files and Civil Liberties (hereinafter referred to as the “French Data Protection Act”) as well as the regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 as from its entry into force, namely 25 May 2018 (hereinafter referred to as the “GDPR”).
The entity responsible for collecting and processing your personal data is the company VIASAY, a French Simplified Joint Stock Company (“Société par Actions Simplifiée”) registered with the Paris Trade and Companies Register under the number 984 651 117, whose head office is located at 152 boulevard Pereire 75017 Paris, France (hereinafter referred to as “us” or “we“).
The legal basis for our processing of your personal data is the following:
Your personal data is processed to meet one or several of the following requirements:
We inform you when collecting your personal data, whether some parts of the data are mandatory or optional. Mandatory data is necessary for the provision of our Services. You are free to provide or withhold optional data. We will also inform you of the possible consequence of failure to reply.
The only persons who have the right to access your personal data are our personnel, the entities responsible for audits (including external auditors), and our subcontractors;
We may also give government agencies access to your personal data for the sole purposes of meeting legal requirements or to representatives of the law, ministerial officers, and organizations responsible for the collection of debts.
Your personal data will not be exchanged with, transferred to, or rented to any third party.
Data concerning current and potential customer management:
Your personal data are kept for the period strictly necessary for the management of our business relationship with you.
Regarding possible prospecting operations concerning you, your data may be stored for a period of 3 (three) years from the end of the business relationship.
Data establishing the proof of a right or contract, which must be retained for the fulfillment of a legal obligation, will be archived for a period of 5 (five) from the. end of the business relationship.
Personal data relating to a potential customers may be stored for a period of 3 (three) years from their collection or the last contact from the prospect.
At the end of this 3 (three) year period, we can contact you again to find out if you wish to continue receiving commercial solicitations.
Identity documents:
When exercising your right of access or correction, data relating to identity documents may be stored for the time limit provided for in Article 9 of the French Criminal Procedure Code, namely 1 (one) year. When exercising your right to object, this data may be archived for 3 (three) years.
Management of opt-out systems:
All information regarding your right to opt-out shall be stored for at least 3 (three) years after exercising this right.
Cookies:
The storage term for the cookies set forth in the article “Cookies” is 13 (thirteen) months.
We inform you that we take all necessary precautions, as well as all appropriate organizational and technical measures, to maintain the security, integrity, and confidentiality of your personal data, including to prevent it being distorted or damaged and denying any unauthorized third-party access to it.
We inform you that your personal data is stored, for the term set forth above, on the servers of the company, Amazon Web Service, located in Frankfurt, Germany in the European Union.
Cookies are small lines of encrypted text that are stored on your web browser. They are created when a user’s browser loads a website. The website sends information to the browser which creates a text file. Each time the user is visiting a website, the browser retrieves this file and sends it to the website’s server.
There are various types of cookies which have different purposes:
In compliance with the French Data Protection Act and GDPR, you have the right to access, modify, and delete any of your personal information. You can exercise this right and gain access to the information concerning you online or by contacting us at:
Persons the data of which are processed on the basis of our legitimate interest, as specified in article “Collecting personal data”, are reminded that they have the possibility to object to the processing of their personal data at any time. We may, however, carry on with this processing if there are legitimate reasons that take precedent your rights and freedoms or if it is required in order to establish, exercise, or defend our rights before courts.
You have the right to define instructions with regard to the storage, deletion, and communication of your personal data after your death.
These instructions may be general directions which are focused on all personal data concerning you. In such a case, they must be registered with a trusted digital third party who is certified by the French data protection authority (CNIL).
These instructions may also be specific to the data processed by our company. You are then required to provide these instructions to us at:
By providing us with these instructions, you hereby expressly consent that they be stored, transmitted, and carried out on the terms and conditions set forth herein.
You have the right to appoint in your instructions a person in charge of their execution. After your death, this person shall be entitled to take ownership of these instructions and to request their implementation. Failing such an appointment, your heirs shall be entitled to take ownership of these instructions and to request to us their implementation.
You may modify or revoke your instructions at any time by writing to the above mentioned contact addresses.
You have a right to portability of the personal data that you have entrusted to us, understood as the data you have actively and deliberately declared when accessing and using our Services. You are reminded that the portability right does not apply to data that was processed on another basis than consent or the execution of a contract between us.
This right may be exercised free of charge at any time, including when closing your account on the Website, so that you may recover and store your personal data.
In this context, we shall provide your personal data, by any appropriate means, in an open standard, current, and machine-readable format in compliance with the latest developments.
You are informed that you have the right to submit a complaint before a supervisory authority which is competent in the member State in which your ordinary residence, your place of work, or the place in which the infringement of your rights was committed (in France, the French Data Protection Authority – CNIL) if you consider that the personal data processing under this Privacy Policy is in violation of the applicable regulations.
This complaint may be exercised without prejudice of other legal action before any administrative or judicial court. You also have a right to effective administrative and judicial redress if you consider that the personal data processing under this Privacy Policy is a violation of the applicable regulations.
You have the right to restrict your personal data’s processing where one of the following applies:
We reserve the right, at our sole discretion, to modify this Privacy Policy, in whole or in part. Any changes will be effective from the time of publication of the new Privacy Policy. Your use of the Website after the changes have been implemented implicitly expresses your acknowledgement and acceptance of the new Privacy Policy. Otherwise, if the new Privacy Policy does not suit you, you must no longer use the Services.
This Privacy Policy has been updated on 24 June 2021.
