Personal data we process and where it is collected from

Identification data (name, date of birth, picture).

Sources of collection of data: we get the data from you when you as your company’s representative sign up for our Platform and Services. We may get the data also from public sources, including by automated means, or from a third party (e.g. when a third-party payment service provider confirms whether your payment was successful or not; when we receive your data from a third-party data intermediary) where relevant and necessary.

Contact data (work address, work phone number, work email address).

Sources of collection of data: we get the data from you when you as your company’s representative sign up for our Platform and Services. We may get the data also from public sources, including by automated means, or from a third party (e.g. when a third-party payment service provider confirms whether your payment was successful or not; when we receive your data from a third-party data intermediary) where relevant and necessary.

Employment data (name of the company you represent, your position within the company).

Sources of collection of data: we get the data from you when you as your company’s representative sign up for our Platform and Services. We may get the data also from public sources, including by automated means, or from a third party (e.g. when a third-party payment service provider confirms whether your payment was successful or not; when we receive your data from a third-party data intermediary) where relevant and necessary.

Communications data (emails, messages sent to us).

Sources of collection of data: we get the data from you when you as your company’s representative reach out to us.

Data related to the use of the Web-Entreprise Solutions and the Services (this includes the data which is generated as a result of visiting and using our Web Site and the Platform (depending on the particular cookie, the data may include, e.g. online identifiers, such as cookie identifiers, IP addresses, device identifiers)).

Sources of collection of data: we get the data when you visit and use our Web Site and the Platform.

The lawful bases for processing (purpose of the personal data collection) 

Performance of contract

We process the personal data on this legal ground if it is necessary for the fulfillment of the contract or for taking measures prior to concluding such a contract based on your request.

Purposes of processing	Categories of personal data
We process your personal data for the purpose of concluding and performing the Contract. This includes providing the Services (including Support Service, Client success Service, etc.) and contacting you otherwise as regards the Platform and the Services.	Identification data, contact data, employment data, communications data, data related to the use of the Web-Entreprise Solutions and the Services.

Legitimate interests

In some cases, we rely on our legitimate interests when processing your personal data. You have the right to ask for clarifications regarding the processing based on the legitimate interests by sending the request to us as detailed below. You also have the right to send the objection, if you find that processing of your data for the purposes provided below prejudice your rights.

Purposes of processing	Categories of personal data
Marketing of our Platform and Services to the Marketing Leads. Considering that Web-Entreprise Solutions we process data that is related to your economic activities and/or employment, we believe that your right to privacy does not override our legitimate interests. Should you wish that we would not process your personal data on that ground and for the aforementioned purposes, contact us at details below or opt-out by clicking on the opt-out link provided to you when we have reached out to you and provided the relevant link.	If you’re a Marketing Lead, we may process the following personal data: name, work email address, work phone number, location, IP address, employment data, communications data, data related to the use of the Web-Entreprise Solutions and the Services.
Safeguarding our rights (establishing, exercising, and defending legal claims). This also includes retention of Contracts after the termination or expiry.	Identification data, contact data, employment data, communications data, data related to the use of the Web-Entreprise Solutions and the Services.
General business administration, i.e. answering the requests, general customer service, information exchange with potential customers (including chat conversations).	Identification data, contact data, employment data, communications data, data related to the use of the Web-Entreprise Solutions and the Services.
Provision of core services of the Web Site and the Platform (the data is processed via technical cookies which are necessary to provide the services online).	Data related to the use of the Web-Entreprise Solutions and the Services.
If you publicly or via the Platform have given feedback concerning our Platform or Services, we may process this information and your personal data for quality assurance, customer success, bettering your experience and referral purposes, and share this within your organization.	Identification data (name), contact data, employment data.
Recording of communication between you and us (including video calls, telephone calls, and your requests for support call-backs) to check for mistakes, train staff, for quality assurance, and to prevent, detect, investigate, prosecute fraud.	Identification data (name), contact data, employment data, communications data, voice or video recording.
Development and improvement of services provided by us on the Web Site and the Platform. For this purpose, we process your Web Site and Platform visit data via analytical cookies. We retain and evaluate information on your recent visits to the Web Site and the Platform for analytics purposes so that we can improve the functionality of the Web Site and the Platform and make it more user-friendly.  For marketing purposes, we also collect and process the Web Site and the Platform visit data via cookies to provide you with personalized offers based on your browsing history.	Data related to the use of the Web-Entreprise Solutions and the Services.
Intra-group data transfers. Since we have several group companies that are interconnected, we may share your personal data among these companies.	Identification data, contact data, employment data, communications data, data related to the use of the Web-Entreprise Solutions and the Services.
Know-your-customer (KYC) checks to identify and verify your identity as a representative of the Client upon entry into the Contract.	Identification data and your identification document (passport, ID card), photo, video recording, contact data, employment data, communications data, personal data found in social media (e.g. LinkedIn, Facebook).

Consent

We may also process your personal data on the basis of your consent (e.g. for some marketing purposes). When processing is based on consent, you can withdraw consent by contacting us at the details below or opt-outing by clicking on the opt-out link provided to you when we have reached out to you and provided the relevant link. As for cookies, you always have the right to withdraw the consent by changing your preferences via our Website. Withdrawal of the consent does not affect the legality of the processing of your personal data prior to withdrawal.

Purposes of processing	Categories of personal data
Direct marketing	Identification data (name), contact data, employment data.
If you have not publicly given feedback concerning our Platform or Services, we may process this information and your personal data based on your prior consent for quality assurance, customer success, bettering your experience and referral purposes, and share this within your organization.	Feedback concerning Platform or Services, identification data (name), employment data.

Legal obligation

We process personal data on this legal ground if the legal obligation for processing arises from the law.

Purposes of processing	Categories of personal data
Bookkeeping (including storage of accounting source documents).	Identification data, contact data, employment data.
Notification of and response to the information requests of public authorities and government institutions.	Identification data, contact data, employment data, communications data, data related to the use of the Web-Entreprise Solutions and the Services.

Recipients of personal data 

We share personal data for the purposes set out in this Privacy Policy and with the following categories of recipients:

• Web-Entreprise Solutions. We may share your personal data among the companies within the Web-Entreprise Solutions of companies.
• Your organization and contacts. We may share your personal data with your organization (the Client) and others with whom you have a relationship in order to fulfill or perform a contract or other legal obligation, including with our Client that arranges access to our Platform and Services for you and pays us in connection with your access. We may also share your personal data with your contacts if you are in the same organization or to facilitate the exchange of information between you and the contact(s).
• Business partners. We may share your personal data with our business partners to jointly offer, provide, deliver, analyze, administer, improve, and personalize the Platform or Services or host events. We may also pass certain requests from you or your organization to these business providers.
• Third-party service providers. We may share your personal data with our third-party service providers (e.g. software providers with whom your site has an Integration) to perform tasks on our behalf and to assist us in offering, providing, delivering, analyzing, administering, improving, and personalizing our Services. For example, service providers who assist us in performing, delivering or enhancing the Platform or Services related to our delivery and operation of our Platform and Services, who provide support on our behalf, who provide application or software development and quality assurance, who provide tracking and reporting functions, research on user demographics, interests, and behavior, and other products or services. These third-party service providers may also collect personal data about or from you in performing their services and/or functions on our Platform and Services. We may also pass certain requests from you or your organization to these third-party service providers.
• Advertisers. We may share your personal data with advertisers, advertising exchanges, and marketing agencies that we engage for advertising services, to deliver advertising on our Platform and Services, and to assist us in advertising our brand and products and services. Those advertising services may also target advertisements on third-party websites based on cookies or other information indicating previous interaction with us and/or our Services.
• In the event of merger, sale, or change of control of Web-Entreprise Solutions. We may transfer this Privacy Policy and your personal data to a third-party entity that acquires or is merged with us as part of a merger, acquisition, sale, or other change of control.

Other disclosures. We may disclose your personal data to third parties if we reasonably believe that disclosure of such data is helpful or reasonably necessary to comply with any applicable law or regulation, to comply with or respond to a legal process or law enforcement or governmental request, to enforce our terms and conditions or other rights (including investigations of potential violations of our rights), to detect, prevent, or address fraud or security issues, or to protect against harm to the rights, property, or safety of Web-Entreprise Solutions, our users, or the public.

Transferring personal data outside the EU

If you are located in the EU, then please note that we or our data processors may transfer (including store) your personal data outside the EU, e.g. the US. If you are located in Australia and Oceania or Asia-Pacific, then we may store your personal data also in Australia. If you are located in Canada or the United States, we may store your personal data in Canada, the United States, or in the EU.

However, we only transfer and store your personal data outside the EU where we have a lawful basis to do so, including to a recipient who is: (i) in a country which provides an adequate level of protection for personal data; or (ii) under appropriate safeguards which cover the EU requirements for the transfer of personal data outside the EU.

Should you require more detailed information as regards transferring your personal data outside the EU (e.g. the names of the recipients and the safeguards for any such transfer), please contact us on the contact details below.