Privacy Policy

The protection of your personal data (the “Data”) is important to DIFFLY (“we”), and this Privacy Policy enables us to inform you about the processing carried out on your Data, in compliance with all European and French regulations on the protection of personal data and privacy, and in particular the General Data Protection Regulation 2016/679 of 27 April 2016 (the “GDPR”) and French Act No. 78-17 of 6 January 1978 on information technology, data files and civil liberties, as amended.

DATA PROCESSED BY DIFFLY AS A DATA CONTROLLER

1. Processing of Data carried out through the DIFFLY website
2. Processing of the Data of DIFFLY’s suppliers, customers and prospects for commercial management purposes
3. Processing of our customers’ Data for the provision of the service via the Google API
4. Processing of the Data collected when using the DIFFLY Platform for the purposes of improving our services and producing statistics
5. Data retention period
6. What are your rights?

DATA PROCESSED BY DIFFLY AS A DATA PROCESSOR

Processing of Data carried out through the DIFFLY Platform

CONTACT

DATA PROCESSED BY DIFFLY AS A DATA CONTROLLER

1. Processing of Data carried out through the DIFFLY website

DIFFLY, publisher of the website https://www.diffly.co/ (the “Site”), may process the Data of visitors to the Site (or “you”) when they browse the Site. This paragraph describes the processing of Data carried out by DIFFLY as a data controller in this context.

Why do we process your Data?

The Data of visitors to the Site is collected and used for the following purposes:

• To respond to your demo and contact requests and to your queries;
• To host your Data;
• To improve our services and the features of our tools;
• To ensure the security of the Site;
• To safeguard the exercise of your rights and the defence of our rights.

We also use cookies. You will find all the information on this subject in our Cookie Policy.

We process your Data with your consent (for cookies), which you may withdraw at any time (i); or because it is necessary to respond to your requests, in particular pre-contractual ones (ii); or to comply with a legal obligation to which we are subject (iii) and on the basis of our legitimate interests, to ensure the security and proper functioning of the Site (iv).

What categories of Data are processed?

Only the Data strictly necessary is processed by DIFFLY in order to achieve the purposes set out above. The Data processed is the Data you provide to us when browsing the Site or when you contact us, such as identification data and contact data, including the email address, as well as usage and connection data. You are invited to update your Data whenever necessary. The Data marked as mandatory in our forms is necessary to handle your request: failing this, we will not be able to respond to it. The provision of the other Data is optional.

Who are the recipients of the Data?

Your Data may be transmitted to our technical service providers for the use of the features of the Site. Your Data may be transferred outside the European Union, to countries recognised as providing an adequate level of protection by a decision of the European Commission or, failing that, on the basis of standard contractual clauses adopted by the European Commission, supplemented where appropriate by additional measures. You may obtain a copy of these safeguards by writing to us at the address set out in the “Contact” section.

Please note that your Data may be transmitted to third parties legally entitled to access it upon specific request, in certain cases provided for by law: judicial authority, administrative authority, etc. Your Data may also be disclosed to third parties where this is necessary to protect and/or defend our rights, or to enforce these provisions.

2. Processing of the Data of DIFFLY’s suppliers, customers and prospects for commercial management purposes

We carry out processing of the personal data of our suppliers, customers and prospects, as a data controller, in the context of our commercial management activities.

Why do we process your Data?

The purpose of this processing of personal data is to enable us to:

• manage the contracts between us and our customers and suppliers (management of the performance of the service, of payment and of invoicing);
• monitor the relationship with customers, prospects and suppliers in order to carry out satisfaction surveys and to handle complaints and after-sales service;
• keep the general accounts and any subsidiary accounts;
• carry out direct marketing activities and in particular communications about our offers;
• manage individuals’ reviews of the services we offer;
• safeguard the exercise of your rights and the defence of our rights.

We process your Data because it is necessary to provide you with our services in accordance with the contract between us and to respond to your requests (i); to comply with a legal obligation to which we are subject, in particular the keeping of accounts (ii); and on the basis of our legitimate interests, in particular to carry out electronic direct marketing in the context of our B2B relationships and satisfaction surveys in order to improve our service (iii). If you no longer wish to receive our communications, you may click on the unsubscribe link provided for that purpose in the email.

What categories of Data are processed?

In this context, DIFFLY will collect only the Data strictly necessary to achieve these purposes. The Data collected falls within the categories of identification data (civil status, identity, email address, etc.) and data relating to professional life, as well as data relating to our commercial relationship. The provision of the Data necessary for entering into and performing the contract and for complying with our legal obligations is mandatory: failing this, we will not be able to enter into or perform that contract.

Who are the recipients of the Data?

Your Data may be transmitted to our technical and support service providers (CRM, accountant, mailing, IT provider). Your Data may be transferred outside the European Union, to countries recognised as providing an adequate level of protection by a decision of the European Commission or, failing that, on the basis of standard contractual clauses adopted by the European Commission, supplemented where appropriate by additional measures. You may obtain a copy of these safeguards by writing to us at the address set out in the “Contact” section.

Please note: your Data may be transmitted to third parties legally entitled to access it upon specific request, in certain cases provided for by law: judicial authority, administrative authority, etc. Your Data may also be disclosed to third parties where this is necessary to protect and/or defend our rights, or to enforce these provisions.

3. Processing of our customers’ Data for the provision of the service via the Google API

We carry out processing of the personal data of our customers in order to offer them the possibility of connecting DIFFLY to their Google account and to allow feedback emails to be sent to their prospects directly from their mailbox.

We process this Data on the basis of your consent, obtained when you grant access authorisation from your Google account, in order to connect that account to the DIFFLY Platform and to allow you to use this service in accordance with our general terms and conditions of sale. You may withdraw your consent at any time by revoking that authorisation in your Google account settings or by contacting us, without affecting the lawfulness of the processing carried out previously.

What categories of Data are processed?

DIFFLY will process only the Data strictly necessary relating to your Google account: surname, first name, email address. No other data will be collected and DIFFLY will not have access to the data stored in your mailbox.

Who are the recipients of the Data?

Your Data is transmitted only to those persons who strictly need to know it. It may be extracted and made accessible to our technical service providers, and in particular to our hosting provider AWS (Amazon Web Services - https://aws.amazon.com/fr/privacy/).

How is the security of the Data ensured?

We use our best efforts to ensure the security of your Data. Appropriate technical and operational measures in line with the state of the art are therefore implemented. In particular, the Data is encrypted in order to prevent it from being compromised.

4. Processing of the Data collected when using the DIFFLY Platform for the purposes of improving our services and producing statistics

We may re-use the Data of users of the DIFFLY Platform for the purposes of improving and monitoring the performance of our services, as well as to produce statistics on market trends, on the basis of our legitimate interest.

What categories of Data are processed?

DIFFLY processes only the Data strictly necessary for these purposes, and in particular technical data on the use of the service, the content of communications with DIFFLY and comments on DIFFLY’s services.

Any Data processed through the DIFFLY Platform may be re-used, in anonymised form, for strictly statistical purposes.

Who are the recipients of the Data?

Your Data may be transmitted to our technical service providers. Your Data may be transferred outside the European Union, to countries recognised as providing an adequate level of protection by a decision of the European Commission or, failing that, on the basis of standard contractual clauses adopted by the European Commission, supplemented where appropriate by additional measures. You may obtain a copy of these safeguards by writing to us at the address set out in the “Contact” section.

5. Data retention period

We retain your Data for the duration of our commercial relationship plus 5 years if you are a customer or a supplier, and for 3 years from the last contact with you, or until the withdrawal of your consent or your objection in respect of the direct marketing operations addressed to you. Accounting data is retained for 10 years.

We also retain your connection Data for a period of 6 months.

Data used for service improvement purposes is retained for the period strictly necessary for that purpose and for a maximum of one year; it is never retained beyond the retention period provided for in the contract with the Customer.

In addition, the Data necessary for the defence of our rights is retained for a period of 5 years after the end of the commercial relationship, in accordance with the applicable legislation or for the applicable limitation period.

However, the Data may be retained for longer where a longer retention period is authorised or required under a legal, contractual, tax or social security obligation.

6. What are your rights?

In accordance with the applicable regulations, and in particular Articles 15 to 22 of the GDPR, you have the following rights in respect of the processing of your Data, within the limits provided by law:

• Right of access: to obtain information about your Data and a copy of your Data;
• Right to information: to obtain information about the conditions of processing (recipients, purposes, categories of data, etc.);
• Right to rectification: to correct or update your Data where it is inaccurate or incomplete;
• Right to object: to object to processing being carried out on grounds relating to your particular situation, or to withdraw your consent for processing based on that legal basis;
• Right to restriction: to request that all or part of the Data temporarily not be processed, without requesting its erasure;
• Right to erasure: to request the deletion of your Data;
• Right to portability: to obtain your Data in a structured, machine-readable format and to be able to transmit it easily to a third party;
• Right to give specific instructions regarding the processing of your Data after your death.

You may exercise your rights via the contact address (below) in respect of the processing of Data for which DIFFLY is the data controller. In the event of doubt as to your identity, proof of identity may be requested from you.

Any abusive or unfounded request under applicable laws and regulations may be rejected.

We undertake to respond to your requests to exercise your rights as soon as possible and, in any event, within the time limits provided by law.

If, after contacting us, you consider that we have not responded to your request, you may lodge a complaint with the CNIL.

DATA PROCESSED BY DIFFLY AS A DATA PROCESSOR

Processing of Data carried out through the DIFFLY Platform

DIFFLY is the publisher of a platform offering its business customers a service for assessing their performance, in terms of the ability of their sales representatives to close a deal, and for providing tailored advice in order to improve that performance.

As a staff member, customer or prospect of the companies using the DIFFLY Platform, your Data is processed in order to allow:

• Where you are a user: your identification on the DIFFLY Platform and the collection of data on your performance;
• Where you are a business contact (customer or prospect): the assessment of the performance of DIFFLY’s corporate customer, in particular through qualitative interviews, surveys and the collection of CRM data from you.

In this context, DIFFLY acts as a data processor on behalf of its customer, which acts as the data controller.

All the information required under the regulations on the protection of personal data is provided to you directly by DIFFLY’s customer.

Accordingly, we invite you to contact the latter for any question relating to the processing of your Data on the DIFFLY Platform; DIFFLY is not authorised to respond directly and will forward your request to the relevant data controller as soon as possible.

DIFFLY, as a data processor, complies with all French and European regulations on the protection of personal data and privacy, and in particular the General Data Protection Regulation 2016/679 of 27 April 2016 (the “GDPR”) and French Act No. 78-17 of 6 January 1978 on information technology, data files and civil liberties, as amended (the “French Data Protection Act”).

CONTACT

To contact us about the processing of your Data that we carry out as a data controller, you may send us an email at: contact@diffly.co

DIFFLY, a société par actions simplifiée with a share capital of EUR 26,000.00 - registered in Nanterre under number: RCS 978 126 050 - Registered office: 1 B RUE BAUDIN, 92300 LEVALLOIS-PERRET.

This Privacy Policy is liable to change; we invite you to consult it regularly.

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