Privacy Policy

This Privacy Policy (the “Policy”) rules the processing of Personal Data by Sociabble (“Sociabble”, or “we”), publisher of the Sociabble platform available at Sociabble (the “Platform”) and of the official Sociabble application available in Playstore and Appstore.

Sociabble engages in with respect to the privacy of the users authorized by Customer to use and have access to the Services (the “User”, or “you”).

In addition to this Policy, Sociabble may provide Users with additional policies and terms that are tailored to regulate the use of the Platform. Sociabble urges the Users to review any such additional policies and terms, and to contact Customer, should they have any questions.
Please read Sociabble’s terms of use carefully for information relating to the use by any Customer’ Users.

Sociabble reserves the right to amend this Policy at any time and without notice. When we update this Policy, we will revise the “Effective date” above and post the new Policy online, make it available through the Platform. We encourage the Users to regularly check back on this page.

1. Definitions

   “Customer”: means the company which contractualizes with Sociabble in order to get access to the Services.
   “Personal Data”: means any information relating to an identified or identifiable natural person processed by Sociabble.
   “Platform”: means the online software created and developed by Sociabble and updated by Sociabble from to time to time.
   “Services”: means, together, the application services and other services provided by Sociabble to Customer.
   “Sub-Processor”: means a third party subcontractor engaged by Sociabble which, as part of the subcontractor’s role of delivering the Services, processes Personal Data

2. About your Personal Data

   What are the collected Personal Data?

   The Personal Data collected on the Platform are the followings:

   • First name / Last name
   • Mobile phone number
   • Professional email address
   • Professional title
   • Profile picture
   • Short biography
   • Temporary authorization tokens for the sharing on social media.

   In case of authorization to connect to social media account, the following complementary informations (hereinafter “Complementary Information”) can be collected:

   • Shared posts on social media
   • Social media whereupon posts are shared
   • Date and time of action

   How are the Personal Data collected?

   • On your Platform: The collect of your Personal Data as a User takes place when you sign up to the Platform. Meanwhile the Complementary Information can be added and collected all along your use of the Platform.
   • On the mobile apps: We may provide features on your mobile device(s) that rely on the use of additional information or that require access to your mobile device(s). The use of these additional features will enhance your user experience but is not required for a regular use of the Services. For example, we may allow you to upload photos to create content or to complete your profile. However, allowing us an access to your photos does not grant us an unlimited access, we will only access these specific information upon your prior authorization. Hence, we will not access your photos or your storage without first gaining your explicit permission and we will never scan or import your photo library or camera roll. If you give us permission to access storage, we will only use images that you specifically choose to share with us. You may use our application to select the photo(s) you choose to share.

3. Use of the Personal Data

   Purposes and legality of the Personal Data processing:

   Purposes of the Personal Data Processing	Legal basis of the processing
   Creation of the User’ profile	Legitimate interest
   Monitoring of the actions and the behaviour of the Users within the use of the Services	Legitimate interest
   Creation of the User experience (such as shared posts, gamification)	Legitimate interest
   Aggregation of the data in the statistical format in relation to the global activity of the Platform	Legitimate interest

   Data transfer to third-countries:

   Sociabble data centers are located in the European Economic Area (the“EEA”). However, in order to provide the Services, Sociabble may processes and transfers some Personal Data with partners, affiliates and other sub-processors located outside the EEA and namely in the United States of America.
   Where doing so, the sub-processors are carefully evaluated to comply with security and confidentiality certifications (ISO 27001, ISO 27018, SOC2) as well as with the General Data Protection Regulation (the “GDPR”) and especially with EU Modal Standard Contractual Clauses.

   Retention periods:

   Your Personal Data are stored by Sociabble for the duration of Customer’s contract and for an additional thirty (30) days for reversibility requests. At the expiration or termination of the contract, and/or at the deletion of a User’ account, Personal Data are anonymized and connections to social media accounts are deleted. After the thirty (30) day period, the data are cleared and can not be retrieve anymore.

4. Cookies and similar technologies

   We do not collect personally-identifiable information with our cookies, but we do want to acknowledge the use of cookie technology on our Platform.

   Cookies:

   Below are the cookies used on the Platform in order to improve and secure your experience as a User:
   Session cookies that expires at the end of the User session when the User closes the browser or the tab and that last for one (1) year lifespan
   Technical cookies that are necessary for the proper functioning of the application which have a 30 days lifespan (i.e. authentication)

   Web Beacon:

   A web beacon is a tracer used on a webpage or an email notification in order to verify the frequency of visit of a webpage or the reception and opening of the sent emails. The data collected by the web beacon are anonymized.

5. Your rights on your Personal Data

   The GDPR grants you certain rights on your Personal Data such as those listed below. You can exercise these rights at any time by emailing us at the following address: privacy@sociabble.com. For any request, please disclose your identity and provide us with reasonable proof of it.

   Right to access:

   You can check your Personal Data at anytime within the Platform via the “my account” tab which leads to your personal space.

   Right to rectify:

   You can modify, at any time, your Personal Data, and your preferences, including your first and last name.

   Right to object:

   You can, at anytime, refuse Sociabble to access to one or several of social media accounts you decided to connect to the Platform. This is an easy process that can be performed directly on the Platform and/or via the settings of any social media account, for the mobile app namely.

   Right of erasure:

   You can request the deletion of your Platform account at any time via your administrator account and/or via the support.

6. Security

   Sociabble engages in with respect to the privacy and the security of User’s Personal Data. Sociabble uses reasonable measures to transfer your Personal Data to the Services and to protect it against the loss, abuse and access to the use, disclosure, modification or destruction.

7. Other websites

   The Services may contain links or references to other leading websites, such as third-parties social media account, to which this Policy does not apply.
   These websites use Personal Data such as posts or photos which you intentionally shared from the Platform to these third-parties’ social medias (eg: Twitter, Linkedin). If you accept to connect with these third-parties websites, you accept to be submitted to their respective terms and privacy policies. For example, if you choose to connect your YouTube account to the Services, this connection uses YouTube’s API services, and the Google Privacy Policy which can be reach at https://www.google.com/policies/privacy will apply to you.
   Sociabble may, upon request, provide you with a detailed documentation on the use of Personal Data by third-parties’ websites.

8. Contact Us

   For the exercise of your rights or any request of information regarding the processing by Sociabble of your Personal Data, you may contact us at the following address: Sociabble SAS, 22 Rue Chapon 75003 Paris, or by email at privacy@sociabble.com.
   If Sociabble’s answer does not satisfy your request, or without any response from us, and if you are located within the EEA, you can submit your request to the competent authority – la Commission Nationale Informatique et Liberté (CNIL) in France which you can contact here : Contact the CNIL | CNIL.