What is the purpose of this Privacy Policy?
We attach great importance to the protection and privacy of your personal data, which represents a guarantee of seriousness and trust.
When you use the website https://www.surfe.com/ (hereinafter the “Website”) we may collect personal data about you.
The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the “GDPR”).
When does this Policy apply? This Policy only applies to personal data that Surfe handles as a Controller (meaning where Surfe controls how and why your personal data is processed). This includes when you:
- Visit or interact with the surfe.com website, our branded social media pages, and other Sites which we operate;
- Register to our services, giving your explicit consent before signing up;
- Register for or participate in our webinars, events, programmes, marketing and promotional activities;
- Interact with us in person, such as when you visit our offices; and
- Inquire about or engage in commercial transactions with us.
Who is the data controller?
The data controller is GROWSTER (Surfe), SAS, registered with the Registry of Trade and Companies of Meaux under the number 882 838 295 and whose head office is located at 17 allée des Gassets 77700 Serris (hereinafter “Us” or “We”).
What personal data do we collect?
Personal data identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.
We may collect the following personal data:
- Identification data (e.g. surname, first name, professional email address and professional address, etc.);
- Data relating to your orders;
- Login data (e.g. logs, IP address);
- Internet data and cookies (information on how you use the Website);
- Data related to recordings from telephone calls with our customer care service (e.g. content of the calls, dates of the calls);
- Economic and financial data (e.g. bank account number, verification code, etc.);
- Any information you are willing to communicate
We inform you, when collecting your personal data, whether some of these data are mandatory or optional. Mandatory data are indicated with an asterisk.
On what legal basis, for what purposes and for how long do we keep your personal data?
Purposes
- To provide you with our services available on our Website
- To perform operations related to contracts, invoices and customer relationship management
- To create a database of customers and prospects
- To send newsletters, requests and direct marketing mailings
- To improve our services
- To answer to your information request and other inquiries, to schedule a demonstration
- To comply with our legal and regulatory obligations
- To elaborate analytics to measure our audience
- To process data subjects’ requests to exercise their rights
Legal basis
- Performance of a contract to which you are party
- Performance of a contract to which you are party
- Our legitimate interest in developing and promoting our business
- Our legitimate interest in winning customer loyalty and informing our customers of our latest news
- Our legitimate interest in improving our services
- Our legitimate interest in responding to your inquiries
- Legal and regulatory obligations
- Your consent
- Our legitimate interest in responding to your requests and keeping records of them
Data retention period
- Your personal data is retained for the duration of your account. In addition, personal data may be archived for probationary purposes for a period of 5 years.
- Personal data is retained for the duration of our business relationship. In addition, the data relating to your transactions are archived for probationary purposes for a period of 5 years.
- For our customers: their personal data are retained for the duration of our business relationship. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action). In addition, personal data may be archived for probationary purposes for a period of 5 years.
- Personal data is retained for a period of 3 years starting from the last contact with us (e.g. communication, action).
- Recording of telephone calls between you and our support team if consent: 6 months from the date of collection. Telephone call content analysis documents: 1 year from the date of collection.
- Personal data is retained during the processing of your request and is deleted once the request has been processed.
- Invoices are archived for a period of 10 years. In addition, the data relating to your transactions are archived for probationary purposes for a period of 5 years.
- The personal data is retained for 1 year.
- If we ask you for proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted. If you exercise your right to object to direct marketing: we keep this information for 3 years.
Who are the recipients of your personal data?
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
- Authorized third-party vendors and service providers. We may share your personal data with third-party vendors and service-providers that help us with specialized services:
- Billing, payment processing (identification, financial data)
- Customer service, email deployment (identification, usage, recording data)
- business analytics, marketing, advertising, performance monitoring (identification, cookies)
- Hosting, logging, and data processing (identification, login, internet data)
- Third party sales enablement integrations (identification data)
- Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
- Legal purposes. We may disclose information to respond to comply with our legal obligations.
How do we protect your personal data?
We implement all the technical and organizational measures required to guarantee the security of your data on a daily basis and, in particular, to struggle against risks of destruction, loss, alteration or unauthorized disclosure of your data.
In particular, our computer passwords require a high level of security, and all our devices are obviously protected by the latest antivirus and firewall software.
Are your personal data likely to be transferred outside the European Union?
Unless strictly necessary and on an exceptional basis, we never transfer your personal data outside the European Union and your personal data are always hosted on European territory. In addition, we do all that we can to use only service providers who host your personal data within the European Union.
In case our service providers transfer your personal data outside the European Union, we scrupulously ensure that they implement the appropriate guarantees to ensure the confidentiality and protection of your personal data with the use of following safeguards:
- Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR : in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or
- The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR : in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited to the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or under an approved certification mechanism; or
- The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR.
What rights do you have regarding your personal data?
You have the following rights with regard to your personal data:
- Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.
- Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.
- Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.
- Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.
- Right to erasure (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.
- Right to file a complaint to a competent supervisory authority (in France, the CNIL), under GDPR article 77, if you consider that the processing of your personal data constitutes a breach of applicable regulations.
- Right to define instructions related to the retention, deletion and communication of your personal data after your death.
- Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.
- Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
- Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.
You can exercise these rights by writing to us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.
What cookies do we use?
For more information on cookies management, please consult our Cookies Policy.
Contact information for data privacy matters
Contact email: dpo@surfe.com
Contact address: 17 allée des Gassets 77700 Serris
Modifications
We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted on any significant change of the privacy policy.
Entry into force: 05/03/2022
