The purpose of this Privacy Policy is to provide you with all the information on the conditions under which Djaboo collects and processes your Personal Data. 
The Privacy Policy forms part of the T&Cs (where applicable to you) and the Software T&Cs and each term defined in those documents has the same meaning in the Privacy Policy. 
By accessing and using our websites and/or the Djaboo Software, you agree to read this Privacy Policy, which may be modified or updated at any time without notice. 
Any modification will be posted on the Site and we advise you to consult it regularly. 

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I. Purposes of the processing and nature of the Personal Data processed

1.1. We collect and process the Personal Data that you voluntarily provide to us in order to access and use the Software, to make requests to our teams (demonstrations, free trial, partnership requests, sponsorship or other) or to access to our online resources. 
We also collect and process data relating to the preferences of our Users and the traffic on our sites (such as the IP addresses of visitors to our Site). 
Finally, we also receive data about you from our partners, who collect it directly from you, or from public sources, as well as from our Customers who would like to sponsor you to take out a Subscription.  

‍More specifically, we process your Data to enable: 

• The creation of accounts on our websites (Djaboo Account, Trial Account, Account on our training platform or Djaboo Academy) in order to access the Software and use our services; 
• The provision of our various websites (the Site, Djaboo Academy, our training platform), and their various functionalities;
• The management of our commercial operations (competitions, organization of events, etc.);
• Sponsorship management;
• Downloading our online resources; 
• Management and monitoring of the commercial relationship (subscriptions, orders, payments, complaints and User Support);
• The improvement of our commercial service. In this context, we may need to record your telephone communications with our sales teams; 
• Monitoring of Customer satisfaction (surveys, monitoring of Customer opinions); 
• Management of technological and commercial partnerships; 
• Management of prospecting and requests for information (sending of commercial and marketing offers, newsletters, white papers, requests for online demonstrations, request for quotes, etc.); 
• Improving our services, by placing cookies on user terminals; 
• the management of the security of our sites and the Software and their improvement, within the framework of tests; 
• The management of requests to exercise the various rights of Users: the rights of access, rectification, erasure, portability, opposition, and limitation; 
• Litigation and litigation management.‍

To open an Account, you must provide us with at least the following personally identifiable information in order to use the Software: 

• Your name
• Your email address
• Your phone number. 

You can complete your profile with other Personal Data (address, other telephone number, date of birth, photo, name of your customers or prospects, etc.). 

We will never collect, or process, sensitive Personal Data within the meaning of the regulations, concerning, for example, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. , health, etc. 

‍1.2. We collect information relating to the contractual relationship we have with you: history, subscribed Modules, billing and payment elements, requests and incidents reported to the support department, etc.  

‍1.3. We also collect data about you during our telephone and/or video exchanges, which may be recorded for the purpose of improving our service. 

‍1.4. We collect through (or the channel) certain cookies placed automatically on your terminal, or other cookies subject to your express consent, certain Personal Data during your visits to our Site (djaboo.com) or during your use of the Software: for example, the date, time and duration of your visit to our Site, the path of your navigation, the type of your operating system, etc. 

A cookie is a small text file sent by the website consulted by the User in his Internet browser or on the device used. Its function is either to allow the site to operate, to facilitate navigation (memorizing technical choices, past activity), to improve the use of the site and the service and to better understand the User experience. 

The maximum lifetime of a cookie is 13 months.

‍Our Cookies Policy is available here. 

‍II. Legal bases of the Processing that we carry out 

We only use Personal Data in the cases provided for by the regulations in force, which are: 

• The execution of the service contract relating to your use of the Djaboo Software or pre-contractual measures; 
• Compliance with a legal obligation; 
• Your consent to use your data (with regard to cookies): You can withdraw this consent at any time, without this affecting the lawfulness of the processing based on the consent given prior to its withdrawal; 
• Our legitimate interest in carrying out prospecting or promotional operations concerning us or our subsidiaries (information concerning our products and services, our promotions or the events that we organize within the Djaboo group). 

‍III. Processing of Personal Data 

Djaboo collects and processes your Personal Data in a fair and lawful manner, and in compliance with the principles of European Regulation 2016/679 of April 27, 2016 (GDPR). 
This Privacy Policy describes Djaboo's obligations as the controller of your Personal Data within the meaning of the GDPR. 
Djaboo has appointed a Data Protection Officer (DPO or data protection delegate) who continuously monitors Djaboo's compliance with the principles and rules of the GDPR and whom you can contact at dpo@djaboo.com. 

‍The DPO is responsible in particular for: 

• To inform and advise the Data Controller on the application of the GDPR in the company; 
• To make Djaboo employees aware of the protection of Users' Personal Data; 
• To accompany them during the implementation of treatments; 
• To respond to requests related to the exercise of your rights, in accordance with Section VIII. 

‍IV. Retention of your Personal Data 

4.1.Safety  

Djaboo makes every effort to avoid the loss, misappropriation, intrusion, unauthorized disclosure, alteration or destruction of the Personal Data that you communicate to us. 

‍So : 

• The Data is stored on our own servers, which are hosted within the CLARANET France infrastructure. The control of the security of the servers and the updating of our Operating Software is carried out in real time. 
• All the information you transmit to us is encrypted [TLS V1.3 protocol]. 
• Djaboo employees are subject to an obligation of confidentiality and non-disclosure and have all signed a specific commitment relating to the protection of Personal Data. 

• Access to your Data is governed by a strict access control policy, reserved for authorized persons, under defined conditions. 

•  When we use service providers to process Personal Data, we have previously verified that these service providers guarantee an equivalent level of protection in terms of security. 

For more information, refer to our Security FAQ, searchable here. 

‍4.2. Duration 

Djaboo stores your Personal Data in accordance with the following legal and regulatory provisions: 

• We keep information relating to the management of the Customer account, orders, invoicing, payments 10 years after the end of the contract or the last contact from the inactive Customer. 

• We keep information relating to the creation and management of prospecting files for 3 years from the last contact from the prospect. 

• We keep the Data of inactive Customers for the purpose of sending information on our commercial and marketing offers, within 3 years after the end of the Commercial relationship. 

• We keep recordings of telephone calls between you and our sales teams for a period of six (6) months.

• We are required to retain the following Personal Data resulting from the creation, modification or deletion of User Content for 1 year:

– The connection identification; 

– The identification given by the terminal; 

– Types of protocols; 

- Nature of the operation ; 

– Date and time of the operation; 

– Identification used by the originator of the operation. 

‍When the retention of Data is no longer justified by the management of a Customer account, a legal obligation, commercial requirements, the recognition, exercise or defense of our legal rights, or when you ask us to do so by application of one of your rights (Section VIII), we securely delete your Data. 

‍4.3. Account Cancellation 

You can also request that your Account be deleted in accordance with the T&Cs. Your Data will then be deleted under the conditions of section 4.2. Above. 

‍V. Recipients of your Personal Data 

5.1. Access to your Data by employees of the Djaboo group 

Depending on the purposes defined in article I, employees of the Djaboo group's customer, support, administrative, accounting, legal, technical, marketing & sales departments are likely to have access to Personal Data. 

Access to your data is based on individual access authorizations, as specified in section 4.1. 

‍5.2. Transmission of Data to third parties

Djaboo may subcontract the following services in particular: 

• Hosting 
• Sending postal or digital mail 
• Customer relationship management 
• Maintenance 
• Technical developments 

‍In accordance with article 28 of the GDPR, access to your Data by our subcontractors is provided for and governed by a contract. This contract which binds us with our subcontractors lists the various regulatory obligations which weigh on him in terms of the protection of Personal Data. 

In addition, Djaboo may transmit Data to third parties (for example to commercial partners), in compliance with its regulatory obligations. 

‍5.3. Limitations on the use of your data as a user of a Gmail account 

You have the option of synchronizing your Gmail account with the Djaboo Software via a connection application. In order to enhance the security and privacy of your user data of a Gmail account, and notwithstanding any other provision of this Privacy Policy, the use of your data by the login application is subject to the following restrictions: 

• The sign-in application uses access to your Gmail User data only to perform the following actions: read, write, modify or control the content of Gmail messages (including attachments) and metadata, in order to provide a web-based email client allowing users to compose, send, read and process emails; 
•  The Connect app never transfers this Gmail data to third parties unless it is necessary to provide and improve the functionality of the Connect app, to comply with applicable laws, or as part of a merger, acquisition or sale of assets; 
• The sign-in app does not use this Gmail data to serve ads;
•  The application does not allow a human person to read this data, unless you expressly authorize it for certain specific emails, for security reasons (investigations on misuse), to comply with applicable regulations, or for an intervention on the application internally on the condition that the data have been previously aggregated and anonymized. 

‍The use by Djaboo and the transfer to any other application of the information received from Google accounts is carried out in accordance with the Google API Services User Data Policy, including Limited Use requirements.

‍VI. Transfer of Personal Data outside the European Union

We host your Personal Data in the European Union (4.1 article). 
However, we are required to transfer certain Personal Data to our subcontractors located outside the European Union. In this case, we ensure beforehand that the appropriate safeguards are provided to govern any transfer of Personal Data (such as the European Commission's Standard Contractual Clauses with additional security guarantees), in accordance with the GDPR and the recommendations of the European Data Protection Board. 
We may disclose your Personal Data to a third party if we are required to do so by law, regulation or court order, or if such disclosure is necessary for the purposes of an investigation, injunction or legal proceedings initiated by a national authority, on national territory or abroad.

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VII. Communications from Djaboo 

7.1. We may send you emails to the email address associated with your Account for reasons related to our commercial relationship, namely, technical or security reasons, administrative reasons relating to your Software Subscription, your participation in our events , or to inform you of the evolution of our service offer. 

‍7.2. We may also send you text messages or emails containing promotional and marketing offers, from which you can unsubscribe under the conditions set out in Section VIII. If you unsubscribe from these communications, you will still continue to receive the communications listed at section 7.1. 

‍VIII. Exercise of User rights 

In accordance with the French law "Informatique et Libertés" and European Regulation 2016/679 of April 27, 2016 (RGPD), in force on May 25, 2018, you have of the following rights regarding processing: 

• Right of access and rectification 
• Right of opposition 
• Right to erasure 
• Right to portability 
• Right to restriction of processing 

‍You can : 

• Modify your Personal Data directly from your Djaboo Account, if you have one, 
• Manage the receipt of promotional communications (not related to a transaction) by simply clicking on the “unsubscribe” link at the bottom of the emails sent by Djaboo, 
• Manage the receipt of SMS by sending a text message “STOP” or via the unsubscribe link provided for this purpose if necessary
• Oppose the recording of our telephone exchanges by indicating this to your interlocutor or by asking us to delete the recording, by email to the address: hello@djaboo.com. 

‍You can exercise these rights by writing to us at the following postal address: Djaboo – 50 2 Ter Rue du jardin MODELS, Asnières sur Seine, or by writing directly to our DPO at the address dpo@djaboo.com. 

Any request must be justified and accompanied by a copy of a valid identity document. 

You can file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), at the following address: 

CNIL- Complaints department, 3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07 – telephone: 01 53 73 22 22. Djaboo