Privacy Policy

Privacy Policy

Version from 23 July, 2019

This is an agreement between you and Smartcontact SAS , doing business as Graam and (hereinafter “we” or “us”). By using or accessing our website or mobile application by providing personal information to us or through this website or mobile application, you consent to the collect, use and disclosure of that information in accordance with this privacy policy. We undertake (i) to remain transparent in the management of your personal information and (ii) to respect the application to remain within the legal framework for protection of personal data.

This privacy policy (“Privacy Policy”) describes (i) the procedure by which we collect personal identifiable information pertaining participants and (ii) how and under what circumstances, we may use, disclose and transfer this personal data when:

  • You use graam.com website (“Website”) or Partners’ website
  • You use all available services from the Website or from the Partner’s website
  • You use the Software.

This Privacy Policy constitutes a regulation associated with Terms and Conditions.

The terms used in this Privacy Policy have the same meanings as defined into the Terms and Conditions to which this Privacy Policy is attached.

Under the event of opposition, between any of the provisions of this Privacy Policy and the General Terms and Conditions, the terms of the present ones shall prevail.

Smartcontact is the controller responsible for the processing of your personal data. 

ARTICLE 1 : DATA COLLECTION

WHAT INFORMATION DO WE COLLECT

You may give us some of your personal data by completing forms or by subscribing to our services. This include personal data you might provide when applying to our products or services, subscribing to our newsletter, as part of  our business relationship or when you contact us or send us feedback. This include:

  • Name and First name 
  • Email address and telephone number
  • Company’s name
  • Login and password
  • Purchase history
  • Every question you might send to us
  • Payment details.

For all payment information, we use the services of the provider, Stripe certified to PCI DSS 3.2, the main international security standard whose objectives are to ensure the confidentiality and integrity of cardholders data under the European Payment Services Directive (PSD, 2015/2366/CE).

We do not store card information, only the elements necessary to the processing of the transactions and their consequences (payment, guarantee, disputes…) are preserved: the name of the card holder associated with the card issuer, the first six and the last 4 digits of the card and the expiry date.

PERSONAL DATA AUTOMATICALLY COLLECTED WHEN USING OUR SERVICE

When using our services, we automatically record information related to (i) your use of our services, (ii) your interaction with our ads and mail, (iii) information on the software and devices feature you use, (iv) information from your browser.

We collect this information by:

  • Log files : when you use our services, some information are automatically registered in our log files such as (i) IP address, (ii) unique identifier, (iii) your operating system and its location, (iv) browser you use, (v) pages viewed.
  • Cookies : We may use tracking technologies such as invisible pixel, log file implemented on our Website that we store on your device (called “cookies”). These technologies allow us to recognize your device and to follow your interaction with our services, mails and ads.

The collection of personal data can be limited with the disable feature you can access directly from your browser. However, this opt out feature may reduce the performance and functionality of the website and its tools. For further information, please read our cookies policy.

ARTICLE 2 : HOW DO WE USE INFORMATION WE COLLECT?

Our primary purpose in collecting information about you is to provide you or connect you with products, services, information that match your interests and preferences. Your data allow us to propose promotional offers only when you authorized it.

We may also use your personal data in order to provide, improve and personalize our services regarding your preferences and to adapt our Website to the device that you use to facilitate your readings, to create use and traffic statistics.

We solely collect data necessary for the purposes of the processing above mentioned.

If we plan to use your personal data for other purposes we commit to prior inform you. You’ll have the right not to give your consent or to withdraw it.

ARTICLE 3 : WHO DO WE SHARE INFORMATION WITH ?

DATAS SHARED WITH SERVICE PROVIDERS

We use service providers for customer management and payment process. We only share with our providers information they need for their mission.

Our service provider must respect our Privacy Policy and commit not to use your data for their own commercial purposes.

DATAS SHARED WITH THIRD PARTIES

We share information with third parties only with your consent. We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we believe may aid a law enforcement investigation. In addition, we reserve the right to release all types of information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of information about you may protect the rights, property, or safety of us or another person.

PLUG-INS AND SOCIAL MEDIA

We use plugins or social media modules on some of our Websites. These include “like”, “share” buttons from third party social networks such as Facebook, Twitter, Google +, that you can find on our Websites. They allow you to like and share information from our Websites with friends on social networks. When you visit a page of our Websites (web or mobile) containing plug-ins or social media modules, a connection is established with the servers of social networks (Facebook, Twitter…) who are then informed that you have accessed the corresponding page of the website consulted, even if you do not have a Facebook or Twitter user account, and even if you are not connected to your Facebook or Twitter account. If you do not want social networks to publish your actions from plug-ins in your social media accounts, you must disconnect for your social networks before visiting our Websites.

WEB ANALYSIS

We use cookies or proprietary identifiers (such as Google Analytics cookie) and cookies or third party identifiers (such as Google Advertising Cookies) to make the advertising more personalized for Users. For more information, please review Google’s Privacy Policy and Terms of Use. We use these technologies for the purpose of target advertising based on the center of interests pertaining to various visits to our Websites and provide internal reports. Datas collected are anonymized or linked to pseudonym so it is not possible to identify you personally.

You can opt out of these Google Analytics advertising features via Ad Settings or providing a Google Deactivation Ad-Block on your browser.

ARTICLE 4 : WHERE DO WE STORE YOUR DATA

Your Personal Data is stored in our databases located in France as well as those of our service providers.

In some cases, for essentially technical reasons, some Data may be transferred outside the territory of the European Union. In this case, We are committed to ensuring the protection of your information by implementing protection systems in accordance with applicable legislation, including data processing agreements based on standard contractual clauses of the European Union.

ARTICLE 5 : HOW LONG WE WILL KEEP YOUR DATA

Your Personal Data is stored by Us and / or any subcontractor of our choice for the strict performance of our obligations, and are retained, unless you specify otherwise, for a maximum of 3 (three) years from the date of termination of the commercial relationship for the purposes of commercial prospecting and in order to comply with our legal obligations, and resolve any disputes that may arise in connection with our services.

The commercial relationship shall be considered as terminated at the date of termination of the agreement. At the end of these 3 (three) years, We commit ourselves to contact you again to determine whether you wish to continue to receive commercial solicitations. Beyond this maximum duration, the data will be archived and anonymized or destroyed.

To comply with our legal obligations, we may keep your personal data longer:

Client management 5 years from the end of our contractual relationship 
Electronic agreements  10 years if the amount of the agreement is higher than 120 euros 
Bills 10 years
Newsletter subscription Until the unsubscribe 

The archiving of your Personal Data is carried out on a reliable support in accordance with the legislation in force. In the event of a dispute between the Data thus stored and any document provided by you, it is expressly agreed as an evidentiary agreement that the Data collected by Us will take precedence and will only be admitted as evidence.

If you do not delete, the data collected via the implementation of cookies are retained for a maximum period of 13 (thirteen) months from the implementation of the cookie on your device.

ARTICLE 6 : YOUR RIGHTS

RIGHTS OF ACCESS, DELETION AND PORTABILITY

You have a general right of access and deletion, the right not to be the subject of an automated individual decision (including profiling) as well as a right to portability of the set of Personal Data about you, collected as you use our services.

You may exercise these rights at any time by going to your Personal Account or by contacting us at the following address: dpo@graam.com enclosing a copy of your identity card.

RIGHT OF OPPOSITION, MODIFICATION AND LIMITATION

You also have, the right to ask for rectification, limitation of your personal data and you may at any time object to the processing of your Personal Data or withdraw your consent by contacting us at the following address: dpo@graam.com .

ADVERTISING AND COOKIES

If you no longer wish to receive targeted advertising based on your interests or any form of tracking please refer to the cookies policy

ARTICLE 7 : EMAIL COMMUNICATION AND TEXT MARKETING

We may send you non-promotional emails, SMS and non-promotional email regarding your personal account at any time. If you give your consent during registration or via your personal account, we may also send you email communication and other promotional messages by email, post or SMS. You can object to the receipt of any promotional message by using the unsubscribe link provided or by sending an email to Graam Customer Service at the following address: contact@graam.com

ARTICLE 8 : UPDATE Of THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, in whole or in part, in the light of changes and developments in our internal practices and procedures.

We invite you to consult this Privacy Policy regularly, before any collection of your Data.