Privacy Policy
Wisepops (or “us”, or “we”) offers tools to build website popups, exit popups and onsite notifications.
The protection of personal data is of paramount importance to us. This Privacy Policy sets out the way we process your Personal Data in our capacity of Controller as well as the rights you have in respect of such data pursuant to the Personal Data Regulations.
1. Definitions
Under this Privacy Policy, the terms below are defined as follows:
-Personal Data Regulations - All applicable laws and regulations related to the protection of personal data, particularly Regulation (EU) 2016/679 of April 27th, 2016 (the “General Data Protection Regulation”, also referred to as the “GDPR”) and Law No. 78/17 of January 6th, 1978 (“loi Informatique et Libertés”) as modified.
-Personal Data - According to Article 4(1) of the GDPR, any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
-Processing - According to Article 4(2) of the GDPR, any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
-Controller - According to Article 4(7) of the GDPR, the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
-Recipient - According to Article 4(9) of the GDPR, a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
-Data Subject (or “you”) - Within the meaning of this Privacy Policy, any natural person qualifying as a User or Subscriber of Wisepops’ website (www.wisepops.com) and/or Services.
The terms “User/Subscriber” and “Services” shall have the meaning attributed to them by Wisepops’ Terms and Conditions.
2. Controller
The Controller of the Personal Data processed via Wisepops’ website is:
Wisepops SAS (simplified joint stock company)
87 Boulevard Suchet 75016 Paris
R.C.S. (Trade and Companies Register) Paris N°792 748 477
3. Personal Data processed
3.1. Categories of Data processed
You are a User/Subscriber: Wisepops is processing your Personal Data when you create a personal account to use Wisepops’ Services - on a free trial or a paid subscription.
Identification data: name and surname.
Contact data: professional email address, professional phone number.
Profile picture - if you log-in with your Google account.
Professional activity: title.
Log-in data: cookies’ data (insofar as you consented to cookies).
You are a prospect: Wisepops is processing your Personal Data for marketing purposes in the context of our customer identification operations, or when you contact us for information requests.
Identification data: name and surname.
Contact data: professional email address, professional phone number.
Professional activity: title.
You are an applicant for a job: Wisepops is processing your Personal Data when you apply for a job offer via one of the recruitment agencies we use, or when you send us an unsolicited application.
Identification data: name and surname, date/location of birth, nationality, photography, etc.
Contact data: mailing address, email address, phone number.
Professional activity: experience, academic path, professional qualifications and skills, etc.
You are a supplier: Wisepops is processing your Personal Data as part of your contractual relationship with us.
Identification data: name and surname, company registration extract (e.g. “extrait Kbis”).
Contact data: entity mailing address, professional email address, professional phone number.
Professional activity: title.
Economic and financial data: IBAN.
3.2. Nature of requirement
When your Personal Data is required to use the Services, it is a requirement necessary to enter into a contract. Failure to provide such data will result in the impossibility to use the Services.
3.3. Automated decision-making
Wisepops does not pursue automated decision-making.
4. Purposes, legal basis and data retention
Wisepops processes your Personal Data in the following manner:
| Your situation | Purposes | Legal basis | Data retention |
|---|---|---|---|
| User/Subscriber | Contract management and customer account management and support. | Processing necessary for the performance of a contract. | The duration of the free trial plus twelve months for Users’ data. The duration of the contractual relationship plus five years for Subscribers’ data. |
| Management of payments and invoices, and bookkeeping. | Compliance with a legal obligation. | ||
| Direct marketing and personalized advertising. Pre-litigation and litigation management. | Legitimate interests pursued by the Controller to develop its clientele and protect from litigation. | ||
| Statistics. | Legitimate interests pursued by the Controller to better understand its customers’ needs. | ||
| Prospect | Direct marketing and personalized advertising. | Legitimate interests pursued by the Controller to develop its clientele. | Three years from the date of last interaction. |
| Applicant | Set-up of a CV library. | Legitimate interests pursued by the Controller to reference future potential employees. | Non-selected applicants: two years from the date of last interaction. Selected applicants: for the duration of the recruitment process until the hiring decision is made. |
| Applicants pre-selection. | Processing necessary for the performance of a contract. | ||
| Drafting the employment contract. | Compliance with a legal obligation. | ||
| Supplier | Supplier contract and order management. | Processing necessary for the performance of a contract | The duration of the contractual relationship plus five years. In some cases, a longer retention period is required by law (e.g. 10 years for invoices, based on Art. L. 123-22 of the French Code of Commerce). |
| Management of payments and invoices, and bookkeeping. | Compliance with a legal obligation. | ||
| Pre-litigation and litigation management. | Legitimate interests pursued by the Controller to protect from litigation. |
5. Data recipients and data transfers
5.1. Data recipients
Recipients of Users/Subscribers’ Personal Data are limited to Wisepops personnel and external consultants, and third party providers to the extent that is strictly necessary to the provision of Services. Such providers relate to the following activities: hosting services, software development, IT support, customer relationship management including client support and mailing, online analytics, direct marketing, payment and invoicing, recruitment firms, accounting firms.
5.2. Data transfers
These providers may be located outside the European Economic Area (EEA) in non-adequate countries, in which case Wisepops ensures to provide appropriate safeguards to the data transfer, in particular standard contractual clauses (SCCs) and additional measures.
6. Data Subject rights
Subject to the conditions set forth in the Personal Data Regulations, you are entitled to exercise the following rights:
Right of access: you have the right to ask us to confirm that we are processing your Personal Data, and to request that we send you a copy of the processed data.
Right to rectification: you have the right to have inaccurate or incomplete Personal Data processed by us rectified or completed.
Right to erasure: you have the right to obtain the erasure of your Personal Data as soon as possible, in particular when it is no longer required for the purposes for which it was collected, or when you withdraw your consent on which the processing of your data was based.
Right to restriction: you have the right to obtain restriction, i.e. a freeze on the processing of your Personal Data, in particular where this is necessary for the establishment, exercise or defence of your legal rights.
Right to object: you have the right to object at any time, for reasons relating to your particular situation, to the processing of your Personal Data. This right can only be opposed by Wisepops for legitimate and compelling reasons, or for the establishment, exercise or defence of legal claims.
Right to portability: you have the right to receive from Wisepops the Personal Data that you have provided to us in a structured, commonly used and machine-readable format, in particular for the purpose of transmission to a third party. Where technically possible, you also have the right to have your Personal Data transmitted directly to that third party.
Post-mortem instructions: you have the right to provide instructions on how your Personal Data is to be stored, deleted and communicated after your death.
In addition, you have the right to lodge a complaint with the competent supervisory authority, in France the Commission nationale de l’informatique et des libertés (CNIL).
You can exercise your rights by sending an email to Wisepops at the following email address: [email protected].
7. Update
Wisepops reserves the right to modify this Privacy Policy at any time, particularly to ensure compliance with the Personal Data Regulations.