Effency

Data protection

- Privacy Policy -

CHARTER FOR THE PROTECTION OF USERS’ PERSONAL DATA

EFFENCY is specialized in the digital support of employees in companies. It has developed TeamGether (“the Application”), a digital companion that delivers knowledge directly on Teams, Slack, Citadel or the Google suite, to accompany training and transformation directly in the daily tools. Thanks to an intuitive editor, the JetPack, TeamGether allows you to associate existing resources (texts, images, ppt, pdf, quizzes, MCQs…) for different and relevant experiences for everyone, in learning anchoring or animation of training intersessions. This editor also allows to manage the employee experience in a continuous improvement process. EFFENCY has developed and makes available to customers a tool for creating, distributing and managing content called JetPack. This service aims to enable customers to create, using JetPack, training courses tailored to their corporate culture and customized through the multitude of formats offered (text, image, video, external links, activities, quizzes, open questions or MCQs, etc.). They also benefit from EFFENCY’s assistance, through a support during the JetPack learning process, then through tutorials and FAQs. In this context, EFFENCY grants to customers who subscribe to this Service access to its licenses editor, manager and provides ongoing technical and functional support for the installation of TeamGether, its chatbot designed for this purpose (hereinafter: “the Application”), on Slack, Teams, Citadel and the Google suite for each of the Team Members concerned. The training courses thus created by the Customer are then distributed to End Customers or Team Members by TeamGether, on Slack, Teams, Citadel or the Google suite, according to the methods defined by the Customer (automated or not, to groups of people or individually, etc.). Finally, the JetPack allows the Customer to store and manage all his training courses within his own library, whose content is made available to the Final Customer or to all Team Members. The Customer also has access, if he decides to opt for the corresponding package, in French and English, to the 2,700 courses and recommendations developed by EFFENCY on collective effectiveness and made available in a common library. The JetPack also allows to manage the employee experience in a continuous improvement process. If necessary, the training courses can target collective effectiveness, in which case they integrate the Services described in our TOS (link to the TOS), including a personality test and a team analysis. The details of these Services (our “Services”) are provided on a Quotation basis, depending on the subscription taken out by the Customer, or marketed on its website www.effency.fr (the “Site”) The purpose of this Privacy Policy is to inform you about the personal data that you entrust to us or that we may collect during your browsing and our interactions on our Site and our Application. We comply, in the collection and management of this data, with the regulations applicable to personal data and in particular the law n°78-17 of January 6, 1978 known as “Informatique et Libertés”, the EU Regulation 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data being the subject of decree n°2019-536 of May 29, 2019.

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Identity of the data controller :

The data controller is SAS Effency, which is registered in the Paris Trade and Companies Register under number 822 320 172 and has its registered office at 78 Avenue de Flandre, 75019 Paris (‘Effency’, ‘We’ or ‘Us’). 

E-mail: team@effency.fr 

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Personal data collected :

Personal data means any information relating to a natural person who can be identified, directly or indirectly, by reference to one or more elements that are specific to him or her, such as surname, first name, postal or e-mail address or by reference to an identification number such as an order number, IP address, etc…

EFFENCY scrupulously observes the principle of minimization of data collected, and collects only the data necessary for the purposes of its services, namely :

  • Identification data transmitted by THE CUSTOMER (name, e-mail address, IP address, Slack, Teams, Citadel or Google suite connection identifier, professional identification data): this data is essential to implement our digital services and services. It is transmitted by a Customer when it enters into a contract with EFFENCY whose purpose is to enable its employees and/or agents to benefit from our Services. Our Customer transmits under its responsibility the email addresses and Slack, Teams, Citadel or Google Suite login credentials of its employees authorized to access our Services.
  • Identifying data transmitted by THE USER (name, e-mail address, IP address, Slack, Teams, Citadel or Google suite login ID, business identification data, telephone number, postal address): this data is also essential for implementing our services. They are transmitted when a user, employee and/or customer’s representative opens an account on the Site or Application or logs on to benefit from our Services (individual tests, group analysis, coaching program follow-up, digital path follow-up).
  • Bank details: these details are required for all orders placed by our customers or for reimbursements. However, no payment is made online, and any banking data we may collect is intended solely for our payment service providers.
  • Technical data (IP addresses, connection logs): this data is collected during your browsing.
  • Browsing data (searches, number of visits, date of last visit): this data is used to offer personalized services and to measure the audience for our products and services.

Contact email: team@effency.fr

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Purpose of processing :

Your data is collected and processed for explicit, legitimate and specific purposes in order to enable us to:

  • Ensure the proper functioning of our Site and Application, their services and functionalities.
  • To send you notifications concerning the service, to consult your results or when we chat via the EFFENCY Chatbot, provided that you have accepted this type of dispatch.
  • To send you solicitations, newsletters and promotional messages, provided you have agreed to this type of communication.
  • To carry out research.
  • To compile commercial and visitor statistics for our Services.

When we collect your personal data, we inform you whether certain information is mandatory or optional. We also inform you of the possible consequences of failing to reply.

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Recipients of the data collected :

EFFENCY does not transfer any data to third-party companies for any reason other than one of the following:

Provision of services ordered: as part of the digital coaching service, in order to provide the digital services offered, your data may be transferred to the companies concerned, namely :

  • Our Consultants : Cog’X
  • Our Partners: La Petite Étincelle, Siclavy, Arborescence, In Facto.

Our staff, consultants and partners have signed an undertaking to respect the confidentiality of the data they process.

Access to third-party services: in order to provide our services, we use collaborative communication platforms, and your data may pass through these platforms:

  • Our providers of collaborative communication platforms: “Slack” (Salesforce), Teams (Microsoft), Citadel or the Google suite.

EFFENCY’s use of information received from these third-party services complies with the user data policy of these applications.

Subcontracting: EFFENCY uses service providers to operate its Site and its Application and provide you with the services and products offered and in particular to the company AWS for data storage. The servers used by EFFENCY are located in the AWS cloud in France (application server, web server and database server).

EFFENCY’s use of information received from these service providers complies with the user data policy of these applications, it being recalled that these technical service providers may only use personal data on behalf of EFFENCY and will only be transmitted :

  • if required by law or to comply with a legal obligation or legal proceedings; in urgent circumstances to ensure data security.

Your personal data may also be passed on to public bodies, exclusively to meet our legal obligations, to court officers, legal representatives and debt collection agencies.

The personal data collected may be used for research and statistical purposes (see article 10 of our General Terms and Conditions). In this context, it may be transmitted to third-party researchers with whom we collaborate. The data is anonymized prior to transmission to these third parties, so that it no longer constitutes personal data at the time of transmission.

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Legal basis for processing :

EFFENCY processes your personal data on the following legal grounds:

Contract performance: the processing of your data is necessary for the performance of the contract entered into between you and EFFENCY, and/or its partners in order to provide you with our Services, via our Site or our Application.

Legitimate interest: EFFENCY may have a legitimate interest in processing your data. This is the case, for example, when EFENCY sends its emails announcing the creation of accounts or when it analyzes your browsing on its Site or its Application in order to improve its offers and services, to conduct statistical studies on the products and / or services it markets, to secure its digital media (websites, applications, etc..).

Consent: EFFENCY carries out processing with your express consent, which may be withdrawn at any time. This is the case for sending our tests, analyses, coaching programs, digital paths or commercial communications concerning special offers.

Compliance with legal obligations: EFFENCY may carry out processing in compliance with its legal obligations. This is also the case for the accounting processing of your orders.

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Duration of storage of personal data :

We store data in accordance with the legal periods recommended by the CNIL and/or the legal periods to which EFFENCY is subject. However, the processing of data is possible for the proof of a right or a contract.

As an exception, user identification data is kept by our company for a period of 1 year from the last contact at the end of the performance of the Services concerned.

For any prospecting operations aimed at users of our Services, data will be kept for a period of three years from the end of the commercial relationship.

Personal data relating to non-user prospects may be kept for a period of three years from the date of collection or last contact with the prospect.

With regard to audience measurement statistics, information stored in users’ terminals or any other element used to identify users and enabling their traceability or frequentation will not be kept beyond 13 months.

For the management of requests for access to your personal data, data will be kept for one year.

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Data transfers outside the European Economic Area :

EFFENCY’s policy is not to transfer data outside the European Economic Area.

In such a case, EFFENCY undertakes that they are made with appropriate safeguards, including contractual and technical, in accordance with applicable regulations on the protection of personal data.

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Cookies :

This section is dedicated to the management of cookies on the Site and Application and is intended to inform you about the origin and use of navigation information processed when you consult our Site or Application and about your rights.

What is a cookie? A cookie or tracer is an electronic file deposited on a terminal (computer, tablet, Smartphone, game consoles, etc.) and read when consulting a website, an e-mail, installing or using software (such as Chatbot) or a mobile application, regardless of the type of terminal used.

What are cookies used for? The cookies used on our Site and Application serve to differentiate you in order to improve your browsing experience and the services we offer you. They may be issued and deposited directly by EFFENCY or its service providers or partners.

How do I manage cookies? Each time you access the Site or the Application and when you start our Chatbot, a banner explaining the use of cookies will appear, which you will have to click on to authorize or not the cookies or to select them. You must accept cookies before they can be stored on your terminal. You can choose which cookies are deposited on your browser, so that cookies are accepted and deposited or, on the contrary, refused on an individual or global basis.

 

Which cookies may be deposited? There are 4 types of cookies placed on our Site and Application:

  • Technical or functional cookies: These cookies facilitate the use of our Site or Application or their functionalities. In particular, they enable you to authenticate yourself without having to re-enter your connection data, and to determine the language in which the site is displayed.
  • Internal cookies necessary for the proper functioning of the site: We do not use cookies of this type.
  • Audience measurement cookies: Our website and application use Google Analytics, a Google web analytics tool that enables EFFENCY to better understand user behavior. This tool may use cookies to collect information and generate reports on website usage statistics without individual users being personally identified by Google. The “__ga” cookie is the one most commonly used by Google Analytics.
    In addition to generating reports on website usage statistics, Google Analytics also makes it possible, in conjunction with certain (…) advertising cookies (…), to display more relevant ads on Google sites (such as Google search) and on the Web. You can access the Google Analytics privacy policy at https://www.google.com/analytics/learn/privacy.html?hl=fr.

Cookies for audience statistics purposes are not kept beyond 24 months.

  • Third-party cookies intended to enhance the interactivity of our Site and Application: Our Site and Application use certain services offered by third-party sites, which generate the deposit of third-party cookies by these services and are subject to their confidentiality policies. These include, in particular, the sharing buttons on the “Twitter” (link to the site), “Facebook” (link to the site) and “Linkedin” (link to the site) websites. We invite you to consult the privacy policies of these social networks and to exercise your choices by configuring your accounts on each of them.

We do not use advertising cookies. However, if we were to use them in the future, we would inform you in advance and you would have the option of deactivating these cookies.

9

What are your rights and how to exercise them :

In accordance with current regulations, you have the following rights with regard to your personal data:

  • A right of access: you have the right to ask us what data EFFENCY holds and to obtain communication.
  • A right of rectification: you have the right to request rectification of inaccurate data held by EFFENCY and to be notified.
  • A right to erasure: you have the right to obtain from EFFENCY the erasure of data concerning you and to be notified thereof.
  • A right to the limitation of processing: you have the right to ask us to suspend and limit the processing of your data until such time as a verification can take place.
  • A right to data portability: you have the right to have your personal data transmitted to you in a structured format and to have it transmitted to another data controller.
  • A right to object: you have the right to object, at any time, to being included in a file for legitimate reasons.
  • A right not to be profiled: you have the prior right to consent or not to any “profiling”, i.e. any decision concerning you taken on the basis of automated processing, and in the event that you have consented to such profiling, you have the right to have your situation re-examined by a human being in order to obtain an explanation of the decision taken or to contest it.

You may exercise your rights directly with EFFENCY by the following means: by e-mail to team@effency.fr , on the Site or Application, in the “contact” section or by post to EFFENCY, 78 avenue de Flandre – 75019 Paris.

If you are asked to provide proof of your identity, we will keep it for 1 year if this communication is made in the context of the exercise of a right of opposition.

In the event of a dispute, you can contact the CNIL at www.cnil.fr or by post: CNIL 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 7.

10

Security of collected data :

We and our partners and subcontractors take all necessary precautions and appropriate organizational and technical measures to protect the security, integrity and confidentiality of your personal data, and in particular to prevent it from being distorted, damaged or accessed by unauthorized third parties. These measures take into account the state of the art, CNIL and ANSSI doctrine, and comply with current security standards.

 

The following principles govern the development of our Site and Application, both in terms of technical infrastructures (secure hosting, security policy and access control) and applications (development of the Site and Application):

Secure data collection ;
Storage guaranteeing data integrity and confidentiality;
Secure development environments;
Secure access to data;
Limited subcontracting.
We process personal data within secure infrastructures located in the European Economic Area; our Site and Application are subject to regular audits to guarantee a high level of security.

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Entry into force

This Privacy Policy is effective as of March 2021.