1. Definition and nature of personal data

The following terms and expressions, when used with capital letters, have the meaning attributed to them in the general conditions of Services.

During your use of the Services accessible through the Solution offered on the site www.wisembly.com (hereinafter together: the “Site”), we may ask you to communicate personal data concerning you.

In the context of this policy, the term “personal data” refers to all data that can identify an individual, which includes your name, first names, IP addresses, postal and e-mail addresses, telephone numbers, date of birth, company name, job title, data relating to your transactions on the Site, details of your purchases and subscriptions, credit card numbers, and any other information that you choose to communicate to us about you.

2. Purpose of this Policy

The purpose of this charter is to inform you about the means we use to collect your personal data, in strict compliance with your rights.

In this regard, we inform you that we comply, in the collection and management of your personal data, with Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms, in its current version (hereinafter: the “Data Protection Act”), as well as Regulation (EU) 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 (hereinafter: the “GDPR”).

3. Identity of the data collector

The company responsible for the collection of your personal data is WISEMBLY, SAS, registered in the Paris Trade and Companies Register under number 523 455 566, with its registered office at 66 avenue des Champs-Elysées, 75008 PARIS (hereinafter: “We”).

4. Collection of personal data

The legal basis for our collection of your personal data is as follows:

The execution of a contract when you subscribe to a License, you register on our Site and you use our Services;
Legitimate interest when you voluntarily provide us with personal data during your visit to our Site, the data being collected to allow us to better respond to your requests for information about our Services.
Your consent for Google Analytics cookies as described in Article 9.

Your personal data is collected for one or more of the following purposes

To manage your access to and use of the Services available on the Site,
To carry out operations relating to the management of Customers and Beneficiaries concerning contracts, orders, invoices, loyalty programs, and follow-up of the relationship with Customers,
To constitute a file of Customers, Beneficiaries and prospects,
To send newsletters, solicitations and promotional messages. In the event that you do not wish it, we give you the faculty to express your refusal on this subject at the time of the collection of your data;
To compile commercial and traffic statistics on our Services,
To manage the management of people’s opinions on products, Services or contents,
To manage any unpaid bills and disputes relating to the use of our Services,
Personalize responses to your requests for information,
Comply with our legal and regulatory obligations.

We inform you, when collecting your personal data, if certain data must be filled in or if they are optional. Mandatory data is necessary for the functioning of the Services. For optional data, you are free to choose whether or not to provide it. We also indicate to you the possible consequences of a failure to answer.

5. Recipients of the data collected

Will have access to your personal data:

the staff of our company,
the services in charge of the control (auditor in particular) and,
our subcontractors.

Your personal data may also be sent to public bodies, exclusively to meet our legal obligations, to judicial officers, to ministerial officers and to bodies responsible for debt collection.

6. Transfer of personal data

Your personal data will not be transferred, rented or exchanged to third parties, with the exception of the organizers of events for which you are registered and to which we communicate your data in connection with their events.

We may generate and share usage statistics collected during an event with event organizers so that they can calculate the usage rate of our services and have a clear understanding of their community’s interaction. This data includes both generic anonymized usage data (e.g., number of users, average number of user contacts, percentage of user additions, number of active users) and personal data related to the events organized by the organizer you registered for.

7. Duration of storage of personal data
Concerning data relating to the management of Clients, Beneficiaries and prospects :

Your personal data is kept for the time strictly necessary to manage our commercial relationship with you.

Regarding any prospecting operations that may be intended for you, your data may be kept for a period of 3 (three) years from the end of the commercial relationship.

The data allowing to establish the proof of a right or a contract, having to be preserved as a respect of a legal obligation, will be preserved during the duration envisaged by the law in force.

Personal data relating to a prospect, not a customer, may be kept for a period of 3 (three) years from the date of their collection or the last contact from the prospect.

At the end of this period of 3 (three) years, we may contact you again to find out if you wish to continue receiving commercial solicitations.

Concerning the users’ data:

Your personal data (email, last name, first name, company, IP) are kept for a period of 2 (two) years from your last use of the application.

Concerning the identity documents:

In case of exercise of the right of access or rectification, data relating to identity documents may be kept for the period provided for in Article 9 of the Code of Criminal Procedure, i.e. 1 (one) year. In case of exercise of the right of opposition, these data can be archived during the prescription period provided for by article 8 of the code of criminal procedure, that is to say 3 (three) years.

Concerning the data relating to the bank cards:

The financial transactions relating to the payment of purchases and fees via the Site are entrusted to the payment service provider Stripe (https://stripe.com/fr/privacy), which ensures the smooth running and security.

For the purposes of the services, this payment service provider may be required to receive your personal data relating to your credit card numbers, which it collects and stores in our name and on our behalf.

We do not have access to this data.

In order to allow you to make regular purchases or to pay the related fees on the Site, your credit card data is kept for the time of your registration on the Site and at least until you make your last transaction.

By checking the box expressly provided for this purpose on the Site, you give us your express consent to this storage.

The data relating to the visual cryptogram or CVV2, written on your bank card, are not stored.

If you do not want your personal data relating to your credit card numbers to be stored under the conditions specified above, we will not store this data beyond the time necessary to complete the transaction.

In any case, the data relating to these may be kept, for the purpose of proof in the event of a possible dispute of the transaction, in intermediate archives, for the period provided for in Article L 133-24 of the Monetary and Financial Code, in this case 13 (thirteen) months following the date of debit. This period may be extended to 15 (fifteen) months in order to take into account the possibility of using deferred debit payment cards.

Concerning the management of the lists of opposition to receive prospecting:

The information allowing to take into account your right of opposition is kept at least 3 (three) years from the exercise of the right of opposition.

Concerning cookies:

The maximum retention period for cookies referred to in Article 10 is 13 (thirteen) months.

Concerning the management of your requests to exercise your rights under the RGPD:

The information allowing the management of your requests to exercise your rights pursuant to the RGPD will be kept for 3 (three) years from the date of the request.

8. Security

We inform you that we take all useful precautions, organizational and technical measures appropriate to preserve the security, integrity and confidentiality of your personal data and, in particular, to prevent them from being distorted, damaged or accessed by unauthorized third parties. We also use secure payment systems that comply with the state of the art and applicable regulations.

In this respect, we inform you that we respect the security measures put in place by our hosting and data flow processing service providers, the company Claranet (FR), the company Microsoft Azure (US) as well as the company Scaleway (FR), whose measures are accessible at the following addresses

For Claranet: https://www.claranet.fr/politique-de-confidentialite
For Microsoft Azure: https://azure.microsoft.com/fr-fr/privacy-data-management/.
For Scaleway: https://www.scaleway.com/en/pdf/PSSI_en.pdf
9. Hosting

We inform you that your data is kept and stored, for as long as it is kept, exclusively on the servers of the Claranet company (Ile-de-France, France).

Your data will not be transferred outside the European Union in the context of the use of the services we offer you.

Your data may also be hosted on the servers of the company Zendesk Inc, in the case of a support ticket opened by you (via email or telephone).

10. Cookies

Cookies are text files, often encrypted, stored in your browser. They are created when a user’s browser loads a given website: the website sends information to the browser, which then creates a text file. Each time the user returns to the same site, the browser retrieves this file and sends it to the website’s server.

There are different types of cookies, which have different purposes:

Technical cookies are used throughout your browsing experience, to facilitate it and to perform certain functions. For example, a technical cookie may be used to remember the answers entered in a form or the user’s preferences regarding the language or layout of a website, when such options are available.

We use technical cookies.

Social network cookies may be set by social platforms to allow web designers to share content from their site on those platforms. In particular, these cookies may be used by social platforms to track how users navigate the relevant website, whether or not they use these cookies.

We do not use cookies from social networks. If we decide to do so in the future, we will ask for your consent before depositing them. You will also be given the opportunity to inform yourself about the nature of these cookies and to accept or reject them.

Advertising cookies may be created not only by the website on which the user is browsing, but also by other websites that display advertisements, announcements, widgets or other elements on the page displayed. These cookies can be used to carry out targeted advertising, i.e. advertising determined according to the user’s navigation.

We do not use advertising cookies. If we decide to do so at a later date, we will ask for your consent before placing them. You will also be given the opportunity to inform yourself about the nature of the cookies and to accept or reject them.

We use Google Analytics which is a statistical audience analysis tool that generates a cookie to measure the number of visits to the Site, the number of pages viewed and the activity of visitors. The configuration we have made of this tool means that no personal information (including your IP address) is collected by it.

We would like to remind you that you can refuse to accept cookies from our site via our Cookie Manager. However, such a refusal could prevent the proper functioning of the Site.

11. Access to your personal data

In accordance with the Data Protection Act and the RGPD, you have the right to obtain communication and, if necessary, rectification or deletion of data concerning you. You can also contact us at

e-mail address: dpo@wisembly.com
postal address: Wisembly, 66 avenue des Champs-Elysées, 75008 Paris

Persons whose data is collected on the basis of our legitimate interest, as mentioned in Article 4, are reminded that they may at any time object to the processing of their data. We may, however, continue to process data if there are legitimate reasons for the processing that override your rights and freedoms or if the processing is necessary to establish, exercise or defend our legal rights.

12. Right to define directives regarding the processing of data after your death

You have the right to define directives concerning the conservation, deletion and communication of your personal data after your death.

These instructions can be general, i.e. they cover all your personal data. In this case, they must be registered with a trusted digital third party certified by the CNIL.

The directives can also be specific to the data processed by our company. In this case, you should send them to the following address:

e-mail address: dpo@wisembly.com
postal address: Wisembly, 66 avenue des Champs-Elysées, 75008 Paris

By sending us such instructions, you expressly give your consent for these instructions to be kept, transmitted and executed according to the terms and conditions set forth herein.

You may designate in your directives a person responsible for their execution. This person will then be entitled, when you die, to take cognizance of the said directives and ask us to implement them. If you do not designate a person, your heirs will have the right to read your instructions upon your death and ask us to implement them.

You may change or revoke your instructions at any time by writing to us at the above address.

13. Portability of your personal data

You have a right to the portability of the personal data you have provided to us, understood as the data you have actively and consciously declared in the context of accessing and using the services, as well as the data generated by your activity in the context of using the services. We remind you that this right does not apply to data collected and processed on a legal basis other than consent or the performance of the contract binding us.

This right can be exercised free of charge, at any time, and in particular when closing your account on the Platform, in order to recover and retain your personal data.

In this context, we will send you your personal data, by any means deemed useful, in a standard open format commonly used and readable by machine, in accordance with the state of the art.

14. Making a complaint to a supervisory authority

You are also informed that you have the right to lodge a complaint with a competent supervisory authority (the Commission Nationale Informatique et Libertés for France), in the Member State in which your habitual residence, your place of work or the place where the violation of your rights would have been committed, if you consider that the processing of your personal data subject to this charter constitutes a violation of the applicable texts.

This recourse may be exercised without prejudice to any other recourse before an administrative or judicial court. Indeed, you also have the right to an effective administrative or judicial remedy if you consider that the processing of your personal data subject to this charter constitutes a violation of the applicable laws.

15. Limitation of processing

You have the right to obtain the limitation of the processing of your personal data, in the following cases:

During the period of verification that we implement, when you dispute the accuracy of your personal data,
When the processing of your personal data is unlawful and you wish to limit the processing rather than delete your data,
When we no longer need your personal data, but you wish to retain it to exercise your rights,
During the period of verification of legitimate reasons, when you have objected to the processing of your personal data.
16. Changes

We reserve the right, at our sole discretion, to modify this Privacy Policy in whole or in part at any time. Such changes will be effective upon posting of the new policy. Your use of the Site after such changes become effective will constitute your acknowledgement and acceptance of the new policy. If you do not agree with the new policy, you should no longer access the Site.

17. Entry into force

This charter became effective on May 25, 2018.

18. Last modifications and updates

This charter was last updated on January 22, 2021.