Personal Data Protection Policy.

Splio places great importance on respecting our Splio website & Services Platform in SaaS mode users’ right to privacy and confidentiality (hereinafter referred to as the “Users” or “You”).

The purpose of this personal data protection policy (hereinafter referred to as the “Data”) is to provide You with information on the ways in which we collect, use and disclose any Data which You may need to give us via this website or the Services Platform. This policy sets out the way in which the data of this website’s Users is processed.

We invite You to carefully read this Data protection policy before using or disclosing information via this website or the Services Platform in SaaS mode (hereinafter the “Platform”).

Users are likely to voluntarily disclose personal Data to Splio (such as their name, surname, address, telephone number or e-mail address, registration or authentication information) by filling out the forms or questionnaires on the website or connecting to the Platform. This Data may undergo automated or manual processing pursuant to French Law no. 78-17 of 6 January 1978, as amended, as well as Directive no. 95/46/EC of 24 October 1995 on Data Protection (hereinafter referred to as the “Data Protection Law”) and to the General Data Protection Regulation [(EU) 2016/679 of 27 April 2016] (hereinafter referred to as the “GDPR”), or pursuant to the local law applicable to subsidiaries of Splio.

Data means all information with which You may need to provide us either directly, or indirectly through cookies during your use of our website, if You have previously accepted these cookies, which allow us to identify You and to provide You with the best possible experience; or when you connect to the Platform.

Our Splio website may contain links to other websites, applications and services maintained by third parties (for example: https: //www.facebook.com/spliogroup,https://twitter.com/login,https://www.linkedin.com/company/splio/). The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy policies and cookies.

Who is in charge of processing the Data and what purposes does this processing have?

The Data is collected by the parent company Splio SAS (simplified joint-stock company with its registered office at 27 boulevard des Italiens, 75002 Paris, France, registered on the Paris Trade and Companies Register under the number 434 533 071, hereinafter named “Splio”), publisher of the website and the Platform, in its capacity as the data processor and in accordance with the Data Protection Law and with the GDPR.

The Data will be used for the following purposes::

Processing related to the use of the Splio Platform by Users:

• Connection, access and use of the Platform by Users
• Users access to support and technical assistance services
• Analyze feedback from Platform Users
• E-Learning on the use of the Platform
• Carry out operations relating to the management of Splio Clients under the Contract, including invoicing, accounting and customer relationship monitoring, third-party CRM tool, allowing Splio to manage its customer relationship (and the processing of which may be carried out in the United States within the framework of a “Data processing contract” including the standard contractual clauses of the European Commission), to establish accounting, technical and commercial documents, to carry out solicitation operations, and to develop trade statistics.

These treatments are legally based on the SaaS Services Contract (hereinafter referred to as the “Contract”) concluded between Splio and its Clients and the legitimate interest of Splio.

Processing of Users’ requests via the Splio Site::

You may need to provide us with Your Data on our website in order to obtain the following services:

• processing of a request for information on Splio products and / or services via a contact form
• obtain a demonstration of the services products and / or services of Splio
• download a Splio publication (such as white papers, articles, studies, survey analyzes, booklets and other publications which are the property of Splio)
• registration and participation in Splio events including Webinars or training sessions carried out by Splio
• application for a job advertisement or spontaneous applications
• interaction via the Splio blog and social networks
• report an abuse of emailing practice
• subscription to a Splio Newsletter (a service consisting in informing, by sending an e-mail, those who wish it of all the news relating to Splio). When You register, we collect the Data allowing us to contact You (e.g. your name, surname and email address). You can unsubscribe from the Newsletter at any time by using the “unsubscribe” link integrated into each Newsletter. The legal basis for this processing is consent.

Processing of survey results:

Splio may also be required to conduct surveys via its website or the Platform. In this case, the people agreeing to participate in these surveys may be required to communicate not only their opinions and / or reactions requested in the context of the survey carried out but also certain Data allowing them to be identified (e.g. name, telephone number, etc.). The categories of Data collected are likely to vary depending on the subject of the survey carried out.

What is the legal basis for processing Users’ requests via the Splio Site mentioned above?

With the exception of the subscription to the Splio Newsletter, the legal basis for other processing is legitimate interest.

The main purpose of collecting your Data is to provide You with an optimal, efficient and personalized experience when You use our services. To this end, you acknowledge that we may use your Data, on the basis of our legitimate interest in offering high quality services and in developing our customer relationships in order in particular to: personalize, evaluate and improve our services, content and materials, analyze the volume and history of your use of our services suggest advice adapted to your use, inform you about our services, any updates and any new service that may be of interest to You.

Splio has nominated a Data Protection Officer which can be reached at : dpo@splio.com

How do we use, gather and retain your Data?

The Data gathered is used only for the purpose of providing You with the information and services requested by You.

You are not obliged to answer all or part of the questions asked.

If certain Data is mandatory, this information will be marked with an asterisk. If You do not fill out these mandatory fields, we will not be able to process Your request.

The Data gathered by Splio is processed, recorded and stored in accordance with the legal provisions in force.

We only retain your Data for the time it takes for us to provide our services or within the timeframes laid down by law. At the end of this period, Your Data will be deleted. We cannot delete your Data if we are under a legal obligation to retain it, for example if required under accounting laws or if there is a legal reason to retain the Data, for example an ongoing contractual relationship.

Use of your Data for market research purposes.

In accordance with the applicable regulations, no market research via phones, e-mail, SMS/MMS or fax, nor any transfer of the Data for market research purposes using these means, will take place if you have not provided your consent to receiving market research messages and/or to your Data being transferred.

If You agree to receive such market research messages by ticking the acceptance boxes provided for this purpose on this website, You may withdraw this consent at any time in accordance with the conditions set out in the paragraph “Procedures for exercising your rights to your Data”. Notably, each of the market research messages sent via one of the abovementioned means will give You the opportunity to refuse to receive any future market research messages via the unsubscribe link “Unsubscribe”.

Security, confidentiality and integrity: how is your Data protected?

Splio’s main concern is preserving the quality, security, confidentiality and integrity of your Data. The technical and organisational measures and security policies thus put in place allow us to protect your Data. Persons with access to your Data are bound by the strictest confidentiality obligations and respect your privacy. We are constantly adapting our security measures by following progress and developments in technology.

Who are the recipients of your Data?

The Data recorded is intended for Splio and to its subsidiaries owned by 100% by Splio.

By completing forms or questionnaires on the website or the Platform, notwithstanding your right to exercise your right of opposition in accordance with the conditions below, You agree that your Data and any updates thereto will be disclosed to the following recipients: IT services, marketing, commercial and human resources departments of Splio, in order to respond to your requests.

Splio will not transfer to recipients other than those specified below on the section Subcontracting. Splio will not sell your Data.

Your Data will not be disclosed to third persons or entities unless the law provides otherwise.

Procedures for exercising your rights to your Data.

In accordance with the Data Protection Law, the GDPR or the local law applicable to subsidiaries of Splio, You may object to Your Data being processed and You may access it, ask for rectification to be made thereto or restrict the processing of certain Data.

You may ask for your Data to be withdrawn at any time.

You may ask for the portability of your Data at any time.

You may also object at any time to your Data being disclosed to third parties or to it being used by the data processor for commercial purposes, in accordance with the conditions set out above.

You have the right to define guidelines concerning Your Data in the event of death.

Your request should be addressed to privacy@splio.com.

These rights may be limited, for example if You ask us to delete Data that we are legally obliged to keep.

You have the right to make a complaint to the CNIL [French National Data Protection Commission] or the local authority in charge of Data protection.

Storage area & transfer of Data outside the European Union?

The servers on which Splio processes and stores the Data are located exclusively in the European Union. However, some Data may transit and be stored outside the European Union through the use of certain Sub-Processors. Any transfer to these third parties is protected by adequate legal frameworks such as a Data transfer agreement based on the standard contractual clauses of the European Commission.

Subcontracting.

The current Splio Sub-Contractors are listed on the Splio website under Data Subprocessors: https: //www.splio.com/subprocessors-list/

Cookies.

Our Cookie Policy can be found here in English or French.

Modifications.

We may modify this Personal Data Protection Policy to enable Splio to comply with new practices and regulations or for other purposes. In this case, we will change the last updated date at the top of this policy.