Privacy policy

At Freqens, protecting your personal data is our priority. Whether you use the website https://www.freqens.com (the "Website") and/or the platform FREQENS (the “Platform”), we may collect personal data about you.

The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR") and French Data Protection Law n° 78-17 of 6 January 1978 (together the "Applicable Regulations").

Who is the data controller?

The data controller is FREQENS, a simplified joint-stock company (“société par actions simplifiée”) registered with the Registry of Trade and Companies of Paris under the number 982 333 783 and whose head office is located at 10 rue de Penthièvre, 75008 Paris (“Us” or “We”) when browsing on our Website or our Platform or to manage our contractual relations with our customers.

However, when we provide our services to our customers, we process personal data on their behalf and for their own purposes. Our customers act therefore as data controllers in accordance with Article 4 of GDPR while we act as data processor.

What personal data we collect?

Personal data is data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.

We may collect the following personal data:

Identification data (e.g., full name, email addresses, telephone number);
Data relating to your professional life (e.g., company name, position/function, number of employees, LinkedIn URL, resume);
Data relating to the contractual relationship;
Login data (ID and login on our Platform);
Data related to recordings from telephone and video calls with Us (e.g., content of the calls, dates of the calls);
Browsing data (IP address, pages viewed, date and time of connection, browser used, operating system, user ID, MAID, user behavior);
Economic and financial data (e.g., bank details);
Any information you wish to send us as part of your contact or demo request.

We inform you, when collecting your personal data, whether some of these data are mandatory or optional.

How do we collect your personal data?

We have collected your data:

Either because you have provided it to us directly (e.g., by filling in a contact request form on our Site or by creating an account on our Platform);
Or because we have collected it indirectly, via commercial partners, service providers or database enhancement tools.

On what legal basis, for what purposes and for how long do we keep your personal data?

<table border="1">
    <thead>
        <tr>
            <th>Objectives</th>
            <th>Legal Basis</th>
            <th>Data Retention Period</th>
        </tr>
    </thead>
    <tbody>
        <tr>
            <td>To provide you with our services available on our Platform through your account</td>
            <td>Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract</td>
            <td>When you have created your account: personal data are retained for the duration of your account. Your connection logs are kept for 1 year.</td>
        </tr>
        <tr>
            <td>To perform operations related to contracts, invoices, and customer relationship management</td>
            <td>Performance of a contract to which you are party</td>
            <td>Personal data is retained for the duration of our contractual relationship. In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years.</td>
        </tr>
        <tr>
            <td>To create a database of customers and prospects</td>
            <td>Our legitimate interest in developing and promoting our business</td>
            <td>For our customers: their personal data are retained for the duration of our business relationship. For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us (e.g., communication, action).</td>
        </tr>
        <tr>
            <td>To send direct marketing mailings</td>
            <td>Our legitimate interest in informing our customers and prospects of our latest news</td>
            <td>Personal data is retained for a period of 3 years starting from the last contact with us (e.g., communication, action).</td>
        </tr>
        <tr>
            <td>To improve our services</td>
            <td>Our legitimate interest in improving our services</td>
            <td>Recording of telephone and video calls: 6 months from the date of collection. Telephone and video call content analysis documents: 1 year from the date of collection.</td>
        </tr>
        <tr>
            <td>To answer to your information and demo request</td>
            <td>Our legitimate interest in responding to your requests</td>
            <td>Personal data are retained for a period of 3 years starting from the last contact with us.</td>
        </tr>
        <tr>
            <td>To elaborate analytics of navigation and Site and/or Platform audience</td>
            <td>Your consent</td>
            <td>The personal data are retained for 25 months.</td>
        </tr>
        <tr>
            <td>To comply with our legal and regulatory obligations</td>
            <td>Our legal and regulatory obligations</td>
            <td>Invoices are archived for a period of 10 years. In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years.</td>
        </tr>
        <tr>
            <td>To process your applications and to manage interview (pre-selection of candidates, contact to evaluate the candidate's ability to fill the position, finalization of the recruitment process)</td>
            <td>Execution of precontractual measures</td>
            <td>Your data is kept in an active database for the duration of the recruitment process until the hiring decision is made. If your application is rejected, your data may be kept for 3 months after the end of the recruitment process, in order to be able to provide you with explanations on the reasons that led to the rejection of your application. Your data may be kept in an intermediate archive for evidential purposes for 5 years from the date of the hiring decision.</td>
        </tr>
        <tr>
            <td>To create a resume database</td>
            <td>Your consent</td>
            <td>The data is kept for two years from the last contact with the data subject.</td>
        </tr>
        <tr>
            <td>To process data subjects’ requests to exercise their rights</td>
            <td>Our legal and regulatory obligations</td>
            <td>If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted. If you exercise your right to object to direct marketing: we keep this information for 3 years.</td>
        </tr>
    </tbody>
</table>

Who are the recipients of your personal data?

The following categories of recipients will have access to your personal data:

The staff of our company;
Our processors: hosting provider, CRM tool, mailing provider, audience measurement tool, electronic signature provider, call and video recording tool, database enhancement tool, cookie management provider;
If applicable: public and private organizations, exclusively to comply with our legal obligations.

Are your personal data likely to be transferred outside the European Union?

Your personal data is hosted for the duration of the processing on the servers of the company Google Cloud Platform, located in the European Union.

As part of the tools, we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or
The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR: in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or an approved certification mechanism; or
The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR.

What rights can you exercise on your personal data?

You have the following rights with regard to your personal data:

Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.
Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.
Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.
Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.
Right to erasure (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.
Right to file a complaint to a competent supervisory authority (in France, the CNIL), under article 77 of the GDPR, if you consider that the processing of your personal data constitutes a breach of applicable regulations.
Right to define instructions related to the retention, deletion and communication of your personal data after your death.
Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.
Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.

What cookies do we use?

For more information on cookies management, please consult our Cookies Policy.

Contact information for data privacy matters

Contact email: contact@freqens.com

Contact address: 10 rue de Penthièvre, 75008 Paris

Modifications

We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

Entry into force: 27/04/2024