Privacy Policy
Smart Flows respects your preference concerning the collection and use of your personal data. The following privacy policy is tailored for the different ways your personal data is collected by Smart Flows.
By using this website, you consent to the collection and use of the information described here. From time to time Smart Flows may also seek your explicit consent to process certain data and information collected on this website or volunteered by you.
Note that all of the information set out below may not apply to you. Below is an overview of all possible situations in which Smart Flows could interact with you, and one or more of these may apply to you depending on how you have interacted with Smart Flows.
Please also note that you must be at least 13 years old or older to use our services.
Controller of the processing
The data controller of your personal data is SAPA, located at 3 rue des Filles du Calvaire, 75003 Paris, FRANCE.
Processing of your data
Your personal data may be collected or received through the website (www.smart-flows.com) and processed by Smart Flows or its third-parties, as follows:
Responding to your information requests:
Smart Flows may use your first name, last name, physical address, email address, phone number, company and job position in order to respond directly to your information request and manage your inquiries (including newsletter registrations and other specific requests). The legal basis for such processing is your consent as you expressed by completing the contact form.
Sending e-marketing campaigns and promotions:
Smart Flows may use your first name, last name, physical address, email address, phone number, company and job position to notify you about new products, releases and service developments and to advertise Smart Flows’ product and services in accordance with this policy. Your website visit, marketing experience, and communication may be tailored to your interests based on your personal data. The legal basis for such processing is your consent as you expressed by completing the contact form.
You may opt out of being contacted by Smart Flows at any time using the opt-out link provided in any newsletter you receive or by contacting Smart Flows in this regard at the following address: dpo@smart-flows.com.
If you later ask Smart Flows to stop sending you marketing and promotional communications, Smart Flows needs to keep some of your personal data on a suppression list so that Smart Flows can be sure it does not contact you again. This is a legal obligation.
Processing job applications received by email or using LinkedIn profile information:
Smart Flows may use your first name, last name, physical address, email address, phone number and your information available via your LinkedIn profile as well as any additional personal data that you may find relevant to communicate, notably information relating to your work experience, education, skills or references, in order to process your job application. The legal basis for such processing is necessary in order to move forward, at your request, prior to entering into a contract.
Statistics:
Smart Flows may use the following data for statistical purposes to analyze the site activity and improve the services Smart Flows provides. Smart Flows analyses audience measurements, such as the number of pages viewed, the number of visits to the site, as well as visitor activity on the site and their frequency of return.
Complying with legal requirements and corporate transactions:
Smart Flows may disclose your personal data as Smart Flows believes necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities, and (d) to enforce our terms and conditions. Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Smart Flows’ business, assets or stock (including in connection with any bankruptcy or similar proceedings), Smart Flows may transfer your personal data to the relevant third party.
Some of the personal data specified above may not be mandatory for the specified uses. Mandatory data is identified by a mention specifying the mandatory nature of their collection for the specified use.
Recipients of your data
Smart Flows relies on trusted third parties that assist and help Smart Flows in providing IT services, such as hosting services, maintenance and support on Smart Flows’ databases as well as on Smart Flows’ software and applications. All such third parties’ servers are located in the EU. The legal basis for this sharing is Smart Flows’ legitimate interests to secure Smart Flows’ tools.
Smart Flows may disclose your personal data to third parties if we have your consent or we are permitted to do so by law.
Transfer of data
You acknowledge and agree that some of your personal data (first name, last name, physical address, email address, phone number, company and job position) may be shared by Smart Flows with:
a third-party provider, located and using servers in the U.S.A. for the purpose of sending e-marketing campaigns and promotions;
a third-party provider located and using servers in the U.S.A for the purpose of doing sales engagement.
The following safeguards have been taken to ensure an adequate level of protection of personal data:
Personal data submitted to such third-party providers is within the scope of n annual certification to the EU-U.S. Privacy Shield framework as administered by the U.S. Department of Commerce.
Except as otherwise expressly provided herein, your personal data will not be shared with or sold to third parties located or using servers located outside the European Economic Area.
Security
Smart Flows takes all appropriate technical and organizational measures, with regard to the nature of the data and the risks of their processing, to preserve the confidentiality, integrity and security of your personal data and, in particular, to prevent their alteration and damage, or access by non-authorized third parties.
Although all useful precautions are being taken by Smart Flows, the absolute integrity of the data cannot be ensured by Smart Flows. Also, Smart Flows may not guarantee the privacy of personal data transmitted over the Internet or that may be collected in transit by others. As a consequence, you acknowledge and accept that you have to take your own measures to protect your personal data against the non-authorized access to your computer, especially by ensuring the confidentiality of your login and password, using an up-to-date virus.
If Smart Flows experiences a breach of security in our services that have an impact on your personal data, Smart Flows will send you a prompt notice.
Data retention duration
Smart Flows will not retain your personal data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
Your rights
You have the right to access, rectify, complete, restrict, oppose and delete your personal data, as well as to data portability. You may exercise the rights above by contacting Smart Flows at: dpo@smart-flows.com. If you decide to exercise these rights, your access to Smart Flows’ services or the job application process, as relevant, may be affected.
Links
The website may provide links to or the ability to connect with non-Smart Flows’ websites, services, social networks or applications. Clicking on those links or enabling those connections may allow the third party to collect or share information about you. Those third-party websites or services are beyond our control. Smart Flows encourages you to check the privacy policies and terms of use of any non-SmartFlows’ websites or services before providing your personal data to them.
Notice of possible changes
In the event Smart Flows modifies this privacy policy, Smart Flows will inform you by email and post a notification on the website. You may elect to accept the changes or not. If you elect not to accept your access to Smart Flows’ services or the job application process, as relevant, may be affected.
Contact on privacy matters
For any questions regarding this privacy policy or its implementation, please contact Smart Flows DPO, Olivier Hervieu - dpo@smart-flows.com - 5 rue Elzevir 75003 Paris - France.