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”).

1. 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.

2. 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.

3. 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.

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

We process your personal data to manage our relationship with prospects and customers, to provide and improve the Website and the Platform, and to comply with our legal obligations. Each processing relies on the performance of our contract, our legitimate interest, your consent or a legal obligation, depending on its purpose.

We keep your personal data only as long as these purposes require, then for the periods set by law. The data customers upload or import into the Platform is kept for the duration of the contract.

5. Who are the recipients of your personal data?

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

1. The staff of our company;
2. 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;
3. If applicable: public and private organizations, exclusively to comply with our legal obligations.

6. 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.

7. How do we use Google user data?

A user of the Platform may connect a Google account to import Google Sheets files into their workspace. Freqens then accesses only the Google Sheets files the user selects in the Google file picker, and the email address of the Google account, to show which account is connected.

• Freqens cannot see any other file in the user’s Google Drive.
• Freqens only reads these files, to import their content into the customer’s workspace and keep it up to date. It never modifies them.
• The imported data is used only to provide the features of the Platform to the customer, such as answering the user’s questions with the help of artificial intelligence providers. These providers process the data on our behalf and do not use it to train their models.
• Freqens does not sell this data, does not use it for advertising, and does not use it to train general-purpose artificial intelligence models.
• Freqens stores this data securely, in the European Union.
• The user can remove Freqens’s access at any time, from the settings of the Platform or from their Google Account (https://myaccount.google.com/permissions).

Freqens’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

8. 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.

9. Contact information for data privacy matters

Contact email: contact@freqens.com

Contact address: 10 rue de Penthièvre, 75008 Paris

10. 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