As part of its activity, SMART GLOBAL PRIVACY SOLUTIONS, a company incorporated under the laws of Monaco, registered under the number 17S07390, whose registered head office is located at 1 rue du Gabian 98000 Monaco, processes personal data in the database of its solution.
Smart Global Privacy Solutions provides a platform for managing and monitoring data protection compliance regulations to Customers around the world, hereinafter referred to as “Customer“. This solution is made available to SMART GLOBAL PRIVACY SOLUTIONS customers who wish to have a solution for compliance with the regulations. SMART GLOBAL PRIVACY SOLUTIONS customers are therefore exclusively composed of public or private organisations concerned by these regulations, who wish to have an online management tool or solution.
3 types of data are processed:
1) The data of Customers and prospects included in the CRM and internal management tools of SMART GLOBAL PRIVACY SOLUTIONS.
2) The personal data of Customers / Users, produced by the Customer directly in the service.
3) The personal data of the partners, processors of Smart Global Privacy Solutions.
This policy may be modified in accordance with legal and regulatory developments, in particular those of Law 1,165 of “informatics and freedom” in relation to data, files and privacy, and the European General Data Protection Regulation “GDPR” as they exist to date and as they may be amended and, to any other standard, law, recommendation, regulation of the French data protection authority or any relevant European supervisory authority.
Controller – Data Protection Officer (DPO)
SMART GLOBAL PRIVACY SOLUTIONS has appointed as the Data Protection Officer (DPO) Ms. Odile Dussart, a lawyer at the Draguignan bar, domiciled at 95 Avenue Victor HUGO 83700 SAINT RAPHAEL (FRANCE).
The Controller is Smart Global Privacy Solutions, represented by Mr. Guignard Benoît, Manager.
Data produced by SMART GLOBAL PRIVACY SOLUTIONS relating to Customers
Description of data processing
SMART GLOBAL PRIVACY SOLUTIONS collects non-sensitive business data about Customers.
The personal data collected may include the following:
• Marital status, name, surname.
• Professional email
• Professional phone or mobile phone number
• Professional postal address
Purpose of obtaining personal data.
SMART GLOBAL PRIVACY SOLUTIONS collects and uses the personal data of Customers and prospects for the specific needs of its activity and, in particular, for the following purposes:
• To follow and guarantee the commercial follow-up of Customers and prospects through marketing, support and communication operations.
• To serve SMART GLOBAL PRIVACY SOLUTIONS Customers, subscribers to our solution.
SMART GLOBAL PRIVACY SOLUTIONS guarantees to update the personal data of the Customers / prospects throughout processing, so that the data is not obsolete.
Subject to the applicable local legislation, by providing your professional email, the Customer has expressly authorised SMART GLOBAL PRIVACY SOLUTIONS to use it, with other personal identification data mentioned in the previous paragraph, to send commercial messages or to guarantee customer support. SMART GLOBAL PRIVACY SOLUTIONS is also likely to use the professional email address for administrative or other non-commercial purposes (for example, to provide access to your personal data to update it).
These purposes have been brought to the attention of the Data Protection Officer of SMART GLOBAL PRIVACY SOLUTIONS who has integrated them into their registry.
Data Storage Period
SMART GLOBAL PRIVACY SOLUTIONS only keeps the personal data of the Customers / prospects during the time necessary for the operations for which they were obtained in compliance with the regulations in force. This parameter is systematic, mandatory and present for each contact. Each data collection indicates the duration of the explicit consent, the storage period and its purpose (with a predetermined storage period of 18 months).
Process of collecting data
Source of collected data
- Direct collectionfromCustomers / prospects or our partners by telephone, respecting the principle of prior information in the context of a BtoB use of personal data.
Qualification of collected data
- Initial qualification
All data must be verified (by telephone or with the person concerned), directly with the decision-maker or, failing that, with a reference contact (assistant, communication department of the company in the applicable case).
- Regular qualification
At least twice a year, SMART GLOBAL PRIVACY SOLUTIONS verifies the non-obsolescence of the personal data collected. This is done automatically through the administrative support and customer service team.
This verification is made through a telephone call in the professional contact information of the decision maker, which makes it possible to identify the professional information change and update the data accordingly, if necessary. This can also be done through the Smart Global Privacy platform, by the end user, who may update their personal information.
Rights regarding your data
SMART GLOBAL PRIVACY SOLUTIONS implements the necessary means to guarantee the rights of access, rectification, objection, limitation, portability and erasure of personal data of Customers / prospects when they make the request. The data can be rectified, complemented, updated, blocked or deleted when they are inaccurate, incomplete, misleading, expired or when its collection, use, communication or storage is prohibited.
In compliance with the Data Protection Law No. 1165 modified, Customers / prospects wishing to exercise their right of access, rectification and objection to information, may do so by contacting: email@example.com (or the Controller).
Transfer of collected data of Customers /prospects
Personal data collected regarding Customers / prospects are only hosted in the European Union. The completeness of the data is handled by SMART GLOBAL PRIVACY SOLUTIONS employees located in the European Union and in Monaco, headquarters of Smart Global Privacy Solutions.
SMART GLOBAL PRIVACY SOLUTIONS uses the services of its processor, Microsoft Azure, to host the integrity of the data affected by its data processing.
Security of personal data
SMART GLOBAL PRIVACY SOLUTIONS attaches particular importance to the security of your data and implements all appropriate security measures to limit the risk of loss, deterioration or misuse of the data.
For this purpose, SMART GLOBAL PRIVACY SOLUTIONS guarantees the security of the personal data of Customers / prospects / users through the implementation of improved data protection, reinforced by the use of physical and logical security means.
SMART GLOBAL PRIVACY SOLUTIONS has taken all the necessary precautions to safeguard the security of personal data and particularly to prevent it from being distorted, damaged or accessed by unauthorised by third parties.
The security measures are the following:
- Organisational measures
- Access for employees of SMART GLOBAL PRIVACY SOLUTIONS after hiring them into and after dismissal from the company. Access includes rights management that limits access to data according to the profile of the employee.
- External security audit performed regularly by an expert provider.
- Inactivation of obsolete data.
- Establishment of secure servers for the exchange of data.
- Logical security measures
- Regular backup of all infrastructure.
- Access to business applications controlled by MDP session initiation with rights management according to the profiles.
- History of massive data manipulation.
- History of all the data consulted in our system.
- Advanced authorisation management.
- Protection of workstations (access to workstations after authentication through login / MDP) and access to the database (authentication through login / dedicated MDP).
- Restricting access to business tools limited to the company’s facilities.
- Daily update of workstations, antivirus software in all positions.
- Connections to application tools are encrypted in TLS or SSH.
- Physical security measures
- Each employee accesses the facilities with a personalised card and at defined times.
- Secured building day and night.
The data is stored in a cloud infrastructure and is subject to a computer processing to provide the service subscribed by the Customer and improve the services. The hosting servers in which SMART GLOBAL PRIVACY SOLUTIONS processes and stores the data of its Customers / Users are exclusively located in the European Union.
• Internally with employees as an appendix to the internal regulations of the company.
• Within the General Conditions of Use.
This policy will be renewed with each new designation of the DPO and failing such, every three years. Validation of Maître Odile Dussart in her capacity as Data Protection Officer.
Date of last update: 05/24/2018