LEGAL NOTICE AND PRIVACY POLICY

LEGAL NOTICE

Publisher Information

The website is published by SMART GLOBAL GOVERNANCE, a simplified joint-stock company with a share capital of €3,350,535.32, registered with the Grasse Trade and Companies Register under number 853 951 556, having its registered office at:
300 rue du Vallon, les Vaisseaux, 06560 Valbonne, France.
VAT number: FR96853951556
Phone: 09 72 64 05 40
Email: hello@smartglobal.com

Publication Director: Olivier GUILLO, President of SMART GLOBAL GOVERNANCE.

Hosting Provider: Microsoft Azure,
39 Quai du Président Roosevelt,
92130 Issy-les-Moulineaux, France
Phone: 09 70 01 90 90

PRIVACY POLICY

SMART GLOBAL GOVERNANCE takes the protection of Users’ personal data seriously and is committed to protecting it in accordance with applicable regulations, specifically Regulation (EU) No 2016/679 of April 27, 2016 ("General Data Protection Regulation" or "GDPR") and the French Law No. 78-17 of January 6, 1978, as amended ("Data Protection Act") (collectively, the "Applicable Data Protection Regulations").

Capitalized terms not defined in this policy have the meanings specified in the Platform’s General Terms of Use or the General Terms for the provision of the software platform.

SMART GLOBAL GOVERNANCE acts as a "data controller" when collecting and processing personal data from visitors to the website (www.smartglobalgovernance.com) ("Visitors") and Users of its Platform, either during a trial period or within an active subscription by the User or their employer ("Client").

SMART GLOBAL GOVERNANCE does not access the data entered by Users into the Platform, which is protected by encryption, unless the User (or Client) grants temporary and limited access to provide user support or Platform maintenance. In this case, SMART GLOBAL GOVERNANCE acts as a "data processor" under instructions from the User (or Client).

I. SMART GLOBAL GOVERNANCE AS DATA CONTROLLER

1. Purpose of Personal Data Processing

SMART GLOBAL GOVERNANCE processes personal data of Users and Visitors for the following purposes:

  • User account management: Creating and operating User accounts.
  • Operational Platform management: Enabling Users to manage personal data processing compliance; providing user support and maintenance.
  • Client relationship management: Invoicing Users representing SMART GLOBAL’s Client companies.
  • Communication with Visitors: Responding to inquiries via contact forms or other communication means (phone, email).
  • Newsletter distribution: Sending news and service offers if explicitly requested by the User or Visitor.
  • Improving Platform and Website performance and features.
  • Traffic monitoring and statistical analysis.

2. Personal Data Collected

SMART GLOBAL GOVERNANCE collects the following User personal data:

  • User Account creation: First and last name, job title, company name, professional email, business phone number, and company postal address.
  • Contact Form: First and last name, company name, professional email, phone number, and message content.
  • Newsletter: Email address.

Mandatory data is marked with an asterisk (*). Providing mandatory data is necessary for the specified purposes. Optional data helps SMART GLOBAL GOVERNANCE better understand Users and Visitors.

3. Data Retention Period

User personal data collected via the Platform or User Account is retained as long as the User actively uses the Platform per the Terms of Use.

Visitor data collected through the contact form is retained for 12 months.

Newsletter subscriber emails are retained until users unsubscribe via the provided link or until the specified retention period expires.

After these retention periods, data is securely archived as required by law for evidentiary purposes in potential legal disputes.

4. Recipients of User Personal Data

User data is confidential and exclusively accessible to SMART GLOBAL GOVERNANCE.

Unless required by legal, accounting, or judicial obligations, SMART GLOBAL GOVERNANCE will not disclose, transfer, rent, or share User personal data with third parties, except for technical hosting providers. The Website and Platform are hosted by Microsoft Azure in France.

The hosting provider acts strictly as SMART GLOBAL GOVERNANCE’s data processor, bound by confidentiality and compliance agreements aligned with applicable data protection regulations.

5. Security Measures

SMART GLOBAL GOVERNANCE ensures the security and integrity of personal data through appropriate technical and organizational measures, preventing unauthorized access, disclosure, loss, or alteration of data and ensuring timely data recovery in case of incidents.

A Data Protection Officer (DPO) has been appointed to oversee compliance with applicable regulations.

6. User and Visitor Rights

Users and Visitors have the following rights regarding personal data:

  • Access: Confirm data processing and access relevant information.
  • Rectification: Correct inaccurate or incomplete data.
  • Erasure (Right to be forgotten): Delete unnecessary data or withdraw consent (subject to conditions specified in the subscription).
  • Restriction: Limit data processing under certain conditions.
  • Data portability: Receive or transfer data to another data controller.
  • Objection: Object to data processing based on personal circumstances, particularly for marketing purposes.
  • Consent withdrawal: Withdraw consent where applicable (e.g., newsletter).
  • Complaint: Lodge a complaint with France’s data protection authority (CNIL).

To exercise these rights, contact SMART GLOBAL GOVERNANCE at: support@smartglobal.com

II. SMART GLOBAL GOVERNANCE AS DATA PROCESSOR

For user support and maintenance purposes, SMART GLOBAL may temporarily access personal data entered by Users into the Platform ("Client Data"). In such cases, SMART GLOBAL GOVERNANCE acts strictly as a data processor on behalf of the User or Client.

The User (or Client) remains responsible as data controller and guarantees compliance with applicable regulations. SMART GLOBAL GOVERNANCE commits to:

  • Process Client Data only as instructed by the User/Client.
  • Maintain data confidentiality and integrity.
  • Not retain Client Data beyond the duration agreed.
  • Not disclose Client Data to unauthorized parties.
  • Inform the User/Client of any subcontractor used for data processing and allow objections.
  • Assist the User/Client in handling rights requests, complaints, audits, and impact assessments (as per separate service agreements).
  • Notify promptly in case of data breaches and provide necessary documentation.
  • Ensure data transfers outside the EU comply with legal requirements and obtain User/Client prior authorization.

III. COOKIE MANAGEMENT

SMART GLOBAL GOVERNANCE uses cookies to operate the Website and Platform effectively, facilitate User identification, enhance communication, and analyze traffic.

Users and Visitors can manage or refuse cookies through the Cookie Preference Center available on the Website, or configure their browser settings accordingly. Relevant instructions for cookie management are provided within commonly-used browser documentation.

IV. SOCIAL MEDIA & TRACKING PLUGINS

The Website utilizes social media plugins from LinkedIn (Microsoft Inc.), Twitter (Twitter International Unlimited Company), and Zoho PageSense (Zoho Corporation B.V.). Interaction with these plugins establishes direct connections between the user’s browser and social media servers, potentially sharing browsing information with these services.

To prevent social media tracking, Users and Visitors must log out of their social media accounts before visiting the Website. SMART GLOBAL GOVERNANCE does not control the data collected via these plugins, governed exclusively by each provider's respective terms and privacy policies, accessible on their official websites.

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