In the course of its activity and for the purposes of providing the Services (as defined in our General Terms of Use), SmartColdMail is required to collect and process the personal data of its users (hereafter referred to as the “Users”).
This privacy policy, implemented by SmartColdMail, is intended to provide the Users with a summary and overview of the processing of personal data carried out by SmartColdMail.
SmartColdMail attaches particular importance to the respect for the privacy of the Users and of the confidentiality of their personal data, and is thus committed to processing the data in compliance with the applicable laws and regulations, and in particular Law No. 78-17 of 6 January 1978 relating to Information Technology, Data Files and Civil Liberties (hereafter referred to as the “Data Protection Act”), and Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (hereafter referred to as the “GDPR”).
Personal data: any information relating to an identified or identifiable natural person, that is, a person who can be identified, directly or indirectly, by reference to an identification number or to one or more elements specific to that person.
Processing of personal data: any operation or any set of operations relating to personal data, whatever the process used, and in particular the collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, as well as locking, erasure, or destruction.
Cookie : a cookie is a piece of information placed on the hard drive of Internet users by the server of the site they visit. It contains several pieces of data: the name of the server which installed it, an identifier in the form of a unique number, and possibly an expiry date. This information is sometimes stored on the computer in a simple text file that a server accesses to read and save pieces of information.
The data controller for the processing of the personal data referred to herein is SmartColdMail.
SmartColdMail has appointed a Data Protection Officer who can be contacted at the following address: legal@smartcoldmail.com.
SmartColdMail collects data from Users in order to make the Services for which they have subscribed to the platform available to them.
The mandatory or optional nature of the data provided (in order to complete the Users’ registration and to render the Services) is indicated at the time of collection by an asterisk.
In addition, certain data is collected automatically as a result of the User’s actions on the site (see the paragraph on cookies).
The personal data collected by SmartColdMail during the provision of the Services is necessary for the performance of the contracts concluded with the Users, or to allow SmartColdMail to pursue its legitimate interests while respecting the rights of the Users. Certain data may also be processed based on the Users’ consent.
The purposes for which SmartColdMail processes data are the following:
The personal data collected is intended for SmartColdMail’s commercial and accounting departments. It may be transmitted to SmartColdMail’s subsidiaries, or to third-party data processors which SmartColdMail is authorized to use within the context of the performance of its Services.
In this context, personal data may be transferred to an EU or non-EU country. SmartColdMail implements guarantees ensuring the protection and security of this data, in compliance with applicable rules and regulations.
SmartColdMail does not transfer or rent personal data to third parties for marketing purposes without the express consent of the Users of SmartColdMail.
In addition, personal data may only be disclosed to third parties for purposes other than marketing in the following cases:
To satisfy its legal obligations or in order to have the necessary elements to assert its rights, SmartColdMail will be able to retain the data under the conditions established by applicable rules and regulations.
Thus, personal data collected by SmartColdMail relating to the identity and contact details of its Users is retained for a maximum period of two years after the termination of the contractual relationship for Users that are customers, or from their collection by the data controller or the last contact from the Users that are prospects, for the data relating to the latter.
The termination of the contractual relationship is understood as the express termination of the contract by the User, or the non-use of SmartColdMail Services for a period of five years.
In accordance with applicable rules, the Users have the right to access and rectify their personal data, which enables them to rectify, complete, update, or delete data that is inaccurate, incomplete, ambiguous, or outdated, or whose collection, use, communication, or storage is prohibited.
The Users also have the right to request the limitation of the processing, and to oppose on legitimate grounds the processing of their personal data. The User may also communicate instructions on the fate of their personal data in the event of their death.
Where applicable, the User may request the portability of their personal data or, where the legal basis for the processing is consent, withdraw their consent at any time.
The Users may exercise their rights by sending an email to legal@smartcoldmail.com.
These requests shall be processed within a maximum period of 30 days.
The Users may unsubscribe from the SmartColdMail newsletter or marketing emails by following the unsubscribe links in each of these emails.
The Users may access detailed information on the use of their personal data, in particular concerning the purposes of the processing, the legal bases enabling SmartColdMail to process the data, its storage period, its recipients, and, where applicable, its transfer to a country outside the European Union as well as the related compliance guarantees put in place for such transfers. To do so, the User can send their request by email to legal@smartcoldmail.com.
SmartColdMail has taken all necessary precautions to preserve the security of personal data and, in particular, to prevent it from being accessed by unauthorized third parties, distorted, or damaged.
These measures include the following:
In addition, access to processing data on behalf of SmartColdMail by the receiving third-party services requires authentication of the persons accessing the data, by means of an individual access code and password, that is sufficiently robust and regularly renewed.
Data transmitted over unsecured communication channels is subject to technical measures designed to make such data incomprehensible to any unauthorized person.
Any questions about the security of the SmartColdMail website can be directed to support@smartcoldmail.com.
SmartColdMail reserves the right to change this Privacy Policy to comply with changes in the applicable laws and regulations.
The Users shall be notified of any changes made to this policy via our website or by email at least thirty days prior, when possible, to their entry into force.
Any questions about SmartColdMail’s Privacy Policy can be directed by email to legal@smartcoldmail.com.