Privacy Policy

Published on June 17th, 2021 by Thibaut Collette

Legal Context

We abide by the recommendations of the relevant authorities and have put in place an organization to ensure our compliance with the regulatory framework established by the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and any other laws or regulations relating to personal data that apply to us.

The “Websites” means Husprey’s websites, including without limitation our commercial website https://husprey.com, and our web application https://app.husprey.com, and any urls related to husprey.com or husprey.net domains.

The “Service” means Husprey’s product, applications and services, in each case in whatever format they may be offered now or in the future.

Our Commitments

We apply a strict policy to ensure the security, confidentiality and continuous protection of personal data.

In order to comply with the principle of lawfulness, the legal bases for each data processing is determined carefully and on a case-by-case basis in accordance with the list provided by

Article 6 of the General Regulation on Data Protection (GDPR).

  • Consent: you have given clear consent to process your personal data for a specific purpose.
  • Contract: the processing of personal data is necessary for a contract you have with us.
  • Legitimate interest: the processing of your personal data is necessary for our legitimate interests.

We do not process your data without your knowledge, nor do we sell or rent your personal data.

What personal data do we collect?

We collect your data through forms that you fill in on our websites. We also collect your data when you correspond with us, specifically with our customer service, by embedded chat, email, telephone. We may also collect your Data when you interact with us on social networks or if you decide to sign up with one of our Single Sign-On (SSO) partner.

In particular this personal data includes:

  • User identity data: email, first name, profile picture, role, ...
  • Payment information: payment card details (processed by our payment service provider) only when subscribing to paying plan

We also collect the information that you may choose to submit to our customer support team, for example regarding a question you have or a problem you are experiencing with our Service. This may include your contact information, a summary of the problem you are experiencing and any other documentation or information that would be helpful in resolving the issue (which, at your option, may include Personal Data).

We will inform you, when requesting your Personal Data, if certain data must be provided or if it is optional.

Finally, when you interact with Husprey we automatically collect information about you through cookies (small text files placed on your device) and other technologies. Our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Website. This log data includes your Internet Protocol (“IP”) address (from which we understand the country you are connecting from at the time you visit the websites), browser type and settings, and the date and time of your request.

How do we use your personal data?

We only collect and process personal data for specified, explicit and legitimate purposes, like:

  • to allow you to register and authenticate to our Service;
  • to connect to the third-parties/tools, you specifically shared consent to with us;
  • to communicate mandatory information about the Service (important notices, product updates, security alerts, payments receipts, ...). Most of the time, you cannot opt out from this communication. When you can, you'll find a dedicated link in the communication footer, the websites settings. You can also contact us at privacy@husprey.com;
  • to communicate secondary information about the Service (newsletters, ...). You may opt out at any time from this communication. You'll find a dedicated link in the communication footer, the websites settings. You can also contact us at privacy@husprey.com;
  • to manage your payment account;
  • to allow you to share your opinion / feedback about our Service;
  • to improve the Service we offer you and provide you with new features based on our collective learnings of our Service usage;
  • to ensure the security of your data and operations, monitor suspicious or fraudulent activity and identify violations of our Service policies;
  • to comply with legal and regulatory obligations and protect our legitimate Business interests.

Your personal data will never be processed for incompatible purposes regarding why it was first collected.

To whom do we disclose your personal data?

Recipients to whom we disclose your personal data are carefully chosen by us. They receive data for legitimate purposes, whether it is to pursue our activity (hosting provider) or to conform with legal obligations (tax authority).

When we transfer your personal data to a recipient outside the European Union, we take care of putting in place sufficient guarantees in accordance with the list provided by Article 44 to 50 of the General Regulation on Data Protection (GDPR), whether it is having it stored in a country with an adequate privacy protection or contracting data protection agreements to ensure your data are protected.

What are the retention periods for your personal data?

Retention periods of your personal data are determined according to the purposes for which we collected it and our legal obligations. When these purposes are fulfilled or when you ask us, your personal data are archived, erased or anonymized.

For instance, we store your email information to send you our newsletter as long as you don't unsubscribe from it. All user generated content is stored as long as your account is opened.

Is your data processed securely?

We care deeply about the safety of your personal data and that is why we put in place adequate technical and organizational security measures to preserve its confidentiality, integrity and availability.

We take into account the risks for data subjects and therefore follow with great care the recommendations of the competent authorities regarding security.

The data we collect is stored and encrypted on the servers of our provider Amazon Web Services, which ensures a high level of security. These servers are located within the European Union. For the purposes of the service, we may transfer some of your Personal Data to our subcontractors, some of whom are located outside the European Union or the European Economic Area. In this case, we ensure that they are located in a country considered adequate by the European Union in terms of Data protection or we ask them to contractually commit to implement equivalent measures to ensure the protection of your Data (European Commission’s standard contractual clauses and additional measures if necessary).

The transmission of your Data via the Internet is secured through the HTTPS connection protected by an SSL certificate.

You can read more in our Security Overview document available upon request by email to privacy@husprey.com.

What are your rights and how to exercise them?

In accordance with Articles 12 to 23 of the General Regulation on Data Protection (GDPR), you have rights over your personal data that we are committed to respect: right of access, right of rectification, right to object, right to data portability, right to erasure, right to limitation of processing.

These rights can be exercised directly and at any time via email to privacy@husprey.com. We make every effort to answer requests in the shortest possible time.

You also have the right to lodge a complaint with the competent supervisory authority. The competent authority for France is: Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07, France, phone: +33 (0)1 53 73 22 22.

Policy Change

This Privacy Policy may be modified in the future for example to keep it updated with legal jurisprudence and evolution. If we believe the changes are material, you'll be informed either by a special mention on our website or by a personalized warning, by email for instance. If the new Privacy Policy does not meet your requirements, you must stop using the Service.

Contact

You may contact us for any enquiry about this Privacy Policy by email at privacy@husprey.com.

Data Privacy Officer is Joffrey Villard, Président and CTO at Husprey.