Privacy Policy

This policy was originally drafted in French. Translations are made available to facilitate understanding by data subjects, with dpo@solpay.com ensuring their accuracy and completeness. The French version constitutes the reference version to be consulted in the event of any doubt regarding the meaning of a provision.

What is the purpose of our Privacy Policy?

Solpay, which manages the solpay.com website, attaches great importance to the protection and confidentiality of your personal data, which we regard as a mark of our reliability and trustworthiness.

As such, our Privacy Policy clearly demonstrates our commitment to ensuring that Solpay complies with the applicable rules on the protection of personal data and, in particular, those of the General Data Protection Regulation (« GDPR »).

In particular, our Privacy Policy aims to inform you about how and why we process your personal data in connection with the services we provide to you.

Who is our Privacy Policy intended for?

Our Privacy Policy applies to you, regardless of where you live, provided you are at least 15 years old, whether you are one of our customers or a “mere” visitor to the solpay.com website.

If you are under the legal age specified above, you are not permitted to use our services without the prior and explicit consent of one of your parents or the person with parental authority, which must be sent to us by email at dpo@solpay.com.

If you believe we hold personal data concerning your children without your consent, please contact us at the dedicated address provided above.

Why do we process your personal data and on what basis?

We process your personal data primarily for the following reasons:

• to browse our website, use our services and so that we can respond to your enquiries (e.g. requests for information, complaints, etc.) on the basis of our terms and conditions of use and our legitimate interest in providing you with the best possible service.
• to manage our customer service based on the performance of the contract and our legitimate interest in responding as effectively as possible to your enquiries and complaints.
• to keep you informed of our latest offers and events by email, based on our legitimate interest in retaining our existing customers and attracting new potential customers.
• to keep you informed of our latest offers and events by telephone, based on our legitimate interest in retaining our customers and attracting new potential customers.
• to manage invoicing and any outstanding payments, based on our legitimate interest in receiving payment for the provision of our service and in accordance with our terms and conditions.
• to follow us and comment on our posts on social media, based on our legitimate interest in maintaining a dedicated social media page.
• to receive our newsletter, which keeps you informed of all the latest news regarding our services, based on our legitimate interest in building customer loyalty and on your consent if you are not yet a customer of our services.
• to play videos on our website based on our legitimate interest in providing you with video content.
• to book appointments with our teams based on our legitimate interest in providing you with an easy way to book an appointment with us.
• to send out satisfaction surveys based on our legitimate interest in improving our services.

How did we obtain your personal data?

Your data is collected directly from you once you become a customer of our services or a “simple” visitor to our solpay.com website, and we undertake to process your data only for the reasons described above.

For business users only, it is also possible that your personal data may be processed indirectly in the context of trade fairs or social media (e.g. LinkedIn).

However, when you voluntarily post content on the pages we manage on social media, you acknowledge that you are fully responsible for any personal information you may share, regardless of the nature and origin of the information provided.

What personal data do we process and for how long?

We have summarised below the categories of personal data and their respective retention periods:

• For individuals, personal identification data (e.g. surname, first name) and contact details (e.g. email address) are retained for the duration of the service provision, plus the statutory limitation periods, which are generally 5 years.
• For businesses, personal identification data (e.g. surname, first name, job title, company, department, etc.) and contact details (e.g. email address and business telephone number, etc.) are retained for the entire duration of the service provision, plus the statutory limitation periods, which are generally 5 years.
• For individuals, financial and economic data (e.g. bank account number, verification code, etc.) is retained for the period necessary to complete the transaction and manage invoicing and payments, plus the statutory limitation periods, which are generally between 5 and 10 years.
• For business owners, where there is confusion between the name of your business and your personal name (e.g. sole trader, micro-enterprise, etc.), economic and financial data (e.g. bank account number, verification code, etc.) are retained for the period necessary to complete the transaction and manage invoicing and payments, plus the statutory limitation periods, which are generally between 5 and 10 years.
• Telephone number used in connection with our telephone-based sales prospecting campaigns is retained for a maximum of 3 years from the date of our last contact with you.
• Email address, retained for a maximum of 3 years from the last contact we had with you as part of our email marketing campaigns, and retained until the end of your newsletter subscription to receive our newsletter.
• Statistical data relating to the viewing of our videos, which is anonymised and retained indefinitely.
• Connection data (e.g. logs, IP address, etc.) retained for a period of 1 year.
• Cookies, which are generally retained for a maximum of 13 months. For further details on how we use your cookies, please consult our Cookies policy, which is available at any time on our website.

Once the applicable retention periods have expired, the deletion of your personal data is irreversible and we will no longer be able to provide it to you after this period. At most, we may only retain anonymous data for statistical purposes.

Please also note that in the event of a dispute, we are obliged to retain all personal data concerning you for the entire duration of the case, even after the expiry of the retention periods described above.

What rights do you have to control the use of your personal data?

The applicable data protection regulations grant you specific rights which you may exercise at any time and free of charge to control how we use your data.

• The right to access and obtain a copy of your personal data, provided that such a request does not conflict with trade secrets, confidentiality, or the secrecy of correspondence.
• The right to rectify personal data that is incorrect, out of date or incomplete.
• Right to object to the processing of your personal data for marketing purposes, as well as to processing based on our legitimate interests, unless there are legitimate and compelling reasons justifying such processing that override your interests, rights and freedoms.
• For consumers only, the right to register free of charge on the Bloctel cold-calling opt-out list at www.bloctel.gouv.fr.
• Right to request the erasure (“right to be forgotten”) of your personal data that is not essential to the proper functioning of our services.
• Right to restrict the processing of your personal data, which allows you to document the use of your data in the event of a dispute regarding the lawfulness of processing.
• Right to data portability, which allows you to retrieve some of your personal data so that you can easily store or transfer it from one information system to another.
• Right to provide instructions regarding the handling of your data in the event of your death, either directly by you, through a trusted third party, or through a beneficiary.

For a request to be considered, it is essential that it is made directly by you or your representative at dpo@solpay.com.

Requests cannot be made by anyone other than you or your representative. We may therefore ask you to provide proof of identity if there is any doubt as to the identity of the applicant, as well as proof of representation.

We will respond to your request as soon as possible, within a maximum of one month from receipt, unless the request is technically complex or we receive a large number of requests at the same time. In such cases, the response time may be up to three months.

Please note that we may refuse to respond to any excessive or unfounded requests, particularly if they are repetitive in nature.

Who has access to your personal data?

Your personal data is processed by our teams and our technical service providers for the sole purpose of operating our service.

We would like to point out that we vet all our technical service providers before engaging them to ensure that they strictly comply with the applicable rules on personal data protection.

Furthermore, we guarantee that we never transfer or sell your data to third parties or business partners.

Can your personal data be transferred outside the European Union?

The personal data processed by our website is hosted exclusively at our premises within the European Union.

Furthermore, we do our utmost to use only technical tools whose servers are also located within the European Union. Should this not be the case, however, we take great care to ensure that they implement the appropriate safeguards required to guarantee the confidentiality and protection of your personal data.

How do we protect your personal data?

We implement all the technical and organisational measures required to guarantee the security of your personal data on a daily basis and, in particular, to combat any risk of destruction, loss, alteration or disclosure.

Do we use cookies when you browse our website?

Please note that we use cookies when you browse our website. For further information, please see our Cookies Policy.

Who can you contact for more information about the use of your personal data?

To best ensure the protection and integrity of your data, we have officially appointed an independent Data Protection Officer (“DPO”) with our supervisory authority.

You may contact our DPO at any time, free of charge, at dpo@solpay.com to obtain further information or details on how we process your data.

How can you contact the CNIL?

You may contact the “Commission nationale de l’informatique et des libertés” (CNIL) at any time using the following contact details: CNIL Complaints Department, 3 place de Fontenoy – TSA 80751, 75334 Paris Cedex 07, or by telephone on 01 53 73 22 22.

Can the Privacy Policy be amended?

We may amend our Privacy Policy at any time to bring it into line with new legal requirements and any new data processing activities we may implement in the future.