Privacy Policy

Article 1. Parties

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This Privacy Policy applies to the relationship between , the publisher of the Site (namely Steeple, hereinafter “Steeple”), and any person accessing the Site, hereinafter “the User.”

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Article 2. Definitions

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“Site Content”: any material published on the Site, whether or not protected by intellectual property rights, such as text, images, designs, presentations, videos, diagrams, structures, databases, or software.

"User": any person who accesses the Site.

“Site”: the website accessible at the URL www.steeple.com, as well as any related sub-sites, mirror sites, portals, and URL variations.

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Article 3. Scope of Application

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This Privacy Policy applies to all Internet users. By simply browsing the Site, you fully and unconditionally accept this Privacy Policy.

The User acknowledges the evidentiary value of Steeple’s automatic logging systems and, unless the User can provide evidence to the contrary, waives the right to challenge them in the event of a dispute.

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Acceptance of this privacy policy implies that Internet users have the necessary legal capacity to do so, or that they are at least 16 years old, or, failing that, that they have the authorization of a guardian or conservator if they lack legal capacity, or of their legal representative if they are under 16, or that they hold a power of attorney if they are acting on behalf of a legal entity.

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Article 4. Personal Data

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In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on April 14, 2016, and applicable national legislation, Steeple provides you with the following information:

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4.1 - Identity of the Data Controller

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The entity responsible for collecting and processing data is Steeple, SAS, with its registered office at 1C rue Louis Braille, 35136 Saint-Jacques-De-La-Lande, SIREN: 809 726 169, represented by Jean-Baptiste DE BEL AIR.

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4.2 - Identity of the Data Protection Officer

The Data Protection Officer is Deshoulières Avocats Associés, 121 Boulevard de Sébastopol, 75002 Paris, Tel.: +33.1.77.62.82.03, rgpd@deshoulieres-avocats.com, www.deshoulieres-avocats.com.

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4.3 - Data Collection by Steeple

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4.3.1 - Data Collected

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4.3.1.1 - Data Collected While Browsing

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When you browse the Site, you consent to Steeple collecting information regarding:

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- the use made of the site;

- the content you view and click on;

- the device you are using and your software environment;

- your geographic location;

- trackers, web beacons, web storage, and unique advertising identifiers;  

- your connection data (times, pages viewed, IP address).

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4.3.1.2 - Data Collected When Using the Contact Form

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When a user submits the contact form, Steeple collects the following personal data:

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- Last name;

- First name;

- Phone number;

- Name of the company or organization where the Internet user works;

- City where the company or organization is located

- Email address.

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4.3.1.3 - Data Collected When Using the Account Creation Form

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When a user fills out the account creation form, Steeple collects the following personal data:

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- Last name;

- First name;

- Email address.

4.3.1.4 - Data Collected When Using the Newsletter Form

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When a user fills out the newsletter form, Steeple collects the following personal data:

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- Last name;

- First name;

- Email address.

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4.3.2 - Purposes of Collecting Personal Data

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1. The data collected while browsing is subject to automated processing for the following purposes:

2. Develop, operate, improve, provide, and manage the website;

3. Send information and contact individuals, including via email, phone, and push notifications;

4. Contextualize and enhance the user experience;

5. Target advertising content;

6. Enforce the terms and conditions governing the use of the Site.

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The data collected when you use the contact form is processed automatically for the following purposes:

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- Verify the user's identity;

- Communicate with the Internet user;

- Provide a detailed response to the user.

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The data collected when you use the account creation form is processed automatically for the following purposes:

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- Register participants;

- Provide Steeple's services.

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The data collected when you use the newsletter sign-up form is processed automatically for the following purposes:

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- Send a newsletter.

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4.3.3 - Legal Basis for Processing

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The legal basis for the data collected while browsing is Steeple’s legitimate interest, namely to analyze user behavior on the Site and to improve the Site’s security and functionality. With regard to data collected through the use of certain cookies, users are encouraged to refer to Steeple’s cookie policy.

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The legal basis for the data collected when using the contact form is the consent of the data subjects.

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The legal basis for the data collected when using the account creation form is the consent of the individuals concerned.

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The legal basis for the data collected when using the newsletter form is the consent of the individuals concerned.

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4.3.4 - Internal Recipients of the Data

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The collected data can be accessed only by Steeple’s management team and by the staff responsible for managing the website, and is never made freely available to any third-party individual.

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4.3.5 - Retention Period for Personal Data

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Personal data collected while browsing is retained for a reasonable period of time necessary for the proper administration of the Site and for a maximum of 26 months, or until the data subjects withdraw their consent.

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Personal data collected when using the contact form is retained for a reasonable period of time necessary to properly handle the user’s request, up to a maximum of 12 months.

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Personal data collected when using the account creation form is retained for the duration of the user's registration.

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Personal data collected when using the newsletter form is retained until the user unsubscribes from the newsletter.

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At the end of each of these periods, Steeple will archive this data and retain it for as long as it may be held liable.

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Once these retention periods have expired, Steeple undertakes to permanently delete the data of the individuals concerned.

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4.3.6 - Security and Confidentiality of Personal Data

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Personal data is stored under secure conditions, using state-of-the-art technology, in compliance with the provisions of the General Data Protection Regulation and applicable national laws.

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4.3.7 - Minimization of Personal Data

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Steeple may also collect and process any data voluntarily provided by a user, particularly when sending an email to the contact address.

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Steeple provides guidance to Internet users whenever possible when they provide unnecessary or superfluous personal data.

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Steeple is committed to retaining and processing only the data strictly necessary for its operations, and will delete any unnecessary data it receives as soon as possible.

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4.4 - Respect for Rights

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You have the following rights regarding your personal data, which you may exercise by writing to us at our mailing address or by sending an email to the following address: rgpd@steeple.fr.

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4.4.1 - Right to Information, Access, and Data Disclosure

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You have the right to access your personal data.

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Due to Steeple’s obligation to ensure the security and confidentiality of personal data, your request will only be processed if you provide proof of your identity, specifically by submitting a scan of your valid identification document (for requests sent by email) or a signed photocopy of your valid identification document (for requests sent in writing), both of which must be accompanied by the statement “I hereby certify that this copy of my identification document is a true copy of the original. Done at … on …,” followed by your signature.

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To help you with this process, you will find here a sample letter prepared by the CNIL.

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4.4.2 - Right to Rectification, Erasure, and the Right to Be Forgotten

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You have the right to request the correction, updating, blocking, or deletion of your personal data, which may, if applicable, be inaccurate, erroneous, incomplete, or outdated.

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You may also establish general and specific guidelines regarding the handling of your personal data after your death. If necessary, the heirs of a deceased person may request that the death of their loved one be taken into account and/or that the necessary updates be made.

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To help you with this process, you will find here a sample letter prepared by the CNIL.

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4.4.3 - Right to Object to Data Processing

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You have the right to object to the processing of your personal data.

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To do so, please send an email to the following address: rgpd@steeple.fr. In this email, you must specify the data you wish to have deleted, as well as the reasons for your request, unless it is related to commercial solicitation.

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4.4.4 - Right to Data Portability

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You have the right to receive the personal data you have provided to us in a transferable, open, and readable format.

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4.4.5 - Right to Restriction of Processing

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You have the right to request that Steeple restrict the processing of your personal data. This means that Steeple will only be able to store your data and will no longer be able to use it.

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4.4.6 - Withdrawal of Consent

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Your consent is required for Steeple to process your data. However, you may withdraw your consent at any time. Withdrawing your consent will result in the deletion of your personal data.

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However, services that require Steeple to process your data will no longer be available.

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4.4.7 - Response Times

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Steeple is committed to responding to your request for access, correction, or objection, or any other request for additional information, within a reasonable timeframe that shall not exceed one month from the date we receive your request.

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4.4.8 - Complaint to the Competent Authority

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If you believe that Steeple is not complying with its obligations regarding your personal information, you may file a complaint or submit a request with the relevant authority. In France, the relevant authority is the CNIL, and you can submit a request here.

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4.5 - Transfer of Collected Data

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4.5.1 - Transfer to Partners

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Steeple hereby informs you that we use authorized service providers to facilitate the collection and processing of the data you have provided to us. These service providers may be located outside the European Union and have access to the data collected on the Site.

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Steeple has ensured in advance that its service providers have implemented adequate safeguards and comply with strict conditions regarding confidentiality, data use, and data protection.

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4.5.2 - Transfer Upon Court Order or Ruling

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The User also agrees that Steeple may disclose the collected data to any person, upon request by a government authority or pursuant to a court order.

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4.5.3 - Transfer in Connection with a Merger or Acquisition

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If Steeple is involved in a merger, an asset sale, a financing transaction, a liquidation, or bankruptcy, or in an acquisition of all or part of its business by another company, the User agrees that the data collected may be transferred by Steeple to that company and that such company may process personal data as described in this Privacy Policy in Steeple’s stead.

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Article 5. Intellectual Property

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5.1 - Legal Protection of the Site's Content

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The Site’s Content may be protected by copyright and database rights. Any representation, reproduction, translation, adaptation, or modification, in whole or in part, carried out unlawfully and without the consent of Steeple or its rights holders or successors in title constitutes a violation of Books I and III of the Intellectual Property Code and may result in legal action for infringement.

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5.2 - Contractual Protection of the Site's Content

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The User is contractually obligated to Steeple not to use, reproduce, or display, in any manner whatsoever, the Site’s Content—whether or not it is protected by intellectual property rights—for any purpose other than its reading by a robot or browser. This prohibition does not apply to web crawlers whose sole purpose is to scan the Site’s content for indexing purposes.

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Article 6. Final Provisions

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6.1 - Changes

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This Privacy Policy may be modified at any time by Steeple. The terms and conditions applicable to the User are those in effect at the time the User logs in to the Site; any subsequent login to the Site constitutes acceptance of the new terms and conditions, if applicable.

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6.2 - Entire Agreement

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The invalidity of any provision of this contract shall not render the other provisions of the contract or the contract as a whole invalid; such provisions shall remain in full force and effect. In such a case, the parties shall, to the extent possible, replace the invalid provision with a valid provision that reflects the spirit and purpose of this contract.

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6.3 - Non-Waiver

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Steeple’s failure to exercise the rights granted to it herein shall in no event be construed as a waiver of its right to assert such rights.

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6.4 - Languages

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These terms and conditions are provided in French.

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6.5 - Unfair Terms

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The provisions of these terms and conditions apply subject to compliance with the mandatory provisions of the Consumer Code regarding unfair terms in contracts between a business and a consumer.

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Article 7. Disputes

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7.1 - Governing Law

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This Privacy Policy is subject to French law and European regulations, in particular the European General Data Protection Regulation.

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7.2 - Disputes

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Pursuant to Order No. 2015-1033 of August 20, 2015, any disputes that may arise in connection with the performance of these general terms and conditions and that cannot be resolved amicably between the parties must be submitted to a certified mediator.

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7.3 - Arbitration

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Any dispute arising out of or relating to this contract shall be resolved by arbitration in accordance with the FastArbitre Rules of the Digital Institute of Arbitration and Mediation.

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