Privacy Policy
Introduction
Please read the following to learn more about Spellz’s privacy policy (hereinafter “Privacy Policy” or “Policy”) in order to understand how Spellz collects, uses, communicates, discloses and otherwise makes use of personal information.
In this Policy, “Spellz”, “we” or “us” refers to DEEPOR, a French company registered with the trade register of Evry under n°B 821 875 705, having its registered address located at 9 rue Charles Fourier 91000 Evry-Courcouronnes France. Within this context “You” or “Users” refers to any natural person who downloads and uses services provided by Spellz’s application.
For the purpose of this Policy, “Personal Data” means any information relating to an identified or identifiable individual. This includes personal information you provide or generate when you use our vocal assistant product (hereinafter “Product” or “Services”).
Other words beginning by a capital letter have the meaning given by the applicable data protection legislation including General Data Protection Regulation 2016/679 enacted April 27th 2016 entered into force in May 25th 2018 (“GDPR”).
According to GDPR, when you use our Services, we act as the “Data Controller”, and you are the “Data Subject”. Acting as a Data Controller means that we determine the purpose and means of the processing of your Personal Data. As a Data Subject, GDPR gives you several rights as described hereinafter in the Privacy Policy.
By using or accessing Spellz’ platform, you acknowledge that you accept our practices and policies as detailed in this Policy. If you do not agree with this Policy, you must not use our Services.
1. Personal Data collected by Spellz
We process your Personal Data as follows:
a) Personal Data that you provide to us:
We collect the following information including your Personal Data:
- Registration Information. When you create an account to use our Services, you will be asked to provide your name, company name, e-mail, phone number, pseudo, password, and you may voluntarily add a profile picture.
- Product Information. When you use the Services, you provide to us your voice audio recordings (“Vocal Recordings”) which constitute biometric data, highly personal data;
- Sensitive data. When you use the Services, you may also record content such as e-mails, schedules and any other highly personal and/or sensitive data included into the Vocal Recordings content. In case you record sensitive data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning health or data concerning a natural person’s sex life or sexual orientation you need to agree specifically to the processing of such data for the purpose of providing the Service by checking he box below. If you do not accept processing of such data you must abstain from including such data in your recordings
b) Personal Data automatically collected generated when you use our Services:
We process the following information including Personal Data automatically generated when you use our Services:
- Usage Information. When you use our Services, you may generate information pertaining to your use such as access, record, share, edit and delete events interactions with co-workers or other third parties;
- Device Information. When you use our Services, you provide information such as your IP address, device IDs and other device information (such as carrier type, whether you access our Service from a desktop or mobile platform, device model, brand, web browser and operating system);
- Cookies. We use Cookies and other similar technologies (“Cookies”) to enhance your experience when using the Service. For more information about our Cookies processing, see how we use cookies below at Article 5.
c) Personal Data you provide to us about third parties
- Information we receive from you about third parties. If you choose to collaborate on a task with your co-workers or other third parties, or refer us to them, you may provide us email addresses and contact information of co-workers or other third parties;
- Information we receive from you about third parties through Vocal Recording. If you provide a Vocal Recording, it may contain third parties’ Personal Data. Before you do so, please make sure you have the necessary permissions from your co-workers or other third parties for sharing their Personal Data.
d) Personal data received by third party platforms
- Information we receive from third party platforms. We may collect Personal Data through the registration process and/or through your account settings such as your name, email address and third-party account credentials (for example, your log-in credentials for Google or other third-party websites). We may also collect Personal Data through data matching with other applications (for example, Salesforce).
2. Personal Data collected by Spellz
Purposes of the processing
Sub-purposes
Legal Base
Registration
• We collect information to set up an account for you to use our Services
Purposes of the processing
• We use your communication information to facilitate support (e.g. retrieval of a forgotten password)
Performance of a contract GDPR Art. 6 1. b)
Purposes of the processing
Services provision
• Enable connection/interaction with other applications/third party platforms: Google Microsoft CRM, Salesforce and others
Performance of a contract GDPR Art. 6 1. b)
Improvement and monitoring of Services through IA
• We train our proprietary artificial intelligence technology on aggregated, non identifying (de-identified) audio recordings
Legitimate interest GDPR Art. 6 1. f)
Cookies
• To enable core functionality of our Services, such as login and security functionalities
Purposes of the processing
• To recognize you when your return to our Services and serve you a personalized experience, such as your language preferences
• To help us to understand how users engage with our Services, and to measure and optimize our advertising effectiveness
Legitimate interest GDPR Art. 6 1. f)Legitimate interest GDPR Art. 6 1. f)
Consent GDPR Art. 6 1. a)
Newsletter
• Send you newsletters about product news or updates that may be of interest to you
GDPR Art. 6 1. a) opt-out or opt in
3. Data retention period
We process your Personal Data as follows:
Purposes of the processing
Category of Data
Data Retention Period
Registration
• ID data: first and last names• Authentication data: e-mail address, log-in, password, pseudo. When login via Google we collect the following information: email address, first and last names, company name, phone number
Deletion of Personal Data at the termination of your accountWe may, to the extent that we are required to do so by law to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention) retain such data for the duration of this purpose in an archival basis
Services provision
• Technical information: IP address• Highly Personal Data: biometric data (Voice Recording)• Sensitive data (GDPR Art. 9): potentially in therecording content, e-mails, schedules (e.g: racial or ethnic origin, political opinions, religious or philosophical beliefs)• Data matched from other applications (e.g Salesforce)
Deletion of Personal Data at the termination of your account
Improvement and monitoring of Services through IA
• Highly Personal Data: voice recordings are pseudonymized
Deleted as soon as improvement of IA has been completed
Newsletter
Authentication data: e-mail address
Spellz keeps e-mail addresses as long as individuals concerned does not unsubscribe (via the unsubscribe link integrated to the newsletter)
Cookies
• To enable core functionality of our Services, such as login and security functionalities
Purposes of the processing
4. With whom we share your Personal Data (Data recipient)
We share your Personal Data with selected third parties, including:
- Vendors and service providers we rely on for the provision of the Services, for example:
- Cloud service providers who we rely on for data storage, including:
- Amazon Web Services (AWS), based in the United States. For more information about Personal Data Processing please refer to their own privacy policy hereinafter: https://aws.amazon.com/fr/compliance/data-privacy-faq/
- OVHcloud based in France. For more information about Personal Data Processing please refer to their own privacy policy hereinafter: https://www.ovh.com/fr/protection-donnees-personnelles/
- Providers of integrated third-party programs, products or platforms, such as Salesforce. When you connect third party platforms to our Services, you authorize us to share designated information and data created and/or uploaded by you to our servers with these third-party programs on your behalf.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you sePersonal Data might be transferred within the meaning of GDPR to recipients outside European Union (EU) which do not offer a level of protection equivalent to GDPR principles. In this context, the Personal Data transfers we operate are compliant with GDPR principles and European Data Protection Board (EDPB) guidelines through Standard Contractual Clauses implementation
5. Data security and confidentiality of Personal Data
Your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via such third-party site or service.
6. Cookies
Cookies are packets of information sent to your web browser or device and that allow Spellz to recognize your browser or device.
We use three types of cookies:
- Technical Cookies. These cookies are required to enable core functionality of our Services, such as login and security functionalities.
- Functional Cookies. These cookies allow us to recognize you when your return to our Services and serve you a personalized experience, such as your language preferences.
- Targeting Cookies. These cookies are provided by third parties to help us understand how users engage with our Services, and to measure and optimize our advertising effectiveness.
Some cookies are removed when you close your browser or product session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies.
You may refuse Cookies by configuring your browser as follows:
For Internet Explorer:
For Firefox:
For Chrome:
For Safari:
For Opera:
If you refuse Cookies you may no longer be able to benefit from a number of features that are necessary to navigate in the Product.
7. User’s Rights
In certain circumstances you have the following rights in relation to your Personal Data that we process.
- Access. You have the right to access the Personal Data we process about you, and the right to receive an explanation of how we use it and who we share it with.
- Correction. You have the right to correct any Personal Data we hold about you that is inaccurate or incomplete.
- Deletion. You have the right to request for your Personal Data to be erased or deleted.
- Object to processing. You have the right to object to our processing of your Personal Data where we are relying on a legitimate interest or if we are processing your Personal Data for direct marketing purposes.
- Restrict processing. You have a right in certain circumstances to stop us from processing your Personal Data other than for storage purposes.
- Portability. You have the right to receive, in a structured, commonly used and machine-readable format, Personal Data that you have provided to us if we process it on the basis of our contract with you, or with your consent, or to request that we transfer such Personal Data to a third party.
- Withdraw consent. You have the right to withdraw any consent you previously provided to us. We will apply your preferences going forward, and this will not affect the lawfulness of processing before your consent was given.
Please note that, prior to any response to the exercise of such rights, we will require you to verify your identity. In addition, we may require additional information (for example, why you believe the information we hold about you is inaccurate or incomplete) and may have valid legal reasons to refuse your request. We will inform you if that is the case.
For any questions regarding the processing of their Personal Data and the exercise of their rights, Users may contact the dedicated service at the following address:
8. Changes to the current Policy
Spellz reserves the right to modify this Policy to comply with obligations under privacy legislation or to adapt it to its practices.
9. Contact
If you have any questions about this Policy or if you have any requests relating to your Personal Data, you may contact us by:
- sending an email to: privacy@spellz.app
- sending a letter to:DEEPORAttention: DEEPOR’s CEO130 rue de Lourmel 75015 Paris, France
For any questions regarding the processing of their Personal Data and the exercise of their rights, Users may contact the dedicated service at the following address: privacy@spellz.app
