This privacy policy (hereinafter referred to as the "Privacy Policy") defines the conditions for the
processing of personal data by SMART ROLE, a simplified joint-stock company, registered with the
Paris Trade and Companies Register under number 987831682, with its registered office at 1 Rue
de Stockholm, Paris, 75008, France (hereinafter "Smart Role"), concerning internet users browsing
the Website and its Clients (hereinafter the "Users").
Terms with an initial capital letter not defined in the Privacy Policy are defined in the General Terms
of Sale and Use of the Company.
The personal data of the User is processed by Smart Role as the data controller. Smart Role
complies in all circumstances with the regulations applicable to it regarding the protection of
personal data, including the provisions of the French Data Protection Act No. 78-17 of January 6,
1978, as amended, and the EU Regulation 2016/679 of the European Parliament and Council of
April 27, 2016, on the protection of natural persons with regard to the processing of personal data
and on the free movement of such data (hereinafter collectively referred to as the "Data Protection
Regulation").
1. CATEGORIES OF DATA PROCESSED
The personal data concerned by the processing implemented in this context are:
- Identification data such as name, first name, email, address, and others;
- Data related to the User's interactions with the Website;
- Data related to purchase behaviors; and
- Location data.
2. PURPOSES OF PROCESSING
Information relating to the Client Account is processed to create and manage the Client Account.
The legal basis for this processing is consent, which can be withdrawn at any time. However, the
provision of the User's personal data is essential for creating a Client Account. Refusal to provide
this data makes it impossible to create the Client Account.
Information relating to orders of Products and/or Services is collected for processing and tracking
orders, as well as for fraud prevention, statistical analysis, and customer knowledge purposes. The
legal basis for this processing is the General Terms of Sale and Use. The provision of the User's
personal data is essential for placing an order on the Website. Refusal to provide this data makes
it impossible to process any order.
Smart Role also uses certain personal data of Users for marketing and targeted advertising
purposes (sending electronic communications, postal or telephone prospecting, and advertising
profiling by data combination) for its own account or that of partners. The legal basis for this
processing is consent, which can be withdrawn at any time, in which case commercial
communications directed towards the User will cease.
3. RECIPIENTS OF PERSONAL DATA
Personal data is hosted by a service provider located in the European Union, whose identity and
contact details are specified in the Website's legal notices.
The User is informed that Smart Role may also share their personal data with public bodies or
authorities requesting it to comply with a legal obligation or protect rights, and with potential
future buyers in compliance with the Data Protection Regulation.
Certain personal data may be transmitted to Smart Role's partners (the "Subsequent Processors").
The Subsequent Processors of Smart Role have their own privacy policies to which the User is
invited to refer. In any event, these partners are only authorized to use the Personal Data within the
framework of the activities described above that they carry out on behalf of Smart Role and only
for the purposes provided herein.
Smart Role informs the User of any addition or modification of Subsequent Processors affecting
the scope of the processing it carries out via the update of its Privacy Policy. The User is invited to
regularly consult this Privacy Policy and to raise any objection regarding a Subsequent Processor,
in writing and as soon as possible.
4. DATA RETENTION PERIOD
The personal data of Users is kept only for the time necessary to achieve the purpose for which
Smart Role collected this data, to meet the needs of Users, or to fulfill its legal or regulatory
archiving obligations.
To determine the retention period for personal data, Smart Role applies the following criteria:
- In case of ordering Products and/or Services: personal data is kept for the duration of the
contractual relationship and three years after collection or the last contact with the User, for
commercial prospecting purposes;
- Smart Role may retain certain data to meet its legal or regulatory archiving obligations, to enable
it to exercise its rights, and/or for statistical or historical purposes.
At the end of the periods mentioned above, the personal data will be deleted, or Smart Role will
proceed with its anonymization.
5. RIGHTS OF THE DATA SUBJECTS
The User has the right to access, rectify, delete (erase), and port their personal data, to limit
processing, and to object to the processing of their data collected and processed by Smart Role,
by directly contacting Smart Role at the following email address: legal@smartrole.ai
In case of a complaint, the User can contact the CNIL, the competent authority for personal data
protection, at the following address: 3 Place de Fontenoy, 75007 Paris, phone: 01 53 73 22 22.
6. COOKIE MANAGEMENT
Cookies are information placed by a website on a user's equipment when they visit the Website. A
cookie does not necessarily contain the name or email address of the User.
Cookies are used to store information relating to the User's terminal navigation on the Website,
such as the pages visited by the User or the date and time of the visit. This allows the page to
display information tailored to the User's needs.
The Website uses cookie technology to process statistical data and provide detailed information
on, in particular, the number of Users who have accessed the Website, the ways of accessing the
Website, and the number of accesses by each User to the Website.
Smart Role uses different types of cookies to meet different needs:
| Cookie Type | Purpose |
| Functional | Essential |
| Audience measurement | Optional |
| Personalized content | Optional |
| Personalized advertising | Optional |
| Developing and improving products | Optional |
The installation of certain cookies is subject to the User's consent when their sole purpose is not
to enable or facilitate navigation on the Website or when they are not strictly necessary for the
provision of Products and/or Services or the management of the relationship with the User. During
the first visit to the Website, the User is informed by a banner of the conditions for placing cookies
on their terminal, and they can freely refuse or accept them.
When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We (or service providers on our behalf) may then send communications and marketing to these emails. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.
The User can always refuse the storage of cookies by configuring their browser. Disabling
essential cookies may hinder the use of all interactive features of the Website.
- If using Internet Explorer:
- In Internet Explorer, click on the "Tools" button, then on "Internet Options."
- Under the General tab, under "Browsing history," click on "Settings."
- Click on the "View files" button.
- Click on the column header "Name" to sort all files alphabetically, then browse through the list
until you see files starting with the prefix "Cookie" (all cookies have this prefix and usually contain
the name of the website that created the cookie).
- Select the relevant cookies and delete them.
- Close the window that contains the list of files, then click twice on OK to return to Internet
Explorer.
- If using Firefox:
- Go to the "Tools" tab of the browser and select the "Options" menu.
- In the window that appears, choose "Privacy" and click on "Show cookies."
- Locate the relevant files, then select and delete them.
- If using Safari:
- In this browser, choose the "Edit > Preferences" menu.
- Click on "Security."
- Click on "Show cookies."
- Select the relevant cookies and click on "Delete" or "Delete all."
- After deleting the cookies, click on "Done."
- If using Google Chrome:
- Click on the "Tools" menu icon.
- Select "Options."
- Click on the "Advanced options" tab and access the "Privacy" section.
- Click on the "Show cookies" button.
- Locate the relevant files, select, and delete them.
- Click on "Close" to return to the browser.
7. INTERACTIONS WITH THIRD PARTY AI MODEL PROVIDERS
In order to deliver our services effectively, Smart Role utilizes third party AI model providers. The integration and interactions with these providers are governed by strict data privacy and security standards to ensure the protection of user data.
• Data Exchange/Isolation: When using third party AI model providers, such as Azure GPT-4, our data exchanges are strictly transactional. This means that the data is used solely for the purpose of processing specific requests and is not retained or used by the third party for any other purposes, including training their models. Our data is isolated and protected, ensuring compliance with data protection regulations.
• Data Localization: When using Azure GPT-4 we have specified that our data and models are hosted in Europe, allowing us to comply with regional data residency and sovereignty requirements. This ensures that user data is handled according to European data protection standards.
• Encryption and Access Control: Data exchanged with third party AI model providers is encrypted both in transit and at rest. Access to data is controlled through granular role-based access controls and auditing mechanisms to ensure that only authorized personnel have access to sensitive information.
• Control and Compliance: We leverage the robust security measures of our AI model providers, which include compliance with industry standards such as ISO, HIPAA, and GDPR. This ensures that user data is managed in accordance with the highest security standards.
• User Interactions: Users should be aware that any information provided to the AI models during interactions is used solely for the purpose of enhancing the interaction and delivering accurate responses. Users are advised not to share sensitive personal information (e.g., credit card information, social security numbers) during these interactions.
For more information about our third party AI model providers and how they handle data, please refer to their respective privacy policies and compliance documentation.