Privacy Policy
The purpose of this Privacy Policy is to clearly inform you about the personal data that may be collected by FASST, the reasons for which it is used, who may have access to it, how long it is retained, and the rights you have.
1. Data Controller
FASST acts as the data controller for the processing of personal data described in this Privacy Policy.
F.ASS.T116 rue du Capitaine Favre
16000
Angoulême
If you have any questions regarding the protection of your personal data or wish to exercise your rights, you may contact our Data Protection Officer at the following address: dpo@fasst.io
2. Personal Data Collected
When you browse the FASST website or use the various services offered, certain personal data may be collected. When you fill out a contact form, request a demo, schedule an appointment, download content, or subscribe to a newsletter or the Gazette, FASST may collect, among other things, your last name, first name, job title, company name, email address, phone number, and any information you choose to provide in your request.
Certain technical information may also becollected while you browse the website, including your IP address, the type of browser or device used, the pages viewed, and the dates and times of your visits.
When you consent to the tracking of our electronic communications, certain information regarding your interaction with our emails may also be collected under the conditions specified in the “Tracking of Our Electronic Communications” section.
FASST ensures that it collects only data that is adequate, relevant, and necessary for the purposes pursued.
3. Purposes and Legal Bases for Data Processing
FASST uses your personal data only for specific purposes and when there is a legal basis for processing it.
Processing Your Requests
When you use a form to contact FASST, request a demonstration, schedule an appointment, or obtain content or a service, your data is used to process your request and contact you.
Depending on the nature of your request, this processing is based on the performance of pre-contractual measures taken at your request or on FASST’s legitimate interest in responding to requests made to it.
Management of the Business Relationship
When you are a FASST customer or have a business relationship with FASST, certain data may be used to manage and monitor that relationship, provide the requested services, and comply with our contractual, administrative, accounting, or legal obligations. Depending on the situation, this processing is based on the performance of a contract, compliance with a legal obligation, or FASST’s legitimate interest.
Newsletters, Updates, and Marketing Communications
When you subscribe to a newsletter or a Gazette, or agree to receive communications from FASST, your email address and related information may be used to send you news, invitations, content, and information regarding FASST’s offers or services.
When your consent is required, these communications are sent to you based on that consent. You may withdraw your consent at any time.
Aspart of its marketing efforts targeting professionals, FASST may use your contact information based on its legitimate interest when the solicitation is related to your professional activity. You may object to the use of your data for this purpose at any time, easily and free of charge.
Personalization and Measurement of Our Electronic Communications
When your consent is required, FASST may analyze certain interactions with its emails to measure their performance, improve the content sent to you, and adjust the frequency of these communications. The terms of this processing are specified in the section “Tracking Our Electronic Communications.”
Audience Measurement and Website Improvement
Subject to your consent where required, certain browsing data may be used to measure website traffic, understand how the site is used, and improve its content, functionality, and user experience.
4. Tracking of Our Electronic Communications
Some emails sent by FASST may contain trackers, including tracking pixels. These pixels are small images hosted on remote servers that may be loaded when the recipient views the images in the message. Loading these pixels may allow FASST to determine whether an email has been opened and to collect certain information regarding its viewing, including the date and time of opening, the IP address, and certain technical information about the device or email software used.
The pixels may be loaded on the various devices from which youaccess the email address in question.
FASST obtains your consent before using tracking pixels for the purposes of measuring and optimizing its email campaigns or detecting and analyzing suspected fraud.
The individual measurement of open rates fordeliverabilitypurposesis also subject to your consent when it does not meet the conditions for an exemption provided for by regulation.
Measuring and Optimizing the Performance of Our Email Campaigns
FASST and its technical service providers use tracking pixels to determine whether you open the emails sent to you, when they are viewed, and certain information regarding the device used. This information allows FASST to measure and optimize the performance of its email campaigns, particularly by personalizing the content of the messages sent to you or by adjusting the frequency with which they are sent. FASST may also implement processes designed to ensure the reliability of this measurement and to identify opens that do not correspond to normal viewing of the message.
Detection and Analysis of Suspected Fraud
FASST may use information from tracking pixels to detect and analyze certain situations that may indicate fraudulent or automated behavior. This analysis may, in particular, help identify unusual or massive numbers of email opens, which may result from an automated process, abnormal registrations, or attempts to misuse FASST’s services or communications. To this end, FASST may, in particular, take into account the date and time messages are opened, as well as certain technical information regarding the device used.
Measuring the Open Rate for Deliverability Purposes
FASST may also analyze the opening of specific emails on an individual basis to assess their deliverability and ensure the proper management of its mailing lists.
This analysis may, in particular, help identify inactive recipients, adjust the frequency of mailings, or discontinue communications sent to certain addresses when they are no longer active or relevant.
When this deliverability measure strictly meets the conditions for a consent exemption as provided by regulations, FASST limits the use of data to what is strictly necessary for this purpose.
When these conditions are not met, FASST obtains your consent before proceeding with this individualized measure.
Managing Your Consent and Objections
You may withdraw your consent or object to the tracking of your emails at any time by using the “I object to the tracking of my emails” link included in the relevant communications. To stop receiving our news, invitations, offers, or content, you can use the separate unsubscribe link included in each of our emails.
The information collected as part of the tracking of communications is accessible to authorized FASST teams as well as to its technical service providers involved in the management, sending, and analysis of its communications, notably HubSpot.
Individualized data resulting from this tracking is used for as long as necessary to fulfill the purposes forwhich it was collected and for as long as your consent remains valid, where consent is required. If you withdraw your consent or object to this monitoring, this data will no longer be used for these purposes and will then be deleted or anonymized in accordance with FASST’s data retention policies.
Evidence of your consent, its withdrawal, or your objection is retained for as long as necessary to demonstrate compliance with our obligations.
5. Recipients of the Data
Your personal data is accessible only to individuals who need to know it in order to perform their duties. In particular, it may be accessible to authorized FASST teams as well as to technical service providers acting on its behalf in the hosting, maintenance, and management of the website; the management of relationships with prospects and customers; the management of forms; the sending of communications; or the analysis of their performance.
FASST usesHubSpot’s services for certain operations related to the website, forms, contact management, and the sending or analysis of communications.
These service providers operate in compliance with the contractual and regulatory obligations applicable to the protection of personal data.
FASST may also be required to disclose certain information when such disclosure results from a legal obligation or a request from a legally authorized authority.
6. Data Transfers Outside the European Economic Area
When using certain technical service providers, personal data may be processed or accessed from countries outside the European Economic Area.
When such transfers occur, FASST ensures that they are governed in accordance with applicable regulations, in particular through an adequacy decision, a recognized applicable protection framework, standard contractual clauses approved by the European Commission, or any other mechanism that ensures an appropriate level of protection.
You can obtain further information on the applicable safeguards by contacting our Data Protection Officer at dpo@fasst.io.
7. Retention Periods
FASST retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to legal retention obligations and the time periods required to establish, exercise, or defend legal rights.
Data provided by a prospective clientvia a form or as part of a pre-contractual business relationship may be retained for a maximum of three (3) years from the last contact with FASST.
Once a contractual relationship is established, the data necessary to manage that relationship is retained for the entire duration of the relationship and then, where necessary, archived for the periods required by applicable legal provisions. Data used to manage your subscription to FASST communications is retained for as long as necessary to manage that subscription.
When you unsubscribe or opt out of marketing communications, FASST may retain the information strictly necessary to comply with and demonstrate that your choice has been taken into account.
Data collected from email tracking is retained under the conditions specified in the section “Tracking Our Electronic Communications.”
8. Cookies and Other Trackers on the Website
The FASST website may use cookies and other trackers. Certain trackers are strictly necessary for the website to function or to provide a requested service and may be used without your consent when the conditions set forth by regulations are met.
Other trackers, particularlythose used for audience measurement, analysis, or personalization, are used only after obtaining your consent when required.
While browsing the site, the cookie management module allows you to accept, reject, or configure the relevant categories of trackers. You can change your choices or withdraw your consent at any time, just as easily as you gave it, using the cookie management tool available on the site.
9. Your Rights Regarding Your Personal Data
In accordance with applicable data protection regulations, you have various rights regarding FASST’s use of your data.
These rights may vary depending on the nature of the processing and its legal basis.
To exercise any of these rights, you may contact our Data Protection Officer at the following address: dpo@fasst.io.
When necessary, FASST may ask you for additional information to verify your identity and ensure that the request is indeed coming from the data subject.
Right of Access
You may ask FASST to confirm whether personal data concerning you is being processed and, if so, to obtain access to that data as well as information regarding its processing. In particular, you may obtain information regarding the purposes of the processing, the categories of data involved, the recipients of the data, the retention period, and your rights.
Right to Rectification
You may request the correction of your personal data when it is inaccurate, as well as its updating or completion when it is incomplete.
Right to erasure
Under the conditions set forth by the regulations, you may request the erasure of your personal data, particularly when it is no longer necessary for the purposes for which it was collected, when you withdraw your consent and no other legal basis justifies its retention, when you validly object to the processing, or when the data has been processed unlawfully. This right is not absolute. FASST may be required to retain certain data when a legal obligation so requires or when such retention is necessary for the establishment, exercise, or defense of legal claims.
Right to Restriction of Processing
In certain situations provided for by law, you may request that the use of your data be temporarily restricted. This may be the case, for example, when you contest the accuracy of your data, for the time necessary to verify it, or when you object to processing, while your request is being reviewed. During this period, the data in question is retained but its use is restricted, except in situations provided for by law.
Right to Object
When the processing of your data is based on FASST’s legitimate interest, you may object to such processing for reasons related to your particular situation.
You may also object at any time, without having to justify your request, to the use of your personal data for marketing purposes. When you object to the tracking of your electronic communications, the tracking activities to which you have objected will cease to be carried out under the conditions specified in the section “Tracking of Our Electronic Communications.”
Right to Data Portability
When processing is based on your consent or on the performance of a contract and is carried out using automated means, you may request to receive the personal data you have provided to FASST in a structured, commonly used, and machine-readable format. Where technically feasible, you may also request that this data be transmitted directly to another data controller.
Withdrawal of Consent
When the processing of your personal data is based on your consent, you may withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of processing carried out prior to such withdrawal. For electronic communications containing tracking pixels that require consent, you may exercise this right by clicking the “I object to the tracking of my emails” link provided in the relevant communications.
Automated Individual Decisions
You have the right not to be subject to a decision based solely on automated processing, including profiling, where such a decision produces legal effects concerning you or similarly significantly affects you, except in situations expressly provided for by law.
In connection with the processing described in this Privacy Policy, FASST does not use decisions based solely on automated processing that produce such effects on you.
However, certain interactions with our emails may be analyzed—subject to your consent where required—in order to measure the performance of our communications, tailor their content or frequency, ensure their deliverability, or detect certain unusual behaviors.
10. Filing a Complaint with the CNIL
If, after contacting FASST, you believe that your rights have not been respected or that the processing of your personal data does not comply with applicable regulations, you may file a complaint with the French Data Protection Authority (CNIL).
11. Data Security and Privacy
FASST implements appropriate technical and organizational measures to protect personal data against destruction, loss, alteration, disclosure, or any unauthorized access. Access to personal data is limited to staff and service providers who need to access it in connection with their duties or the services they provide to FASST.