At Jool, the protection of your personal data is a priority. When you use the website “www.jool.co” (the “Site”) and within the context of managing our contractual relationships with our customers, we may collect personal data about you. The purpose of this policy is to inform you about how we process this data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) and the French Act No. 78-17 of 6 January 1978 on data processing, files and individual liberties.
1. Who is the data controller?
When you browse our Site or within the context of managing our contractual relationships with our customers, the data controller is JOOL, a simplified joint-stock company, registered with the RCS of Bobigny under number 981 367 493 and whose registered office is located at 1-3 place Martin Levasseur, 93400 Saint-Ouen, France (“Us”).
2. What personal data do we collect?
Personal data means data that can identify an individual directly or by cross-referencing with other data. We collect personal data falling within the following categories:
- Identification data (last name, first name, email address, phone number);
- Professional life data (company name, position and role);
- Recorded phone calls between you and our customer-service team (call content, dates);
- Any information you wish to share with us in the context of a contact request.
Mandatory data is identified when you provide it. It is flagged by any appropriate means.
3. On what legal grounds, for what purposes and for how long do we keep your personal data?
| Purpose | Legal basis | Retention period |
|---|---|---|
| Improving our services | Our legitimate interest in improving our services | Recorded phone calls are kept for six months from collection. Documents analysing the content of phone calls are kept for one year from the recording. |
| Managing your reviews of our services | Our legitimate interest in gathering your feedback on our services | 2 years from publication of the review. |
| Producing statistics (browsing, Site audience, etc.) and improving Site features via audience-measurement cookies | Our legitimate interest in analysing the composition of our customer base and improving our services | Data is kept for 25 months. |
| Building a file of customers and prospects | Our legitimate interest in growing and promoting our business | For customers: data is kept for the entire duration of the contractual relationship. For prospects: data is kept for 3 years from your last contact. |
| Sending newsletters, solicitations and promotional messages by email | For customers: our legitimate interest in retaining and informing our customers. For prospects: your consent. | For prospects and customers, data is kept for 3 years from your last contact. |
| Conducting telephone outreach | Our legitimate interest in growing and promoting our business | Data is kept for 3 years from your last contact. We commit to checking beforehand that your number does not appear on a BLOCTEL-type opt-out list. |
| Responding to your information requests | Our legitimate interest in responding to your requests | Data is kept for 3 years from your last contact. |
| Managing requests to exercise data subject rights | Our legitimate interest in responding to your requests and keeping track of them | If we ask for an identity document, we keep it only for the time needed to verify your identity. Once verification is done, the document is deleted. Information used to handle your data-rights requests under the GDPR is kept for 3 years from the date of the request. |
4. Who are the recipients of your data?
The following will have access to your personal data:
- Our staff;
- Our subcontractors: hosting provider, newsletter and SMS provider, analytics and performance solution, communication tools (CRM, customer feedback, internal logistics), audience-measurement and analysis provider, email provider, cookie-management tool;
- Where applicable, public and private bodies, exclusively to meet our legal obligations.
5. Is your data likely to be transferred outside the European Union?
Your data is kept and stored throughout the duration of processing on servers operated by Google LLC (Firebase Hosting), located in the United States. As part of the tools we use (see the section on recipients regarding our subcontractors), your data may be transferred outside the European Union.
Such transfers of your data are secured using the following:
- either the data is transferred to a country that has been the subject of an adequacy decision from the European Commission, in accordance with Article 45 of the GDPR: in this case the country ensures a level of protection deemed sufficient and adequate to the GDPR;
- or the data is transferred to a country whose level of data protection has not been recognised as adequate to the GDPR: in this case the transfers are based on appropriate safeguards listed in Article 46 of the GDPR, tailored to each provider, including (without limitation) entering into Standard Contractual Clauses approved by the European Commission, applying Binding Corporate Rules, or using an approved certification mechanism;
- or the data is transferred on the basis of one of the appropriate safeguards described in Chapter V of the GDPR.
6. What are your rights regarding your data?
You have the following rights regarding your personal data:
- Right to information: which is precisely why we have written this policy. This right is provided for by Articles 13 and 14 of the GDPR;
- Right of access: you have the right to access all your personal data at any time, under Article 15 of the GDPR;
- Right to rectification: you have the right to rectify your inaccurate, incomplete or outdated personal data at any time, in accordance with Article 16 of the GDPR;
- Right to restriction: you have the right to obtain restriction of the processing of your personal data in certain cases defined in Article 18 of the GDPR;
- Right to erasure: you have the right to require that your personal data be erased, and to prohibit any future collection of it on the grounds set out in Article 17 of the GDPR;
- Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a violation of the applicable rules, in accordance with Article 77 of the GDPR;
- Right to set directives regarding the retention, erasure and communication of your personal data after your death;
- Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you can withdraw your consent at any time. Such withdrawal will not affect the lawfulness of processing carried out before the withdrawal;
- Right to portability: subject to certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data you have provided to us in a standard, machine-readable format and to require its transfer to the recipient of your choice;
- Right to object: under Article 21 of the GDPR, you have the right to object to the processing of your personal data. Note however that we may continue processing despite this objection, on legitimate grounds or for the defence of legal claims.
You can exercise these rights by writing to us at the contact details below. We may ask you on that occasion to provide additional information or documents to justify your identity.
7. Which cookies do we use?
To learn more about how we manage cookies, please see our cookie policy.
8. Contact point to exercise your rights
- Contact email: support@jool.co
- Contact address: 1-3 place Martin Levasseur, 93400 Saint-Ouen, France.
9. Changes
We may modify this policy at any time, in particular to comply with regulatory, case-law, editorial or technical changes. These changes will apply from the effective date of the amended version. You are therefore invited to regularly consult the latest version of this policy.
Nonetheless, we will inform you of any significant changes to this privacy policy.
Effective date: 19 February 2024.