# Privacy Policy

This Privacy Policy has been compiled to allow a clear understanding of how Stelace collects, uses, protects or otherwise handles Personally Identifiable Information of Users (“You”) such as your name, contact information or IP address. It is a legal document so some of the language is necessarily “legalese”, but We have tried to make it as readable as possible.

# 1. Introduction

This Privacy Policy belongs to the company Sharinplace (referred to as “Stelace”, “We” or “Company”) a French company with a capital of 15.000 euros with registered address at 12 rue Dumas, BAL 68, 93800 Épinay-sur-Seine and registered with the Commercial Court of Bobigny, under the number 813 758 653 and whose VAT number is FR50813758653. Stelace may be contacted through the email address hello [at] stelace [dot] com.

The Company is the publisher of the website stelace.com (hereinafter the “Website”) which it makes available to Users.

The Company offers the opportunity to Users on the Website to access APIs (Application Programming Interfaces) on a subscription basis (as a Software as a Service) (hereinafter the “Services”).

The User declares having read and accepted this Privacy Policy before placing an Order on the Website.

# 2. Protection of Personal Data

In order to allow Users to Order Services on the Website, the Company acting as data controller, reserves the right to collect Personal Data relating to Users, including the following Personal Data:

  • Last name and first name;
  • Professional e-mail address;
  • Registered Address;
  • Company Name;
  • Function within the company;
  • Additional addresses (billing if applicable).

The User is informed that if he does not wish to provide the requested Personal Data, the Company will not be able to execute his Order.

The Company uses the Personal Data of Users for the following purposes, among others:

When treatment is based on consent

  • Creating an account;
  • Account Management.

When the processing is necessary for the execution of the contract concluded with the User

  • Provision of Services;
  • Taking into account Orders;
  • Order management and processing;
  • Billing;
  • Response to any questions / complaints from Users;
  • Management of requests for rights of access, portability, deletion, rectification and opposition;
  • Management of unpaid bills and litigation.

When the treatment is necessary for the legitimate interests pursued by the Company

  • Information on the Company, the Services and the activities of the Company;
  • Statistics about the use of Services.

Personal Data of Users is stored only for the time necessary to achieve the purpose for which the Company holds this data, in order to meet Users' needs or to fulfill their legal obligations.

To establish the retention period for Personal Data, the Company applies the following criteria:

  • in case of Order of Services, the Personal Data is kept for the duration of the contractual relation and for the legal periods of prescription;

  • the collected Users' data is also used for commercial prospecting purposes and is kept for three (3) years after the collection or last contact with the User;

  • if the User participates in a promotional offer, the Personal Data is kept for the duration of the promotional offer concerned and for the legal periods of prescription;

  • if the User makes a request to the Company, the Personal Data will be kept for the time necessary to process the request and for the legal periods of prescription;

  • if the User creates an Account, the Personal Data will be kept until the User requests the deletion of his account or at the end of a period of inactivity, within the limits of the duration of the legal prescriptions;

  • if cookies are placed on the User's computer, the Personal Data is kept for the duration of a User session and for any period defined in accordance with applicable regulations;

  • the Company may retain certain data in order to fulfill its legal or regulatory obligations or 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 the Company will proceed with their anonymisation.

The Personal Data of the Users are processed by the Company and by the service providers who support the Company's activity such as the host of the Website, acting as a subcontractor.

The Company may also disclose Personal Data in order to cooperate with the administrative and judicial authorities.

The Company takes care to secure the Personal Data of Users appropriately and has taken the necessary precautions to preserve the security and confidentiality of data and in particular to prevent them from being distorted, damaged or communicated to unauthorized persons.

The Company uses the services of Third Parties as hosts for User data. Servers are located in the European Union for European Customers unless they make another choice during Order. The Company does not make international transfers of Personal Data of European Users.

Under the Decree n° 2011-219 of February 25, 2011 relating to the conservation and the communication of the data allowing to identify any person having contributed to the creation of contents put on line, the User is informed that the Website provider has the obligation to keep for a period of one (1) year from the day of the creation of the contents, for each operation contributing to the creation of content:

  • The identifier of the connection at the origin of the communication;
  • The identifier assigned by the information system to the object of the operation;
  • The types of protocols used for connection to the service and for the transfer of contents;
  • the nature of the operation;
  • the date and time of the operation;
  • The identifier used by the author of the operation when provided.

In case of Termination of the contract or closure of the Account, the provider must also keep for one year from the date of termination of the contract or closure of the Account the information provided when subscribing a contract (Order) by the User or when creating an Account, namely:

  • At the moment of the creation of the Account: the identifier of this connection;
  • The surname and forename or the company name;
  • The postal addresses associated;
  • The pseudonyms used;
  • The email addresses or associated accounts;
  • phone numbers;
  • The password and related data to verify or modify it, in their latest updated version.

The provider of the Website must finally, when the subscription of the contract (Order) or the Account is paid, keep for one year from the date of issue of the invoice or the payment transaction, for each invoice or transaction the following payment information, for each payment transaction:

  • the type of payment used;
  • the reference of the payment;
  • The amount;
  • The date and time of the transaction.

User Obligations:

Users acknowledge that the Personal Data disclosed by them is valid, up-to-date and adequate.

Users undertake not to infringe the privacy and protection of the Personal Data of any third party and thus not to communicate to the Company the data of third persons without their consent.

User Rights:

Users have a right to access, rectify, delete (erase) and apply portability of their Personal Data. They also have a right to object to the processing of their data collected and processed by the Company, by contacting the Company directly at the following e-mail address: privacy [at] stelace [dot] com.

Users may also, at any time, withdraw their consent to the processing of their Personal Data by the Company and by subcontractors by contacting the Company at the following e-mail address: privacy [at] stelace [dot] com , who will have to inform them about their rights.

Pursuant to Article 40-1 of the Data Protection Act as amended, the Company will respect the instructions given by any User regarding the storage, deletion and communication of his Personal Data after his death. In the absence of such instructions, the Company will grant the claims of the heirs as limited in Article 40-1, III of the Data Protection Act.

In case of complaint, Users may contact the CNIL, which is the competent French authority for the protection of Personal Data, whose contact details are: 3 Place de Fontenoy, 75007 Paris,phone: +33 (0) 1 53 73 22 22.

For any question concerning the processing of his Personal Data, the User may contact the Company by e-mail at the following address: privacy [at] stelace [dot] com.

# 3. Cookies and Statistical tools

In connection with the use of the Website or the ordering of Services on the Website by Users, the Company may use cookies.

In accordance with the CNIL's deliberation 2013-378 of December 5, 2013, the Company informs Users that cookies record certain information that is stored in the memory of their computing equipment or mobile device. This information is used to improve the use and functioning of the Website, but also to understand how the Website, as well as the tools and services that the Company makes available to them are used by Users.

If and when the Company uses cookies storing Personally Identifying Information such as full User IP address, Users going to the home page or another page of the Website directly from a search engine will be informed about:

  • precise purposes of the cookies used;
  • The ability to oppose these cookies and change the settings by clicking on a link in the banner. To guarantee the free, informed and unambiguous consent of the User, this banner will not disappear until he has continued his navigation.
  • And the fact that the continuation of its navigation is an agreement to the deposit of cookies on its device.

Except with the prior consent of the User, the deposit and reading of such cookies will not be carried out:

  • If he goes on the Website (home page or directly on another page of the Site) and does not continue his navigation: a mere lack of action can not be assimilated to a manifestation of will;
  • Or if he clicks on the link in the banner allowing him to set cookies and refuses the deposit of cookies.

The User may at any time choose to disable such cookies and other tracers. His browser can show which cookies are stored in his device and lets him remove any of them.

The configuration of each browser is different. It is described in the help menu of the browser, which will enable the user to know how to change his wishes in terms of cookies.

The Company also uses an anonymized version of Google Analytics, an internet analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies. The information generated by the cookie about the use of the Site and User IP address are anonymized before being transmitted and stored by Google on servers located in the United States. Google may use this information for the purpose of evaluating the use of the Website, compiling reports on the Website's activity for Website operators and rendering services relating to the activity of the Website and its Users. Google may also transfer this information to third parties when required by law, or when such third parties process the information on Google's behalf.

Last Updated: 7/8/2019, 11:26:01 AM