Privacy Policy

PRIVACY POLICY

At Policy Mate, protecting your personal data is our priority.

The purpose of this policy is to inform you about how we process your personal data in connection with the use of the website policymate.eu (the “Site”) and the platform PolicyMate (the “Platform”) 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 (hereinafter the "GDPR") and French Data Protection Law n° 78-17 of 6 January 1978 (together the "Applicable Regulations").

This Privacy Policy does not describe the methods of collecting and processing your data via cookies and other tracers (“Cookies”) on the Site and the Platform. For more information, please consult our Cookies Policy.

Who is the data controller?

The data controller is PolicyMate SAS, organized under the laws of France, having its registered office at 165 avenue de Bretagne (EuraTechnologies) – 59000 LILLE (“Us” or “We”) when browsing on our Website or when using your account on our Platform/Website as our Client (the Account).

However, when we provide our services to our Clients, we process personal data on their behalf and for their own purposes. Our Clients act therefore as data controllers in accordance with Article 4 of GDPR while we act as data processor.

What personal data we collect?

Personal data is a data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.

We may collect the following personal data:

Identification data (e.g., full name, email and postal addresses, telephone number, your photo);

Login data (e.g., logs, IP address);

Location data;

Data related to recordings from telephone calls with our customer care service (e.g., content of the calls, dates of the calls);

Browsing data (IP address, pages viewed, date and time of connection, browser used, operating system, user ID);

Email performance data;

If you choose to sign in using a third-party authentication service (e.g., Google or Microsoft), certain data such as your name and email may be collected from that service. By choosing this method, you agree that the service may share this information with us. We do not collect your third-party account password;

Economic and financial data (e.g., bank details);

Data related to your credit cards;

Marketing and communications data;

Any information you wish to send us as part of your contact request.

Mandatory data are indicated when you provide us with your data. They are indicated by any means, including notification at the time of collection.

How do we collect your personal data?

We may collect your personal data in two ways:

directly, when you provide it to us (for example, by sending us a contact request or by creating an account on our Platform);
indirectly, via commercial partners, service providers or database enhancement tools.

Details of the processing of your personal data

Objectives	Legal basis	Data retention period
To provide you with our services available on our Platform PolicyMate through your account	Performance of a contract to which you are party and/or taking steps at your request prior to entering a contract	When you have created your account: personal data are retained for the duration of your account. Your connection logs are kept for 6 months/1 year. If your account is inactive for a period of 2 years, it will be deleted if you do not respond to our reactivation email. In addition, personal data may be archived for probationary purposes for a period of 5 years.
To perform operations related to contracts, invoices and customer relationship management	Performance of a contract to which you are party	Personal data are retained for the duration of our business relationship. In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years. The data relating to your contract and the elements relating to the signature of the contract are stored for 5 years from the end of the contract. The data related to your credit card are retained by our payment service provider until complete payment. The CVV2 (Card Verification Value), listed on your credit card details, will not be stored.
To analyze your use of the services, understand your expectations and improve the functionalities offered (in particular by analyzing exchanges or by compiling statistics on browsing and the audience for the Site/Application/Platform).	Our legitimate interest in improving our services	Recordings of telephone calls are kept for six months) from the time they are collected. Documents analyzing the content of telephone calls are kept for one year from the time of recording. If this does not concern telephone recordings (via cookies to improve the user experience): Personal data is stored for two years. Once your data has been anonymized, it is no longer considered personal data, as it cannot be re-identified. They are kept for as long as necessary.
To manage your opinions on our products, services or content	Our legitimate interest in collecting your opinions on our products, services	2 years from the publication of the opinion
To create a database of customers and prospects	Our legitimate interest in developing and promoting our business	Personal data are retained for the duration of our business relationship. In addition, the data relating to your transactions are archived for probationary purposes for a period of 5 years.
To comply with our legal obligations to report illegal content on the Platform	Comply with our legal and regulatory obligations imposed in connection with our Platform	Your identification data is kept for 5 years after the end of the validity of the Terms of Use, the closing of your account or the closing of the report. Other information provided by the user, including payment information, is kept for one year from the end of the validity of the Terms of Use, the closing of your account or the closing of the report. The technical data allowing to identify the source of the connection or those relating to the terminal equipment used are kept for a period of one year as from the connection or the use of the terminal equipment.
To send newsletters, requests and direct marketing mailings	For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news. For our non-professional prospects: your consent. For our professional prospects: our legitimate interest in winning customer loyalty and informing our prospects of our latest news.	Personal data are retained for a period of 3 years starting from the last contact with us (e.g., communication, action) or until you withdraw your consent.
Telephone prospecting	Our legitimate interest in developing and promoting our business	Data is kept for 3 years from the date of your last contact. We undertake to check beforehand that your number is not on a BLOCTEL-type opposition list.
To answer to your information request and other inquiries	Taking steps at your request prior to entering a contract	If you become a client: personal data is retained for the duration of the contract. If you do not become a client: personal data is retained for 3 years from the date of your last contact.
To process your applications and to manage interview (pre-selection of candidates, contact to evaluate the candidate's ability to fill the position, finalization of the recruitment process)	Execution of precontractual measures	Your data is kept in an active database for the duration of the recruitment process until the hiring decision is made. If your application is rejected, your data may be kept for 3 months after the end of the recruitment process, in order to be able to provide you with explanations on the reasons that led to the rejection of your application. Your data may be kept in an intermediate archive for evidential purposes for 5 years from the date of the hiring decision.
To organize contests and promotional operations	Our legitimate interest in winning clientele loyalty and offering them gifts	The personal data is kept for the duration of the contests or promotional operations and may be archived for 5 years for evidential purposes.
Fighting fraud, taking into account international economic and financial penalties)	Our legitimate interest in preventing and dealing with fraud	For data related to identity verification, the data is kept for 2 years. Assessment of the relevance of the alert: the data is kept for a maximum of 6 months from the time the alert is issued, the time it takes for us to qualify the alert. We delete without delay the alerts qualified as not relevant. Retention of the alert qualified as relevant: the data are kept for 5 years from the closing of the fraud file.
To process data subjects’ requests to exercise their rights	Legal and regulatory obligations	If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted. If you exercise your right to object to direct marketing: we keep this information for 3 years.

Who are the recipients of your personal data?

The following categories of recipients will have access to your personal data:

The staff of our company;
Our processors: hosting provider, database provider, CRM tool, mailing provider, audience measurement tool, payment service provider, billing tool, cookie management tool;
Our partners acting as independent data processors. We accept no responsibility for the processing of personal data by our partners, and invite you to consult their general terms of use and privacy policy;
to any authority legally empowered to deal with it, in particular the judicial, police or administrative authorities, if they so request.

Are your personal data likely to be transferred outside the European Union?

Your personal data is hosted for the duration of the processing on the servers of the company, located in the European Union.

As part of the tools, we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or

The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR: in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or an approved certification mechanism; or

The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR.

What rights can you exercise on your personal data?

You have the following rights regarding your personal data:

Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.

Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.

Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.

Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.

Right to erasure (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.

Right to file a complaint to a competent supervisory authority (in France, the CNIL), under article 77 of the GDPR, if you consider that the processing of your personal data constitutes a breach of applicable regulations.

Right to define instructions related to the retention, deletion 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 may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.

Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing to us at the following address: privacy@policymate.eu.

We may ask you to provide us with additional information if there is reasonable doubt, or any document likely to prove your identity if the doubt persists.

For any unsuccessful questions or requests, you are entitled to lodge a complaint with the competent supervisory authority in France, the Commission Nationale de l'Informatique et des Libertés (“CNIL”), located at 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

Modifications

We may modify this privacy policy at any time, in particular to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

Effective Date: 4 July, 2025