Privacy declaration

We are aware that the trust you place in us is the greatest capital of Callbell S.A.S. (hereinafter “Callbell” or “we” or “us”). Privacy protection is of essential importance to us. This privacy statement (hereinafter “Privacy Statement”) also applies to (i) our website https://callbell.eu and all its subdomains (hereinafter the “Website”), (ii) visits to our offices and (iii) all (commercial) relationships between Callbell and its actual and potential customers, and its business partners.

This Privacy Statement includes information about the personal data that Callbell collects, as well as how Callbell uses and processes such personal data.

We would like to note that this Privacy Statement does not apply to third party websites (hereinafter “third party” or “third parties”) linked to us. Since Callbell has no influence over the use of data by third parties, we advise you to consult the privacy statements of these third parties.

Callbell wishes to specify that it has made arrangements to act in accordance with (i) the French Privacy Law of 8 December 1992 on the protection of privacy with respect to the processing of personal data (that is for the entire period in which it is in force), (ii) the 2016 EU regulation concerning the protection of individuals with regard to the processing of personal data, as well as the free circulation of such data and the revocation of Legislation 95/46 / EC and (iii) any other (future) French law relating to the implementation of this regulation.

Callbell uses Amazon Web Services (AWS) to store user data. These servers are subjected to frequent checks to ensure compliance with the latest industry standards, and undergo constant risk management. By using AWS as a data center, our software infrastructure is accredited by

ISO 27001
SOC 1 and SOC 2 / SSAE 16 / ISAE 3402 (formerly SAS 70 Type II)
PCI Level 1
C5 Operational Security
ENS High
IT-Grundschutz

For more information on AWS Security Services, click here: https://aws.amazon.com/es/compliance/programs

Moreover, please note that all data processing providers used by Callbell declare to be compliant with the GDPR regulation (Cloudflare, Google Cloud, DigitalOcean, Stripe).

Visiting the Website, creating an account for the purpose of using Callbell’s demo, creating an account to use Callbell’s services, subscribing to the newsletter and/or a seminar, webinar or event, imply your explicit consent (by communicating your personal data or opt-in) to the Privacy Statement and, therefore, to the way in which we collect, use and process your personal data.

Please review this Privacy Statement along with Callbell’s Cookie policy.

Updates

This Privacy Statement was updated on January 3rd, 2021 (section 5,8,9)
This privacy statement was updated on November 11th, 2020 (section 3,7,8,9)

  1. Company name and address

Callbell S.A.S.
Siret : 87775038000017
2 Rue de Fontarabie
75020 Paris
France

Email: [email protected]
Website: https://www.callbell.eu

  1. Data Protection Officer

Callbell has designated as data protection officer:

Carlo Morandi
Role: Co-founder & CEO
Email: [email protected]
Location: Callbell offices in France (See “1) Company Name and Address”)

  1. Awareness 

All employees responsible for software development and maintenance of Callbell S.A.S’s infrastructure are fully aware of the privacy and security requirements implemented.

To learn more about how Callbell manages security, you can consult this link: https://www.callbell.eu/en/security/

  1. Type of Data we possess

Callbell holds the data of 2 types of subjects:

Our clients (meaning all those who have registered on Callbell and who use Callbell to manage communications with their users)
The end-users (meaning our client’s users)

Callbell does not sell any type of user data whatsoever (the data aforementioned in point 1 or 2). Our business model is based exclusively on paid subscriptions at our customers’ expense.

Client Data we hold

Callbell collects account information for each client (we refer to all those who have registered on Callbell, who are using Callbell to manage communications with their users or who have contacted Callbell via email, phone, or through a message via Facebook, WhatsApp, or Telegram, or by filling out a contact form, or in any other way).

For this purpose, we may process the following personal data :, including:

  • Name and Last name
  • Company job and role
  • Profile picture
  • Permanent address
  • Registered office address
  • Billing address
  • Client payment details (includes billing information, such as company address and country – the credit card number and all its data are stored exclusively by Stripe)
  • Email address
  • Telephone number (landline and / or mobile)
  • Username
  • Password
  • Company name
  • Information regarding the use of Callbell’s Website. Such as, by way of example but not limited to: type and version of browser used, the operating system used by the access system, the website from which an access system reaches our website, the date and time of access to the website, the Internet Protocol address (IP address), and any other similar data and information that can be used in the event of attacks to our computer systems.
  • Information regarding the use of Callbell’s platform (hereinafter “Platform”) and/or Callbell’s mobile app (hereinafter “App”) (such as, but not limited to, heat maps, browsing recordings, IP address, browser type, the web page visited when the Website was accessed)
  • The access data of the mobile device used, as well as data on the geographical location (if necessary
  • All personal data freely provided to Callbell (for example those shared during a correspondence with Callbell).

Our support via WhatsApp

If you create an account on Callbell or If you contact Callbell via the WhatsApp messaging service, we will use your phone number to communicate with you via WhatsApp. Moreover, we process other personal data stored by WhatsApp, in particular name and last name, nickname used to register on WhatsApp, your profile picture as well as the messages and files you send us through the app.

We process your mobile number to identify you. Your nickname and profile picture, provided via WhatsApp, are used visualisation purposes. Your communication with us is stored as chat transcript. This serves the purpose of using previous communication with you as context for future communication. The transcript also contains proof of receipt and reading.

WhatsApp collects data independently. For more information regarding the purpose and scope of WhatsApp’s data collection, WhatsApp’s further processing of your data, and your rights and setting options for protecting your privacy, please read WhatsApp’s Privacy Policy. You can find them here or directly within WhatsApp’s app.

The entity responsible for the WhatsApp messaging service under the GDPR is WhatsApp Ireland, the competent supervisory authority under the GDPR is the Irish data protection authority: WhatsApp Ireland Limited, Attn: Privacy Policy, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland.

User activity

We do not log user activity, except for system logs which include the IP, user agents and connection time. They are stored for a maximum of 1 year, and exclusively for debugging and legal purposes. This log retention policy is subject to French law (which requires that in the event of a potential search warrant by the judicial system, Callbell must be able to provide log data for up to 1 year).

Our client’s end users data we hold

  • End user’s phone number (if provided by the end user, implying consent)
  • End user username
  • Message exchange between our client and the end user
  • Date and time of the end user’s last activity
  • End user profile information (from public data shared by the end user)

Callbell gathers information on the identity of the end user (username, telephone number, user profile information) from external APIs. These external APIs collect such data from public information that the end user has consented to share on a third party service (by way of example but not limited to, Whatsapp or Facebook). This end user’s identity information is stored within Callbell’s services for as long as Callbell’s customer wishes it to be stored in his/her Callbell account.

It is the responsibility of our clients to manage the data stored in their Callbell account in compliance with the regulations in force in the country in which they operate.

  1. Personal data collection methods

Such personal data are collected during, or as part of:

  • An account creation (both for the demo and for subscription usage)
  • A collaboration with Callbell
  • The Website visit
  • A visit to Callbell’s offices
  • The use of Callbell’s services either through the Platform and/or the App, and/or by means of a mobile device, or without the aid of such tools
  • Newsletter and/or blog subscription (through the Website or not)
  • A webinar, seminar and/or event registration
  • An identity verification process (e.g. when seeking customer service)
  • Correspondence with and from Callbell
  • Sharing with Callbell ideas on how to improve the services, the Platform and/or the App
  • Quote request and its related negotiation
  • Business cards exchange
  • A link created between the Platform and the social network platforms

  1. Use of personal data

Callbell may use your personal data for the following purposes:

  • Creation of an account (demo) and its confirmation
  • Execution of an agreement with Callbell (including a follow-up)
  • Provision of Callbell’s services either through the Platform and/or the App, and/or by means of a mobile device or even without the aid of such tools
  • Provision of support/assistance (e.g. in case of problems)
  • Sending of targeted marketing and advertising actions, updates and promotional offers based on your preferred means of communication and, where applicable, with your prior express consent
  • Sending of invoices and payment collection requests
  • Sending of newsletters and/or blogs
  • Sending of a registration confirmation for a webinar, seminar, event
  • Optimization of the quality, management and content of the Website, the Platform and/or the App
  • Creation of statistics
  • Drafting of a quote
  • Conducting customer satisfaction studies, surveys and other market researches
  • Registration of visitors visiting Callbell’s offices
  • Callbell office security

The processing takes place, depending on the case, for the following legal reasons:

  • The client has given consent to the processing of their personal data for one or more specific purposes
  • The processing is necessary for the execution of the contract with Callbell or to take measures at your request before entering into a contract
  • The processing is necessary for the fulfilment of a legal obligation which Callbell is subject t
  • The processing is necessary to protect your vital interests or those of another natural person
  • The processing is necessary to carry out a task of public interest
  • The processing is necessary for the purposes of the legitimate interest pursued by Callbell, except when such interest prevails over the interest or fundamental rights and freedoms of the subject, which require the protection of personal data (in particular when you are a minor).

  1. Disclosure of personal data to third parties

Callbell will not disclose any personal client data to third parties, unless necessary for the provision of Callbell’s services and their optimisation (such as, by way of example but not limited to, maintenance work, payment processing, the provision of services to Callbell (for example, subcontracts) and database management). In this regard, personal data may be disclosed to payment gateway providers, software providers, cloud partners, datacenters, external IT consultants, service providers.

Notwithstanding the above, it is also possible for Callbell to disclose your personal data:

To the competent authorities (i) when Callbell is required to do so by law or as part of an ongoing or future legal proceeding and (ii) to safeguard and protect our rights;
If in any case Callbell, or most of its assets, are taken over by a third party, your personal data collected by Callbell will be one of the transferred assets.
In order to detect profiles similar to yours, unless you expressly oppose to it.

In any other case, Callbell will not sell, lease, or transfer your personal data to third parties, unless (i) it has obtained your consent for this purpose and (ii) a data processing agreement has been finalised with the third party concerned, which mus include the necessary guarantees relating to the confidentiality and privacy compliance of your personal data.

  1. Storage of personal data

Notwithstanding the cases where a longer retention period is required or justified (i) by law or (ii) by virtue of the fulfilment of another legislative obligation, Callbell will store your personal data only for the period necessary to comply and to fulfil the purposes described in this Privacy Statement under the paragraph ‘use of personal data’

  1. Right to privacy

In light of the processing of your personal data, you benefit from the following privacy rights:

  • Right to access the personal data that Callbell may have about you;
  • Right to rectify, complete or update your personal data;
  • Right to delete your personal data (‘right to be forgotten’) (Callbell wishes to point out that in this case some services will no longer be accessible and/or will no longer be provided in the event of cancellation or request for cancellation of some personal data);
  • Right to a restriction of the processing of your personal data;
  • Right to the transferal of your personal data;
  • Right to object/oppose to your personal data processing.

If you wish to invoke your privacy rights, as defined below, please contact [email protected] or fill out the form to exercise such rights and deliver it to Callbell by e-mail or post. Callbell responds to all access requests (positively or negatively) within 30 days.

You can exercise these rights free of charge using the aforementioned form. Moreover, through your account, you can update, delete, modify and/or verify – at any time – which personal data you communicated when you created your account (demo).

If you no longer wish to receive newsletters or information about our services, you can unsubscribe at any time by clicking on the “unsubscribe” button at the bottom of each e-mail by Callbell.

  1. Personal data protection

Callbell undertakes to adopt any reasonable physical, technological and organizational precautionary measure to prevent (i) unauthorized access to your personal data, as well as (ii) the loss, misuse, or modification of your personal data.

Callbell will store all personal data collected in the cloud (by means of datacenters located throughout the EU territory).

Despite Callbell’s security policy and the actions and verifications it carries out in this field, an infallible level of security cannot be guaranteed. Since no method of transfer or transmission via the Internet nor electronic storage is 100% secure, Callbell cannot guarantee absolute data protection.

Finally, the security of your (demo) account will also depend on the confidentiality of your password for accessing the Platform and/or the App. Callbell will never ask you for any private password, which is why you will not be required to share it with us. However, in the event that you have communicated your password to a third party, for example because that party has expressed its willingness to offer you additional services, said third party will be able to access your account (demo) and your personal data, through your password. In this case, you will be responsible for the actions that will be carried out following the use of your account (demo). In case you encounter unauthorized access to your account (demo), Callbell strongly recommends that you change your password immediately, and get in touch with us.

  1. Cross-border processing of personal data

Any transfer of personal data outside the European Economic Area (EEA) to a recipient whose residence or registered office is in a country not subject to an adequacy decision issued by the European Commission will be governed by the provisions of a data transfer agreement which will include (i) the standard contractual clauses referred to in the ‘European Commission decision of February 5th, 2010 (decision 2010/87 / EC)’ or (ii) another mechanism under privacy legislation or other regulations relating to personal data processing.

  1. Data breaches

Our team closely monitors any unauthorized access to the system, and has put in place multiple preventative measures to reduce the chances of attack on our systems and services. To date, Callbell has not reported any major security issues and related data breaches.

Callbell will notify its users of any data breach – at the latest – 24 hours after becoming aware of it, and correcting the security flaw. It will then be our users’ responsibility to report this data breach to their end users in due course.

To learn more about how Callbell manages security, you can consult this link: https://www.callbell.eu/en/security/

  1. Provider for Messaging Services

The possible providers of messaging services that can be integrated with Callbell are:

Whatsapp: WhatsApp, Inc., 1601 Willow Road, Menlo Park, California 94025, USA. Their privacy policy is available at the link https://www.whatsapp.com/legal/business-policy

Facebook Messenger: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. Their privacy policy is available at the link https://www.facebook.com/about/privacy

Telegram: Telegram Messenger LLP 71-75 Shelton Street, Covent Garden, London, United Kingdom. Their privacy policy is available at the link https://telegram.org/privacy

Instagram: Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA. Their privacy policy is available at the link https://www.facebook.com/help/instagram/155833707900388

Gupshup : 415 Jackson Street, Suite B, San Francisco, CA 9411, USA. Their privacy policy is available at the link: https://www.gupshup.io/developer/privacy

Twilio: Twilio Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105, USA. Their privacy policy is available at the link: https://www.twilio.com/legal/privacy

  1. Data protection provisions on the application and use of Google Analytics and Google Tag Manager

Google Analytics

Callbell uses Google Analytics. Google Analytics is a web analysis service. Web analysis is the collection, detection and analysis of data regarding the behavior of visitors when browsing websites. A web analysis service collects, among other things, data about the website from which a person comes (the so-called referrer), which sub-pages were visited, or how often and for how long a sub-page was viewed. Web analytics is mainly used for the optimization of a website and to carry out a cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1501, USA

Further information, and the applicable data protection provisions of Google Analytics, can be found in this section https://www.google.com/intl/en/policies/privacy

Google Tag Manager

Callbell uses Google Tag Manager. Google Tag Manager is a solution that allows you to manage site tags through an interface. The Tag Manager tool itself (which implements the tags) is a cookie-free domain and does not log any personal data. The tool manages the activation of other tags which, under certain circumstances, can log data. Google Tag Manager does not access this information.

Further information and the applicable data protection provisions of Google Tag Manager can be found in this section https://support.google.com/tagmanager/answer/9323295?hl=en

  1. Data protection provisions on the application and use of Google AdWords

Callbell uses Google AdWords.

The operator of the Google AdWords component is : Google Inc, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.

Within Google AdWords, we use the so-called “conversion tracking”. When you click on a Google sponsored ad, a conversion tracking cookie is set up. These cookies expire after 30 days and are not used for a personal identification of the user. If the user visits certain pages of the website and the cookie has not yet expired, Google and the website will know that the user clicked on the ad and went to that page. The information obtained through the conversion cookie is used to create conversion statistics for AdWords advertisers who have opted for conversion tracking. AdWords customers are informed about the total number of users who clicked on their ad and who were redirected to a page in the conversion tracking tag. However, advertisers do not obtain any information that can be used to personally identify those users.

For more information on Google AdWords and Google Conversion Tracking, please read Google’s Privacy Policy: https://www.google.de/policies/privacy

  1. Data protection provisions on the application and use of Facebook and Facebook’s “Custom Audiences” Retargeting services.

Callbell may use the services of “Custom Audience” by Facebook Inc.

The operator of the Facebook Inc. component is: Facebook Inc. 1601 Willow Road, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 , Ireland.

Callbell may use the “Custom Audiences” service by Facebook Inc. through a pixel (JavaScript code embedded in all our web pages), to provide personalized ads to our website’s visitors. Facebook’s “Custom Audiences” service allows us to track user behavior on our website after they have been redirected to our website by clicking on a Facebook ad. This allows us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous for Callbell.

For more information on Facebook Inc., consult their privacy policy: https://www.facebook.com/about/privacy/

  1. Data protection provisions on the application and use of SendinBlue

Callbell uses SendinBlue’s services to send newsletters and transactional emails (for example account activation emails, password reset).

This service is provided by: SendinBlue SAS, 55, rue d’Amsterdam 75008 Paris, France.

SendinBlue is a service that manages and analyzes the distribution of newsletters and transactional emails. If you provide data (e.g. e-mail address) to subscribe to our newsletter, these will be stored in SendinBlue’s servers .

For more information on SendinBlue, consult their privacy policy : https://it.sendinblue.com/legal/privacypolicy/

  1. Data protection provisions on the application and use of Drift

Callbell uses Drift’s services to manage sales and post-sales support communications with customers, through live chat.

The operator of the Drift component is : Drift Inc. 222 Berkeley Street, 6th FL, Boston, MA, 02216, USA.

For more information about Drift, please read their privacy policy: https://www.drift.com/privacy-policy/

  1. Data protection provisions on the application and use of Typeform

Callbell uses Typeform’s services to manage the collection of information from customers (by way of example, but not limited to, incoming client feedback about our services, an access request to certain functions of the platform, the request for a telephone appointment).

The operator of the Typeform component : TYPEFORM SL, C/Bac de Roda, 163 (Local), 08018 – Barcelona (Spain)

For more information on Typeform, read their privacy policy : https://admin.typeform.com/to/dwk6gt/

  1. Data protection provisions on the application and use of Livestorm

Callbell uses Livestorm to handle and manage informative webinars on our products.

The operator of the Livestorm component is : LIVESTORM SAS. 24 rue Rodier 75009 Paris FRANCE

For more information on Livestorm, read their privacy policy: https://livestorm.co/privacy-policy/

  1. Data protection provisions on the application and use of Sentry

Callbell uses Sentry as a tool for solving user errors within the platform and the mobile app.
The operator of the Sentry component is: Functional Software, Inc. dba Sentry, 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA.
For more information on Sentry, read their privacy policy: https://sentry.io/privacy

  1. Data protection provisions on the application and use of Zendesk

Callbell uses Zendesk exclusively for the management and implementation of the dedicated help center (https://callbellsupport.zendesk.com/hc/)

The operator of the Zendesk component is : Zendesk International Ltd. 55 Charlemont Place, Saint Kevin’s, Dublin, D02 F985 Ireland

For more information about Zendesk, read their privacy policy: https://www.zendesk.co.uk/company/customers-partners/privacy-policy

  1. Links to other websites

The Website may include hyperlinks to other websites. By clicking on one of these links, the user could be redirected to another website or another Internet source that could collect information about the user through cookies or other technologies. Callbell assumes no responsibility or supervisory authority on these other websites or Internet resources, nor on their collection, use and disclosure of the user’s personal data. You should check the Privacy Statements of these other websites and internet sources to be able to judge whether they are in accordance with the privacy legislation in force.

  1. Privacy Statement update

Callbell has the right to update this Privacy Statement by publishing a new version on the Website. For this reason it is strongly recommended that you regularly consult the Website and the related page on which it was published to ensure that you are aware of any changes.

If you are not satisfied with the way in which Callbell has handled your questions and/or your observations, or if you wish to file a complaint about the way in which Callbell collects, uses and/or processes your personal data, you can contact the competent Privacy Commission. in its country.

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