Privacy Policy & Legal Terms

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: January 1, 2020

Last Reviewed: December 26, 2019

This Privacy Notice for California Residents supplements the information on this Privacy Policy & Legal Terms webpage and applies solely to visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Where noted below, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (”B2B personal information”) from some of its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:  

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples Corresponding to Category

Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial information. Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Geolocation data. Physical location or movements.
Sensory data. Audio, electronic, visual, or similar information.
Professional or employment-related information. Current or past job history or professional activities.
Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, behavior, attitudes, abilities, and aptitudes.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you through person-to-person communication. For example, from electronic communications with our marketing and sales personnel.
  • Directly from you through our Website. For example, from your submitting information through online forms or from your interacting with our Website’s chat bot. 
  • Indirectly from you. For example, through observing your actions on our Website.
  • From third-party advertising, performance marketing, contact database platforms and event-hosting companies, as well as from social media. 
  • From third-party professional references that are internal or external to your company.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To satisfy the reason you provided information. For example, if you share your contact information to inquire about our services, we will use that personal information to respond to your inquiry and help you evaluate our services. 
  • If you provide your personal information to purchase a service, we will use that information to process your requests, transactions and payments, to prevent transactional fraud, and to facilitate service. 
  • To create, maintain, customize, and secure your account with us.
  • To protect against malicious, deceptive, fraudulent, or illegal activity.
  • To monitor and improve our responses and services, as well as to support and develop our Website and its content.
  • To meet performance obligations under contracts with customers, including those related to billing and collections. 
  • To deliver marketing and sales content as well as service offerings relevant to you and your interests, including email alerts and materials delivered in hard copy.
  • For testing, research, analysis, and improvement of products and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As needed to protect the rights, property or safety of CYBELANGEL, our customers or others.
  • For internal finance and operational functions, including audits. 
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization or other sale or transfer of some or all of our interests or assets, in which personal information held by us about our consumers may be transferred.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosures of Personal Information for a Business Purpose

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 

In the preceding twelve (12) months, CYBELANGEL has disclosed the following categories of personal information for a business purpose:

Identifiers.

California Customer Records personal information categories.

Protected classification characteristics under California or federal law.

Commercial information.

Internet or other similar network activity.

Geolocation data.

Sensory data.

Professional or employment-related information.

Inferences drawn from other personal information.


We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers, including those offering marketing and event management software, chat bot technology, website hosting, application usage analytics, and digital advertising solutions.
  • Third-party individuals or businesses, when you may have agreed to act as a reference or referral. 

In the preceding twelve (12) months, CYBELANGEL has not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.‌

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you.
  • If we disclosed your personal information for a business purpose, a list of the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at 1 (888) 203-8737.
  • Emailing us at data-privacy@cybelangel.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. 

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which CYBELANGEL collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1 (888) 203-8737 

Email: data-privacy@cybelangel.com

LEGAL TERMS

Company

CYBELANGEL
a simplified joint stock company (“Société par Actions Simplifiée”) with a capital of €27,082 registered with the Paris Trade and Companies Register under number 791 341 274 having its registered office is at 45-49 Rue de Monceau, 75008, Paris, France.

VAT number : FR50791341274

The website is hosted by Pagely, Inc. a private company, having its registered office at 4729 E. Sunrise Dr. Ste 435, Tucson AZ 85718-4535

Access and Content

CYBELANGEL informs the users of the following :

  • The access to the website is free 24/7. In case of, but not limited to, force majeure, technical problems, problems regarding the structure of telecommunication networks, maintenance purposes, the access to a part of the website or to the whole website might be suspended or cancelled upon decision of CYBELANGEL.
  • The information displayed on the website is provided, for reference, CYBELANGEL cannot guarantee the accuracy, the exhaustiveness, and the update.
  • Nothing on this web site should be construed as constituting a proposition of sale or purchase.
  • The website is likely to be subject to modifications and evolutions, without any notification.

The user acknowledges that :

  • it has the required skills and the necessary means to access the website and to use it, and acknowledges have checked that the computer system does not have any virus and is fully functioning.
  • it uses the information and the tools provided on the website under its own responsibility.
  • it undertakes not to perform any act which may harm the computer security of the website, or other users’ computing system.
  • it undertakes, when it is required, to provide only complete, accurate and updated information.

Intellectual Property

The user is prohibited from reproducing other than for your private use, selling, distributing, issuing, broadcasting, adapting, modifying, publishing, communicating in full or in part in any form the data, site presentation or organisation, or the works shown on our web site without the specific prior written consent of the holder of the copyright attaching to the work, the site presentation or organization, or the data reproduced.

The reproduction of the website or of an element of the website without any express authorization of CYBELANGEL is forbidden.

Data bases displayed on the website are protected by the applicable intellectual property code and every reuse or extraction in a substantial qualitative and quantitative manner of the database is liable for compensation.

Trademarks and logo displayed on the website are registered trademarks by CYBELANGEL or by third parties. Every reproduction, imitation or use, complete or partial, of distinctive marks, without express authorization, infringes Intellectual property code dispositions and the author is liable for compensation.

The other distinctive signs, especially the corporate name, trade names and the domain names on the website are the property of CYBELANGEL or third parties and all reproduction without express authorization is likely to constitute an infringement liable for compensation.

The user is not allowed to introduce data on the website that would modify or would be likely to modify the content or the appearance of the data, the presentation, or the organisation of the website or the works displayed on the website by any process.

Cookie Policy

CYBELANGEL takes your concerns seriously and wants to keep the trust you have placed in us. We want to provide you with transparent information on our website. This Cookie Policy explains what different types of cookies are used by our website and how you can change or delete them.

What is a cookie?

Cookies are small text files that are placed and stored by your browser on your computer or smartphone, or any other device optimized for internet use when you visit a website (for more information on “cookies” see https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs.

What types of cookies do we use ?

1. Cookies strictly necessary to the use of the website

CYBELANGEL only uses cookies strictly necessary to the use of its website, in order to improve the quality of its services.

Therefore these cookies are exempted from the consent requirement, in accordance with the recommendations of the CNIL (French National Commission on Informatics and Liberty).

These cookies ensure that the website works as it should. Without these cookies you will not be able to use the website normally, we advise you not to delete them.

Third parties cookies – Analytical cookies

Analytical cookies collect information about the use of the website and help to improve the way the website works based on the users’ demand (pages and headings most frequently consulted, the most read articles, navigation, etc.).

How to enable or disable cookies on your browser?

You are free to accept or refuse cookies that are subject to your consent (such as advertising or analytics cookies). Your browser or device may allow you to block, delete or otherwise limit the use of cookies.

However, we would like to draw your attention to the fact that cookies improve your browsing experience on our website. If you decide to block all cookies with the settings on your browser it may affect your user experience when accessing certain services, and you may not be able to access all or parts of our website.

To make or change your selection, go to the help menu or the dedicated heading of your browser. Depending on your browser, you can also activate the private browsing mode or choose the “Do Not Track” setting in your browser.

For more information on these options, please visit the following websites:

Personal Data Policy

CYBELANGEL is committed to ensuring a high level of data protection for its clients, potential clients, and users of its website. Therefore CYBELANGEL complies with the provisions of Law No. 78-17 of 6 January 1978, (hereinafter “Data Protection Act”) and Regulation (EU) 2016/679 on data protection (hereinafter ‘GDPR’).

CYBELANGEL as Data Controller

CYBELANGEL is the data controller for the collection of the personal data performed via the site accessible at the address URL, hereinafter the Site.

Data Protection Officer

The data protection officer (DPO) can be contacted by using the contact form on the Site or by writing to the following address: CYBELANGEL – Service Data Privacy – 45-49 Rue de Monceau, 75008, Paris, France

Categories of Personal Data collected and purpose(s) of the processing

CYBELANGEL may collect and receive your Personal Data as defined under GDPR through its Site:

  • Your Personal Information through the form present on the Site: first name, last name and email address, job title, phone number and country

Your Personal Data are collected by CYBELANGEL for the following purposes:

  • To answer to your requests made via the online form
  • To manage our business relationship with you, as our client or potential client
  • To provide more effective user experience (internal operations such as testing, research, data analysis)

Your Personal Data shall be stored by CYBELANGEL for only as long as is necessary for the management of our Site and your business relationship with CYBELANGEL and will be deleted upon termination or expiry of the business relationship (including precontractual or contractual agreement). Your Personal Data will in any case be deleted when no longer required, as required by applicable law or as notified to our DPO. However, any data required to establish proof of a right or a contract, or to comply with a legal obligation, can be legally archived, as required by applicable law, legal process or regulation.

The data collected by CYBELANGEL on the Site are shared with the following recipients, and only for the management of the Site:

  • Google (hosting provider, USA)
  • Salesforce (business relationship, Europe)
  • Drift (chatbot, USA)

In this context, some of your Personal Data may be transferred to Google Inc. or Drift, Inc. outside of the European Union, in the United States. CYBELANGEL has measure in place to ensure that these transfers are subject to appropriate safeguard in accordance with the GDPR, since those companies have certified that they adheres to the EU-US Privacy Shield Principles (for more information, please visit the following link: https://www.privacyshield.gov)

  • Your Navigation Data through its Cookies

The purposes of Navigation Data are described in our Cookie Policy.

Your Rights

You have the right to access, rectify or erase the Personal Data relating to you. You have the right to restrict and object to processing of your Personal Data, and to data portability. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing when it is based on consent. You also have the right to define guidelines in relation with your Personal Data that will take effect after your death.

Finally, you have the right to lodge a complaint with the French supervisory authority (CNIL): www.cnil.fr

You can exercise these rights by using the contact form on the Site or by writing to the following address : CYBELANGEL – Service Data Privacy – 45-49 Rue de Monceau, 75008, Paris, France