This privacy policy is issued by the company GetHeroes, a French société par actions simplifiée having its registered office at 160 rue Jeanne d’Arc, 75013 Paris registered under number 922 560 065 RCS Paris (“Zeliq”, “we”, “us” and “our”) and includes information on how we collect, Process and share Personal Data through our Website and Services and how you can exercise your rights over your Personal Data (the “Privacy Policy”).   

Capitalized terms used in this Privacy Policy shall have the meanings set out in Section 11 “Definitions”. This Privacy Policy supplements the Term of Use of our Website and our Terms of Services, which are available on the following link:

https://www.zeliq.com/privacy-policy/ and https://www.zeliq.com/terms-of-use/

This Privacy Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data or changes in applicable law. We encourage you to read this Privacy Policy carefully and to regularly check this page to review any changes we might make in accordance with the terms of this Privacy Policy. 

This Privacy Policy was last updated on 2024, March 6^th.

If you do not agree with this Privacy Policy or any changes to it, you should immediate close the Website and cease using our Services. 

1.What categories of Personal Data do we Process?

2. Why do we Process Personal Data? 

3. On which legal base(s) do we Process Personal Data? 

4. How do we share Personal Data we Process?

5. How do we select, store and retain Personal Data we Process?

6. How do we secure Personal Data we Process?

7. How to access and control your Personal Data?

8. Do we transfer Personal Data internationally?

9. When do we conduct direct marketing? 

10. How to contact us? 

11. Definitions

1. What categories of Personal Data do we Process?

   1.1 Business information Personal Data 

We collect and Process Personal Data and more precisely business information and maintain a Database that is offered to our customers as part of our Services for the purpose of business-to-business sales prospecting. The Personal Data we store for each profile in our Database are: [data relating to your identity (e.g., full name, email address, phone number, postal address) and data relating to your professional career (e.g., professional email addresses, job title and department, company/employer name and postal address, employment history, educational background and related social media profiles)]. We do not Process any sensitive Personal Data such as racial or ethnic origin, political opinions, religious beliefs, medical or biometric data, etc. We do not Process any Personal Data about minors.

The Database contains: (i) Output Data we obtain from multiple sources that include, without limitation, licensed information from other companies, publicly available information and market research, and (ii) Submitted Data we obtain directly from our users and/or customers. 

If your profile is in our Database and you wish it to be removed, please contact us through our privacy center at privacy@zeliq.com. By not exercising your right to be removed, you will remain in our Database and may be contacted by our customers.

1.2 Personal Data Processed from the use of our Website and Services 

1.2.1 Users account and provision of our Services 

When you become a customer by registering for an account and using our Services, you will submit the following Personal Data on our Website: full name, professional email address and phone number, company name, job title. To purchase and access our Services, we will ask you to submit payment information (e.g., bank account number or credit card number, IBAN details etc.). 

1.2.2 Our Submitted Data program  

Our users and/or our customers have the option of sharing with us their Personal Data for business purposes. This helps keep our Database accurate and up-to-date. If you sign up for Submitted Data program, we will have access to your email account, calendar and/or contacts. The Personal Data that we obtain from our users and/or our our customers about their contacts include their full name, professional email address, phone number, job title and company/employer name and address, any related social media handles or other information typically found in an email signature block or contacts directory. We will not read the content of any email correspondence and will not process any Personal Data beyond the aforementioned professional Personal Data. 

Once we have accessed your contacts, and if applicable by law, we will inform these contacts about the Processing of their Personal Data by us and how they can manage or remove their Personal Data from our Database.

You can quit the Submitted Data program at any time and we will stop collecting and Processing new Personal Data from your email account, calendar and/or contacts.

1.2.3 Cookies 

When you visit our Website, we will typically place Cookies into your device or read Cookies already on your device, subject always to obtaining your prior consent, where required, in accordance with applicable law.

For your full information, Cookies are small text files that may be stored on your device when you visit a website. They are generally used to make websites work, to keep track of your movements within the website, to remember your login details, to remember preferences and interests etc.

There are different types of Cookies and they can be distinguished on the basis of to their origin, function and lifespan. Depending on the owner, Cookies can be classified as follows:

• Own Cookies: these are those sent to the user's computer or device from a device or domain managed by us and from which the platform or service requested by the user is offered; 

• Third party Cookies: these are those that are sent to your computer or device from a device or domain that is not operated by us but by another party that processes the data obtained through the Cookies. We do not control the collection or further use of Personal Data by third parties.

We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. In particular, we (and other third parties acting on behalf of our behalf) will be able to automatically track and capture information about your IP address, domain service, country location, time zone, language, type of computer and web browser in use and the pages you visit (including through the use of web beacons and other similar technologies). 

If you access the Website via your mobile device, we may also collect information about your mobile service provider and your mobile device. We will use this data to be able to manage and improve the system, analyze trends, track user movements, collect mass demographic information for aggregate use, and detect suspicious or fraudulent transactions.

In any case, you can configure or disable Cookies from the cookie banner, available on the Website or from your browser. Please note that certain features and functionality of our Website may be impacted if Cookies are disabled.

In which concerns third party Cookies, we have no control over these cookies or how the third parties use them. These Cookies allow third parties to provide us with a service, for example, analytics about the effectiveness of our marketing activities and user behaviour.

1.2.4 Third party websites 

Our Website contains links to third party websites. If you click on these links, the third-party websites may collect Personal Data about you. We cannot control and are not responsible for what Personal Data third party websites Process about you and encourage you to review the third party’s privacy policy and data Processing practices.

2. Why do we Process Personal Data?

When you use our Website and/or our Services, we Process Personal Data for the following purposes: 

• Provision of our Services to you (for instance, Personal Data is Processed by us when logging in or when providing customer support); 

• Improvement and customization of our Services (managing our Website and Services, providing content, displaying content and information, monitoring and analyzing trends, usage, and activities); 

• Communication with you, including but not limited direct marketing (including via email, telephone, text message, social media, post or in person to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law);

• Compliance with our legal obligations; 

• Compilation of our Database; 

• Financial management (sales, finance, corporate audit and vendor management);

• Surveys (engaging with you for the purposes of obtaining your views on our Website, or our Services)

• Establishment, exercise and defense of legal claims (management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defense of legal rights and claims, including formal legal proceedings);

• Fraud prevention (detecting, preventing and investigating fraud and breach of policies or terms).

  3. On which legal base(s) do we Process Personal Data? 

We Process Personal Data for multiple purposes as explained in Section 2 under the following legal bases: 

The performance of the agreement signed between you and us to provide the Services 

Your consent to the Processing of Your Personal Data

The pursuit of our legitimate interests

Compliance with our legal obligations

4. How do we share Personal Data we collect?

To the minimum extent necessary to achieve the purposes for using the Personal Data, we disclose such Personal Data to:

• our customers i.e., when we share to our customers the Personal Data from our Database as part of our Services. Note that when the Personal Data is accessed and processed by our customers for their own purposes, they are Controllers of that Personal Data under the GDPR; 

• accountants, auditors, consultants, lawyers and other outside professional advisors to us, subject to binding contractual obligations of confidentiality;

• third party Processors located anywhere in the world, subject to the requirements noted below in this Section 6 (such as data hosts, email service providers, customers service providers, venue operators, payment services providers, postal carriers; etc.);public forums (our Website offers publicly accessible blogs, therefore if you directly disclose any information through our public message blogs, including profile information associated with the account you use to post the information, it may be read, collected and used by any member of the public who accesses these websites);

• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims and/or for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties; 

• any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

• any relevant third party provider, where our Website use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. 

We specify that we will naturally never sell your Personal Data to any third party.

5. How do we select, store and retain Personal Data we collect 

We take every reasonable step to ensure that your Personal Data that we Process are accurate and, where necessary, kept up-to-date. Any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Privacy Policy.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Privacy Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows: 

• We will retain Personal Data in a form that permits identification only for as long as:

• i) we maintain an ongoing relationship with you (e.g., where you are a user of our Services, or you are lawfully included in our mailing list and have not unsubscribed); or 

• ii) your Personal Data are necessary in connection with the lawful purposes set out in this Privacy Policy, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data).

  The duration of: 

• iii) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and

• iv) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim). 

• In addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in the above paragraphs, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods above, each to the extent applicable, have concluded, we will permanently delete or destroy the relevant Personal Data or anonymize the relevant Personal Data. If this is not possible, we will securely store your information and isolate it from any further use until deletion is possible.

6. How do we secure Personal Data we collect

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access and other unlawful or unauthorised forms of Processing, in accordance with applicable law. 

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

Our personnel and partners are aware of personal data protection issues and are committed to guaranteeing the confidentiality and security of Personal Data to which they have access in the course of their tasks and missions. 

In the event of a violation of your Personal Data, presenting a risk to your rights and freedoms, we will notify the violation in question to the competent personal Data Protection Authority within the time limits prescribed by the GDPR. 

In the event that the violation presents a high risk to your rights and freedoms, we further undertake to: 

• Notify you in accordance with the conditions prescribed by the GDPR; and 

• Provide you with the necessary information and recommendations to be implemented in order to remedy it.

  7. How to access and control your Personal Data? 

Pursuant to the GDPR and the French Data Protection Act (n°78-17) dated 6 January 1978, you may avail yourself regarding the Processing of your Relevant Personal Data of the following rights:

• Right of access, rectification and right to erasure of data: you have the right to obtain from us the limitation of the Processing of your Personal Data (for example if you think that your data is inaccurate) or to object at any time, for reasons relating to your particular situation, to the Processing of your Personal Data. You also have the right to erasure of your Personal Data;

• Right to data portability: you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit them to another controller. If technically possible, you can also ask us for your Personal Data to be transmitted directly to another Controller;

• Right to limitation and opposition to data processing: you can request restriction of Processing of Personal Data when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your Personal Data;

• Right not to be subject to a decision based exclusively on an automated process;

• Right to determine the survival or not of data after death; and

• Right to lodge a complaint with the competent supervisory authority: you have the right to make a complaint at any time to the relevant Data Protection Authority (the CNIL), and the right to obtain compensation from the competent courts if you consider that we have not respected your rights to the protection of Personal Data.

Exercising your rights is free of charge. However, in the event of manifestly unfounded or excessive requests, particularly due to their repetitive nature, we may require payment of a reasonable fee.

To exercise your rights, please write to GetHeroes 160 rue Jeanne d’Arc, 75013 Paris or send an e-mail to privacy@zeliq.com.

8. Do we transfer Personal Data internationally?

To ease our operations, we may transfer Personal Data to third parties as indicated above, in connection with the purposes set out in this Private Policy.

This Privacy Policy will apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to require that your Personal Data will remain protected wherever it is transferred.

We may transfer Personal Data to third parties based in countries that may not have equivalent privacy and data protection laws to the country in which you reside. Nonetheless, we use a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Standard Contractual Clauses, as well as additional safeguards where appropriate. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided in Section 10 below. 

Please note that when you transfer any Personal Data directly to any entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Privacy Policy. 

9. When do we conduct direct marketing? 

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding the Website and our Services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Website or our Services. If we provide our Services to you, we may send or display information to you regarding our Website and our Services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law. 

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances, we will continue to contact you to the extent necessary for the purposes of any services you have requested. 

10. How to contact us?

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us:

• Email: privacy@zeliq.com.

• Address: 160 rue Jeanne d’Arc, 75013 Paris

  11. Definitions 

• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Privacy Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

• “Database” means our database containing all the professional profiles we have collected. 

• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

• “EEA” means the European Economic Area.

• “GDPR” means the General Data Protection Regulation (EU) 2016/679.

• “Output Data” means the Personal Data we collect and Process from multiple sources that include, without limitation, licensed information from other companies, publicly available information and market research etc. 

• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

• “Relevant Personal Data” means Personal Data in respect of which we are the Controller. 

• “Services” mean the provision of the Output Data, the Metadata, our platform and the Beta services and any accompanying or related infrastructure, functionality, technology or analytics, including any services or add-ons described in an order form.  

• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.

• “Submitted Data” means the Personal Data we collect and Process from the users of our Website and from our customers. 

“Website”means the website accessible at the following URL https://www.zeliq.com/.