The purpose of this Privacy Policy is to inform users of the ALCMEON application (hereinafter referred to as the “Users” and the “Application”) about the processing of their personal data by ALCMEON in its capacity as a data processor.
ALCMEON provides a SaaS application that enables its Clients to centralize the management of communication from social networks, improve the speed and consistency of customer support responses, and create personalized marketing campaigns.
The service offered by ALCMEON allows Clients to manage requests made by Consumers via social networks such as Facebook, Instagram, LinkedIn, TikTok, and X, review sites such as Google Business Places and Trustpilot, instant messaging applications like WhatsApp, Apple Messages, Line, KakaoTalk, and AlcmeonChat, a chat widget operated by ALCMEON. It also facilitates the management of marketing campaigns on WhatsApp and Facebook Messenger.
The "Users" of the Application are employees, collaborators, or contractors authorized by ALCMEON’s Client companies to access the Application.
In this context, ALCMEON complies with the applicable data protection laws, including:
1. Identity of the Data Controller and Individuals Concerned
The Client company of ALCMEON is the data controller. ALCMEON acts as a data processor under Article 28 of the GDPR.
The individuals concerned are:
2. Nature of Collected Data
When creating a User account, ALCMEON collects the User’s email address based on the Client’s instructions. During the Application's use, ALCMEON collects connection logs and User actions.
The User account with administrator status on the ALCMEON Application allows the social networks, customer review sites and instant messaging applications mentioned in the preamble to transmit certain information relating to messages sent by Consumers to the ALCMEON Application. The User account, which does not have administrator status, allows the information transmitted to be consulted and processed.
The Consumer information sent to Users is as follows:
- Consumers identification data : data supplied by social networks, customer review sites and instant messaging applications about Consumers, such as their identifier (first and last name, pseudonym or telephone number) and profile photo; on the other hand, the data provided by the Consumers on their own initiative as part of their exchanges with the Users on social networks, customer review sites and instant messaging applications, and ALCMEON's asynchronous chat widget, such as e-mail address, telephone number, Consumer number, order number, etc. Unless specifically agreed between ALCMEON and the Customer, this data does not include sensitive data (race, health, religion, political opinions) within the meaning of Article 9 of the GDPR.
- Messages exchanged between Users and Consumers, including text and attachments (photos, animated gifs, videos, pdf documents), published with a timestamp, received from Consumers and transmitted by Users, and in certain cases declarations of location received from Consumers via the social network or messaging application concerned.
ALCMEON, acting as a data processor and in application of the applicable regulations, undertakes in particular to:
Minors
If the User identifies Consumer data from children under the age of 15, ALCMEON undertakes to delete this data as soon as possible.
3. Purposes of processing
The purposes are determined by the Client.
Users data collected by ALCMEON is used to:
Consumers data is made available to the User as follows:
The legal bases applicable to such processing shall be determined by the Customer, in accordance with Article 6 of the GDPR.
4. Data retention period
The Users and Consumers data within the Application are kept by ALCMEON for the period indicated by the Client, who is the data controller.
Depending on the Client’s choice, Consumers data is anonymised individually for each Consumer who has not received a message for a configurable period (generally between 12 and 36 months). The anonymisation process includes the complete deletion of message content and identification data, including the pseudonym.
These data are deleted at the end of the contract between ALCMEON and its Client, except for the purposes of (i) proof of proper performance of the contract by ALCMEON, (ii) management of pre-litigation, litigation or (iii) at the request of the Client.
5. Recipients of the data
6. Transfer of data outside the European Union
The data collected is stored on secure servers located in France or in another Member State of the European Union (Germany).
ALCMEON transfers data outside the European Union for the use of its CRM, to the United States. This transfer is based (i) on the certification of the service provider to the Privacy Framework between the European Union and the United States and (ii) on the signature of the Standard Contractual Clauses published by the European Commission.
7. Rights of Users and Consumers
7.1. Nature of Users' rights
In accordance with the laws on the protection of personal data in force, in particular the General Data Protection Regulation and the French laws transposing it, all Users and Consumers have the following rights:
7.2. Exercising Users' rights
The Users or Consumers may exercise their rights by sending a request to the Data Controller.
The User may also at any time ask ALCMEON to stop receiving offers of similar or analogous services, or offers of services falling within the scope of their professional activity, by contacting ALCMEON by the means mentioned above or by using the unsubscribe link included in any promotional communication that ALCMEON may send them by e-mail.
Wherever possible, ALCMEON undertakes to assist the Customer and/or Users in fulfilling their obligation to respond to requests to exercise the rights of the persons concerned. In this case, the User may write to ALCMEON at the dedicated address: privacy@alcmeon.com
The User may also transmit at any time to ALCMEON the request of a Consumer by carrying out the same steps, after having verified the identity of the applicant as a Consumer whose data has been processed on the Application.
To this end, the User must specify :
- The Consumer's identifier on the social network concerned
- The nature of the operation requested
8. Security measures
ALCMEON implements technical and organisational measures to ensure the security and confidentiality of personal data when using the Application. These measures are put in place to prevent any loss of integrity, confidentiality or availability of personal data.
9. Use of Cookies
Users are informed that a cookie may be automatically installed in their browser software when they visit the Application. A cookie is a file, often anonymous, containing data, including a unique identifier, sent by the Application server to the User's browser and stored on the User's hard disk.
Contrary to the obligation incumbent on publishers of websites and open mobile applications, which are online public communication services, the Application only processes the data of ALCMEON Customer Users connecting to the Application. The cookies deposited in this context do not fall within the scope of the European e-privacy directive and are not subject to the system of prior consent, in accordance with the CNIL's precisions regarding intranets.
Each time a User visits the Application, these cookies make it possible to carry out comprehensive statistical studies on the audience for the Application, to identify the User where applicable, to investigate the behaviour of Users within the various areas of the Application, in order to personalise the Application as far as possible in terms of organisation, display and content according to the personal data collected from the User.
The cookies used in the Application are as follows:
Type of cookie: Authentication cookie
Source: ALCMEON application
Usage: These cookies are used to identify visitors to our service and control their access to our service. For obvious security reasons, a User who has deactivated this cookie and therefore cannot be identified will not be able to access our Application.
Expiration: Session: a session is terminated when the client browser is closed.
Type of cookie: Cookie for traffic analysis: ga, gat and gid
Source: Google Analytics
Usage: These cookies are used to collect information about how visitors use our service. We use this information to compile reports and help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, how visitors arrived at the site and the pages they visited.
Expiration: Some of these cookies are automatically deleted from your system when you close your browser. Other cookies may remain for up to 13 months from the date of your last visit to our site.
Cookies from third-party sites may be stored on the User's terminal when browsing the Application. In particular, these cookies may come from the content of social networks published in the Application or from the use of the Flash application to view graphic animations or video sequences.
When browsing ALCMEON pages on social networks, cookies from these social networks or third-party sites may be installed in the User's browser. These cookies are subject to the privacy protection policies of these third party sites and are beyond the control of ALCMEON. The User is invited to read the policy for managing cookies from social networks and Flash cookies by visiting the sites concerned.
10. Changes
ALCMEON reserves the right to modify this privacy policy at any time. The version currently in force is the one available in the Application on the date of the User's connection to the Application.