Privacy Policy
1. Purpose of the Privacy Policy
1.1. This Personal Data Protection Policy
(the “Policy”) outlines Stairwage's practices for collecting and sharing personal data in connection with the Services provided.
1.2. The person responsible for processing Personal Data
The person responsible for processing Personal Data is the company Stairwage.
1.3. This Policy covers the following issues:
• (a) Personal Data that may be collected;
• (b) Use of Personal Data;
• (c) Personal Data Protection;
• (d) Exercise of rights concerning Personal Data.
2. Personal Data that may be collected as part of the Services
2.1. Stairwage collects and processes all or part of the following Personal Data:
• (a) First name; Last name; Employer identity; Unique identifier; Unique identifier; date of employment; date of end of employment contract; IBAN; Contact details (postal addresses, email addresses, telephone numbers); personal and professional; Personal and professional; Available Accounts; Payroll Estimation; Request for Deposits; Deposits Received.
• (b) Any correspondence between the User and Stairwage: in the event of an exchange between a User and Stairwage, the latter keeps a record of the correspondence (s).
• (c) Data relating to the Application, and to the use of the connection to the Application.This data includes in particular connection logs and details of visits to the Application as well as information collected through tracking technologies including, but not limited to, the IP address, the version of the operating system, the version of the operating system, the traffic data, the location data, etc.
2.2. Personal Data that may be collected as part of the Services (i.e. directly entered by the User via the Application):
• (a) Name and first name of the Employee;
• (b) Employee email address;
• (c) Employee's mobile phone number;
• (d) Postal address of the Employee.
3. Use of Personal Data
3.1. The purposes for which Stairwage uses the Personal Data collected
The purposes for which Stairwage uses the Personal Data collected through the Client Web Interface and/or in connection with the provision of the Services are set out below as well as the “legal bases” on which Stairwage relies to process Personal Data.
3.2. These “legal bases” are set out in the regulation (EU)
2016/679 of 27 April 2016 relating to the protection of natural persons with regard to the processing of personal data and to the free movement of such data, and repealing Directive 95/46/EC (the “RGPD”), which authorizes companies to process personal data only on the basis of the specific “legal bases” provided for by the RGPD and, where applicable, national laws such as Law No. 78-17 of 6 January 1978 as amended (the “Data Protection Act”). Freedoms”).
The main legal bases justifying the use of Personal Data are the following:
• Consent: when a User has consented to the use of their Personal Data (a form for collecting their consent is submitted to them for this purpose, it being specified that the User may withdraw their consent by contacting Stairwage in the manner described in the Privacy Policy);
• Contract execution: when Personal Data is necessary for the conclusion or execution of the contract (i.e., the General Terms of Use), for example in the context of the provision of Services;
• Legal obligation: when Stairwage must use Personal Data to comply with its legal obligations;
• Legitimate interests: when Stairwage uses Personal Data for the pursuit of a legitimate interest and the reasons for which Stairwage uses such Personal Data take precedence over any infringement of the User's data protection rights.
3.3. Stairwage processes Personal Data as an employer's subcontractor for the following purposes:
• (a) To allow employers to offer their employees flexible salary management
Legal bases: execution of the contract, consent
• (b) To allow employees to request monthly installment payments
Legal bases: execution of the contract, consent
• (c) To monitor the salary in real time. This will make it possible to estimate the amount of the deposit that can be granted
Legal bases: execution of the contract, consent
3.3. Stairwage processes Personal Data as a data controller for the following purposes:
• (a) To allow Users to use the Application and provide them with the Services.
Legal grounds: contract execution, consent
• (b) To communicate effectively with Users: in order to carry out its activities, including to answer Users' questions, and to communicate with Users by any means.
Legal grounds: contract execution, consent
• (c) To reorganize or make changes related to Stairwage's business: in the event that: Stairwage (i) is subject to negotiations concerning the transfer or transfer of its business or part of it to a third party; (ii) sees its business transferred or ceded to a third party; or (iii) undergoes a reorganization, Stairwage may be forced to transfer Personal Data to the third party concerned (or, (where applicable, to its advisers) as part of any audit process in order to analyze any transfer, transfer or reorganization considered. Stairwage may also transfer Personal Data to a third party after the transfer, transfer or reorganization so that they can use it for the same purposes as those defined in this Policy.
Legal grounds: legitimate interests
4. Transfer, storage and security of Personal Data
security
Stairwage maintains physical and electronic protection measures in order to protect Personal Data.
All information provided by the Customer or a User is stored on secure servers of Stairwage or subcontractors and is accessible and used in accordance with the Policy and according to the security standards applicable in this area.
Transfer of Personal Data outside the European Economic Area (EEA)
Personal Data may be viewed, transferred and/or stored by Stairwage or its suppliers in a location outside France, whose data protection laws may be of a lower level than those applicable in France. In this case, Stairwage is committed to protecting, under all circumstances, Personal Data in accordance with this Policy.
The Personal Data thus transmitted may, during various operations, be transferred to a country within the European Union or outside the European Union. As part of a transfer to a country outside the European Union, “Standard Contractual Clauses” drawn up by the European Commission have been signed by Stairwage (or are in the process of being signed, if applicable).
In the event that Stairwage transfers Personal Data from the European Economic Area (EEA) to outside the EEA, Stairwage may be required to take specific additional measures in order to protect the Personal Data concerned. Some countries outside the EEA have been considered by the European Commission to guarantee a level of protection equivalent to that guaranteed by the laws of the EEA relating to the protection of Personal Data, and therefore no additional guarantees are required to transfer Personal Data to these countries. In countries that have not received these approvals, Stairwage implements appropriate guarantees for such a transfer, for example by using standard contractual clauses approved by the European Commission, or other guarantees authorized by applicable regulations.
If a user wishes to obtain a copy of the specific protection measures that apply to the transfer of their Personal Data, they can contact Stairwage in the manner indicated in the “” Contact us ” of the Privacy Policy.
Retention periods
Stairwage's Personal Data retention periods are based on its commercial needs, on the duration of its contractual relationships with the User, and on legal requirements. Stairwage retains Personal Data for as long as necessary for the purposes pursued by collecting Personal Data and for any other authorized related purpose. For example, Stairwage may keep information relating to a User account for the duration of the Services it provides to it. When Personal Data is no longer required, it can be irreversibly anonymized (and in this case, stored and used by Stairwage) or destroyed.
At the end of this period, they will be deleted within a maximum of one month. However, in order to meet the legal obligations of the Employer and/or Stairwage, the data may be kept in an archival database for 10 years. This data may be consulted on an ad hoc basis and motivated by specifically authorized persons.
Stairwage ensures the confidentiality of Personal Data posted or collected on the Application, through security devices and authorizations to access the portal to meet its legal obligations.
5. User Rights - Contact Stairwage
Updating Personal Data relating to User Information
Stairwage makes every effort to ensure that User Information is accurate. However, the User is required to notify Stairwage via his Personal Space of any modification of his User Information or by contacting Stairwage according to the procedures indicated in the “” Contact Stairwage ” of the Privacy Policy.
User Rights
The User can exercise his right to access, modify, rectify, rectify, oppose, oppose, delete and limit personal data concerning him, by sending a request by clicking on the “Need help?” section. Contact us” available on the Application. The User can assert his right to portability by the same process.
The User can also send Stairwage his wish to delete the account by clicking on the “Deactivate my account” section available on the Application. The User can update the information in his profile at any time on his Personal Space.
Users have the right to ask Stairwage to:
• (a) Provide them with more details about the use made of their Personal Data;
• (b) Provide them with a copy of all the Personal Data provided by the User;
• (c) Update any errors in User Information held by Stairwage;
• (d) Delete any Personal Data that Stairwage would no longer have the legitimacy to process;
• (e) When the processing of certain Personal Data is based on consent, to withdraw consent in order for Stairwage to end this particular processing;
• (f) Oppose any processing based on legitimate interest, unless the reasons why Stairwage has undertaken such processing outweigh any prejudice to the User's rights in terms of the protection of Personal Data;
• (g) Limit Stairwage's use of Personal Data when a complaint is being investigated;
• (h) Define guidelines on the fate of their Personal Data after their death in accordance with the Data Protection Act.
In the event that a User is not satisfied with the use made of his Personal Data or with Stairwage's response to the exercise of one of his rights, he has the right to file a complaint with the Commission Nationale de l'Informatique et des Libertés (the “Commission Nationale de l'Informatique et des Libertés”).CNIL”) or directly online on the CNIL website: https://www.cnil.fr or by post by writing to the following address: CNIL, 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07.
Contact Stairwage
For any question relating to their Personal Data, Users are invited to contact our DPO - Stairwage at the following email address: contact@stairwage.com
