Last updated: October 2023
Offspend, a company operating under the trade name Greenly, processes your personal data to help you improve your ecological impact, taking care of the health of the planet and that of your data.
Personal data refers to any information likely to identify you directly (e.g. your name) or indirectly (e.g. your IP address) ("Personal Data").
2. What are the sources of your Personal Data?
a. Personal Data you provide directly to us
We process Personal Data that you may communicate directly to us, for example when you subscribe to a demo or to our newsletter, when you contact us in writing via our chatbot on the Greenly Website, or when you download one of our resources in the "Resources" section of the Greenly Website (the "Greenly Resources").
b. Personal Data that you indirectly provide to us
We also process your Personal Data shared by external service providers when you browse the Greenly Website, for example your IP address collected by audience measurement cookies.
3. Characteristics of the processing of your Personal Data
· a "Prospect" refers to any individual who expresses an interest in the Greenly Services (as defined below) by visiting the Greenly Website, for example by (i) formulating questions via the chatbot of the Greenly Website, (ii)subscribing to a demo or to our newsletter and/or (iii) downloading one of the Greenly Resources, without creating a customer account;
· an "Internet user" refers to the individual browsing the Greenly Website, without expressing interest in the Greenly Services.
· the "Greenly Services" refer to the services provided via the Greenly Corporate SaaS platform, intended for companies.
|PROCESSING PURPOSE||DATA SUBJECTS||PERSONAL DATA COLLECTED||LEGAL BASIS||RETENTION PERIOD*|
|Management of demo requests subscribed via the Greenly Website||Prospects||Data relating to professional life (position held, name and size of company, business sector) as well as identification and contact data (surname, first name, phone number)||Offspend's legitimate interest||3 years from (i) the last contact made by the Prospect or (ii) the end of the contractual relationship with the Prospect, if the Prospect enters into a contract with Offspend following the demo request|
|Processing requests to download Greenly Resources||Prospects||Data relating to professional life (position held, name and size of company, business sector) as well as identification and contact data (surname, first name, phone number)||Offspend's legitimate interest||3 years from (i) the last contact made by the Prospect or (ii) the end of the contractual relationship with the Prospect, if the Prospect enters into a contract with Offspend following the demo request|
|Processing contact requests / questions submitted via our chatbot on the Greenly Website||Prospects||Content of the contact request / questions (subject, date of the request / question), and e-mail address in case of electronic mail||Offspend's legitimate interest||3 years from the data collection or from the last contact made by the Prospect|
|Direct marketing||Prospects||Contact details (e-mail address and phone number)||Consent||Until (i) unsubscription or, (ii) failing that, 3 years from collection of the Personal Data or from the last contact made by the Prospect|
|Managing the sending of newsletters||Prospects||Contact details (surname, name and e-mail address)||Consent||Until unsubscription or, failing that, 3 years from the last contact made by the Prospect.|
|Audience measurement on the Greenly** WebsiteSending of targeted advertising by third-party companies||Internet usersProspects||Connection identifier (IP address) and browser dataClickstream data||For audience measurement cookies: Offspend's legitimate interests For other cookies (e.g. advertising): consent||For audience measurement cookies: the information collected via these cookies is kept for 25 monthsFor other cookies (e.g. advertising): 6 months from the date of choice by the data subject.|
*At the end of these retention periods, your Personal Data, which is strictly necessary, may be archived in an intermediate database for administrative reasons (legal, accounting, tax, etc.). For example, it may be archived for a period of 5 years from the end of the retention period in the active database, for litigation purposes (duration of the statute of limitations), or for 10 years for accounting purposes. At the end of these periods, the data will be deleted from our databases.
** These tracers do not allow the overall tracking of your browsing on the Greenly Website and are only used to produce anonymous statistical data, allowing us to measure the frequentation and/or the performance of the Greenly Website, as these measures are essential to the proper functioning of the latter.
We may also carry out statistical processing, as further processing for certain purposes in order to improve Greenly Services and carry out aggregate studies for the purposes of communication and information.
4. Do we share your Personal Data?
However, in order to allow you to browse the Greenly Website or to fulfil certain legal obligations, Offspend may share your Personal Data with the following recipients:
|Trusted service providers||Categories of trusted service providers: • For the purposes of technical support, maintenance and hosting of the Greenly Website, your Personal Data is shared with our service provider Heroku, established in Ireland; • For communication and marketing purposes: your Personal Data may be shared with Customer.Io, which hosts it exclusively within the European Union; • For the purposes of improving the Greenly Website and and statistics: your Personal Data may be shared with our service providers A/B Tasty, PostHog Cloud EU, Mixpanel and Clearbit. In such cases, your Personal Data is exclusively hosted within the European Union. Offspend ensures that these third parties implement security measures to guarantee the confidentiality, integrity and availability of your Personal Data.|
|Offspend internal services||Your Personal Data is processed by Offspend's competent internal departments and more specifically by Offspend's marketing and tech teams based in France.|
|Administrative and judicial authorities||Offspend may also be required to disclose your Personal Data when required to do so by judicial and administrative authorities that have a legitimate need to access such information or to allow Offspend to defend its own rights before the competent authorities. In addition, if Offspend is subject to a transfer of a business or assets, we may communicate your Personal Data to the potential buyer of this business or these assets.|