Privacy policy

Last updated on 15 February 2022

This privacy policy (“Privacy Policy”) has been drafted by the simplified joint-stock company (société par action simplifiée) SalesCrew, registered under laws of France to the trade companies registered of Evry under the number 879 223 923, with its head office located 3 rue Jules Guesde à Ris-Orangis (91330) (“SalesCrew”).

SalesCrew is a publisher of softwares dedicated to the management of variable compensation. Within the framework of its activity, SalesCrew provides its clients with a software, which consists of a specific interface for the staff in charge of the follow-up of the variable compensation and a specific interface for the sales representatives concerned by the variable compensation.

The purpose of the Privacy Policy is to describe the processing of personal data that SalesCrew carries out in order to fulfil its obligation to provide information as a data controller within the meaning of the texts on the protection of personal data. The Privacy Policy is published and accessible at any time on
the following website: https://bit.ly/privacypolicy-qobra

1. Definitions and vocabulaires

The following definitions are applicable to the entire Privacy Policy:

  • “Administrator”: refers to any natural person who is an employee of the Client and/or any thirdparty, expressly authorized by the Client to use the Software in order to manage the variablecompensation of the Users.
  • “Account”: refers to the personal account allowing any Administrator and any User to accessthe Software.
  • “Client”: refers to any legal entity that has entered into a contract with SalesCrew in order tobenefit from the Software and Services as well as any natural person representing, employed ormandated by the legal entity to act on its behalf.
  • “Contract”: refers to any contract concluded between SalesCrew and a Client in order to providethe Software and the Services.
  • “Data Subject”: refers to a Visitor, Administrator, User, or Client.
  • “Data Processor”: refers to any company whose services SalesCrew uses to implement thevarious personal data processing operations described below.
  • “Personal Data Regulation”: refers to Regulation (EU) 2016/679 of the European Parliamentand of the Council of 27 April 2016 on the protection of natural persons with regard to theprocessing of personal data and on the free movement of such data and of the French Law No.78-17 of 6 January 1978, Loi relative à l’informatique, aux fichiers et aux libertés, in its latestversion in force.
  • “Software”: refers to the digital Software called Qobra available at https://app.qobra.co andpublished by SalesCrew.
  • “Service”: refers to any service provided by SalesCrew as part of the Software as specified inthe Contract.
  • “User”: refers to any natural person who uses the Software for the calculation of his/her variablecompensation as an employee or as a service provider of the Client.
  • “Visitor”: refers to any person consulting or browsing the Website.
  • “Website”: refers to SalesCrew’s marketing website available at https://www.qobra.co/.

Unless circumstances request otherwise, definitions in the singular include the plural and vice versa.

2. Roles and liabilities of salescrew

2.1 SalesCrew acting as a data controller

SalesCrew is the data controller, within the meaning of the Personal Data Regulation of the following data:

  • Visitors’ connection data on the Website (IP address, browsing history, unique numberassociated to a cookie, language preferences);
  • Visitors’ and Clients’ contact data (surname, first name(s), email address, telephone number,job title, company name for/with which Visitors and Clients work);
  • Client’s billing data (billing address, payment method, chosen bank, transaction history, IBAN);
  • Administrators’ and Users’ login date (login ID, protected password).

For any question relating to the processing of their personal data or to exercise their rights under the Personal Data Regulation, Data Subjects may contact SalesCrew at the following addresses:

  • Via email: data@qobra.co and/or
  • Via letter : SalesCrew, Données personnelles, 3 rue Jules Guesde, 91330 Ris-Orangis (France).

2.2 SalesCrew acting as a data processor

SalesCrew is the data processor, within the meaning of the Personal Data Regulation of the following data:

  • Administrators’ and Users’ identifying data (surnames, first names, email address, pictures);
  • Users’ data allowing the calculation of the compensation (career path, position held,compensation received, customer performance).

SalesCrew has no control over the means and purposes of the processing carried out by the Client, and therefore acts as a data processor within the meaning of the Personal Data Regulation. The manner in which the Client has entrusted SalesCrew with the processing of personal data has been contractually stipulated in the Contract signed between SalesCrew and the Client, in accordance with the Personal Data Regulations.

Consequently, Administrators and Users contacting SalesCrew at the above address will be redirected to the data controller of their personal data.