Privacy Policy

Application date: May 1st 2021

SoftFluent Software Personal Data Protection Policy

SoftFluent Software (hereinafter “SoftFluent Software” or “we”) offers users (hereinafter the "User(s)" or "you") a "RowShare" software service (hereinafter the “Service”) allowing them to create and personalize data tables and share them. The Service is accessible through a recent browser connected to the Internet.

SoftFluent Software may collect and process certain personal data in this context.

In accordance with European Regulation 2016/679 of 26 April 2016 on the protection of personal data (“GDPR”) and the “Data Protection Act” of 6 January 1978 as amended, SoftFluent Software agrees to implement measures adequate to ensure the protection, confidentiality and security of the personal data of any person from whom data is collected.

All the personal data of Users collected on the site https://www.rowshare.com and its mobile versions (hereinafter together the “Site”) and/or during registration for the Service and during its use, are processed by SoftFluent Software as data controller. On the other hand, for the personal data of third parties contained in the tables created by the Users during use of the Service (hereinafter the “User Content Data”), SoftFluent Software only acts as a subcontractor on behalf of Users.

The purpose of this data protection policy (hereinafter the “Data Protection Policy”) is to inform Users of the commitments made by SoftFluent Software in order to ensure that personal data is respected.

1.       Definitions

• “Personal data”: any data allowing the direct or indirect identification of a natural person.
• “Data processing”: operations performed on personal data, notably collection, recording, use, transmission or communication.
• “Data Controller”: legal entity in charge of determining the purposes of processing and the means implemented.
• “Subcontractor”: the entity that processes personal data on behalf of the data controller. 

2.       Treatment of the personal data of Users

2.1.  Data collected

SoftFluent Software takes care to collect and process personal data that is relevant, adequate, not excessive and strictly necessary to achieve the purposes which have been previously determined. SoftFluent Software takes all necessary steps to ensure that your data is accurate, complete and, if necessary, updated.

Thus, we process personal data concerning you that you may send to us, notably during the following operations:

• When you browse the Site; 
• When you wish to contact us via the “chat” or the form offered on the Site;
• When you subscribe to our Service and authenticate yourself within this framework (whether directly or by using social network authentication protocols);
• When you proceed to payment for the Service;
• When you use our Service. 

In this context, SoftFluent Software may, in particular, be required to collect and process the following personal data (depending on the version of the Service chosen):

• Your identity: first name, last name;
• Your contact details: email address, postal address, telephone number;
• Your account identifiers: email address and password;
• Your usage data: logs of access to the pages of the Site, activities related to features and notifications (please see the section below relative to cookies);
• Your payment data (for paid offers) - however, please note that SoftFluent Software does not directly process your data in this context, since said data is collected and hosted by the payment service provider used by SoftFluent Software;
• Any other information that you provide to us directly and voluntarily in connection with use of the Site / Service and in connection with our activity. 

The mandatory nature of the information you must provide is generally indicated by an asterisk at the time of data collection on the corresponding forms. Any failure to respond or any response deemed abnormal by SoftFluent Software may result in SoftFluent Software's refusal (or impossibility) to take your request into account.

You agree that the personal data concerning you communicated to SoftFluent Software is up-to-date, accurate, complete and unambiguous.

The case of data from other Users

Within the framework of the Service, you have the possibility of offering access to one or more of your tables to other people and the possibility of contributing to it. To do so, SoftFluent Software will contact these people by email at the email address you provided. You agree to inform the persons concerned about providing their email address to SoftFluent Software.

In any case, SoftFluent Software will only use this email address for the purpose of allowing these people to participate in and contribute to your table. The same goes for the referral programs that allow a User to recommend RowShare.

In the event that they register for the Service, they will then be covered by this Privacy Policy.

SoftFluent Software will process this data as a data controller in accordance with this Data Protection Policy.

2.2.  Purposes of processing

The processing done by SoftFluent Software serves explicit, legitimate and determined purposes.

Your data may be processed for the following purposes:

• To answer your questions, requests for information and complaints;

In this context, the legal basis for processing is either execution of the contract if the request is linked to an existing contractual relationship between SoftFluent Software and you, or the legitimate interests of SoftFluent Software, specifically its economic interest in communicating simply and effectively with you and understanding your needs and expectations.

• To manage your subscription to the Service and your authentication in this context;

In this context, the legal basis for processing is execution of the contract between you and SoftFluent Software.

• To manage your payments (when you subscribe to a paid offer);

In this context, the legal basis for processing is execution of the contract between you and SoftFluent Software and SoftFluent Software's compliance with its legal obligations.

• To manage your use of the Service (your identification within the community, your creations and customizations of tables and sharing of them);

In this context, the legal basis for processing is execution of the contract between you and SoftFluent Software.

• To send you commercial information about us if you agree;

In this context, processing is based on the legitimate interests of SoftFluent Software, specifically its economic interest in informing you of its activities and in offering you personalized offers;

•  To send you notifications relative to (i) your activity and/or that of another User on the tables created and shared (modification of a table or reminder, for example) and/or (ii) intrinsic functioning of the Service (confirmation of account creation, payment confirmation, password renewal, etc.). Notifications relating to your activity and/or that of another User on the tables can be deactivated via the settings of the Service. However, notifications relative to the intrinsic functioning of the service are necessary for operation of the Service and will, therefore, be sent to you systematically.

In this context, the legal basis for processing is the legitimate interest of SoftFluent Software in offering its Users a quality Service (for notifications not necessary for operation of the Service) or compliance by SoftFluent Software with its legal obligations (for notifications necessary for operation of the Service).

• To allow other users to access the tables and contribute to their content and to manage sponsorship operations;

In this context, the legal basis is the legitimate interest of SoftFluent Software to offer an effective and collaborative Service and to attract new Users.

• To perform statistical analyses, develop the Site and the Service, optimize your browsing and provide you with a personalized experience (please see section 8 below relative to cookies);

In this context, the legal basis for processing is the legitimate interest of SoftFluent Software, more specifically its economic interest in constantly improving its Site and its Service and in offering you suitable content and optimal browsing.

• To satisfy our legal obligations, defend ourselves in the event of litigation and respect any court decision;

In this context, the legal basis for processing is SoftFluent Software's compliance with its legal obligations and its legitimate interest in dealing with any possible litigation.

2.3.  Recipients of data

SoftFluent Software only communicates your personal data to authorized and determined recipients, in accordance with the provisions of applicable regulations.

SoftFluent Software may provide access to your personal data to its third-party service providers to perform services of:

• Data hosting;
• Sending and monitoring of notification emails/messages and marketing campaigns;
• Management of the “chat” available on the Site and of your requests in this context;
• Monitoring and analysis of your navigation and your actions;
• Management of Site functionalities (including User authentication);
• Management of payments and the life cycle of your subscription (subscription, cancellation, change of plan, etc.).

Data transmissions to these service providers are done in a secure manner. SoftFluent Software is committed to each recipient being aware of the guiding principles of the protection of personal data and being bound by them in application of the law and/or a specific contract.

In addition, your personal data may be shared with third parties for the following reasons:

• In the context of a merger or acquisition of all or part of SoftFluent Software by another company, which you accept;
• In response to legal or administrative proceedings of any kind or to law enforcement measures requested by the competent authorities;
• To comply with legal obligations, to protect the rights and/or safety of an individual, to protect the rights and property of SoftFluent Software, including the need to have this Data Protection Policy and our Terms of use respected and to prevent fraud, security or technical issues. 

2.4.  Transfer of data

SoftFluent Software takes care of storing your personal data within the European Union.

2.5.  Duration of data retention

The retention periods practiced by SoftFluent Software are as follows: 

• 5 years following the end of the commercial / contractual relationship for any data provided within the framework of your subscription to the Service;
• 3 years following the last contact with you for any data collected for commercial prospecting purposes;
• 10 years for any data necessary for accounting purposes;
• Until the end of the processing of your request for any request / complaint (and in accordance with the limitation periods applicable in the event of litigation);
• Your account information is kept until your account is closed;
• When cookies or other tracers not necessary for operation of the Site are placed on your terminal, they are kept in accordance with the legal obligations and recommendations issued by the authorities. 

2.6.  Security of data

The security of your data is a priority for SoftFluent Software, which agrees to make every effort, in accordance with standard industry practices, to guarantee the security of the data stored on its servers.

However, SoftFluent Software cannot guarantee the full and complete security of data sent via the Internet since, by definition, this cannot be the responsibility of SoftFluent Software. Therefore, it is recommended that RowShare not be used to store highly confidential or sensitive data.

2.7.  Your rights

You have the following rights over your personal data:

• Access right: You have the right to obtain (i) confirmation that personal data concerning you is not being processed and, when such data is being processed, to obtain (ii) access to this data and a copy of it.
• Rectification right: You have the right to obtain the rectification of personal data concerning you which is inaccurate. You also have the right to have incomplete personal data completed, including by providing a supplementary statement.
• Deletion right: In certain cases, you have the right to obtain the deletion of your personal data. This right is not, however, an absolute right and SoftFluent Software may have legal or legitimate reasons for keeping such data. 
• Limitation of processing right: In certain cases, you have the right to obtain limited processing of your personal data.
• Portability right: You have the right to receive your personal data that you have provided to SoftFluent Software, in a structured, commonly used and machine-readable format. You also have the right to send this data to another data controller without SoftFluent Software being able to prevent this. This right only applies when the processing of your personal data is based on your consent or on the performance of a contract and such processing is done using automated processes.
• Opposition right: At any time, you have the right to object, for reasons relating to your particular situation, to the processing of personal data concerning you when said processing is based on the legitimate interests of SoftFluent Software. SoftFluent Software can, however, invoke legitimate and compelling reasons requiring further processing. When your personal data is processed for prospecting purposes, you have the right to object to the processing of this data at any time. You can benefit from this right by clicking on the “unsubscribe” link available at the bottom of the messages received.
• The right to provide instructions regarding the use of your data after your death: You have the right to give SoftFluent Software instructions regarding the use of your personal data after your death.

To exercise one or more of these rights, you should contact SoftFluent Software by email at [email protected] or by postal mail at SoftFluent Software, 5 rue de la Renaissance, 92160 Antony, France.

You also have the right to contact the CNIL in order to lodge a complaint concerning the practices relative to the protection of personal data of SoftFluent Software.

3.       Processing of User Content Data

Users are likely to enter the personal data of third parties in the tables created on the Service.

This User Content Data remains the property of the Users who can collect, use and delete this Data as they wish. User Content Data is, therefore, never used by SoftFluent Software for its own purposes. It is only processed by SoftFluent Software on behalf of Users, in application of the Terms of Use and their instructions (except in the event of a legal obligation to the contrary). This, SoftFluent Software performs a hosting service on behalf of Users for User Content Data and consultation of said Data in certain cases (request for assistance from a User, performance of maintenance). In the free version of the Service, SoftFluent Software reserves the right to delete User Content Data after 90 days of inactivity by the User concerned.

SoftFluent Software agrees to process User Content Data in accordance with the GDPR and the “Informatique et Libertés” law.

4.       Cookies

4.1.  What are cookies?

This Data Protection Policy applies to cookies and other technological systems present in the digital services published by SoftFluent Software and accessible by a User via his computer, tablet, smartphone or other mobile terminal.

The User is informed that during his visits to the Site, a cookie may be installed automatically on his browser. A cookie is a block of data that does not identify users but is used to record information relative to his browsing on the Site.

SoftFluent Software stores cookies on your hard drive:

• When you consult the pages of the Site through which the Service is provided;
• During certain specific operations that are logged to track User behavior, notably around the creation, editing and sharing of tables;
• To memorize the settings of your tables on your behalf (notably filters and sorts)
• When activating the notifications configured by the User, which notably allows the sending of emails on changes to tables or their data.

Please note that SoftFluent Software reserves the right to collect your IP address. This IP address will be kept for the same duration as the cookies and will only be used to allow proper administration of the Service and the Site.

Some of these cookies are first-party, meaning that they are our own cookies, which we use to improve your experience. Other cookies are third-party cookies that are placed on our Site by third parties in order to propose their services.

4.2.  Purposes of cookies

The purpose of the cookies stored during your browsing on the Site and your use of the Service is to ensure proper functioning of the Site and the Service, to allow us to improve and optimize operation of the Site and the Service by knowing the frequency of use of certain parts and, finally, to allow or facilitate communication between you and SoftFluent Software.

These cookies help us better understand how our Users interact with our Site. They allow us to recognize and count the number of visitors and to know how they navigate on the Site. These cookies help us improve the way the Site and the Service work by ensuring, for example, that Users can easily find what they are looking for. Lastly, we can use these cookies to find out more about the features that are used the most by our Users and to find out what we can improve.

4.3.  Cookies used

4.4.  Disabling and deleting cookies

The storage of a cookie on your browser terminal is subordinate to your will. We collect your express consent prior to storing cookies on your terminal. You can modify your choices at any time in terms of accepting or rejecting cookies placed on your terminal, either directly on the Site, or on your browser, or online with different operators.

The cookies listed above as essential are necessary for proper functioning of the Site and the Service. They cannot, therefore, be deactivated on the Site. If you block them by a third-party mechanism, proper functioning of the Site and the Service will be compromised.

How can you exercise your choices?

a.       From the “cookies” banner displayed during your first visit to our Site

You can Accept all cookies or Refuse all cookies with one click via this banner.

If you refuse all cookies, those indicated above as essential will nevertheless be stored because they are necessary for proper functioning of the Site and the Service.

b.       From your browser settings

You can configure your browser software so that (i) either the choice to accept or reject cookies is offered to you occasionally, before a cookie is likely to be saved, (ii) or you can systematically accept or refuse to have cookies stored on your terminal.

For the management of cookies and of your choices, the configuration of each browser is different. It is described in the browser's help menu, which makes it possible to know how to modify your wishes regarding cookies.

• Microsoft Edge https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy
• Apple Safari http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
• Google Chrome http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• Mozilla Firefox http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
• Opera http://help.opera.com/Windows/10.20/fr/cookies.html 

“Do not track”: You can also configure your browser so that it sends a code indicating to websites that you do not want to be tracked (“Do not track” option).

• Microsoft Edge https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy
• Apple Safari http://support.apple.com/kb/PH11952
• Google Chrome https://support.google.com/chrome/answer/114836?
• Mozilla Firefox https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister
• Opera http://help.opera.com/Windows/12.10/fr/notrack.html

c.        Directly online with third parties

You can request the deactivation of tracking by the following actors directly on their respective sites:

·         Google: https://adssettings.google.com/ and https://tools.google.com/dlpage/gaoptout

·         LinkedIn: https://www.linkedin.com/mypreferences/g/guest-cookies

·         Facebook: http://www.youronlinechoices.eu/

·         Mouseflow: https://mouseflow.com/opt-out/

·         Intercom: https://www.intercom.com/legal/cookie-policy

5.       Contact

For any additional questions or issues regarding our Data Protection Policy, please contact us by email at [email protected] or by post at SoftFluent Software, 5 rue de la Renaissance, 92160 Antony, France.