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goFLUENT General Privacy Policy

Date Updated: 28 March 2022

goFLUENT is committed to protecting individuals from possible misuse of their Personal Data, protecting their right to data protection and privacy in compliance with the General Data Protection Regulation (“GDPR”), and other Data Protection Legislations, where goFLUENT operates.

goFLUENT Group SA and its subsidiaries (“goFLUENT”, “Company”, “Us”, or “We”) have created this Privacy Policy to demonstrate our firm commitment to the individual’s (“You”, “Your”) right to data protection and privacy. This Privacy Policy outlines how we handle your Personal Data and all the information you may have provided on this website that can be used to directly or indirectly identify you. We will also inform you of your Privacy Rights.

1. Who We Are

goFLUENT Group SA (Route de Pré-Bois 20, 1215 Geneva, Switzerland) is the entity that primarily controls the Company’s website and acts as “Data Controller” as defined in the General Data Protection Regulation 2016/679 (hereinafter, “GDPR”).

As Data Controller, goFLUENT respects your privacy and we are committed to processing your personal data in accordance with the Principles and Responsibilities under the GDPR.

If you have any concerns or questions about this Privacy Policy, including any requests to exercise your rights in connection with data protection as mentioned below, please feel free to contact our appointed Data Protection Officer (“DPO”): privacy@gofluent.com

goFLUENT is committed to following the Principles of Article 5 of the GDPR for the processing of your Personal Data.

2. When Does This Privacy Policy Apply?

This Privacy Policy applies to Personal Data that you provide when you interact through this website, request information from us using different media, or participate in marketing activities organized by goFLUENT Group SA, its subsidiaries (“goFLUENT”) and our partners. To learn more about the Personal Data we may collect and the purposes for which it is used, please visit Sections 4 and 5 below.

3. What Personal Data Do We Collect?

3.1. Personal Data

Personal Data means any information that directly or indirectly identifies you or another individual and which may include:

  • Identity and contact details: Name, title, company name, job function, telephone number, email address.
  • Technical and usage data: Information about how you use our website, including browser and device information (including IP address), time zone settings and location, browser plug-in types and versions, operating system and platform, and any other information you may have been provided to us and/or collected through cookies and similar technologies.
  • Marketing data: Includes your preferences in receiving marketing communication from us.

If you submit any Personal Data relating to other people, you represent that you have the authority to do so and that you permit us to use the information in accordance with this Privacy Policy.

3.2. Sensitive Personal Data.

goFLUENT does not intend to collect, use or process any Sensitive Personal Data for the delivering of our services through our website. To comply with our internal commitment, we ask you not to send us or disclose any Sensitive Personal Data (e.g., information related to racial or ethnic origin, sexual orientation, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background, or trade union membership).

3.3. Children’s Personal Data.

We do not intend our websites or online services to be used by anyone under the age of 16. If you are younger than 16, you may not register with or use this website. If you are a parent or guardian and believe we may have collected information about a child, please contact us at privacy@gofluent.com.

3.4. Personal Data of Deceased Persons

Following the GDPR, where local Data Protection Regulations may provide for rules regarding the processing of Personal Data of deceased persons, we will respond to the rights the heirs might have recognized to exercise on behalf of the deceased person.

4. How Do We Collect Your Personal Data?

We collect Personal Data from and about you in various ways, including:

4.1. Direct interaction through this website: you may share with us some of your Personal Data by filling out forms or by communicating with us by email, phone, website chat or by using other media, e.g., when you request a free trial or demo, inquire about our products or services, register for a webinar or an offline event, download marketing content, subscribe to our blog, contact us, apply for a job opening or give us feedback;

4.2. Offline events: we collect information from you when you attend any of the events organized by goFLUENT or where goFLUENT is a participant;
4.3. Cookies and other automated technologies: as you interact with our website, we may automatically collect certain information through your browser or through your device, e.g., your IP address. We collect this Personal Data by using cookies, server logs, and other similar technologies;

4.4. Through third parties: we may receive data about you from third-party services based on your online activity and actions linked to our website. Please note that goFLUENT is not responsible for the collection, use and disclosure policies of other companies. We encourage you to visit Section 10. Cookie Policy to get more information about how third-party services (Marketo, SnapEngage and Google Analytics) collect and use your Personal Data.

4.5. Through third-party public online sources: In addition to the Personal Data you share with us, we may collect data about you from third-party public online sources, such as LinkedIn, ZoomInfo and Kalibrr, based on the data you have provided on these sites. Whenever you send your data to apply for a job opening through these third-party public online sources, we will acknowledge that you are giving us your consent to use and process your data for the said purpose. goFLUENT will not be responsible for the collection, use, and disclosure of your Personal Data of these third-party public online sources other than specified in this Privacy Policy. You may click the links provided above to know more about how these third-party public online sources handle and use your Personal Data.

5. How Do We Use And Process Your Personal Data?

goFLUENT will use and process the Personal Data you provided as set out in Section 4 of this Privacy Policy.

According to article 6.1 a) GDPR, goFLUENT uses and processes your Personal Data for the following cases and purposes:

To send You Updates And News To Market Our Products And Services
Subject to a respective provision and your consent, goFLUENT may use the Personal Data that you provided in order to keep you updated on the latest product announcements, latest updates on our blog, software updates and upgrades, special offers, and other information about goFLUENT’s software and services (including marketing-related newsletters) as well as events of goFLUENT.

5.2. In Order To Take Steps Prior To The Engagement With Our Services.

According to article 6.1. b) GDPR, goFLUENT processes your Personal Data for the following purposes:

To Provide The Requested Information And Services

When you request services from goFLUENT, we will use the Personal Data provided to us or entered on our registration form to process and to provide the requested services from us, such as access to our solutions. This may include necessary steps prior to entering into the contract, creating your user profile in our Solution, providing your billing information and providing responses to your feedback on your experience or concerns about our services.

5.3. goFLUENT’s Legitimate Interest

Each of the use cases below constitutes a legitimate business interest of goFLUENT to process or use your Personal Data. If you do not agree to this approach, you may object against goFLUENT’s processing or use of your Personal Data as set out below in Section 8.

5.3.1. To Communicate And Respond To Your Queries

goFLUENT uses and processes the Personal Data you provide to us to communicate and respond to your concerns and queries when you send us an email or contact us through our website forms to inquire about products and services and to acknowledge your feedback. This may also include conversation data that you may enter via the goFLUENT web presences, contact forms, emails, or telephone.

5.3.2. To Process Your Job Application

The data provided through our Career Section or through third-party public online sources (as stated in section 4.5) will be used and processed to evaluate your candidature for present job openings you have applied for.

The processing of your Personal Data may include your (i) first and last name; (ii) contact information, including postal address, email address, social media URL, and telephone number(s); (iii) employment history; (iv) professional and educational history (including diplomas and/or certifications you might share with us), and (v) language proficiency.
It may also include conversation data that you may enter through screenings via video calling, phone, and personal interviews.

In case your profile does not meet the requirements for our open positions, you give goFLUENT the right to store and process your Personal Data, including your CV and the data provided for relevant job openings in the future.

However, in case you prefer us not to store your Personal Data attached to your job application, please let us know by reaching out to us and asking for the deletion of your personal data.

6. Where Do We Process And Transfer Your Personal Data?

6.1. How Does goFLUENT Group Handle Your Personal Data Globally?

goFLUENT may disclose, share, and transfer your Personal Data to other entities within the goFLUENT Group, but only for the purposes set forth in Section 5 of this Privacy Policy. As part of a global group of companies, goFLUENT has subsidiaries within as well as outside of the European Economic Area (the “EEA”). Therefore, whenever goFLUENT is processing your Personal Data for the purposes set forth in this Privacy Policy, goFLUENT may transfer your Personal Data to countries outside of the EEA, including to such countries in which a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. Whenever such a transfer occurs, it is based on the Standard Contractual Clauses (according to article 46.2 c) GDPR and EU Commission Decision 2021/914 or any future replacement).

6.2. How Do We Share Your Personal Data With Third-parties?

goFLUENT may also share your Personal Data with third-parties. E.g. When we co-organize events with partners, you accept that we share your registration information to process your Personal Data. In such cases, your Personal Data will be processed according to GDPR.
Kindly note, that we do not sell your Personal Data with anyone.

7. How Do We Secure And Store Your Personal Data?

7.1. Data Security

goFLUENT has implemented appropriate organizational, technical and administrative measures to protect Personal Data within our organization. These measures include information security tools to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference, and unauthorized access, modification and disclosure, you should be aware that no security procedures or protocols are ever guaranteed to be 100% secure from intrusion or hacking. Therefore there is always some risk related to Personal Data management.

7.2. Handling Data Incidents.

goFLUENT has established an internal framework which includes audit and procedures on how we handle and address your concerns regarding data breaches.

If you think there are any data breaches that have occurred with regards to your Personal Data that is connected with our services, please do contact us immediately and send us the details at privacy@gofluent.com.

7.3. Data Retention

We will keep your data for five years from our last communication with you. After that period of time, we will delete your Personal Data.

Kindly note that we might delete your Personal Data before that five years time lapse has passed, if

  • 1. you state that the Personal Data goFLUENT has about you is incorrect, (but only for as long as goFLUENT requires to check the accuracy of the relevant Personal Data),

  • 2. there is no legal basis for goFLUENT processing your Personal Data and you demand that goFLUENT restrict your Personal Data from further processing,

However, where goFLUENT is required by mandatory law to retain your Personal Data longer or where your Personal Data is required for goFLUENT to assert or defend against legal claims, goFLUENT will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.

8. Your Individual Rights

If you have any requests to exercise your rights in connection with data protection as mentioned below, please feel free to contact us at: privacy@gofluent.com.

We are committed to responding to your request within thirty (30) days.

8.1 Right Of Access To Information.

You can request from goFLUENT at any time information about which Personal Data goFLUENT processes about you.

8.2. Right To Rectification.

If the Personal Data that we process is incomplete or incorrect, you have the right to request their completion or correction at any time.

8.3. Right To Erasure.

You have the right to request the deletion of your Personal Data at any time. However, in case goFLUENT is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law.

8.4. Right To Restriction Of Processing.

You can request that goFLUENT restrict your Personal Data from any further processing in any of the following events:

  • 1. you state that the Personal Data goFLUENT has about you is incorrect, (but only for as long as goFLUENT requires to check the accuracy of the relevant Personal Data),

  • 2. there is no legal basis for goFLUENT processing your Personal Data and you demand that goFLUENT restrict your Personal Data from further processing,

  • 3. goFLUENT no longer requires your Personal Data but you claim that you require goFLUENT to retain such data in order to claim or exercise legal rights or to defend against third-party claims or

  • 4. in case you object to the processing of your Personal Data by goFLUENT (based on goFLUENT’s legitimate interest) for as long as is required to review whether goFLUENT has a prevailing interest or legal obligation in processing your Personal Data.

8.5. Right To Object.

You may object to goFLUENT using Personal Data for the above purposes set in Section 5.3 at any time. If you do so, goFLUENT will cease using your Personal Data for the above purposes (that is to say, under a legitimate interest set out above) and remove it from its systems unless goFLUENT is permitted to use such Personal Data for another purpose set out in this Privacy Policy or goFLUENT determines and demonstrates a compelling legitimate interest to continue processing your Personal Data.

If your Personal Data is processed on the basis of your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

8.7. Rights In Relation To Automated Decision And Profiling.

We respect your legal rights not to be subject to decisions that are based solely on automated processing of your Personal Data, including profiling, especially where such processing has legal or other significant effects on you. In delivering services to you, We generally do not use any automated decision making pursuant to the GDPR.

8.8. Right To Lodge A Complaint.

If you believe that goFLUENT is not processing your Personal Data in accordance with the requirements set out herein or applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country in which you live or with the data protection authority of the country or state in which goFLUENT has its registered seat.

11. Effectivity And Changes To This Privacy Policy

To ensure that our Privacy Policy is updated for our commitment to your rights to data protection and privacy and best practices, goFLUENT may revise this Privacy Policy from time to time. The Date Updated is the effective revision date of this Privacy Policy as indicated above.

12. How To Contact Us

goFLUENT respects your privacy and it is important to us. If you have any concerns or questions about this Privacy Policy, including any requests to exercise your rights in connection with data protection as mentioned above, please feel free to contact our appointed Data Protection Officer (“DPO”).

You may send us your concerns and questions using the details provided below:

DPO Evgeny Boychuk
Email address: privacy@gofluent.com