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Privacy Policy

20240519_rev01 → 20240903_rev01COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED
1212- the management of marketing communications or prospection
1313- the use of one of our websites (not already covered by a specific privacy policy)
1414- the recruitment management
1515- the compliance with our legal obligations
1616- the guarantee of legitimate interests
1717
18The data collected for the operation of our services, where Scaleway acts as a processor, is governed by our [General Conditions of Services](https://www.scaleway.com/en/contracts/) as well as our [Data Processing Agreement (DPA).](https://www.scaleway.com/en/contracts/)
19
1820## What kind of personal data is processed ?
1921
2022Scaleway is required to process the following categories of data:
2123
2224- Data relating to identity: name, first name, postal and email address, telephone number, customer number, signature, proof of identity.
2325- Billing data: bank details, means of payment, invoices, etc.
2628- Connection data: IP address, user ID, location data, connection and event logs etc.
2729
2830The categories of data used are indicated in each of the treatments in the following section. Any reference to "user account data" includes all account data.
2931
3032## How we use your data.
3133
32Contracts management and customer relations
34## Contracts management and customer relations
3335
3436Scaleway processes your data in order to manage contracts for the services you use. This includes the management of accounts, support and payment methods.
3537
36| | | | | |
37| --- | --- | --- | --- | --- |
3838| Purposes | Categories of data | Legal basis | Retention | Categories of recipients |
39| Management of contracts and customer relations (management of accounts, support and means of payment) | Identity data Billing data Consumption data Communication data Connection data | Execution of the contract | Duration of the contractual relationship plus an archiving period to meet our legal obligations and guarantee the defense of our legitimate interest | Scaleway Services Entitled Scaleway Partners for support and payment management Authorized third parties\* |
40| Management of contracts with our partners (service providers and suppliers) | Identity data Commercial relationship monitoring data (activity reports and, communications) | Execution of the contract | Duration of the contractual relationship | Scaleway Services Entitled Scaleway Partner for the management of suppliers Authorized third parties |
39| --- | --- | --- | --- | --- |
40| Management of contracts and customer relations (management of accounts, support and means of payment) | Identity data
41Billing data
42Consumption data
43Communication data
44Connection data | Execution of the contract | Duration of the contractual relationship plus an archiving period to meet our legal obligations and guarantee the defense of our legitimate interest | Scaleway Services
45Entitled Scaleway Partners for support and payment management
46Authorized third parties\* |
47| Management of contracts with our partners (service providers and suppliers) | Identity data
48Commercial relationship monitoring data (activity reports and, communications) | Execution of the contract | Duration of the contractual relationship | Scaleway Services
49Entitled Scaleway Partner for the management of suppliers
50Authorized third parties |
4151
42Sales and Marketing
52\*Means any public authority or administration authorized by a text to receive personal information
4353
54## Sales and Marketing
55
4456Scaleway processes certain data in order to send its service offers to its customers or prospects, guests for events or even collect their opinions on products (processing may involve profiling techniques). These processing operations may be based either on legitimate interest, if the person is already a customer of the company, particularly if the proposals concern products or services similar to those already subscribed, or on consent. Scaleway mainly collects this data directly but can also obtain it indirectly via specialized data processors in conformity with all applicable legal requirements.
4557
46| | | | | |
47| --- | --- | --- | --- | --- |
4858| Purposes | Categories of data | Legal basis | Retention | Categories of recipients |
49| Commercial prospecting and communication campaigns relating to our products and services | Identity data Billing data Consumption data Communication data Connection data | Legitimate interest Consent | Duration of the contractual relationship Account deletion request withdrawal of consent objection of the person | Scaleway Sales and Marketing Teams Entitled Scaleway Partners for the management of marketing campaigns and customer relation Authorized third parties |
50| Organization of events to promote our services | Identity data Communication data Connection data | Legitimate interest Consent | Duration of the contractual relationship Account deletion request | Scaleway Sales and Marketing Teams Entitled Scaleway Partners for the management of events Authorized third parties |
51| Management of cookies and other trackers (learn more about our cookie policy) | Connection data | Consent | Cookies are stored between 3 months and 1 year depending on the type of cookie used | Scaleway Sales and Marketing Teams Entitled Scaleway Partners for the cookies management Authorized third parties |
52| Carrying out satisfaction surveys or quality surveys on our services and the training of our teams | Identity data Billing data Consumption data Communication data Connection data Audio or video recording | Legitimate interest Consent | 1 year and anonymization | Scaleway Sales and Marketing Teams Entitled Scaleway Partners for marketing analysis Authorized third parties |
53| Produce usage statistics | Connection data | Legitimate interest | Cookies: between 3 months and 1 year Service usage data kept during the contractual period or anonymized | Scaleway Sales and Marketing Teams Entitled Scaleway Partners for quality analysis Authorized third parties |
59| --- | --- | --- | --- | --- |
60| Commercial prospecting and communication campaigns relating to our products and services | Identity data
61Billing data
62Consumption data
63Communication data
64Connection data | Legitimate interest
65Consent | Duration of the contractual relationship
66Account deletion request withdrawal of consent objection of the person | Scaleway Sales and Marketing Teams
67Entitled Scaleway Partners for the management of marketing campaigns and customer relation
68Authorized third parties |
69| Organization of events to promote our services | Identity data
70Communication data
71Connection data | Legitimate interest
72Consent | Duration of the contractual relationship
73Account deletion request | Scaleway Sales and Marketing Teams
74Entitled Scaleway Partners for the management of events
75Authorized third parties |
76| Management of cookies and other trackers (learn more about our cookie policy) | Connection data | Consent | Cookies are stored between 3 months and 1 year depending on the type of cookie used | Scaleway Sales and Marketing Teams
77Entitled Scaleway Partners for the cookies management
78Authorized third parties |
79| Carrying out satisfaction surveys or quality surveys on our services and the training of our teams | Identity data
80Billing data
81Consumption data
82Communication data
83Connection data
84Audio or video recording | Legitimate interest
85Consent | 1 year and anonymization | Scaleway Sales and Marketing Teams Entitled Scaleway Partners for marketing analysis
86Authorized third parties |
87| Produce usage statistics | Connection data | Legitimate interest | Cookies: between 3 months and 1 year
88Service usage data kept during the contractual period or anonymized | Scaleway Sales and Marketing Teams
89Entitled Scaleway Partners for quality analysis
90Authorized third parties |
5491
55Recruitment
92## Recruitment
5693
5794Scaleway also processes the personal data of candidates as part of its recruitment procedure.
5895
59| | | | | |
60| --- | --- | --- | --- | --- |
6196| Purposes | Categories of data | Legal basis | Retention | Categories of recipients |
62| Recruitment | Identity data | Execution of contract or pre-contractual measures | If the application is not accepted, the data is kept for a maximum period of 2 years If the application is accepted, the data is kept for the entire duration of the contract, accompanied by an archiving period intended to comply with our legal obligations or guarantee the legitimate interests of the company. | Human resources services Manager and team concerned Scaleway partners for human resources Authorized third parties |
97| --- | --- | --- | --- | --- |
98| Recruitment | Identity data | Execution of contract or pre-contractual measures | If the application is not accepted, the data is kept for a maximum period of 2 years
99If the application is accepted, the data is kept for the entire duration of the contract, accompanied by an archiving period intended to comply with our legal obligations or guarantee the legitimate interests of the company. | Human resources services
100Manager and team concerned
101Scaleway partners for human resources
102Authorized third parties |
63103
64Legal obligations
104## Legal obligations
65105
66106Scaleway processes some of your data in order to meet its legal obligations. This is particularly the case in order to secure our services as a provider of electronic communications services, to meet our accounting and tax obligations or to process your requests for rights relating to data protection.
67107
68| | | | | |
69| --- | --- | --- | --- | --- |
70108| Purposes | Categories of data | Legal basis | Retention | Categories of recipients |
71| Guarantee the security of our customers as a provider of electronic communications services (Directive 2002/58/EC and art 32 of the GDPR) | Identity data Billing data Consumption data Communication data Connection data | Legal obligation | Duration of the contractual relationship plus an archiving period for the data necessary to guarantee compliance with our legal obligations | Entitled Scaleway Services Entitled Scaleway Partners for security management Authorized third parties (auditors etc.) |
72| Abuse of Scaleway services includes cyber-crime, copyright violation, illegal or offensive content, spamming and malware distribution. Abuse should be reported in the console. These data processings are likely to be subject to automated decision-making (e.g. anti-spam control) | Identity data User account information | Legal obligation | Duration necessary to meet our legal obligations | Entitled Scaleway Services Entitled Scaleway Partners for the ticketing and support management Authorized third parties |
73| Responses to the data protection requests and any complaints related to the protection of personal data | Identity data (including proof of identity) User account information ll the data related to the complaint | Legal obligation | 5 years from ticket closing Verification of identity card: 1 month | Entitled Scaleway Services Entitled Scaleway Partner for the management of subject requests Authorized third parties Entitled Iliad service |
74| Data breaches management | Identity data User account information related to the data breach All data related to the data breach | Legal obligation | 5 years from the closure of the data breach | Entitled Scaleway Services Competent administrative authority |
75| Accounting obligations | Billing data | Legal obligation | 10 years from the end of the contract | Entitled Scaleway Services Entitled Scaleway Partner for the management of payments and invoices Competent administrative authority |
76| Legal or administrative procedure management | Identity data User account information related to the case | Legal obligation | The necessary data is kept until the expiration of the legal remedies | Scaleway Legal Department Iliad Legal Department Competent administrative authority Entitled third parties (legal advisor etc.) |
109| --- | --- | --- | --- | --- |
110| Guarantee the security of our customers as a provider of electronic communications services (Directive 2002/58/EC and art 32 of the GDPR) | Identity data
111Billing data
112Consumption data
113Communication data
114Connection data | Legal obligation | Duration of the contractual relationship plus an archiving period for the data necessary to guarantee compliance with our legal obligations | Entitled Scaleway Services
115Entitled Scaleway Partners for security management
116Authorized third parties (auditors etc.) |
117| Abuse of Scaleway services includes cyber-crime, copyright violation, illegal or offensive content, spamming and malware distribution. Abuse should be reported in the console. These data processings are likely to be subject to automated decision-making (e.g. anti-spam control) | Identity data
118User account information | Legal obligation | Duration necessary to meet our legal obligations | Entitled Scaleway Services
119Entitled Scaleway Partners for the ticketing and support management
120Authorized third parties |
121| Responses to the data protection requests and any complaints related to the protection of personal data | Identity data (including proof of identity)
122User account information
123All the data related to the complaint | Legal obligation | 5 years from ticket closing
124Verification of identity card: 1 month | Entitled Scaleway Services
125Entitled Scaleway Partner for the management of subject requests
126Authorized third partiesEntitled Iliad service |
127| Data breaches management | Identity data
128User account information related to the data breach
129All data related to the data breach | Legal obligation | 5 years from the closure of the data breach | Entitled Scaleway Services
130Competent administrative authority |
131| Accounting obligations | Billing data | Legal obligation | 10 years from the end of the contract | Entitled Scaleway ServicesEntitled Scaleway Partner for the management of payments and invoices
132Competent administrative authority |
133| Legal or administrative procedure management | Identity data
134User account information related to the case | Legal obligation | The necessary data is kept until the expiration of the legal remedies | Scaleway Legal Department
135Iliad Legal Department
136Competent administrative authority
137Entitled third parties (legal advisor etc.) |
77138
78Legitimate interest
139## Legitimate interest
79140
80141Scaleway processes some of your data in order to meet a legitimate interest. This is particularly the case in order to secure our services, ensure the management of unpaid debts and the training of our teams (processing relating to security or fraud may involve profiling techniques).
81142
82| | | | | |
83| --- | --- | --- | --- | --- |
84143| Purposes | Categories of data | Legal basis | Retention | Categories of recipients |
85| Guarantee the security of services we offer | Identity data User account information | Legitimate interest | Duration of the contractual relationship or duration limited to the limitation period from the closure of the event concerned | Scaleway IT security service Competent administrative authority |
86| Debt collection | Identity data User account information | Legitimate interest | 5 years from the payment incident | Scaleway Legal and Accounting Services Entitled Scaleway Partner for debt collection |
87| Fraud detection and prevention | Bank details Identity data User account information | Legitimate interest | 5 years maximum from the suspicion of an incident ID card verification: 1 month | Entitled Scaleway service Entitled Scaleway Partner for support and ticketing |
88| Litigation management | Identity data Data necessary for the purposes of establishing evidence | Legitimate interest | The data is kept until the expiration of the legal remedies and archived for 10 years | Scaleway legal department Entitled Scaleway partner |
89| Ensure the training of our teams | Identity data User account information | Legitimate interest | The data is kept during the contractual period | Entitled Scaleway service |
144| --- | --- | --- | --- | --- |
145| Guarantee the security of services we offer | Identity data
146User account information | Legitimate interest | Duration of the contractual relationship or duration limited to the limitation period from the closure of the event concerned | Scaleway IT security service
147Competent administrative authority |
148| Debt collection | Identity data
149User account information | Legitimate interest | 5 years from the payment incident | Scaleway Legal and Accounting Services
150Entitled Scaleway Partner for debt collection |
151| Fraud detection and prevention | Bank details
152Identity data
153User account information | Legitimate interest | 5 years maximum from the suspicion of an incident
154ID card verification: 1 month | Entitled Scaleway service
155Entitled Scaleway Partner for support and ticketing |
156| Litigation management | Identity data
157Data necessary for the purposes of establishing evidence | Legitimate interest | The data is kept until the expiration of the legal remedies and archived for 10 years | Scaleway legal department
158Entitled Scaleway partner |
159| Ensure the training of our teams | Identity data
160User account information | Legitimate interest | The data is kept during the contractual period | Entitled Scaleway service |
90161
91162## Data processors
92163
93164As a data controller, Scaleway uses data processors for the following purposes:
94165
95166- customer relationship management (support management, etc.)
108179## Transfer of data outside the European Union
109180
110181Scaleway strives to minimize data transfers outside the European Union and only carries out such transfers as data controller for the purposes listed above. Data transferred as part of our services is governed by our [Data Processing Agreement (DPA)](https://www.scaleway.com/en/contracts/)
111182
112183All transfers outside the European Union are subject to a strict control to ensure that the contracts entered into with our service providers comply with the Standard Contractual Clauses (SCC) updated by the implementing decision ( EU) 2021/914 of the Commission of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries under Regulation (EU) 2016/679 of the European Parliament and of the Council (Text presenting interest for the EEA) and where possible, to supplement these clauses
113184
185## Requests from authorities
186
114187Scaleway undertakes to inform its customers in advance in the event of a request for information from an administrative or judicial authority in order to enable them to assert their rights subject to compliance with applicable regulations. Scaleway cannot oppose such a request if it complies with French or European regulations, an international agreement (art. 48 of the GDPR) or with one of the exemptions provided for in art. 49 of the GDPR.
115188
116189## Children
117190
118191Scaleway does not provide services to children. Any children wishing to use our services must be accompanied and under the responsibility of an adult.
119192
141214In accordance with our general conditions of service, we remind you that the customer is solely responsible for the management and security of its content as well as the environments and systems that it deploys on the infrastructures made available to it as part of the services offered by Scaleway. It is also up to the customer to make any backups of their content (or other means aimed at ensuring their longevity) that he considers necessary in order to protect against possible deletion, alteration or modification of said content.
142215
143216For more information regarding all of our security measures, you can consult our [Security and Resilience page.](https://www.scaleway.com/en/security-and-resilience/)
144217
145218If you have identified a vulnerability or would like to send us a security question, please send it to us at: [security@scaleway.com](mailto:security@scaleway.com)
146219
220\## Data subjects rights & contact
221
147222Scaleway informs you that you have the following rights depending on the purpose of processing:
148223
149224- Be informed why we process your personal information
150225- Access your data and obtain a copy of the personal data we process about you
151226- Rectify incorrect, incomplete or outdated data
152227- Limit the use of your data
153228- Oppose the processing of your data if it is processed on the basis of legitimate interest
154229- Withdraw your consent at any time if the processing is based on this legal basis
155230- Delete data that is no longer necessary for processing or to meet a legal obligation
156231- Exercise your right to portability
157232
158You can exercise your rights directly in the privacy section of your Scaleway account or via privacy@scaleway.com. If you believe that your rights have not been respected, you can also file a complaint [with the competent supervisory authority](https://www.edpb.europa.eu/about-edpb/about-edpb/members_fr).
233You can exercise your rights directly in the privacy section of your Scaleway account or via [privacy@scaleway.com](mailto:privacy@scaleway.com). If you believe that your rights have not been respected, you can also file a complaint [with the competent supervisory authority](https://www.edpb.europa.eu/about-edpb/about-edpb/members_fr).
159234
160235## Policy update
161236
162237This privacy policy may be updated according to regulatory developments. Any modification will enter into force from its date of publication.
163238
164_Last update : january 2024_
239\_Last update : january 2024 \_