Privacy policy

1. Data controller

The data controller is:

• WELLWISH — SASU with share capital of €1,000
• 78 avenue des Champs-Élysées, 75008 Paris, France
• SIREN: 980 616 890
• Contact regarding personal data: contact@wellwish.fr

2. Data that may be collected

Depending on your use of the site, WELLWISH may process:

• Identification data: surname, first name
• Contact details: email address, telephone number where provided
• Professional data: company, website, role or professional information that may be communicated
• Project information: project type, maturity level, indicative budget, objectives, problem to solve, deadline, description of the need and information freely provided in form fields
• Exchange data: content of messages sent to WELLWISH or BusinessLead through the site
• Technical data, depending on the tools actually enabled: IP address, browser type, device, pages viewed, browsing data, technical logs, information relating to cookies and consent

2 bis. Sensitive data

WELLWISH does not ask users to transmit sensitive data through the site's forms.

3. Purposes of processing

Data may be used in order to:

• respond to contact requests;
• analyse a project request;
• arrange a discussion with a prospect, partner or supplier;
• prepare a commercial proposal when one is requested;
• follow up on exchanges;
• manage commercial and contractual relationships;
• ensure the security and proper functioning of the site;
• measure use of the site where audience measurement tools are enabled in accordance with applicable rules;
• comply with applicable legal and regulatory obligations.

3 bis. No resale

The data collected is not sold.

4. Legal bases

Depending on the situation, processing may rely on:

• Pre-contractual measures — when a user requests information, presents a project, requests a quote or enters into discussions with a view to a collaboration.
• Performance of a contract — when processing is necessary for the performance of a contractual relationship.
• Legitimate interest — to ensure the security of the site, prevent abuse, manage certain professional relationships and improve services where individuals' rights and freedoms do not override that interest.
• Consent — where regulations require it, in particular for certain cookies, trackers or electronic communications.
• Legal obligation — where WELLWISH is required to retain or process certain information under a legal or regulatory obligation.

5. Mandatory nature of data

Fields marked as mandatory in the forms are necessary to process the request.

Without this information, WELLWISH may be unable to respond or to review the project.

Other fields are optional.

6. Recipients

The data is accessible only to persons who need access to it as part of their duties.

It may also be processed by technical providers involved in particular in:

• hosting;
• IT infrastructure;
• form management;
• messaging;
• security;
• audience measurement;
• the tools necessary for the site to operate.

6 bis. Processors actually used

To date, messages sent from the site's forms are routed by Resend, a technical email delivery provider acting as a processor.

These providers access the data only to the extent necessary for their duties.

7. BusinessLead

Where a request concerns an external project presented in the “Work with us” area, the information may be used in order to review and manage that request as part of the BusinessLead activity.

The presentation of BusinessLead on the site does not change the identity of the data controller where the processing is legally carried out by WELLWISH.

Should another entity subsequently become the controller for a given activity, users would be informed.

8. Retention periods

Data is retained only for as long as necessary for the purposes for which it was collected and for applicable legal obligations. As a general policy:

• Contact requests with no commercial relationship: the time needed to handle the request, then archiving or deletion depending on its nature.
• Prospects and project requests: up to 3 years from the last active contact, unless a specific need or different obligation applies.
• Contractual data: for the duration of the contractual relationship, then for the applicable statutory limitation or retention periods.
• Accounting documents and supporting records subject to a legal obligation: for the period provided by applicable regulations.
• Security logs: for a period proportionate to security needs.
• Cookie consent: for the periods stated in the Cookie policy.

8 bis. End of retention

On expiry of the applicable periods, data is deleted, anonymised or archived where its retention remains legally necessary.

9. Transfers outside the European Economic Area

Certain technical providers used by the site may be established, or may process certain data, outside the European Economic Area.

Where such a transfer exists, WELLWISH ensures that it relies on a mechanism provided for by applicable regulations, in particular an adequacy decision or appropriate safeguards such as the European Commission's standard contractual clauses where these are required.

The exact list of transfers depends on the providers actually used by the site.

10. Security

WELLWISH implements appropriate technical and organisational measures to protect data against, in particular, accidental or unlawful destruction.

As no computer system can offer absolute security, WELLWISH adapts its measures to the risks identified and to the evolution of its tools.

11. Your rights

Under the conditions provided for by applicable regulations, you may have the following rights:

• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to object;
• right to portability where applicable;
• right to withdraw your consent at any time where processing relies on it.

11 bis. Exercising your rights

To exercise your rights: contact@wellwish.fr

Proof of identity may be requested only where necessary to verify the identity of the requester.

WELLWISH responds to requests within the timeframes provided by applicable regulations.

12. Complaint to the CNIL

If you consider that your rights relating to your personal data are not being respected, you may lodge a complaint with the French data protection authority (Commission nationale de l'informatique et des libertés, CNIL).

Official CNIL website ↗

13. Automated decision-making

Unless otherwise indicated for a particular processing operation, information submitted via the site's forms is not subject to a decision producing legal effects based solely on automated processing.

14. Changes to this policy

This policy may change in order to take account of legal, regulatory, technical or functional changes to the site.

The date of last update appears at the top of this page.

15. Contact

For any question relating to this policy or to the use of your data: contact@wellwish.fr