PRIVACY POLICY

 

At Welcome Account, protecting your personal data is our priority.

Whether you use the website https://welcomeaccount.com (the "Website") and/or Welcome Place's Web App (the "Web App") as our client (the "Client"), we may collect personal data about you.

The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR") and French Data Protection Law n° 78-17 of 6 January 1978 (together the "Applicable Regulations").

 

  1. Who is the data controller?

 

The data controller is Welcome Place, a French joint stock company, registered with the Registry of Trade and Companies of Paris under the number 920 756 020 and whose head office is located at 60 rue François 1er - 75008 Paris ("Us"or "We").

 

 

  1. What personal data do we collect?

 

Personal data is a data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.

 

We may collect the following personal data:

  • Identification data (full name, email and postal addresses, telephone number, date and place of birth, passport or ID number, type of ID);
  • Data relating to your professional life (company name, professional email address);
  • Data relating to the product/service you are searching for;
  • Browsing data (IP address, pages viewed, date and time of connection, browser used, operating system, user ID, MAID, user behavior (mouse tracking));
  • Login data (logs, IP address);
  • Economic and financial data (wallet data, bank details, products and services held and used, card number, transfers of funds, assets, declared investor profile, credit history, payment incidents);
  • Transactional data (data relating to transactions, including transfers, data relating to beneficiaries including their full names, addresses and contact details, expenditure and income categorization data);
  • Data relating to your bank cards;
  • Data related to recordings from telephone calls with our customer care service (content of the calls, dates of the calls);
  • Any information you wish to send us as part of your contact request.

 

 

We inform you, when collecting your personal data, whether some of these data are mandatory or optional.

 

  1. For what purposes, on what legal basis, and for how long do we keep your personal data?

 

 

Objectives

 

 

Legal basis

 

Data retention period

To provide you with our services available on our Web App through your account and deliver bank cards

Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract

When you have created your account: personal data are retained for the duration of your account.

 

Your connection logs are kept for 1 year.

 

In addition, personal data may be archived for probationary purposes for a period of 5 years.

 

To perform operations related to contracts, orders, invoices, and customer relationship management

Performance of a contract to which you are party

Personal data are retained for the duration of our business relationship.

 

In addition, personal data may be archived for probationary purposes for a period of 5 years.

To create a database of customers and prospects

Our legitimate interest in developing and promoting our business

For our customers: their personal data are retained for the duration of our business relationship.

 

For our prospects: their personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action).

To comply with the legal obligations applicable to our business, in particular banking and financial regulations (e.g. with regard to the fight against money laundering and the financing of terrorism, the fight against tax fraud, the fight against corruption, etc.).

Comply with our legal and regulatory obligations

 

 

Invoices are archived for a period of 10 years.

 

Data relating to the fight against money laundering and the financing of terrorism are kept for 5 years from the end of our contractual relationship.

To send newsletters, requests and direct marketing mailings

For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news

 

For our prospects: your consent

Personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action) or until you withdraw your consent.

To improve our services

Our legitimate interest in improving our services

Recording of telephone calls: 6 months from the date of collection.

 

Telephone call content analysis documents: 1 year from the date of collection.

To manage your opinions on our products, services or content

Our legitimate interest in collecting your opinions on our products, services

Data are retained 2 years from the publication of the opinion.

To answer to your information request and other inquiries

Our legitimate interest in responding to your inquiries

Personal data are retained during the processing of your request and is deleted once the request has been processed.

To process your applications and to manage interview (pre-selection of candidates, contact to evaluate the candidate's ability to fill the position, finalization of the recruitment process)

Execution of precontractual measures

Your data are kept in an active database for the duration of the recruitment process until the hiring decision is made.

 

If your application is rejected, your data may be kept for 3 months after the end of the recruitment process, in order to be able to provide you with explanations on the reasons that led to the rejection of your application.

 

Your data may be kept in an intermediate archive for evidential purposes for 5 years from the date of the hiring decision.

To elaborate analytics on navigation and improve our services

Our legitimate interest in analyzing the composition of our customer base and improving our services

Data are retained for 25 months.

 

Fighting fraud (including verifying your identity as part of our KYC obligations, taking into account international economic and financial penalties)

To comply with our legal and regulatory obligations

For data related to identity verification, the data are kept for 2 years.

 

Assessment of the relevance of the alert: data are kept for a maximum of 6 months from the time the alert is issued, the time it takes for us to qualify the alert. We delete without delay the alerts qualified as not relevant.

 

Retention of the alert qualified as relevant: the data are kept for 5 years from the closing of the fraud file.

Combating money laundering and terrorist financing

Comply with our legal and regulatory obligations

Data relating to the fight against money laundering and the financing of terrorism are kept for 5 years from the end of the contract.

To process data subjects' requests to exercise their rights

Our legitimate interest in responding to your requests and keeping records of them

If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted.

The information allowing the management of your requests to exercise your rights under the GDPR will be kept for 3 years from the date of the request.

 

  1. Who are the recipients of your personal data?

 

The following categories of recipients will have access to your personal data:

  1. The staff of our company;
  1. Our processors: hosting provider, CRM tool, mailing provider, audience measurement tool, payment service provider, billing tool, cookie management tool;
  1. Our partners acting as autonomous data controllers. We accept no responsibility for the processing of personal data by our partners and invite you to consult their privacy policy (e.g. banking establishment, NGO and associative partners);
  1. If applicable: public and private organizations, exclusively to comply with our legal obligations.

 

  1. Are your personal data likely to be transferred outside the European Union?

 

Your personal data is hosted for the duration of the processing on the servers of the company Microsoft Azure, located in the European Union.

 

As part of the tools, we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

  • Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or
  • The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR: in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or an approved certification mechanism; or
  • The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR.

 

  1. What rights can you exercise on your personal data?

 

You have the following rights with regard to your personal data:

 

  • Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.

 

  • Right of accessYou have the right to access all your personal data at any time as defined by article 15 of the GDPR.

 

  • Right to rectificationYou have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.

 

  • Right to restriction of processingYou have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.

 

  • Right to erasure ("right to be forgotten"): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.

 

  • Right to file a complaint to a competent supervisory authority (in France, the CNIL), under article 77 of the GDPR, if you consider that the processing of your personal data constitutes a breach of applicable regulations.

 

  • Right to define instructions related to the retention, deletion and communication of your personal data after your death.

 

  • Right to withdraw your consent at any timeFor purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.

 

  • Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
  • Right to objectYou have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing us using the contact details below. For this matter we may ask you to provide us with additional information or documents to prove your identity.

  1. What cookies do we use?

 

For more information on cookies management, please consult our Cookies Policy.

 

  1. Contact information for data privacy matters

 

Contact email: [email protected]

 

Contact address: Welcome Place - 60 rue François 1er 75008 Paris

 

  1. Modifications

 

We may modify this privacy policy at any time, in particular in order to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

 

Entry into force: 13/12/2023

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WelcomeLogoHeader

Welcome Account is a mission-driven company that provides simple, inclusive financial solutions to all newcomers who come to Europe to work, study or simply live.

Welcome Place, a société par actions simplifiée (simplified joint stock company), registered in the Nanterre Trade and Companies Register under number 920 756 020, with its registered office at 60 rue François 1er 75008 Paris, is a payment service agent (#737375) of OKALI, an electronic money institution authorized in France and supervised by the ACPR (Autorité de Contrôle Prudentiel et de Résolution, 4 place de Budapest - CS 92459 - 75436 PARIS Cedex 09), a simplified joint stock company with a single shareholder and share capital of €5.660,962, registered in the Paris Trade Register under number 8901117761, established and having its registered office at 50 rue de la Boétie 75008 Paris. Okali is a subsidiary of La Fabrique by CA, the Crédit Agricole Group's start-up studio (827 899 394 R.C.S. Paris, 50 rue La Boétie, 75008 Paris, FR 02 827 899 394).

Welcome Account logo

Welcome Account is a company with a mission to provide simple, incisive financial solutions to all newcomers who come to Europe to work, study or simply live.

Welcome Place, a société par actions simplifiée (simplified joint stock company), registered in the Nanterre Trade and Companies Register under number 920 756 020, with its registered office at 60 rue François 1er 75008 Paris, is a payment service agent (#737375) of OKALI, an electronic money institution authorized in France and supervised by the ACPR (Autorité de Contrôle Prudentiel et de Résolution, 4 place de Budapest - CS 92459 - 75436 PARIS Cedex 09), a simplified joint stock company with a single shareholder and share capital of €5.660,962, registered in the Paris Trade Register under number 8901117761, established and having its registered office at 50 rue de la Boétie 75008 Paris. Okali is a subsidiary of La Fabrique by CA, the Crédit Agricole Group's start-up studio (827 899 394 R.C.S. Paris, 50 rue La Boétie, 75008 Paris, FR 02 827 899 394).