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“).
- 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”).
- What personal data 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.
- For what purposes, on what legal basis, and for how long do we keep your personal data?
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Objectives
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Legal basis |
Data retention period |
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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.
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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. |
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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). |
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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
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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. |
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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. |
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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. |
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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. |
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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. |
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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. |
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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.
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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. |
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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. |
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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. |
- Who are the recipients of your personal data?
The following categories of recipients will have access to your personal data:
- The staff of our company;
- Our processors: hosting provider, CRM tool, mailing provider, audience measurement tool, payment service provider, billing tool, cookie management tool;
- 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);
- If applicable: public and private organizations, exclusively to comply with our legal obligations.
- 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.
- 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 access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.
- Right to rectification: you 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 processing: you 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 time: for 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 object: You 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.
- What cookies do we use?
For more information on cookies management, please consult our Cookies Policy.
- Contact information for data privacy matters
Contact email: [email protected]
Contact address: Welcome Place – 60 rue François 1er 75008 Paris
- 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
Welcome Place, société par actions simplifiée, inscrite au Registre du commerce et des sociétés de Nanterre sous le numéro 920 756 020, dont le siège social est situé 60 rue François 1er 75008 Paris, est agent prestataire de service de paiement (#737375) de OKALI, établissement de monnaie électronique agréé en France et contrôlé par l’ACPR (Autorité de Contrôle Prudentiel et de Résolution, 4 place de Budapest – CS 92459 – 75436 PARIS Cedex 09), société par actions simplifiée à l'actionnaire unique au capital social de 5.660.962 € inscrite au Registre du Commerce de Paris sous le numéro 8901117761, établie et ayant son siège social à 50 rue de la Boétie 75008 Paris. Okali est une filiale de La Fabrique by CA, le start-up studio du Groupe Crédit Agricole (827 899 394 R.C.S. Paris, 50 rue La Boétie, 75008 Paris, FR 02 827 899 394).
Welcome Account est une société à missionqui fournit des solutions financières simples et incisives à tous les nouveaux arrivants qui viennent en Europe pour travailler, étudier ou simplement vivre.
Welcome Place, société par actions simplifiée, inscrite au Registre du commerce et des sociétés de Nanterre sous le numéro 920 756 020, dont le siège social est situé 60 rue François 1er 75008 Paris, est agent prestataire de service de paiement (#737375) de OKALI, établissement de monnaie électronique agréé en France et contrôlé par l’ACPR (Autorité de Contrôle Prudentiel et de Résolution, 4 place de Budapest – CS 92459 – 75436 PARIS Cedex 09), société par actions simplifiée à l'actionnaire unique au capital social de 5.660.962 € inscrite au Registre du Commerce de Paris sous le numéro 8901117761, établie et ayant son siège social à 50 rue de la Boétie 75008 Paris. Okali est une filiale de La Fabrique by CA, le start-up studio du Groupe Crédit Agricole (827 899 394 R.C.S. Paris, 50 rue La Boétie, 75008 Paris, FR 02 827 899 394).