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Updated: 18/01/2023
For the purposes of this Policy, the following terms are defined as follows:
The person in charge of processing is SAS SOLAL TECH, registered in the Chambéry Trade and Companies Register under number RCS 901455030, whose registered office is at 19 bd de la mer Caspienne, 73370 LE BOURGET DU LAC.
All inquiries regarding this Policy and the RGPD can be sent, by mail to its headquarters, or by e-mail to the following address: dataprivacy@solaltech.fr
The "data subjects" as defined in Article 4 of the GDPR, and subject of this Privacy Policy, are the Users as defined in Article 1 of this document.
In the context of the use of the Platform, the following personal data of Users are processed by SOLAL TECH. Data with an asterisk * are optional.
Testers' data
4.1 Testers' data
Account creation data
- Name, first name, email address, cell phone number, password
Digital Assets
- Nature and identification of the Asset (e.g. Facebook account, Bitcoin wallet, Google Drive)
- Asset access credentials (IDs and passwords, access keys)
Digital Wishes
- Designation of Beneficiaries by Asset
- Designation of the Guardian
- Wishes expressed for each Asset (transmission, account closure, suspension, etc.)
- Choice of Notary Partner
Activity on the Platform
- Connection logs (date and time of connection, pages visited)
- Support requests
Storage space (*)
- All types of Personal Data of the User: photos, videos, text documents, audio files, etc.
4.2 Gatekeeper Data
Account creation data
- Name, first name, email address, cell phone number, password
Exchanges with the Platform
- Messages exchanged, notifications to the User
Activity on the Platform
- Connection logs (date and time of connection, pages visited)
- Support requests
5.1 Testers' data
Account creation data
- Collection
- Registration
- Conservation
Digital Assets
- Collection
- Registration
- Structuring
- Accommodation
- Consultation (Support + Guardian)
- Encryption (for access data to Digital Assets)
- Transmission of the Data to the Custodian and/or Beneficiaries under the conditions provided for in the GCU ;
Digital Wishes
- Collection
- Registration
- Structuring
- Accommodation
- Consultation (Support + Guardian)
- Sending messages to Partner Notaries not registered on the Platform
- Transmission of the Digital Wills to the Custodian and/or the Notary Partner under the conditions provided for in the GCU;
Activity on the Platform
- Registration
- Conservation
Storage Space
- Accommodation
- Consultation
5.2 Guardian Data
Account creation data
- Collection
- Registration
- Conservation
Exchanges with the Platform
- Registration
- Conservation
Activity on the Platform
- Registration
- Conservation
We have decided to list the purposes of the processing for each type of data processed within the Service.
6.1 Testers' data
Account creation data
- Access to the Service provided by the Platform;
- Identification of the User by double authentication
Digital Assets
- Identify the Testator's digital assets;
- Transmit to the Custodian and/or Beneficiaries the access identifiers to the Digital Assets, in accordance with the wishes expressed by the User;
Digital Wishes
- To allow the expression of the Testator's Digital Wishes
- Generate the Digital Will Document and the Will template,
- Send the chosen Partner Notary an invitation to join the Platform, if he is not registered,
- To transmit to the Beneficiaries the Digital Assets in conformity with the expressed Wishes;
- Inform the Guardian of the Testator's choice to request acceptance;
- Transmit to the Guardian the Digital Wishes expressed by the Testator
Activity on the Platform
- Respond to requests from administrative or judicial authorities for identification of the author of online content
- Respond to User support requests
Storage Space
- Allow the Testator to store Data and Assets that can be bequeathed to the Beneficiaries, in secure conditions;
6.2 Gatekeeper Data
Account creation data
- Access to the Service provided by the Platform;
- Identification of the User by double authentication
Exchanges with the Platform
- Assist the Guardian in executing the Testator's Digital Wishes;
- Put him in contact with the Notary Partner
Activity on the Platform
- Respond to User support requests
Again, we thought it would be clearer to present such a legal basis for each type of data processing.
7.1 Testers' data
Account creation data
- Execution of the contract concluded with the User (GCU)
Digital Assets
- Execution of the contract concluded with the User (GCU)
Digital Wishes
- Execution of the Contract concluded with the User (GCU)
- Legitimate interest of SOLAL TECH (registration of new notary partners)
Storage Space
- Execution of the contract concluded with the User (GCU)
Activity on the Platform
- Performance of the Contract (UGC);
- Legal obligation to comply with the Service;
- Legal obligation to respond to requests to identify authors of online content;
- Legitimate interest of SOLAL TECH (improve the performance of the Service)
7.2 Gatekeeper Data
Account creation data
- Execution of the Contract concluded with the User (GCU)
Exchanges with the Platform
- Execution of the Contract concluded with the User (GCU)
Activity on the Platform
- Execution of the Contract concluded with the User (GCU)
- Legitimate interest of SOLAL TECH (improve the performance of the Service)
8.1 Testers' data
Account creation data
- The User's Account is maintained for the duration of the Service, i.e., until the full settlement of his digital estate.
- However, it may be closed (a) by the User under the conditions set out in the GTC (at any time for a free Account, or at the end of the Subscription for a paid account) or (b) by SOLAL TECH under the conditions set out in the GTC, particularly in case of violation of the terms of use of the Platform; or (c) by the Guardian after the death of the Testator, if he considers his mission as completed.
- The data is no longer processed in an active database as of the closure of the User's Account. However, the email address may be processed for a period of 3 years from this closure for marketing purposes, in accordance with the CNIL Reference on commercial management, unless the User objects, and except in the case where SOLAL TECH has been informed of the death of the User.
Digital Assets
- The Data is processed until the Account is closed by the Testator or the Custodian, after completion of his mission;
- SOLAL TECH no longer has access to this Data when the Account is closed.
- SOLAL TECH may keep this data in anonymous form for statistical purposes and to improve the Service;
Digital Wishes
- The Data is processed until the Account is closed by the Custodian;
- They are nevertheless kept in the archive (outside the active database) by SOLAL TECH for 5 years from the closing, to justify the performance of its contractual obligations by SOLAL TECH vis-à-vis the User or to assist the Notary Partner in the settlement of the estate;
Activity on the Platform
- Data stored in archives for 5 years (for proof of payment) from the closure, to justify the performance of its contractual obligations by SOLAL TECH vis-à-vis the User;
Storage Space
- The Data are no longer kept after their transmission to the Beneficiaries, only the date of transmission and the identity of the Beneficiary being kept (5 years from the date of processing);
Activity on the Platform
- The Data are no longer processed in an active base as of the closing of the Account; but they are kept for one year as of the closing or deletion of the account by the User, in accordance with the provisions of Decree No. 2011-219 of February 25, 2011 relating to the conservation and communication of data allowing the identification of any person having contributed to the creation of content published online;
- The Support Data are kept until the closure of the Account, and for 5 years from the closure, to justify the performance of its contractual obligations of Support by SOLAL TECH
8.2 Guardian Data
Account creation data
- The User's Account is maintained for the duration of the Service, i.e., until the full settlement of his digital estate.
- However, it can be closed (a) by the User at any time under the conditions set out in the GTC (especially if he refuses his mission) or (b) by SOLAL TECH under the conditions set out in the GTC, especially in case of violation of the terms of use of the Platform; or (c) by the Guardian after the death of the Testator, if he considers his mission as completed.
- The data is no longer processed in an active database as of the closing of the Guardian's Account. However, the email address may be processed for a period of 3 years from this closure for marketing prospecting purposes, in accordance with the CNIL Reference Guide on commercial management, unless the User objects.
Exchanges with the Platform
- Data are no longer processed on an active basis after the closure of the Account but are kept for 5 years from the closure, to justify the performance of its contractual obligations by SOLAL TECH
Activity on the Platform
- The Support Data are kept until the closure of the Account, and for 5 years from the closure, to justify the performance of its contractual obligations of Support by SOLAL TECH
The Application is hosted in France, on the servers of the company OVH.
A daily backup of the Users' Data is performed.
The machines and servers are secured, only SOLAL TECH employees and subcontractors are allowed to connect.
In addition, the Data related to the access identifiers to the Digital Assets of the Users (Testers) are encrypted, and only the Tester and his Guardian have access to the encryption key. The keys used are generated from the user's login information and are never shared directly with Solal Tech. The user's password is never saved and their session expires after 15 minutes. A recovery key derived from a passphrase of 20 random characters is generated at creation and the User is invited to store it, for example in paper format, in a safe to allow eventual recovery of his Data.
Yes, and that is the very principle of our service!
Specifically, we pass on the following Personal Data upon your death:
- Your Digital Wishes to the Custodian you have designated,
- Access credentials to certain Mixed or Non-Valuable Assets (e.g., Facebook, Youtube accounts, etc.) to your Custodian, or to your Beneficiaries, according to the Wishes expressed in the Digital Wills Document;
- The name of the Notary Partner to your Guardian,
- The name of the Custodian to your Beneficiaries,
In addition, we may provide our Users' Data to partners, either free of charge or for a fee, but only in aggregate and anonymized form. We undertake to ensure that our Users cannot be re-identified in the context of the processing of this Data by our partners.
In addition, our technical partners (subcontractors) are subject to security and confidentiality commitments, and may not process your Data for any purpose other than the performance of their mission.
To date, our technical providers are :
- OVH SAS for hosting the Service
- Google Workspace for project management
- Sendinblue for commercial emailing operations
- Salesforce to conduct commercial emailing operations
- Webflow to collect incoming requests from the solaltech.fr website
- Zendesk to follow up on customer requests
We only use audience cookies, in this case Google Analytics, Meta 4 Business ...
A pop-up consent form will be displayed when you access the Platform, allowing you to accept or reject these cookies.
The Platform does not contain any other "cookie" (tracer) likely to be installed on the User's mobile terminal.
11.1 Your rights
As a User of the Platform, you have the right to ask us:
You can also opt-out of notifications through your User Account settings.
11.2 How to exercise them
You can delete your User Account or update your Data directly from the Platform.
For all other requests, please send us an email at the following address: dataprivacy@solaltech.fr indicating the subject of your request, your name(s) and surname(s).
We will respond as soon as possible, but no later than one month after receiving your request.
We remind you that you have the right to file a complaint with the CNIL if you feel that your rights have not been respected. For more information on your rights concerning your data, we invite you to consult the following web page: https: //www.cnil.fr/fr/plaintes.