Confidentiality Policy

Cards micro-learning SaaS Platform

Who are we?

SAS Seekoya
12 Rue de la Part-Dieu 69003 Lyon
Represented by Matthieu THOMAS, in his capacity as President, and Nicolas LEGENDRE, in his capacity as CTO.

Legal information: SIRET: 83460654300024
RCS: LYON — NAF: 6201Z

Quality, Purpose and Purpose of Data Processing

So-called personal data is processed by Seekoya as data controller when you are a customer, administrative contact or prospect linked to our commercial relationship.

We are sometimes required to work with our partners to successfully manage and maintain the commercial relationship with our customers and prospects. Our partners, as trusted third parties, therefore act as subcontractors for Seekoya (this is achieved through our tools such as CRM, payment, newsletters, customer satisfaction, statistical monitoring of our Cards, etc.)

If you access the Cards platform as an end user to access micro-learning and materials shared by one of our customers or partners, Seekoya may need to process personal data as a subcontractor.

The Treatment that will be carried out by Seekoya is as follows:
- Customer account configuration
- Customer account management (registration, storage, consultation and deletion of Personal Data and Provision of the Tool)
- Technical Support/Maintenance

The Customer's Personal Data is Processed for the following purposes:
- Purpose 1: Offer micro-training courses (micro-learning) accessible online
- Purpose 2: To provide support and advice for the use of the Tool
- Purpose 3: To allow statistical monitoring

Categories of data processed

We distinguish 2 types of profiles on Cards:
- owners: the people who create their space on the platform, and who manage the subscription
- learners & editors: users, added by the owner

Identification data:
- first name
- name
- photography (optional)

Professional data:
- professional email address
- department/service (optional)
- telephone (optional except for the owner at registration)

Duration of treatment

Purpose of the Treatment -> Duration of the Treatment
- Offer micro-training courses in e-learning -> 6 months following the end of the contract
- Provide support and advice for using the Tool -> 6 months following the end of the contract
- Allow statistical monitoring -> Only during the term of the contract
- Contractual relationship management -> Duration of the provision agreement +10 years according to legal requirement

Ownership of data

Data used, processed, hosted, saved or stored by Seekoya on behalf of the Customer or at the Customer's initiative are and remain the property of the Customer.

Confidentiality and integrity

Seekoya is committed to:
- Have its staff sign a confidentiality agreement for the performance of the Services, in accordance with art. 5, paragraph 1 f) of the RGPD;
- Train and inform its staff about Data Protection regulations, and Customer guidelines;
- Do not disclose the Customer's confidential information without the prior written authorization of the Customer;
- Do not use the Customer's confidential information, for any reason whatsoever, except in execution of the rights and obligations arising from this Agreement;
- Do not disclose the Client's confidential information to anyone, by any means whatsoever, except to their staff, potential agents or subcontractors to whom this information is necessary for the performance of the Services and provided that they are subject to confidentiality obligations at least as stringent as those herein, or in the event of a request from a police, judicial or administrative authority;
- Warn its staff, potential agents, subcontractors and their staff and potential agents, as well as third party entities or legal persons, of the confidential nature of the information communicated by the Customer and to assume responsibility for any disclosure arising from them;
- Take the necessary protective measures that it would take to protect its own confidential information, especially in the context of teleworking.


Access to Personal Data

- Seekoya and his staff
Some teams at Cards can see your data, but only the data they need to do their jobs. They cannot use this information for anything else and must keep this data secret.- Your company and your staff
Depending on whether you are a Learner or a User on the platform, your employer and those who have the right to manage the platform (such as Owners and Editors) can access your data.
- The competent authorities

We may share your personal data with the authorities if a law, regulation, or decision of a competent authority, whether regulatory or judicial, requires us to do so. We are committed to scrupulously complying with applicable laws and regulations, in particular those concerning the protection of your data, to limit, regulate or prevent the disclosure of your information without compromising your privacy.
- Social networks
If you interact on social networks and media via our pages and our site, this information will be sent to the social network and shown on your profile. To prevent the social network from connecting this information to your account, log out of your account first. Also, check out their privacy policies for more information.
- Our partners and service providers

Some data may be transmitted to our partners, listed below in the “Data Hosting” section below.

Data hosting

Data is stored on servers in France only.
The [app.cards-microlearning.com] site and the MS Teams application are hosted by:
Clever CloudClever Cloud SAS is a simplified joint stock company with a capital of 22,952€
Registered at French Trade Register (RCS) in Nantes under the number RCS Nantes B 524 172 699.
Head office: 3 rue de l'Allier, 44000 Nantes, France.
Intra-community VAT number: FR 87 524 172 699

The files and databases are hosted by:
SCALEWAY Simplified Joint Stock Company with a capital of 214,410.50 Euros
SIREN: 433 115 904 RCS ParisHead office: 8 rue de la Ville l'Evêque, 75008 Paris
Intra-community VAT number: FR 35 433115904

The doc.cards-microlearning.com site is hosted by:
GANDI SAS, a simplified joint stock company with a capital of €630,000 having its head office at 63-65 boulevard Masséna Paris (75013) FRANCE
Siren 423 093 459 RCS PARIS
VAT no. FR81423093459
Tel +33 (0) 1 70.37.76.61

Some data may be transmitted to our partners and third party services when creating your Cards account.
The list of services and partners that have access to this data is available on request, before creating a customer account, or when creating your Cards account by accepting and consulting our Cards privacy policy.

Data protection officer

‍ The company's or manager's data protection officers are:
Matthieu THOMAS and Nicolas LEGENDRE, representing the company Seekoya 12 Rue de la Part-Dieu 69003 Lyon

To contact them please use the following email format: DPO [AT] seekoya [DOT] com
or via the contact form

User rights

Any user concerned by the processing of their personal data may exercise the following rights, in application of European Regulation 2016/679 and the Data Protection Act (Law 78-17 of 6 January 1978):
Right to access, rectify and right to delete data (set out respectively in articles 15, 16 and 17 of the RGPD);
Right to data portability (article 20 of the RGPD);
Right to limitation (article 18 of the RGPD) and to oppose the processing of data (article 21 of the RGPD);
Right not to be the subject of a decision based exclusively on an automated process;
Right to determine the fate of data after death;
Right to refer the matter to the competent supervisory authority (article 77 of the GDPR).

To exercise your rights, please send your request to Matthieu THOMAS or Nicolas LEGENDRE, by post to the company's headquarters, or by email to DPO [AT] seekoya [DOT] com

In order for the data controller to grant his request, the user may be required to provide him with certain information such as: his first and last names, his e-mail address as well as his account number, personal space or subscriber number.