Privacy policy

Systema Conseil, through its registered trademark Feel Agile, focuses primarily on providing certification support services to organizations in the digital sector and information security consulting, mainly within Europe.

The company offers an agile approach to obtaining certifications and qualifications, such as ISO 27001, 9001, 20000, TISAX, SecNumCloud, GDPR, and HDS.

FEEL AGILE supports its clients with audits, training, and the implementation of tailored security solutions, with the goal of providing a flexible and agile certification solution.

FEEL AGILE offers other complementary services, including but not limited to: Consulting, e-learning, awareness campaigns, training, diagnostics, audits, GDPR compliance, the OVERSECUR solution, penetration testing, and outsourced SOC services.

Given the sensitive nature of its cybersecurity and data protection consulting and support services, Feel Agile is committed to complying with the relevant legal framework, in particular the General Data Protection Regulation (GDPR) 2016/679, which took effect on May 25, 2018, and the French Data Protection Act of 1978, as amended.

This policy is intended to provide you with accurate and comprehensive information about how we use your data and your rights. As this policy is subject to updates, we encourage you to review it regularly.

The data controller

Feel Agile, (hereinafter "FeelAgile" or "we"), located at 8 Chemin de la Cavée in Menneval (27300), is responsible for processing your personal data.

Our Data Protection Officer (DPO)

Feel Agile has appointed a Data Protection Officer (hereinafter "DPO").

How to contact Feel Agile's DPO?

The DPO can be contacted :

  • In writing to the following address: Attention: Data Protection Officer – 8 Chemin de la Cavée – 27300 Menneval;
  • By e-mail to the following address: dpo@feelagile.com.

Why do we collect your personal data?

We collect and process the Personal Data of our Users solely for the following purposes:

Browsing our website: responding in writing or by telephone to various requests made via contact forms, managing quote and registration requests sent via dedicated contact forms, carrying out statistical studies on our website audience, applying for a job on our website or sending an unsolicited application.

Customers benefiting from our Services: ensure the follow-up of the customer file, provide the services you have subscribed to, transmit information on the services we offer and the events we organize, if necessary, obtain feedback from you on the services you benefit from.

Customers with access to our Platforms: process requests for subscription to our Platforms, manage your access and use of them, provide technical support and maintenance to enable the Platforms to function properly.

Commercial prospecting: to process your personal data in order to send you quotes, confidentiality agreements for the study of parts, information on the support and services offered by Feel Agile or to inform you of organized events that may be of interest to you.

Communication and Business Development:

  • Send marketing communications and newsletters;
  • Invite people to events, webinars, or conferences;
  • To present our services and news;
  • Monitor trade activities;
  • Use of tracking pixels:  

As part of the data collection process using tracking pixels in our emails, this data is used to:

  • To track the open rates and click-through rates of the emails we send you in order to assess interest in our content and campaigns;  
  • Improve the quality of the information and content (topics, frequency, formats) we send you  
  • To improve deliverability, but also to better target marketing campaigns so that more relevant messages are sent to the contacts most likely to be interested.  

Registration for public online events (In-person/Remote):

  • Manage and track registration requests, particularly for events to which access is restricted due to the person's status (private events reserved for Feel Agile customers, etc.);
  • Ensure the logistical organization of our events (transmission of access to webinars, etc.);
  • Carry out studies on the actual attendance of our events and the satisfaction of participants as part of a continuous improvement approach;
  • Communicate about events organized through Feel Agile’s various communication channels (press, website, social media: LinkedIn, YouTube);
  • Communicate about other Feel Agile events.

Recruitment  

Implementation and monitoring of the recruitment process and evaluation of applications for a position at FEEL AGILE:  

  • Receive and process applications;
  • Analyze candidates' profiles and skills;
  • Organize interviews and discussions with candidates;
  • Assess the fit between the candidate's profile and the open positions;
  • Communicate with candidates throughout the recruitment process;
  • With the candidate's consent, where required, create a resume database so that we can contact the candidate again for future opportunities;
  • To meet our legal obligations and handle any recruitment-related disputes that may arise.

Video Conference Recordings

  • Improving the quality of service provided to customers;
  • Training and support for employees in the course of their work.

What data do we collect?

By using our Site or our Platforms, you may provide us with Personal Data, either directly or indirectly, or through your use of the Site and our Platforms.

Certain personal data is collected from you or when you use our services:

Data from website use :

  • Technical data: computer IP address, operating system used, type and version of browser used by the data subject;
  • Connection/browsing data: features used, pages visited, site settings, timestamps of visits, information searched for on the site via the search bar;
  • Location data: geographical location, address of the data subject;
  • Usage data.

Contact us via the website form or by phone:

  • Data related to contacts submitted via the form: last name/first name, email address, job title, company, phone number, reason for the request, email address if requesting to receive updates; any information related to a job application (unsolicited application);
  • Data related to telephone calls: telephone number, any information provided in a request submitted by the data subject;

Prospect Information:first and last name, mailing address, email address, phone number, job title, and company you work for.

Communication and Sales Development/Clients:  

If you accept cookies through our Axeptio CMP:

  • IP address (if applicable), date and time an email was opened, confirmation that an email was opened, links clicked in our communications, pages viewed and navigation paths on our website, date and time of visits, browser type and operating system, type of device used, technical identifiers (cookies or session identifiers, as applicable), and approximate location data derived from the IP address, where applicable.

Data concerning Feel Agile customer support :

  • Data relating to customer files: surname/first name, e-mail and telephone number, job title, Platform identifiers, company concerned, social networks, organization charts;
  • Awareness via the Moodle tool: surname/first name; e-mail; username, password, connection logs;
  • Phishing via the Bluesecure tool: name/first name; e-mail ;
  • Contact details of the people involved in the project: surname/first name; e-mail; telephone; position; company ;
  • Training / Audit / Diagnosis: last name/first name; e-mail; position; company ;
  • Connection data.

Our Oversecur Solution

  • Connection data: e-mail, user name, password, connection logs;
  • Data related to the use of the Solution: surname/first name; e-mail; job title; company;
  • Data related to the Oversecur newsletter: e-mail.

Data regarding registration for online public events:  Last name/first name, mailing address, email address, phone number, job title, company you work for, registration and participation data necessary for organization (including participant contributions for recorded events), technical data generated by the use of the video conferencing tool (including device identification, date and time of login and logout), images and audio captured during the events (photographs, videos, audio recordings, webinar recordings).

Some of this Personal Data is also collected through cookies on our Site or our Platforms.

We may also obtain your personal information from our Partners and other third parties.

These third parties may include the following:

  • Social networks (when the data subject authorizes access to your data on a social network);
  • Public sources.

When your Personal Data is collected, you may be informed that certain pieces of information must be provided in order to achieve the expected result.

If you do not provide this required information, we may be unable to process your request.

Recruitment

  • Identification information: last name, first name, title, date of birth (if applicable), photograph (if included on the resume);
  • Contact information: mailing address, email address, phone number;
  • Information regarding your professional background: resume, work experience, skills, qualifications, certifications, professional references (if applicable);
  • Information regarding academic background: degrees, courses, and institutions attended;
  • Application information: cover letter, salary expectations, geographic flexibility, availability, desired contract type;
  • Information from the recruitment process: interview summaries, evaluations, test or exercise results, and comments from recruiters and managers;
  • Administrative information, when necessary for the recruitment process or for hiring: national ID card, work permit, proof of degrees or certifications.

We do not collect special categories of data (such as health data, political opinions, religious beliefs, or union membership), except when required by law or when such information is voluntarily provided by the applicant and is strictly necessary for processing the application (for example, to accommodate a disability during an interview).

Video Conference Recordings

  • Work email address, first and last name, image/video, voice.

On what legal grounds do we collect your Personal Data?

We collect and process your Personal Data in compliance with the Regulations.

Data processed in connection with customer contracts

  • Performance of your contract;
  • Feel Agile's legitimate interest in sending you information about its internal activities, its public and private events, its support offers or the tools/platforms it offers;
  • Consent for post-coaching feedback or recording of workshops for internal training purposes.

Data processed in connection with website navigation

  • Feel Agile's legitimate interest in communicating with Internet users (prospects, customers, partners, etc.);
  • Execution of pre-contractual measures (prospects, recruitment, partnerships, etc.);
  • Feel Agile's legitimate interest in improving the quality and ergonomics of its website (audience statistics).

Events/webinars

  • Feel Agile's legitimate interest in ensuring the proper organization of its public and private events;
  • Legitimate interest of Feel Agile in knowing the level of attendance and satisfaction of registrants and to drive a continuous improvement approach for future events;
  • Consent (Event-related communication) for webinar recordings.

Commercial prospecting

  • Legitimate interest in connection with the conduct of communication and marketing activities;
  • Consent regarding the recording of meetings for internal training purposes;
  • Tracking pixels: Measure email open rates and clicks to assess interest in content and campaigns: Consent
  • Tracking pixels: Improving the quality of the information and content sent (topics, frequency, formats) and deliverability: The company’s legitimate interest in improving its communications  
  • Tracking pixels: Improving the targeting of marketing campaigns to deliver more relevant messages: consent.  

Recruitment

  • Execution of pre-contractual and contractual measures in the context of applicant analysis and recruitment;
  • Consent for the retention of unsuccessful applicants.

Video Conference Recordings 

  • These recordings are made with the participants' prior and unambiguous consent;  
  • The moderator also systematically makes a verbal announcement reiterating these points at the beginning of each session, before any recording begins. The participant’s continued participation in the videoconference following this announcement constitutes explicit consent to the recording. The participant retains the right to withdraw their consent at any time, including during the session, without this affecting the course of the meeting.
  • This measure was the subject of a consultation with the Social and Economic Committee (CSE) on July 31, 2024, and is listed in the record of processing activities maintained by FEEL AGILE in accordance with Article 30 of the GDPR.

What rights do I have to my data?

We guarantee the effective exercise of all the rights granted to you by the Regulations. You can therefore, free of charge :

  • Access to your Personal Data;
  • Rectify inaccurate Personal Data;
  • Obtaining the deletion of your Personal Data;
  • Restricting our processing of your Personal Data;
  • Withdraw your consent to the processing of your Personal Data ;
  • Object to the processing of your Personal Data, in particular when the purpose of the processing in question is commercial prospecting;
  • Obtain a copy of your Personal Data (right to data portability);
  • Making a complaint to a supervisory authority ;
  • Define instructions on what to do with your data after your death.

How to exercise your rights

You may exercise your rights at any time via one of the following contacts:

  • By e-mail: dpo@feelagile.com;
  • By mail: Attention: Data Protection Officer – 16 Rue du Champ de Courses, 27300 Bernay.

We strive to process your requests as quickly as possible.

If you believe that we are not complying with our obligations or respecting your rights regarding your personal data, you may file a complaint with the CNIL via the following link : CNIL—File a Complaint Online.

Who receives your personal data?

Your personal data is transmitted to the various entities with which we collaborate in order to provide the service offered, after we have ensured that they comply with obligations in terms of personal data security.

Website navigation

The data is processed :

  • Internally: Audience statistics are analyzed by the relevant departments: Marketing Department
  • External: statistical data collection via GA4.

Customer file management

The data is processed :

  • In-house: General Management; Customer Relations Department; Projects Department; Marketing Department; Legal Department; Sales Department;
  • Externally: to the service providers in charge of our accounting: Cocerto ;
  • Externally: to our subcontractors: Furious; Hubspot; Teams; Leexi
  • Externally: After obtaining your express consent, your data may be distributed to the public, in particular as part of the dissemination of feedback and opinions.

Our Oversecur Solution

Your data will be processed :

  • Internally: Production Department – Customer Information Systems;
  • Externally: to our partners and the solution's hosting providers: AWS (hosting); Oakandi (development).

Private / public events

Your data will be processed :

  • Internally: to the departments in charge of organizing public and private events, i.e. General Management, the Marketing Department, as well as the staff involved in these events;
  • Externally: for remote events, data may be transmitted to the WebinarGeek videoconferencing solution provider;
  • Externally: Some participant data (mainly images and/or audio recordings, as well as surname, first name, job title and position/company) may be publicly distributed, in particular via the press or our own communication channels (website and social networks).

Prospects

Your data will be processed :

  • Internally: Marketing, Sales and General Management;
  • Externally: to our subcontractors HubSpot and Full Enrich.

Recruitment :

Your data will be processed :

  • Internally: Human Resources Department, Executive Management.

Video Conference Recordings

  • The employee who conducted the videoconference, their immediate supervisor, and, if applicable, the individuals in charge of internal training.  

How long is my data kept?

Your Personal Data is retained only for as long as is strictly necessary to fulfill the purposes set forth in this Policy, in accordance with applicable regulations and laws. After this period, your Personal Data is deleted.

Website navigation

  • Cookies are not stored for longer than 12 months.

Customer file management

  • We retain your data for the duration of the contractual relationship plus five (5) years following the end of that contractual relationship (statute of limitations under general law: Article 2224 of the Civil Code);  
  • However, we are required to retain accounting data for 10 years beyond the end of the contractual relationship in order to comply with a legal obligation incumbent upon Feel Agile (Article L123-22 of the Commercial Code; Article L102 B of the Book of Tax Procedures). At the end of this ten (10)-year period, the data will be deleted from our databases.

Our Oversecur Solution

  • Management of user accounts for the Solution: duration of the contractual relationship;
  • Information on updates and new products sent by e-mail: duration of contractual relationship ;
  • Oversecur newsletter: duration of subscription or, failing that, date of request to unsubscribe from the newsletter.

Private/public events

  • We keep your data until the event is over, plus 5 years.

Prospects

  • We keep your data for 3 years from the date of our last contact. At the end of this three (3) year period, the data will be deleted from our databases.

Recruitment

  • Application management: time for application analysis ;
  • Candidate Pool: Retained for two (2) years, then deleted.

Requests to exercise rights

  • Processing of the request:  
    • Simple application: one (1) month;
    • Complex application: three (3) months;
    • Request for health data: eight (8) days;
  • Retention of a copy of the information after the application has been processed for traceability purposes: Records are retained for the duration of the application’s processing plus five (5) years.

Video Conference Recordings

  • Data is retained for a period of six (6) months from the date of creation, after which it is permanently deleted.  

Where do we transfer your personal data?

Feel Agile chooses service providers who host their data within the European Union. A Data Processing Agreement is drawn up with each processor within the meaning of the RGPD as part of our contractual relationship.

Nevertheless, when necessary, we may transmit your Personal Data to service providers operating outside the European Union.

If these service providers operate in a country that is not considered to offer adequate protection by the European Commission, we implement the Standard Contractual Clauses approved by the aforementioned Commission, and we also include a Data Processing Agreement ("DPA") as part of our contractual relations with these service providers.

Video conference recordings: These recordings are not shared with any third parties.