Privacy policy

Last updated on 30 April 2025

This privacy policy (“Privacy Policy”) has been drafted by the simplified joint-stock company (société par action simplifiée) SalesCrew, registered under laws of France to the trade companies registered of Evry under the number 879 223 923, with its head office located 3 rue Jules Guesde à Ris-Orangis (91330) (“SalesCrew”).

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SalesCrew is a publisher of softwares dedicated to the management of variable compensation. Within the framework of its activity, SalesCrew provides its clients with a software, which consists of a specific interface for the staff in charge of the follow-up of the variable compensation and a specific interface for the sales representatives concerned by the variable compensation.

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The purpose of the Privacy Policy is to describe the processing of personal data that SalesCrew carries out in order to fulfil its obligation to provide information as a data controller within the meaning of the texts on the protection of personal data. The Privacy Policy is published and accessible at any time on the following website: www.qobra.co/privacy-policy

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1. Definitions and vocabularies

The following definitions are applicable to the entire Privacy Policy:

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“Administrator”: refers to any natural person who is an employee of the Client and/or any third party, expressly authorized by the Client to use the Software in order to manage the variable compensation of the Users.
“Account”: refers to the personal account allowing any Administrator and any User to access the Software.
“Client”: refers to any legal entity that has entered into a contract with SalesCrew in order to benefit from the Software and Services as well as any natural person representing, employed or mandated by the legal entity to act on its behalf.
“Contract”: refers to any contract concluded between SalesCrew and a Client in order to provide the Software and the Services.
“Data Subject”: refers to a Visitor, Administrator, User, or Client.
“Data Processor”: refers to any company whose services SalesCrew uses to implement the various personal data processing operations described below.
“Personal Data Regulation”: refers to Regulation (EU) 2016/679 of the European Parliament and of the Council 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 and of the French Law No. 78-17 of 6 January 1978, Loi relative à l’informatique, aux fichiers et aux libertés, in its latest version in force.
“Software”: refers to the digital Software called Qobra available at https://app.qobra.co and published by SalesCrew.
“Service”: refers to any service provided by SalesCrew as part of the Software as specified in the Contract.
“User”: refers to any natural person who uses the Software for the calculation of his/her variable compensation as an employee or as a service provider of the Client.
“Visitor”: refers to any person consulting or browsing the Website.
“Website”: refers to SalesCrew’s marketing website available at https://www.qobra.co/.

Unless circumstances request otherwise, definitions in the singular include the plural and vice versa.

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2. Roles and liabilities of SalesCrew

2.1 SalesCrew acting as a data processor

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SalesCrew is the data controller, within the meaning of the Personal Data Regulation of the following data:

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Visitors’ connection data on the Website (IP address, browsing history, unique number associated to a cookie, language preferences);
Visitors’ and Clients’ contact data (surname, first name(s), email address, telephone number, job title, company name for/with which Visitors and Clients work);
Client’s billing data (billing address, payment method, chosen bank, transaction history, IBAN);
Administrators’ and Users’ login date (login ID, protected password).

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For any question relating to the processing of their personal data or to exercise their rights under the Personal Data Regulation, Data Subjects may contact SalesCrew at the following addresses:

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Via email: data@qobra.co and/or
Via letter : SalesCrew, Données personnelles, 3 rue Jules Guesde, 91330 Ris-Orangis (France).

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2.2 SalesCrew acting as a data processor

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SalesCrew is the data processor, within the meaning of the Personal Data Regulation of the following data:

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Administrators’ and Users’ identifying data (surnames, first names, email address, pictures);
Users’ data allowing the calculation of the compensation (career path, position held, compensation received, customer performance).

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SalesCrew has no control over the means and purposes of the processing carried out by the Client, and therefore acts as a data processor within the meaning of the Personal Data Regulation. The manner in which the Client has entrusted SalesCrew with the processing of personal data has been contractually stipulated in the Contract signed between SalesCrew and the Client, in accordance with the Personal Data Regulations.

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Consequently, Administrators and Users contacting SalesCrew at the above address will be redirected to the data controller of their personal data.

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3. Processings, purposes, legal basis

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‍4. Recipients of processed data

The personal data collected on the Data Subjects and processed are necessary for the pursuit of all of the aforementioned purposes and are exclusively intended for the internal management services of SalesCrew as well as, if necessary, for its Data Processors.

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The categories of Processors to whom personal data may be transferred are the following:

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Day-to-day services: Data Processors who provide digital solution for SalesCrew day-to-day activities such as data hosting, client and prospect management solutions, detections of Software errors or bugs, monitoring of the use of the Software, updates and proper function of the Software.
Maintenance services: Data Processors who have access to SalesCrew technology to perform maintenance or troubleshoot technical problems in connection with SalesCrew products and/or services in case of emergency.
Financial services: Data Processors who provide specialized financial services solutions such as payment services.

It is hereby clarified that neither SalesCrew nor its Data Processors sell personal data of Data Subjects.

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5. Duration of retention of personal data

The personal data of the Data Subjects are not kept beyond the necessary period:

Personal data collected during the visit to the Website through cookies is kept for a period of twenty-five (25) months from the collection of personal data.
Personal data collected when visiting the Website by filling in a form is kept for a period of thirty-six (36) months from their last interaction with SalesCrew or otherwise from the filling in of the form.
Personal data collected during the creation of Accounts, identification of Users and Administrators to their Accounts, use of the Accounts and and during assistance requests related to the Accounts, is kept for a period of sixty (60) days from the deletion of the Account by the Client.

SalesCrew undertakes to anonymize, archive or delete the personal data of Data Subjects as soon as the purpose and retention period expire.

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6. Rights of data subjects

6.1 Type of rights

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In accordance with the Personal Data Regulation, the Data Subject benefits from the rights provided by the Personal Data Regulation, namely:

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Right of access: any Data Subject may know what personal data SalesCrew has about him or her and obtain a copy of this data.
Right to rectification and to erasure: any Data Subject may request that erroneous or obsolete personal data concerning him or her be rectified and deleted.
Right to object and to restriction of processing: any Data Subject may object to the way in which SalesCrew processes his/her personal data or request that the processing concerning him or her be limited, provided that this is possible and without prejudice to any compelling legitimate grounds that may be justified by SalesCrew for continuing the processing, such as for example legal obligations in terms of the fight against money laundering and terrorist financing.
Right to data portability: any Data Subject may request SalesCrew to send personal data concerning him or her in a structured, commonly used and machine-readable format for transmission to another data controller, provided that this is possible.
Right to lodge a complaint with a supervisory authority : any Data Subject may contact the French data protection authority CNIL or any other competent data protection authority if he or she believes that SalesCrew has not complied with certain rules provided for in the Personal Data Regulation (information on how to lodge a complaint with French national data protection authority is provided on their website).

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6.2 Exercice of rights

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The exercise of the rights offered by the Personal Data Regulations is not unlimited - SalesCrew is entitled to refuse to act to manifestly unfounded or excessive requests - and each of them meets conditions that are imposed by the Personal Data Regulation. As such, the following elements are specified:

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Identity: any Data Subject must prove his or her identity and indicate the address at which he or she wishes to be contacted.
Response time: the requests are processed by SalesCrew within a reasonable time taking into account the complexity, the number of requests formulated and the Personal Data Regulation.
Free of charge: the exercise of rights is in principle free of charge. In cases where a request would imply important costs, the Data Subject could be required to pay a fee.

These requirements must be respected, otherwise requests may not be processed.

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7. Data transfers

The personal data processed by SalesCrew is hosted by Amazon Web Services, whose servers are located in the European Union.

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Some of the personal data processed by some Data Processors, are transferred outside the European Union, including to the United States. In such a case, as transfers to the United States do not benefit from an adequacy decision, SalesCrew has ensured that Data Processors have implemented appropriate legal, technical and organizational measures to frame any transfer of personal data, in particular by having recourse to the standard contractual clauses drawn up by the European Commission.

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Data Subjects may obtain a copy of the personal data transferred by contacting the following address: data@qobra.co

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8. Cookies

A "cookie" is a small computer file, a tracer, placed and read, for example, when consulting a website, reading an e-mail, installing, or using a software or a mobile application, regardless of the type of terminal used (computer, smartphone, digital reader, object connected to the Internet...).

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In accordance with article 82 of the French Law No. 78-17 of 6 January 1978, Loi relative à l’informatique, aux fichiers et aux libertés, any subscriber or user of an electronic communications service must be informed in a clear and complete manner, unless he or she has been informed beforehand, by the data controller or its representative of (i) the purpose of any action aimed at accessing, by electronic transmission, information already stored in his or her electronic communications terminal equipment or at entering information in this equipment and (ii) the means available to him or her to object to it. Such access or writing may only take place on the condition that the subscriber or user, after receiving such information, has expressed his consent. Data Subjects may withdraw their consent to the use of these cookies by clicking on “Consent choices” in the footer of the Website.

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It is also provided that these rules are not applicable if the access to information stored in the user's terminal equipment or the registration of information in the user's terminal equipment (i) either has the exclusive purpose of enabling or facilitating communication by electronic means, or (ii) is strictly necessary for the provision of an online communication service at the express request of the user.

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Within the framework of this exception, SalesCrew uses the following cookies:

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Cookies for audience measurement in order to measure the activity and the traffic of the Website. These cookies are kept for a period of thirteen (13) months from the first placement of cookies.
Cookies for personalization of the interface in order to allow to record the language preferences expressed by the Visitor. These cookies are kept for a period of 6 months from the last visit of the Website.
Cookies storing the choice expressed by the Visitor on the placement of cookies in order to allow the recording of the choice expressed by the Visitor. These cookies are kept for a period of six (6) months from the last acceptance, refusal or personalization by the Visitor.

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9. Security measures

SalesCrew takes all physical, logistic and organizational security measures to guarantee a high level of security for the protection of personal data and in particular to prevent the latter from being distorted, damaged or communicated to unauthorized persons. The security measures include in particular:

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Use of Cloud technologies recognized for their robustness and the systematic use by SalesCrew and its Data Processors of HTTPS protocol;
Restricted access to the personal data of Data Subjects by SalesCrew employees, according to their clearance profiles;
Use of password security solutions by all SalesCrew employees and Data Processors;
The hash of passwords;
Use of physical security measures on the premises.

All SalesCrew security measures are accessible at trust.qobra.co.

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10. Changes to the privacy policy

SalesCrew may change this Privacy Policy from time to time as the manner in which personal data is handled may change due to development of the Website, the Software, the Services, or applicable rules.

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In such a situation, Data Subjects will be notified of updates, either by sending an email or through a notice on the Website, at least fifteen (15) days prior to a material change to the Privacy Policy.