This privacy policy (“Privacy Policy”) has been drafted by the simplified joint-stock company (société par actions simplifiée) SalesCrew, registered with the Trade and Companies Register of Evry under the number 885 069 039, with its head office located at 3 rue Jules Guesde à Ris-Orangis (91130) (“SalesCrew”).
SalesCrew is a publisher of software 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 responsible for tracking/monitoring variable compensation and a specific interface for the sales representatives concerned by the variable compensation.
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: https://www.qobra.co/privacy-policy.
1. Definitions
The following definitions are applicable to the entire Privacy Policy:
- “Account”: means the personal account allowing any Administrator and any User to access the Software.
- “Administrator”: means 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.
- “Agreement”: means any contract concluded between SalesCrew and a Client in order to provide the Software and the Services.
- “AI Agent”: refers to the artificial intelligence-based features agents made available by SalesCrew within the Software.
- “Client”: means 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.
- “Data Processor”: means any company whose services SalesCrew uses to implement the various personal data processing operations described below.
- “Data Subject”: means a Visitor, Administrator, User, Trial User, prospect or any other individual whose personal data is processed by SalesCrew.
- “Personal Data Regulation”: means 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.
- “Service”: means any service provided by SalesCrew as part of the Software as specified in the Agreement.
- “Software”: means the digital software called Qobra available at https://app.qobra.co and published by SalesCrew.
- “Trial Agreement”: means the agreement governing free and temporary access to the Trial Environment, accepted by Trial Users on behalf of a prospect company.
- “Trial Environment”: means the dedicated evaluation environment of the Software, currently available at https://try.qobra.ai.
- “Trial User”: means any natural person who creates an account to access the Trial Environment on behalf of a prospect company.
- “User”: means 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”: means any person consulting or browsing the Website.
- “Website”: means SalesCrew’s marketing website available at https://www.qobra.co/.
Unless circumstances request otherwise, definitions in the singular include the plural and vice versa.
2. Roles and liabilities of SalesCrew
2.1 SalesCrew acting as a data controller
SalesCrew is the data controller, within the meaning of the Personal Data Regulation of the following data:
- Visitors’ connection data on the Website (IP address, browsing history, unique number associated with a cookie, language preferences);
- Visitors’, prospects and Users’ contact data (surname, first name(s), email address, telephone number, job title, company name for/with which Visitors, prospects and Users work);
- Client’s billing data (billing address, payment method, chosen bank, transaction history, IBAN);
- Administrators’ and Users’ login data (login ID, protected password, IP address).
- Browsing data of Administrators and Users;
- Trial Users’ data: identification and contact data provided when creating an account in the Trial Environment (surname, first name(s), professional email address, job title, company name, company size), login data, data relating to the use of the Trial Environment (pages viewed, features used, actions performed, time spent, progress of the configuration, requests for a demonstration or a call) and data relating to the use of the AI Agents in the Trial Environment;
- Data relating to the use of the AI Agents, in particular the content submitted by Users and Administrators to the AI Agents (prompts, attached files), as well as the exchanges and content generated by the AI Agents.
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:
- Via email: data@qobra.co and/or
- Via letter: SalesCrew, Données personnelles, 3 rue Jules Guesde, 91130 Ris-Orangis (France).
2.2 SalesCrew acting as a data processor
SalesCrew is the data processor, within the meaning of the Personal Data Regulation of the following data:
- Administrators’ and Users’ identifying data (First name, last name, ID number, professional email address, date of birth, photography);
- Users’ data allowing the calculation of the compensation (contract start date, seniority, manager’s email address, professional category, position, hierarchy within the company (team, subordinates), IP address, login information, CRM identifier, remuneration information, amount of commissions, commission plan);
- Personal data contained in the documents and data uploaded by Trial Users in the Trial Environment (in particular compensation plans and data relating to the prospect’s sales teams), which SalesCrew processes on behalf of the prospect company acting as data controller;
- Data relating to the use of the AI Agents.
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 Agreement signed between SalesCrew and the Client, in accordance with the Personal Data Regulation. Where personal data is contained in documents or data uploaded by Trial Users in the Trial Environment, such processing is governed by the Trial Agreement and SalesCrew’s Data Processing Agreement.
Consequently, Administrators and Users contacting SalesCrew at the above address will be redirected to the data controller of their personal data.
3. Processings, purposes, legal basis
| Processing |
Purpose |
Legal basis |
| Prospecting and analysis of Visitors |
To identify the Visitors to the Website, in particular for marketing purposes and to provide them with the most appropriate content according to their activity |
Consent |
| Creation of Accounts |
To create Accounts so that Clients can allow Administrators and Users to use the Software |
Performance of the Agreement |
| Processing of assistance request and access to Services |
To provide assistance to Clients and enable them to benefit from the Services as contractually agreed |
Performance of the Agreement |
| Monitoring of bugs and errors in the Software, the Services, or the Website |
To analyze browsing and usage data of the Software in order to detect, diagnose, and correct technical anomalies |
SalesCrew's legitimate interest in ensuring the proper technical functioning of the Software, the Services, and the Website |
| Commercial relationship and prospecting of Clients |
To develop the commercial relationship with Clients and inform them of the evolution of SalesCrew offers |
Legitimate interest of SalesCrew to use this data |
| Satisfaction survey and improvement of the Website, the Software, the Services |
To continuously improve the Website, the Software and the Services, by conducting surveys and analyzing statistics |
Legitimate interest of SalesCrew to use this data to improve its Website, Software, Services |
| Client management |
To follow the execution of the Agreement, in particular the establishment of invoices, orders and contracts and the management of unpaid invoices and complaints |
Performance of the Agreement |
| Litigation |
To allow SalesCrew to organize its defence in the circumstances of any litigation or prelitigation |
Legitimate interest of SalesCrew to defend itself |
| Payment |
To enable the execution of payment authorized by the Clients |
Performance of the Agreement |
| Fraud |
To prevent fraud and all scams that may target Clients, Administrators and Users of SalesCrew including but not limited to the use of stolen credit cards |
Legitimate interest of SalesCrew to prevent fraud |
| Connection of Administrators and Users |
To identify Administrators and Users while using the Software and allowing them to connect to their Accounts |
Performance of the Agreement |
| Compliance with contractual terms |
To detect and prevent uses that do not comply with the applicable contractual terms, in particular the Terms of Use and the AI Supplementary Terms |
SalesCrew's legitimate interest in ensuring compliance with the terms governing access to, and use of, the Software, the Services, and the Website |
| Analysis of User behavior |
To measure the use or adoption of the Software's features |
SalesCrew's legitimate interest in understanding the use of the Software |
| Improvement of the Software, the Website and the Services |
To improve the performance, quality, and reliability of the Software and its features, in particular the AI Agents |
SalesCrew's legitimate interest in continuously improving the Software, the Website and the Services |
| Management of access to the Trial Environment |
To create Trial Users' accounts, give them access to the Trial Environment and operate the AI Agents during the trial |
Performance of the Trial Agreement |
| Follow-up of the trial and prospecting of Trial Users |
To inform SalesCrew's sales and pre-sales teams of Trial Users' actions in the Trial Environment (progress of the configuration, features used, time elapsed, requests for a demonstration) and to contact Trial Users to follow up on the trial, propose a demonstration and present SalesCrew's offers |
SalesCrew's legitimate interest in developing its business with professional prospects (Trial Users may object at any time) |
| Preparation of personalized demonstrations |
To use the configuration created in the Trial Environment to prepare a demonstration of the Software tailored to the prospect's needs |
SalesCrew's legitimate interest in presenting the Software in a relevant way |
| Security of the Trial Environment and prevention of abuse |
To detect and prevent abusive or fraudulent uses of the Trial Environment (automated access, multiple accounts, access by competitors, circumvention of usage limits) |
SalesCrew's legitimate interest in protecting the Software and its know-how |
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.
The categories of Processors to whom personal data may be transferred are the following:
- Day-to-day services: Data Processors who provide digital solutions 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 functioning 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.
- Providers of artificial intelligence solutions: Data Processors that provide the infrastructure and artificial intelligence models necessary for the operation of the Software, including the AI Agents.
It is hereby clarified that neither SalesCrew nor its Data Processors sell personal data of Data Subjects.
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, during assistance requests related to the Accounts and data relating to the use of the AI Agents, is kept for a period of sixty (60) days after the end of the Agreement with the Client unless shorter or longer retention periods are required by the Client and/or provided for by SalesCrew's internal policies pursuant to applicable regulations.
- Personal data relating to Trial Users and to the use of the Trial Environment (including data relating to the use of the AI Agents in the Trial Environment) is kept for the duration of the trial and for a period of ninety (90) days after its end, extended, where discussions relating to a subscription are in progress, until the end of such discussions and at most six (6) months after the end of the trial. Trial Users’ contact data used for prospecting purposes is kept for a period of thirty-six (36) months from their last interaction with SalesCrew.
SalesCrew undertakes to anonymize, archive or delete the personal data of Data Subjects as soon as the purpose and retention period expire.
6. Rights of data subjects
6.1 Type of rights
In accordance with the Personal Data Regulation, the Data Subject benefits from the rights provided by the Personal Data Regulation, namely:
- 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).
6.2 Exercise of rights
The exercise of the rights offered by the Personal Data Regulation is not unlimited - SalesCrew is entitled to refuse to act on 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:
- 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 received and the Personal Data Regulation.
- Free of charge: the exercise of rights is in principle free of charge. In cases where a request would involve significant costs, the Data Subject could be required to pay a fee.
These requirements must be respected, otherwise requests may not be processed.
7. Data transfers
The personal data processed by SalesCrew is hosted by Amazon Web Services, whose servers are located in the European Union.
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, SalesCrew has ensured that Data Processors have implemented appropriate legal, technical and organizational measures to govern any transfer of personal data, in particular by having recourse to the standard contractual clauses drawn up by the European Commission.
Data Subjects may obtain a copy of the personal data transferred by contacting the following address: data@qobra.co
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 software or a mobile application, regardless of the type of terminal used (computer, smartphone, digital reader, object connected to the Internet...).
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 or her consent. Data Subjects may withdraw their consent to the use of these cookies by clicking on “Consent choices” in the footer of the Website.
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.
Within the framework of this exception, SalesCrew uses the following cookies:
- 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 the recording of 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.
In the Trial Environment, SalesCrew uses (i) cookies strictly necessary for authentication, session management and security, which are exempt from consent, and (ii) subject to the Trial User’s prior consent, collected through a consent banner when first accessing the Trial Environment, analytics and product guidance cookies used to measure the use of the Trial Environment and to inform SalesCrew’s sales and pre-sales teams of the Trial User’s progress. These cookies are kept for a period of thirteen (13) months from their placement. Trial Users may withdraw their consent at any time via “Consent choices” in the Trial Environment.
9. Security measures
SalesCrew takes all physical, logical 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:
- 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 hashing of passwords;
- Use of physical security measures on the premises.
All SalesCrew security measures are accessible at trust.qobra.co.
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 the development of the Website, the Software, the Services, or applicable rules.
In such a situation, Data Subjects will be notified of updates, either by sending an email or through a notice on the Website, within a reasonable period prior to their entry into force.