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Publisher:
The website https://blog.lemlist.com/ and https://lemlist.com/ are published by :

The company LEMPIRE
Simplified joint stock company with a capital of 1 024,00 euros
Registered with the RCS of Paris under the number 823 475 082
Head office : 128 rue La Boétie - 75008 Paris - France
Intra-community VAT number: FR61823475082
E-mail address: contact@lempire.co

Director of the publication:
Mr Guillaume MOUBECHE, President of LEMPIRE company

Hosting provider:
The website https://blog.lemlist.com/ is hosted by :
The company  Webflow, Inc.
Head office : 398 11th St., Floor 2, San Francisco, CA 94103.
E-mail address: contact@webflow.com

lemlist Privacy Policy

as of Jan 22th, 2022

Privacy and security are of utmost importance to lemlist (hereinafter known as “lempire”, “Provider,” “us”, “we”, “the App” or “the Site”) and we strive to ensure that our technical and organizational measures in place respect your data protection rights.

This Privacy Policy describes how we manage, process and store personal data submitted in the context of providing our services. “Personal data” refers to any information relating to an identifiable individual or his or her personal identity.

CONSENT

In subscribing to our services or filling in a contact form on our website (lemlist.com) or other sites owned by lempire, you agree and accept that we may gather, process, store and/or use the personal data submitted in accordance with the rules set forth below.

By giving your consent to us, you also retain the right to have your personal data rectified, to be forgotten and/or to be erased.

PERSONAL DATA COLLECTED

1. Identity and contact details of the data processor

Personal data is collected on our website by lempire SAS, a company registered under France law number 823 475 082 with the Paris Trade & Companies Register, and having its registered office at 128 rue La Boétie, 75008 Paris, France.

2. Data collected on the site
Classification

Collected data are classified as either

• Information intended for use only by specific individuals on a need-to-know basis
• Information protected by law, contractual obligation, or policy
• Information with the potential for severe negative repercussions to lempire’s reputation, resources, services, or individuals if disclosed
• Information intended for lempire use only
• Non-public information that does not reach the sensitivity of Confidential
• Information with the potential for moderate negative repercussions to lempire’s reputation, resources, services, or individuals if disclosed
Public
• Information intended to be publicly available
• Information that poses little or no risk to lempire’s reputation, resources, services, or individuals if disclosed
Internal
Confidential

All confidential data are encrypted at rest.



Data collected
When you subscribe to our services, the following data is collected and managed (note that there is no aggregated elements)
Data element
Isolated
- Access tokens and resume tokens (Google, Microsoft, linkedIn, Aircall, Hubspot, Pipedrive, Salesforce, Dropcontact)
- Passwords (lempire applications, SMTP/IMAP)
Confidential
email address, first name, last name, company name, Intra-community VAT number (when applicable), login, password, mailing address, country, phone number, IP address(es) and domain name, user application notifications, campaign data, campaign leads, email templates, graveyard email list, user tasks, team activity logs, order history, complaints, incidents, information on subscriptions and messages on our site. Some data is collected automatically by reason of your activity on the site (see paragraph on cookies below).
Internal
pages templates
Public

The data submitted should not include any sensitive personal data, such as government identifiers (i.e. social security, driving licence, or taxpayer identification numbers), complete credit card or complete personal bank card numbers, medical records or particulars connected with applications for care or treatment associated with private individuals.

Data handling

The chart below summarizes the requirements for handling information based on classification. Information comingled with multiple classifications must always be handled with the highest applicable classification (e.g. public information that is stored or transmitted along with Confidential information may be encrypted in order to simplify the use of encryption solutions).

Confidential

Distribution

  • Not shared with third parties
  • Customer information never included in reports, regardless of accompanying data

Labeling

  • Documents, spreadsheets, presentations and text files labeled “Confidential”
  • All paper documents labeled “Confidential”

Paper documents

  • Only printed when there is a legitimate business need and no reasonable alternative, with management approval 
  • Stored in a locked cabinet 
  • Placed in destruction bin for shredding immediately after use

Electronic files

  • Collected or stored when there is a legitimate business need and no reasonable alternative, with management approval
  • Stored and transmitted encrypted 
  • Wiped from electronic media immediately after use

Internal

Distribution

  • Redistributed to anyone within lempire

Labeling

  • Not labeled

Paper documents

  • Only printed when there is a legitimate business need and no reasonable alternative 
  • Stored on lempire premesis or in locked cabinet
  • Placed in destruction bin for shredding immediately after use

Electronic files

  • Stored and transmitted in clear text on lempire corporate systems
  • Deleted or wiped from electronic media immediately after use

Public

Distribution

  • Shared with anyone internal or external to lempire

Labeling

  • Not labeled

Paper documents

  • Recycled conventionally when no longer needed

Electronic files 

  • Stored and transmitted in clear text
  • Deleted or wiped from electronic media immediately after use

3. Purposes of processing and legal basis

Your personal data is processed to meet one or several of the following purposes. Each purpose is associated with a legal basis, the list of which can be found below.

On the basis of our legitimate interest of offering you a safe, optimum, efficient and personalized experience, we carry out processing operations for the following purposes:

  • To solve any problems and improve the use of our sites and services;
  • To personalize, assess, and improve our services, content and materials;
  • To analyze the volume and history of your use of our services;
  • To inform you about our services as well as our partners’ services and/or promotional offers.

On the performance basis of a contract to which you are a party, we carry out processing operations for the following purposes:

  • To provide our services;
  • To facilitate performance, including verifications relating to you.

On the bases of your consent or legitimate interest, we carry out processing operations for the following purposes:

  • To sign up to our newsletters, use case studies and marketing material.

On the basis of the compliance with our legal and regulatory obligations, we carry out processing for the following purposes:

  • To prevent, detect and investigate any activities that are potentially prohibited, unlawful, contrary to good practices and to ensure compliance with our terms of use and sending policy.

We use the personal data submitted to us only in accordance with the applicable data protection legislation.

4. Newsletter and marketing emails

For those of you that have expressly opted in to receive our lemlist newsletters, you are easily able to unsubscribe by following the “unsubscribe” links included in every email sent.

5. Email statistics

Without systematically doing so, we may analyze and track the various rates (for example: click, open, bounce rates) and the number of emails sent with lemlist which you open to assess performance rates on your emailing campaigns.

6. Testimonials

lemlist publishes a list of Customers & Testimonials on its sites with information on our customers’ names and job titles. lemlist undertakes to obtain the authorization of every customer before publishing any testimonial on its websites. If you wish to be removed from this list, you can send us an email to privacy@lemlist.com and we will delete your information promptly.

7. Third party disclosures

Personal data relating to you collected on our website are destined for lemlist’s own use and may be forwarded to lemlist’s partner companies so that we may obtain assistance and support in the context of carrying out our services. lemlist ensures that it has in place clear data protection requirements for all of its third party providers.

lemlist does not sell or rent your personal data to third parties for marketing purposes whatsoever.

In addition, lemlist does not disclose your personal data to third parties, except if: (1) you (or your account administrator acting on your behalf) requests or authorized disclosure thereof; (2) the disclosure is required to process transactions or supply services which you have requested (i.e. to check you are employing best practices in your mailings or for the purposes of processing an acquisition card with credit-card issuing companies); (3) lemlist is compelled to do so by a government authority or a regulatory body, in the case of a court order, a summons to appear in court or any other similar requisition from a government or the judiciary, or to establish or defend a legal application; or, (4) the third party is a subcontractor or sub-processor of lemlist in the carrying out of services (for example: lemlist uses the services of an Internet provider, a telecommunications company, a host provider, CRM tools, customer support client tools, invoices tools, payment tools, analytics tools).

8. Your data protection rights

In accordance with the French Data Protection Laws and the European General Data Protection Regulation 2016/679 (GDPR) you have several rights related to the collection of your personal data:

  • Right to be informed: This is precisely why we have drafted this privacy policy.
  • Right of access: You have the right to access all your personal data at any time.
  • Right to rectification: You have the right to rectify your inaccurate, incomplete or obsolete personal data at any time.
  • Right to restriction of processing: You have the right to restrict the processing of your personal data in certain cases stated in art.18 of the GDPR.
  • Right to erasure (‘right to be forgotten’): You have the right to demand that your personal data be deleted and to prohibit any future collection.
  • Right to file a complaint to a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a breach of applicable regulations.
  • Right to define instructions related to the retention, deletion and communication of your personal data after your death.
  • Right to data portability: You have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
  • Right to object: You have the right to object to the processing of your personal data. Please note however that we may continue to process your personal data despite this opposition for legitimate reasons or for the defence of legal claims.

You can exercise these rights by sending us a support ticket directly on the support chat (either on the website or on the app) or, by sending an email at privacy@lemlist.com. Your requests will be processed within 30 days. We may require that your request be accompanied by a photocopy of proof of identity or authority.

You are also able at any time to modify personal data by logging into your account and navigating to “User Settings”.

GOOGLE COMPLIANCE

lemlist’s use and transfer to any other app of information received from Google Accounts will adhere to Google API Services User Data Policy, including the Limited Use requirements.

THIRD PARTY DATA

In the context of using our services, namely creating emailing campaigns and contact lists, lemlist has access to the information contained in the email contact lists you create in your account, as well as the subject and content of the emails that you send out via our services.

This data is stored on secure servers and only a limited number of people are authorized to access your contact lists, in particular for the purpose of providing support services.

You are easily able to recover your contact lists from your lemlist account at any time, by clicking on the “export” button. You may also modify and or delete contacts at any time from your account.

In no case does lemlist sell, share or rent out your contact lists to third parties, nor does it use them for any purposes other than those set forth in this policy. We will use the information from your contact lists only for legal requirements, to invoice and collect summaries for our own statistics and for the purposes of providing you with customer support services.

As creator of the contact lists and associated email campaigns, you are considered the data controller within the meaning of the GDPR, and lemlist is acting only as a data processor. In this capacity, you are responsible in particular for:

  • making all the declarations necessary to the relative data protection authority,
  • complying with all current regulations in force, including the data protection laws,
  • obtaining the explicit consent of the persons concerned when collecting their personal data,
  • ensuring your authority to use the personal data collected in accordance with the defined end purposes and refraining from any unauthorized use.

If a recipient of your emails sent via our services requests us to modify or delete his/her personal data, we will honor that request after proper verification and will inform you of it.

DATA RETENTION PERIODS

Your personal data is kept for the periods set out below.

  • Personal data collected for the execution of the services as well as information about how and when you use the services: The time needed to provide to you our services, and in no event no longer than 3 years after closing your account (unless otherwise required by law).
  • Personal data collected in order to send newsletters, requests and direct marketing: 3 years from data collection or last active contact with the prospect.
  • Personal data collected for evidentiary purposes: Duration of the statutory limitation period (generally 5 years).
  • Personal data collected as part of your data subject’s rights: If we ask you for proof of identity, we only retain it for the time necessary to verify your identity. Once the verification has been carried out, the proof is deleted.

LOCATION OF DATA STORAGE AND TRANSFERS

The host servers on which lemlist processes and stores its databases are located exclusively within the European Union.

lemlist will inform you immediately, to the extent we are legally authorized to do so, in case of any application or order originating from an administrative or judicial authority relating to your personal data.

Regarding the tools we use (see article “Third party disclosures” on recipients of the collected data, concerning our processors), your personal data could be transferred outside the European Union. The transfer of your data within this framework is secured by the following safeguards:

  • Either these data are transferred to a country which has been deemed to offer an adequate level of protection by the European Commission;
  • Or we have concluded with our processors a specific contract governing the transfer of your data outside the European Union, based on the standard contractual clauses approved by the European Commission between a data controller and a processor.

SECURITY

Within the framework of its services, lemlist attributes the very highest importance to the security and integrity of its customers’ personal data.

Thus and in accordance with the GDPR, lemlist undertakes to take all pertinent precautions in order to preserve the security of the data and, in particular, to protect them against any accidental or unlawful destruction, accidental loss, corruption, unauthorized circulation or access, as well as against any other form of unlawful processing or disclosure to unauthorized persons.

To this end, lemlist implements industry standard security measures to protect personal data from unauthorized disclosure. Using industry recommended methods of encoding, lemlist takes the measures necessary to protect information connected with payments and credit cards.

Moreover, in order to avoid in particular all unauthorized access, to guarantee accuracy and the proper use of the data, lemlist has put the appropriate electronic, physical and managerial procedures in place with a view to safeguarding and preserving the data gathered through its services.

Notwithstanding this, there is no absolute safety from piracy or hackers. That is why in the event a breach of security were to affect you, lemlist undertakes to inform you thereof without undue delay and to use its best efforts to take all possible measures to neutralize the intrusion and minimize the impacts. Should you suffer any loss by reason of the exploitation by a third party of a security breach, lemlist undertakes to provide you with every assistance necessary so you are able to assert your rights. Moreover if, by some exceptional case, the direct loss incurred arose due to fault or gross negligence by lemlist, you will be able to seek compensation within the limit of liability referred to in our Terms of Use.

You should keep in mind that any user, customer or hacker who discovers and takes advantage of a breach in security renders him or herself liable to criminal prosecution and that lemlist will take all measures, including filing a complaint and/or bringing court action, to preserve the data and the rights of its users and of itself and to limit the impacts.

Cookie’s name
Cookie’s function
Shelf life
intercom-id-*
Used by Intercom (Support) to identify users
9 months
intercom-sessions-*
Used by Intercom (Support), to identify user sessions
1 week
cookieconsent_status
To store cookie consent preferences
Session
cfmrk_cic
Used by Cloudfare to route user traffic for this site
3 months
Cookie’s name
Cookie’s function
Shelf life
poptin_old_user
Used by Poptin to identify old user
Session
poptin_session_account_*
Used by Poptin to identity user sessions
Session
poptin_session
Used by Poptin  to identify user sessions for Poptin display settings
30 minutes
poptin_c_visitor
Used by Poptin to anonymously track visitors to display popups with better accuracy
1 day
poptin_user_ip
Used by Poptin to save user IP address
1 year
poptin_user_id
Used by Poptin to provide a unique visitor ID
1 year
poptin_user_country_code
Used by Poptin to save user country code
1 year
poptin_referrer
Used by Poptin as original referrer
2 minutes
_fbp
Used by Facebook to deliver a series of advertisement products
3 months
_gcl_au
Used by Google Adsense to store and track conversions
3 months
gclid
Used by Google Adsense to uniquely track individual AdWords clicks
Session
Cookie’s name
Cookie’s function
Shelf life
_gid
Used by Google Analytics to count pageviews
1 day
_ga
Used by Google Analytics to register a unique ID that is used to generate statistical data on how the visitor uses the website
2 years
ajs_anonymous_id
Used by Segment to store last visit
1 year
ajs_user_id
Used by Segment to identity user
1 year
ajs_group_id
Used by Segment to group visits
1 year
cfmrk_cic
Used by Cloudflare to route user traffic for this Site.
90 days
_hjTLDTest
Used by Hotjar to determine generic cookie path
Session
_hjid
Used by Hotjar to store a unique user ID
1 year
_hjAbsoluteSessionInProgress
Used by Hotjar to store unique visits
Session
__hstc
Used by Hubspot to store time of visit
13 months
hubspotutk
Used by Hubspot to store and track a visitor’s identity
13 months
refiner_cookie_uuid
Used by Refiner to understand who our customers and visitors are
1 year
__stid
Used by ShareThis to store and track audience reach
1 week
__stidv
Used by ShareThis to determine the pages visited, amount of time spent, etc
6 months
_gac_*
Used by Google Analytics and Google Ads to store and count pageviews
90 days
amplitude_id
Used by Amplitude for session tracking
Session

PRIVACY POLICY CHANGES

lemlist reserves the right to update this Privacy Policy at any time, in particular pursuant to any changes made to the laws and regulations in force. Any modifications made will be notified to you via our Website or by email, to the extent possible, thirty (30) days at least before any changes come into force. We would recommend that you check these rules from time to time to stay informed of our procedures and rules relating to your personal information.

CONTACT US

If you have questions, you can email us at Data Protection Officer directly at: privacy@lemlist.com or by mail to: lempire SAS, Attn: Data Protection Officer / Legal Department, 128 rue La Boétie, 75008 Paris, France.