Terms of Use

Discover in this article the general terms of use of Steeple.

1. Personal data protection policy.

2. Steeple acceptable use policy.

3. Intellectual property.

4. Hyperlink.

5. Cookie policy.

6. Changes to the general terms of use.

7. Jurisdiction – Applicable law.

1. Personal data protection policy

Steeple is a communication solution intended for organizations (companies, associations, schools, etc.). Steeple's business model is a subscription taken out by the organization in question. Thus, no data is used for commercial purposes, which ensures total protection of your information.

In this context, users may provide personal data about themselves by using the various collection media, tools and services made available to them on the site:

• Registration form

• Profile edit form

It is also possible to import other users' data as part of the invitation to join the platform. Prior consent from the people in question must first be obtained. When they respond positively to the invitation, they are asked to confirm the pre-filled data.

The collected data may be subject to processing, automated or otherwise, in accordance with the General Data Protection Regulation, the “GDPR”, of April 27, 2016. In this context, Steeple acts as the data controller.

Purpose of processing

To ensure optimal use of the platform, we ask that anonymity, which is a source of overflow, be avoided, which is why we ask for the user's identity.

How to exercise your rights

You have rights over the personal data concerning you that we collect and process in the context of your use of the site, its services and your requests. These rights are as follows:

• a right of access, rectification and erasure of data (inaccurate, incomplete, ambiguous, or outdated),

• the right to object to the processing of your data at any time in the context of commercial prospecting,

• the right to restrict the processing of your data under the conditions provided for by the regulations,

• the right to data portability,

• the right to withdraw your consent at any time,

• the right to lodge a complaint with a supervisory authority.

You can exercise these rights by writing by email: [e-mail]

1.1 What personal data do we need and why?

Mandatory information relating to the user account:

For security reasons, but also for community life on the solution, each user is attached to a natural person. It is therefore necessary to be able to identify the user through their:

• Last name / First name: this information is visible to all registered members of the community.

• Email: this information is only accessible to the user and the Steeple community administrators.

All login passwords as well as the 4-digit codes allowing interaction on the notice board are completely encrypted and invisible.

Optional information relating to the user account:

In order to further pursue our mission of creating connections between community members, certain optional information may be requested.

• Profile photo: allows you to recognize the person interacting on the Steeple solution.

• Biography: also helps better understand other members and be indexed in the internal search engine.

Optional information relating to the user account and modules:

In order to continuously improve the Steeple experience, we are continuously developing modules offered to administrators. Administrators choose whether or not to activate these modules. For the proper functioning of certain modules, additional information is requested from the user.

• Birthday: This data makes it possible to wish the member in question a happy birthday on the day itself. No notion of age is mentioned, only the day matters to us.

• Date of arrival in the company: allows us to wish a happy work anniversary. Here the notion of day and year is important.

• Department within the organization: In order to visualize all the members of a community, we created the organizational chart module. This groups members according to the department or group to which the registered member belongs.

1.2 How can this information be modified?

All this information can be changed directly from your profile page. So all you need to do is go to the menu, then profile, then edit profile, and you will be able to change this information.

Please note that if you replace information with an empty field, Steeple considers this to be deletion of information.

1.3 Where is the data hosted?

Steeple works with the provider Heroku to host and protect this data. Heroku hosts and protects this data in the European Community and more specifically in Ireland.

The servers comply with the following accreditations:

• ISO 27001

• SOC 1 and SOC 2/SSAE 16/ISAE 3402 (Previously SAS 70 Type II)

• PCI Level 1

• FISMA Moderate

• Sarbanes-Oxley (SOX)

1.4 How is your data protected?

Platform protection:

Access to a community is strictly reserved for members who are part of it. Administrators have several means of limiting access to their community.

A password of at least 8 characters is required when registering.

Penetration tests and vulnerability assessments are carried out regularly by independent agencies.

Server protection:

A firewall system restricts access from external networks. By default, all access is closed; only the necessary ports and protocols are open.

DDoS mitigation techniques are in place, including "SYN cookies" and "rate limiting".

Physical protection:

No one can access the servers without a secure pass. A fire alarm and fire suppression system is in place. Generators help protect against power outages.

All security elements are accessible here: https://www.heroku.com/policy/security

1.5 How do you delete your data?

To delete your information, several options are available:

• Go to the profile page and edit the information by replacing it with empty content.

• You can also delete your account in the settings section.

When the account is deleted, all of your information and contributions are deleted. This information is retained for 30 days in case of accidental deletion on your part.

What happens when you leave a Steeple client organization?

When an administrator removes access to your organization or when you leave a community, your account is not deleted.

1.6 How will you be informed of changes to our data protection policy?

Each update will be communicated to you through a message appearing directly in your news feed.

1.7 How can you contact us?

To contact us, you can do so at [e-mail] or via the support chat on the website at the bottom right of your screen or in the Steeple messaging system.

2. Steeple acceptable use policy

In order to ensure proper use of the Steeple tool, certain rules are necessary.

2.1 What you must not do when using Steeple

• Use a false identity, or a pseudonym, or impersonate another person.

• Distribute illegal, discriminatory, harmful, fraudulent, misleading or defamatory content, or content that promotes or encourages violence, violation of laws, self-harm, eating disorders or substance abuse.

• Distribute content that is offensive to another member of the community.

• Share your login details with other people.

• Spam the community with promotional content.

2.2 How to report abuse

You can report any breach of the acceptable use policy of the tool directly to the community administrators or directly to the Steeple team, via the support chat or by email at [e-mail].

2.3 Image rights policy

By registering on Steeple you agree that your image may be displayed within the closed community. In case of disagreement, make this explicit to the administrators.

2.4 Steeple SAS disclaims all liability

In the event of interruption of the Steeple service for technical maintenance operations or updating published information.

In the event of temporary inability to access the Steeple service and the various related communities in the event of technical problems, whatever their origin and source.

In the event of incorrect information exchanged on the Steeple service between different members.

In the event of damage to or non-return of equipment lent on the Steeple service and its various related communities.

In the event of direct or indirect damage caused to the user, of whatever nature, resulting from the content, access to, or use of the Steeple service (and/or sites linked to it).

In the event of abnormal use or unlawful exploitation of the Steeple service. The user of the Steeple service is then solely responsible for damage caused to third parties and for the consequences of claims or actions that may arise. The user also waives any recourse against Steeple SAS in the event of legal action brought by a third party against them due to the use and/or unlawful exploitation of the site, including partner offers.

In the event that the member of the Steeple service loses their username and/or password or in the event of identity theft.

3. Intellectual property

3.1 Copyright and related rights

All the elements making up the Steeple.com site (texts, graphics, software, photographs, images, videos, sounds, plans, names, logos, trademarks, various protectable creations and works, databases, etc.) as well as the site itself, are subject to copyright and related rights (in particular Articles L122-4 and L122-5 of the Intellectual Property Code) governed by French and international legislation. All these elements are the exclusive property of Steeple SAS. By accepting the general terms of use, the user of the Steeple.com site undertakes the following obligations, which prohibit them from:

• Using or querying the Steeple.com site on behalf of or for the benefit of another person,

• Using the information, database, services, user profiles present on the Steeple.com site for commercial purposes.

• Reproducing in large numbers, for commercial or non-commercial purposes, the information, database, items, skills, user profiles present on the Steeple.com site for commercial or non-commercial purposes.

• Copying all or part of the content of the Steeple.com site into a third-party site for commercial or non-commercial purposes.

• Using a robot, in particular a spider, a search or site retrieval application, or any other means allowing the retrieval or indexing of all or part of the content of the Steeple.com site.

• Copying the information onto any type of medium allowing all or part of the original files to be reconstructed.

Any use of elements of the Steeple site constitutes a violation of copyright and is an act of counterfeiting. These unauthorized uses may also constitute a violation of image rights, personal rights or any other applicable rights and regulations. They may therefore incur the civil and/or criminal liability of their author. Steeple SAS reserves the right to take legal action and to pursue all legal remedies against persons who have not respected the prohibitions contained in this article.

3.2 Database producer rights

Steeple SAS is the producer of the database constituted by all the pages and activities on the steeple.com site. Within the meaning of Article L 341-1 et seq. of the Intellectual Property Code. Any extraction or use of the content of the database may incur the civil and/or criminal liability of its author. Steeple SAS reserves the right to take legal action against persons who have not respected this prohibition.

3.3 Trademark rights

The name Steeple is a registered trademark, property of Steeple SAS. Any use may incur the civil and/or criminal liability of its author. Steeple SAS reserves the right to exercise all legal remedies against persons who infringe its rights.

4. Hyperlink

4.1 Links from Steeple

Steeple may contain hyperlinks to third-party sites. Steeple SAS has no control over these sites and disclaims all responsibility for access to, content of, or use of these sites, as well as for the consequences and possible damages resulting from consulting information on these sites. The decision to click and activate these links is the sole and entire responsibility of the internet user.

4.2 Links to Steeple

No hyperlink may be created to Steeple without the prior consent of Steeple SAS. If an internet user or a legal entity wishes to create a hyperlink from their site to Steeple, they must first request this via the Steeple SAS contact details mentioned in point 2. Their request will be reviewed and admissibility or otherwise will be communicated to the interested party.

5. Cookie policy

Cookies are small texts present in the solution's code that are used to store information on web browsers. Cookies are used to store and receive information on devices such as computers or phones.

We use cookies to make it easier for you to use the Steeple tool.

5.1 Use of the cookie system to facilitate logins

In order to remember your login details and allow you to log in more easily, we use cookies. Without cookies, you would have to enter your login details every time you open Steeple and every time you open a new Steeple page.

5.2 Use of the cookie system to improve user experience

In order to better understand how you use the tool, we analyze which elements you find most useful and interesting and identify the features that could be improved.

6. Changes to the general terms of use

Steeple SAS reserves the right to freely modify the Steeple Terms of Use at any time. Each change to the T&Cs will be mentioned in your information feed and will appear in the summary sent by email to each registered member.

7. Jurisdiction – Applicable law

Any dispute that may arise concerning the validity, interpretation, acceptance and performance of these general terms of use, regardless of the place of subscription or payment, shall be subject to an attempt at amicable settlement that the parties undertake to seek. These general terms of use are governed by French law, which determines, on a case-by-case basis, the applicable law.