1. Personal Data Protection Policy
2. Steeple Good Practice Policy.
3. Intellectual property.
4. Hypertext link
5. Cookie policy
6. Modification of the General Terms and Conditions of Use
7. Jurisdiction – Applicable law
1. Personal Data Protection Policy
Steeple is a digital workplace solution that has been designed for organisations (companies, associations, schools, etc.). Steeple’s business model takes the form of a subscription that is taken out by the organisation in question. Consequently, no data is used for commercial purposes, which ensures that your data is fully protected.
In this context, users are likely to communicate their personal data by using the various collection media, tools and services made available to them on the site:
- Registration form
- Profile modification form
It is also possible to import data from other users as part of the invitation to join the platform. The consent of the individuals in question must be obtained beforehand. If they accept the invitation, they are invited to confirm the pre-filled data.
The data collected may be subject to processing, whether automated or not, in accordance with the General Data Protection Regulation (GDPR) of 27 April 2016. In these circumstances, Steeple is considered to be the data controller.
Purpose of processing
In order to ensure optimal use of the platform, we ask subscribers not to remain anonymous, the cause of anti-social comments, and to identify themselves.
How to exercise your rights
You have rights concerning the personal data about you that we collect and process in connection with your use of the site, its services and your requests. These rights are as follows:
- the right of access, rectification and erasure of the data
(inaccurate, incomplete, ambiguous or out-of-date data), - the right to object to the processing of your data at any time in the context of commercial prospecting,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 regulation,
- 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 sending an email to: rgpd@steeple.com
1.1 What personal data do we need and why?
Mandatory user account information:
For security reasons, but also for the operation of the digital community on the solution, each user is connected to a natural person. It is therefore necessary to be able to identify the user through his/her:
- Surname / First name: this information is visible to all registered users in the community.
- Email address: this information can only be accessed by the user and the administrators of the Steeple community.
All login passwords and 4-digit codes for interacting on the bulletin board are fully encrypted and invisible.
Optional user account information:
In order to continue bringing members of the community together, some optional information may be requested.
- Profile photo: serves to recognise the person who interacts with the Steeple solution.
- Biography: also makes it possible to get to know the other members better and to be indexed on the internal search engine.
Optional user account and module information:
In order to further improve the Steeple experience, we are continuously developing modules offered to administrators. Administrators may or may not choose to enable these modules. So that certain modules can function correctly, the user is asked to provide additional information.
- Date of birth: This data is used to wish the user a happy birthday on the day in question. No notion of age is mentioned, only the day matters to us.
- Date of arrival at the company: used to congratulate the user on the anniversary of his or her arrival. In this case, the day and the year are important.
- The department within the organisation: In order to view all the members of a community, we created the organisation chart module. It groups members according to the department or group to which the registered member belongs.
1.2 How do I change this information?
All of this information can be modified directly on your profile page. You just have to go to the menu, then profile, and then change the profile to modify this information.
It should be noted that if you replace a piece of information with an empty field, Steeple considers the piece of information to have been deleted.
1.3 Where is the data hosted?
Steeple works with the service 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 have the following certificates:
- 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?
Protection on the platform:
Access to a community is strictly reserved for its members. Administrators limit access to their community in several ways.
A password of at least 8 characters is required when signing up.
Intrusion testing and vulnerability assessments are performed regularly by independent agencies.
Protection of servers:
A firewall system is used to restrict access to external network systems. By default, all access is closed, only the necessary ports and protocols are open.
DDoS mitigation techniques are implemented, including “SYN cookies” and “rate limiting” techniques
Physical protection:
No one can access the servers without a secure pass. A fire warning and extinguishing system is in place. Generators provide protection against power cuts.
All security features : can be found here
1.5 How can you delete your data?
There are several ways to delete your data:
- On your profile page, you can remove the information by deleting it and leaving the fields empty.
- 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 kept for 30 days in case you delete the account by mistake.
What happens when you leave a Steeple customer organisation?
When an administrator deletes access to your organisation 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 change will be communicated to you via a message that appears directly in your news feed.
1.7 Contact us
To contact us, you can use the address, contact@steeple.com or the support chat on the website in the bottom right-hand corner of your screen or the Steeple messaging service.
2. Steeple Good Practice Policy.
In order to ensure Steeple is used correctly, certain rules have to be respected.
2.1 What you should not do when using Steeple
- Use a false identity or a pseudonym, or steal the identity of another person.
- Disseminate content that is illegal, discriminatory, harmful, fraudulent, deceptive or defamatory, or that promotes or encourages violence, the violation of laws, self-harm, eating disorders or substance abuse.
- Disseminate content that is offensive to another member of the community.
- Share your log in details with others.
- Spam the community with promotional content
2.2 How to report abuse
You can report any breach of the Steeple Good Practice Policy directly to the community administrators or directly to the Steeple team, in the support chat or by email to contact@steeple.com.
2.3 Image rights policy
By registering on Steeple, you accept that your image can be disseminated within the closed community. If you disagree, please mention this explicitly to the administrators.
2.4 Steeple SAS accepts no liability whatsoever:
Should Steeple be interrupted due to technical maintenance operations or to update posted information;
If access to Steeple and to the various related communities is temporarily unavailable due to technical problems, regardless of their origin and provenance;
In the event of incorrect information exchanged on the Steeple website between different members;
In the event of damage to or non-return of the equipment loaned on the Steeple website and its various related communities;
In the event the user experiences any direct or indirect damage of any kind as a result of the website’s content or of accessing or using the website (and/or sites linked to the website);
If Steeple is misused or operated illegally. The user of Steeple is solely responsible for any damages caused to third parties and any consequences, claims or action that may arise as a result. The user also waives the right to take action against Steeple SAS should any third party pursue the user as a result of his/her use and/or illegal operation of the website, including partner offers.
If the Steeple member loses his/her login and/or password or if his/her identity is stolen.
3. Intellectual property.
3.1 Copyright and related rights
All the elements that make up the Steeple site (texts, graphics, software, photographs, images, videos, sounds, plans, names, logos, brands, various creations and protectable works, databases, etc.) as well as the site itself, are subject to copyright and related copyright rights (in particular, Articles L122-4 and L122-5 of the Intellectual Property Code) which are governed by French and international legislation. All of these elements are the exclusive property of Steeple SAS. Thus, the user of the Steeple website makes, by accepting the General Terms and Conditions of Use, the following commitments, which prohibit him/her from:
- Using or querying the Steeple website on behalf of or for the benefit of others;
- Using the information, database, services and user profiles on the Steeple website for commercial purposes;
- Reproducing in large numbers, for commercial or non-commercial purposes, the information, the database, the objects, the skills and the profile of the users present on the Steeple website for commercial or non-commercial purposes;
- Incorporating some or all of the content of the Steeple website on to third-party websites for any commercial purposes or other purposes;
- Using a web crawler, in particular a spiderbot, an application for searching or retrieving websites or any other means enabling all or part of the content of the Steeple website to be retrieved or indexed;
- Copying the information on to devices of any kind which may enable the source files to be partially or wholly reproduced.
Any use of elements of the Steeple website that has not been expressly authorised constitutes a violation of copyright and an act of counterfeiting. Such unauthorised use may also lead to a breach of image rights, personal rights or any other rights and regulations in force. This may lead to civil and/or criminal proceedings against the perpetrator. Steeple SAS reserves the right to take legal action and seize any legal proceedings against persons who have not complied with the prohibitions contained in this article.
3.2 Database Producer Rights
Steeple SAS is the producer of the database made up of all the pages and activities on the Steeple website. Within the meaning of Article L 341-1 et seq. of the French Intellectual Property Code. Any extraction or use of the content of the database may incur the civil and/or criminal liability of the perpetrator. Steeple SAS reserves the right to use all legal means at its disposal to pursue any person who has failed to adhere to these prohibitions.
3.3 Trademark rights
The name, Steeple is a registered trademark, owned by Steeple SAS. Any use of this trademark can lead to civil and/or criminal proceedings against the perpetrator. Steeple SAS reserves the right to exercise all legal remedies against persons who infringe its rights.
4. Hypertext link
4.1 Links from the Steeple website
The Steeple site may contain hypertext links to sites belonging to third parties. Steeple SAS has no control over these sites and accepts no responsibility for the access, content or use of these sites, as well as for the consequences and possible damages resulting from viewing the information on these sites. The decision to click on and activate these links is entirely the responsibility of the Internet user.
4.2 Links to the Steeple website
No hypertext link may be created to the Steeple site without the prior agreement of Steeple SAS. If an Internet user or a legal entity wishes to create a hypertext link from their site and to the Steeple website, they must first request this via the contact details of Steeple SAS mentioned in point 2. The application will be examined and the applicant will be informed whether his or her application has been accepted.
5. Cookie policy
Cookies are small text files present in the code of the solution 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 cookies system to facilitate connections
In order to retain your login details and enable you to log in more easily, we use cookies. Without cookies, you would have to enter your log in details whenever you open Steeple and whenever you open a new Steeple page.
5.2 use of the cookies system to improve user experience
In order to better understand how you use the tool, we analyse which elements you find most useful and interesting and identify the functionalities that could be improved.
6. Modification of the General Terms and Conditions of Use
Steeple SAS reserves the right to freely modify the General Terms and Conditions of Use (GTCU) of the Steeple website at any time. Each change to the GTCU will be mentioned to you in your news feed and will appear in the summary sent by email to each registered member.
7. Jurisdiction – Applicable law
The parties shall attempt to resolve any dispute that may arise concerning the validity, interpretation, acceptance and performance of these General Terms and Conditions of Use, regardless of the place of subscription or payment, amicably. These General Terms and Conditions of Use are subject to French law, which determines the applicable law on a case-by-case basis.