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Privacy lemwarm


Publisher: The website https://blog.lemwarm.co/, https://help.lemwarm.co/, and https://lemwarm.co/ 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.lemwarm.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

lemwarm Privacy Policy

as of June 7th, 2023

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 organizationalmeasures in place respect your data protection rights.
This Privacy Policy describes how we manage, process and store personal data submitted in the context ofproviding our services. “Personal data” refers to any informationrelating to an identifiable individual or his or her personal identity.It appliesto the processing of personal data carried out on lemlist.com and completes the legal notice and the General Conditions of Use that canbe consulted by users at the following address.


We use the personal datasubmitted to us only in accordance with Regulation (EU) 2016/679 of 27 April2016 on the protection of natural persons with regard to the processing ofpersonal data and on the free movement of such data (the "GDPR")and the French Data Protection Act of 6 January 1978 (referred together as the“Applicable Regulation”).


When you subscribe to our services, the following data is collected and managed : First name, last name, email, phone number, Intra-community VAT number (whenapplicable), mailing address, country, IP address(es) and domain name, login,password.

By using our services, the following data is collected and managed : log-in data and browsing data when youauthorize it, order history, complaints, incidents, information onsubscriptions and messages on our site.  

Some data is collected automatically by reason of your activity on the site(see paragraph on cookies below).

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


Your personal data is processed to meet one orseveral of the followingpurposes. Each purpose is associated with a legalbasis, the list of which canbe found below.

Based on our legitimate interest ofoffering 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.
- To sign up to our newsletters, use case studies and marketing material.

On the performance basis of a contract to which you are a party, we carry out processing operations for the following purposes:
- To provice our services.
- To facilitate performance, including verifications relating to you.

On the bases of your consent, we carry out processing operations for the following purposes :
- To use cookies, as described in our cookies policy.

Based on the compliance with our legalandregulatory 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.
- To answer to exercise of rights.


Personal data relating to you collected on ourwebsite are destined for lemlist’s own use and may be forwarded to lemlist’spartner companies so that we may obtain assistance and support in the contextof carrying out our services. lemlist ensures that it has in place clear dataprotection requirements for all its third-party providers. We do not sell or rent your personal data tothird parties for marketing purposes whatsoever.In addition, lemlist does not disclose yourpersonal data to third parties, except if: you (or your accountadministrator acting on your behalf) requests or authorized disclosure thereof.the disclosure is required toprocess transactions or supply services which you have requested (i.e. to checkyou are employing best practices in your mailings or for the purposes ofprocessing an acquisition card with credit-card issuing companies) ; lemlist is compelled to do soby a government authority or a regulatory body, in the case of a court order, asummons to appear in court or any other similar requisition from a governmentor the judiciary, or to establish or defend a legal application ;or the third party is asubcontractor or sub-processor of lemlist in the carrying out of services(lemwarm uses the services of an Internet provider, a telecommunicationscompany, a host provider, CRM tools, customer support client tools, invoicestools, payment tools, analytics tools).


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.

If you exercise your right to object to direct marketing: we keep this information for 3 years.

The information allowing the management of your requests to exercise your rights under the GDPR will be kept for 3 years from the date of the request


The host serverson which lemlist processes and stores its databases are located exclusivelywithin the European Union.Regarding thetools we use (see article “Third party disclosures” on recipients of thecollected data, concerning our processors), your personal data could betransferred outside the European Union. The transfer of your data within thisframework is secured by the following safeguards: 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.


Within the framework of its services, lemlistattributes the very highest importance to the security and integrity of itscustomers’ personal data.Thus and in accordance with the GDPR, lemlistundertakes to take all pertinent precautions in order to preserve the securityof the data and, in particular, to protect them against any accidental orunlawful destruction, accidental loss, corruption, unauthorized circulation oraccess, as well as against any other form of unlawful processing or disclosureto unauthorized persons.To this end, lemlist implements industry standard security measures toprotect personal data from unauthorized disclosure. Using industry recommendedmethods of encoding, lemlist takes the measures necessary to protectinformation connected with payments and credit cards.Moreover, in order to avoid in particular all unauthorized access, toguarantee accuracy and the proper use of the data, lemlist has put theappropriate electronic, physical and managerial procedures in place with a viewto safeguarding and preserving the data gathered through its services.Notwithstanding this, there is no absolutesafety from piracy or hackers. That is why in the event a breach of securitywere to affect you, lemlist undertakes to inform you thereof without unduedelay and to use its best efforts to take all possible measures to neutralizethe intrusion and minimize the impacts. Should you suffer any loss by reason ofthe exploitation by a third party of a security breach, lemlist undertakes toprovide you with every assistance necessary so you are able to assert yourrights. Moreover if, by some exceptional case, the direct loss incurred arosedue to fault or gross negligence by lemlist, you will be able to seekcompensation within the limit of liability referred to in our Terms ofUse.You should keep in mind that any user, customer,or hacker who discovers and takes advantage of a breach in security renders himor herself liable to criminal prosecution and that lemlist will take allmeasures, including filing a complaint and/or bringing court action, topreserve the data and the rights of its users and of itself and to limit theimpacts.


          In accordance with the French Data ProtectionLaws and the European General Data Protection Regulation 2016/679 (GDPR) you haveseveral 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 withdraw your consent at any time: for purposes based on consent, Article 7 of the     GDPR provides that you may withdraw your consent at any time. Such     withdrawal will not affect the lawfulness of the processing carried out     before the withdrawal. 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.For those of you that have expressly opted in to receive our lemwarm newsletters and emails, youare easily able to unsubscribe by following the “unsubscribe” links included in every email sent.

          How to exercice your rights : You can exercise these rights by sending us asupport ticket directly on the support chat (either on the website or on theapp) or, by sending an email at privacy@lempire.com. Your requests will beprocessed within 30 days. We may require that your request be accompanied by aphotocopy of proof of identity or authority.You are also able at any time to modify personaldata by logging into your account and navigating to “User Settings”.

          Right to refer to the supervisory authority :If you believe, after having contacted us, thatyour rights on your data are not respected, you can address a complaint to thecompetent Supervisory authority of your country of residence.In France, where our head office is located, thecontrol authority is the CNIL.

          Newsletters and marketing emails :

          For those of you that have expressly opted in toreceive our lemwarm newsletters, you are easily able to unsubscribe byfollowing the “unsubscribe” links included in every email sent.

          Testimonials : lemwarm publishes a list of Customers &Testimonials on its sites with information on our customers’ names and jobtitles. lemlist undertakes to obtain the authorizationof every customer before publishing any testimonial on its websites. If you wish to be removed from this list, youcan send us an email to privacy@lempire.com and we will deleteyour information promptly.

          Third party data : In the context of using our services, namelycreating emailing campaigns and contact lists, lemwarm has access to theinformation contained in the email contact lists you create in your account, aswell as the subject and content of the emails that you send out via ourservices.This data is stored on secure servers and only alimited number of people are authorized to access your contact lists, inparticular for the purpose of providing support services.You are easily able to recover your contactlists 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 youraccount.In no case does lemlist sell, share or rent outyour contact lists to third parties, nor does it use them for any purposesother than those set forth in this policy. We will use the information fromyour contact lists only for legal requirements, to invoice and collectsummaries for our own statistics and for the purposes of providing you withcustomer support services.As creator of the contact lists and associatedemail campaigns, you are considered the data controller within the meaning ofthe GDPR, and lemlist is acting only as a data processor. In thiscapacity, 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 ourservices requests us to modify or delete his/her personal data, we will honorthat request after proper verification and will inform you of it.


          lemlist reserves the right to update this Privacy Policy at any time, inparticular 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 intoforce. We would recommend that you check these rules from time to time to stayinformed of our procedures and rules relating to your personal information.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 lemwarm which you open to assessperformance rates on your emailing campaigns.

          CONTACT US

          If you have questions, you can email at Data Protection Officer directlyat: privacy@lempire.com or by mail to: lempire SAS, Attn: Data Protection Officer / Legal Department, 128rue La Boétie, 75008 Paris, France. and we will delete your informationpromptly.