Privacy policy

VISCONTI DEVELOPPEMENT SAS (hereinafter referred to as "VISCONTI") specializes in, among other activities, the selection, training, management, and promotion of a network (hereinafter the "VISCONTI Network") of independent partners (hereinafter the "VISCONTI Coaches") who provide, under the "VISCONTI" brand, coaching, consulting, and leadership training services (hereinafter the "Coaching Services").

The Coaching Services provided by VISCONTI Coaches are primarily intended for individuals acting on behalf of corporate entities (hereinafter the "Clients").

To facilitate the monitoring of the Coaching Services provided by VISCONTI Coaches and to support the promotional efforts of the VISCONTI Network, VISCONTI has implemented an automated customer relationship management tool (hereinafter "CRM") designed for use by both VISCONTI and VISCONTI Coaches.

VISCONTI Coaches are encouraged to input certain information into the CRM regarding the Clients to whom they have provided Coaching Services.

VISCONTI Coaches are also encouraged to enter into the CRM relevant information about individuals or entities that have expressed interest in receiving Coaching Services (hereinafter the "Prospects").

VISCONTI Coaches use the CRM to track the Coaching Services they provide to Clients and to conduct promotional activities directed at Prospects.

VISCONTI uses the CRM to manage the institutional promotion of the VISCONTI Network and to monitor the activities of VISCONTI Coaches.

Each VISCONTI Coach is bound by a contract with VISCONTI, which specifically outlines the conditions under which the confidentiality of data related to Clients and Prospects (hereinafter the "Collected Data") must be maintained.

Each VISCONTI Coach is also bound by a contract with the Client, which defines the terms under which the confidentiality of the Collected Data concerning them must be preserved (hereinafter the "Coaching Contract").

The purpose of this Privacy Policy is to inform Clients and Prospects about how VISCONTI and VISCONTI Coaches directly or indirectly collect, process, and store their Collected Data.

By using the services of VISCONTI Coaches or VISCONTI, Clients acknowledge that they have read and accepted the terms of this Privacy Policy

Data Controller

The Collected Data used within the CRM is processed by:

  • The VISCONTI Coach, who originally collects the Collected Data from the relevant Clients and Prospects and enters it into the CRM.
  • VISCONTI DEVELOPPEMENT, a simplified joint-stock company (SAS) with a capital of €50,000, headquartered at 9, avenue Marceau, 75116 Paris, registered under No. 477 865 109 RCS Paris.

Collected Data

The Collected Data includes, depending on the case:

1. Identification Data

These are data points used to identify Clients and Prospects (hereinafter the "Identification Data"):

  • For Clients:
    • Company name
    • Registered office address
    • Phone number
    • Revenue size
    • Industry sector and spoken language
    • Name, first name, business email address, and professional landline or mobile phone number of individuals involved in the Coaching Services
  • For Prospects:
    • Name and first name of the individual representing the Prospect
    • Business postal address
    • Business email address
    • Professional landline or mobile phone number
    • Spoken language

2. Coaching Data

These are data points used to measure the scope of Coaching Services provided to Clients by the respective VISCONTI Coaches (hereinafter the "Coaching Data"):

  • Identity of the VISCONTI Coach linked to the Client through a Coaching Contract
  • Duration of the Coaching Contract
  • Type of Coaching Services provided
  • Currency and invoiced amount

All Collected Data related to a Client or Prospect is stored in the CRM and associated with the VISCONTI Coach who collected and entered it or with VISCONTI itself. Duplicate records are regularly removed by VISCONTI based on the frequency of contact made with the relevant Client or Prospect by their associated VISCONTI Coaches

Exclusion of Specific Data

The Collected Data does not include any information provided by the Client to the VISCONTI Coach in the course of executing the Coaching Contract, such as commercial, organizational, financial, operational, or marketing data, or any other information exchanged during the Coaching Services in any form or on any medium (hereinafter the "Specific Data").

Specific Data is not integrated into the CRM in any way and remains subject to a strict confidentiality commitment by the relevant VISCONTI Coach. The VISCONTI Coach is expressly prohibited from disclosing any Specific Data to any third party, including VISCONTI and other VISCONTI Coaches.

Purposes of Data Processing

Only Identification Data and Coaching Data are processed through the CRM, strictly excluding Specific Data.

1. Use of Identification and Coaching Data for Coaching Services

The Identification Data and Coaching Data of Clients are used exclusively for the provision of Coaching Services by VISCONTI Coaches, in accordance with the terms of the contract between the VISCONTI Coach and the Client.

2. Use of Identification Data for Commercial and Communication Purposes

Subject to the consent of the Clients and Prospects concerned, their Identification Data may be used for the following purposes:

  • Commercial prospecting operations conducted by:
    • The VISCONTI Coach who collected the data
    • Other VISCONTI Coaches
    • VISCONTI
  • Communication and marketing activities organized by VISCONTI, including:
    • Sending newsletters, brochures, and informational materials
    • Organizing conferences, informational meetings, and events
  • Managing requests for data access, rectification, objection, and processing preferences related to Identification Data.

3. Use of Coaching Data for Service Monitoring and Statistical Analysis

Subject to the consent of the Clients concerned, their Coaching Data may be used for the following purposes:

  • Service tracking by the VISCONTI Coach who collected the data, to ensure effective follow-up of the Coaching Services provided to the Client.
  • Monitoring by VISCONTI of the activities within the VISCONTI Network and the Coaching Services delivered by VISCONTI Coaches.
  • Statistical analysis by VISCONTI to assess and improve the performance of Coaching Services provided by VISCONTI Coaches.

Data Retention

1. Retention of Client Data

  • Identification Data and Coaching Data related to Clients, used for the provision and monitoring of Coaching Services by the VISCONTI Coach who collected them, are retained in the CRM for the entire duration of the Coaching Services provided by the respective VISCONTI Coach.
  • Identification Data and Coaching Data related to Clients will be retained for commercial prospecting and communication purposes for up to three years after the expiration or termination of the Coaching Services, subject to the Client's consent.

2. Retention for Legal and Compliance Purposes

  • Collected Data that serves as evidence of a right or is retained for legal compliance will be stored in an intermediate archive for a period not exceeding the duration necessary for the purposes for which they are kept, in accordance with applicable regulations.

3. Retention of Prospect Data

  • Identification Data related to Prospects will be retained in the CRM for a period of three years from the date of collection, subject to the Prospect’s consent.

4. Data Storage Location and International Transfers

  • The Collected Data is stored exclusively in France or within the European Union (EU).
  • Some technical service providers may be located in countries that do not offer an equivalent level of personal data protection as the EU.
  • In such cases, VISCONTI ensures that any data transfer is governed by contractual commitments with its technical service providers, requiring them to implement sufficient safeguards to protect the Collected Data.

Confidentiality

CONFIDENTIALITY OF COLLECTED DATA

The Collected Data (Identification Data and Coaching Data) is accessible only to the following individuals and entities, excluding any other third parties:

  • VISCONTI Coaches
  • VISCONTI
  • VISCONTI’s technical service providers, including the provider operating the CRM on behalf of VISCONTI

VISCONTI ensures that all VISCONTI Coaches and technical service providers strictly comply with applicable European Union data protection regulations and fully adhere to the obligations set forth in this Privacy Policy.

CONFIDENTIALITY OF SPECIFIC DATA

Specific Data is collected individually by each VISCONTI Coach as part of the provision of Coaching Services and is subject to the strictest confidentiality standards.

Each VISCONTI Coach commits, notably under the Coaching Contract, not to disclose or share Specific Data with any third party, including other VISCONTI Coaches and VISCONTI itself.

Right of Access – Modification – Deletion

In accordance with the General Data Protection Regulation (GDPR), any individual whose data is collected within the CRM has the right to:

  • Access their data or request its deletion (subject to compliance with applicable legal requirements).
  • Object to data processing, request corrections, or seek restrictions on the processing of their data.
  • Exercise their data portability rights, as recognized under the GDPR.

How to Exercise Your Rights

Requests regarding data access, modification, deletion, or any other GDPR-recognized rights must be submitted:

Any individual whose data is collected within the CRM also has the right to file a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés), the French data protection authority.