PRIVACY POLICY – 5Feedback application

  • General information

 The company 5Feedback (hereinafter “COMPANY” or “5FEEDBACK”) considers the protection of personal data to be of fundamental importance for the conduct of its activities. The personal data of customers and users of the 5 FEEDBACK application (hereinafter “the APP“) are protected and handled with the greatest care, in accordance with the legislation in force.

The COMPANY undertakes to respect your rights regarding the confidentiality of data when you use the APP and communicate with it electronically.

This Privacy and Data Protection Policy (hereinafter the “PRIVACY POLICY“) enables you to learn more about your rights and the origin and use of your browsing information and personal information processed in connection with your use of the APP managed by the COMPANY.

For the purposes of this PRIVACY POLICY, the term “personal data” refers to information that may be used to identify you personally or to contact you online or offline. This information includes your surname, first name, email address, language, position, department and hierarchical level (“personal information”), and the soft skills you possess in the context of your professional activity, when this data is linked to your personal information (collectively referred to as “personal data”).

Before using the APP, please read this PRIVACY POLICY carefully.

Legally, you are not obliged to provide the COMPANY with personal data and here you confirm that you knowingly and freely provide your personal data. By using the APP, you agree to the terms of this PRIVACY POLICY and the collection, analysis and sharing of personal data for the purposes set forth herein.

If you do not agree to the terms of this PRIVACY POLICY, please refrain from using the APP.

The COMPANY reserves the right to modify this PRIVACY POLICY at any time. The COMPANY will inform you of any changes by publishing them in this PRIVACY POLICY. The COMPANY therefore requests that you regularly consult this PRIVACY POLICY to ensure that you are aware of any changes made and how your data may be used.

  • Cookies and other technologies

The COMPANY uses access logs such as cookies, IP address or event logs, in order to collect certain information, including the type of browser and the operating system, the landing page, the browsing pathway through the site, the domain name of the ISP, etc., to improve the use and functionality of its APP, and to better understand how visitors use the APP, as well as the tools and services that it provides. The tracking technologies allow it to tailor the APP to your personal interests and needs.

Subject to obtaining your consent when required by applicable law, the APP uses cookies and similar technologies (“cookies”). Cookies are small files on your device that perform a variety of functions, including allowing you to navigate between pages efficiently, remember your preferences, and generally improve your experience. The use of cookies on the APP gives you greater fluidity during your consultations and assesses the way you move around the APP with more precision.

As a general rule, a cookie contains the name of the website/app from which it comes, the length of time the cookie will remain on the device and a value, usually a unique number generated randomly.

An IP address is a number used by computers on the network to identify your computer each time you are connected to the Internet. The COMPANY may store IP (Internet Protocol) addresses in order to: (i) resolve certain technical issues, (ii) maintain the security of its APP, (iii) restrict its access to certain users, and (iv) better understand how the APP is used.

The COMPANY (or a third party on its behalf) may collect information in the form of an event log that records the activity of the APP and compiles statistics concerning users’ browsing habits. These entries are generated anonymously and can collect, among other things, (i) the operating system and browser type of a user, (ii) information about a user’s session (such as the original URL, the date and time the APP was consulted, the pages consulted on the APP, as well as their duration of consultation) and (iii) other similar data concerning the browsing pathway.

The COMPANY also uses the information contained in the event logs as part of internal marketing and demographic studies, in order to constantly improve and personalise the online services it offers. Event logs are only used internally and are not linked to any particular user.

Among the types of cookies that the COMPANY may use are session cookies, persistent cookies and internal cookies.

  • Session cookies are used to activate certain features of the COMPANY’s and APP’s services, in order to better understand how you interact with the APP and track global usage as well as the routing of Internet traffic. Unlike persistent cookies, session cookies are removed from your computer when you close your browser. Typically, they save an anonymous session ID on your computer, allowing you to browse an Internet site/app (for example) without having to sign in to each page.
  • Persistent cookies are used to back up your login data and remember your settings when you next log in to the APP. A persistent cookie is stored as a file on your computer and is kept there when you close your Internet browser. The cookie can be read by the APP that created it when you browse it again.
  • Internal cookies are the COMPANY’s own cookies, which it uses to improve your experience. They are linked to a user’s personal information. No third party may have access to the information that the COMPANY collects by means of its own cookies.

You will find below a list of the different types of cookies that the COMPANY uses on the APP:

Essential cookies

They are absolutely necessary for the proper functioning of the APP and the use of its services and features.

The COMPANY also uses technical cookies that enable the APP to remember your choices (such as your username, language or country) for personalisation purposes. These cookies do not collect any information about you that may be used for advertising purposes or to remember the pages you have viewed on the Internet.

These cookies are essential for the proper functioning of the APP. You cannot refuse their use.



The APP may also use analytics cookies (such as Google Analytics). These cookies collect information about how you use and navigate the APP.

As an example, these cookies will store the most viewed pages, IP addresses (Internet Protocol), browser type, Internet Service Provider (ISP), landing/exit pages, operation system, time-stamp and browsing pathway.

The COMPANY uses this information to analyse trends, manage the APP, track users’ browsing experience on the APP and collect demographic data about the user base as a whole.

  • Collection of personal data

Personal data is collected only with your consent obtained directly by the COMPANY or through your employer, especially when you first log in and only if you want to access the features and services offered by the APP, for example:

  • Creating a user profile to access the services offered by the COMPANY via its “5Feedback” app;
  • Completion of a soft skills evaluation form for other users of the “5 Feedback” app within the scope of their professional activity following a request for feedback;
  • Any other request requiring the transmission of personal data.

The types and amount of data collected for the features listed above will vary depending on the activity.

The personal data requested includes: surname, first name, email address, language, position, department and hierarchical level. For some activities and in particular the creation of a user profile, you will be prompted to generate and/or modify a password, and/or provide other information, including: (i) the soft skills on which you wish to be evaluated, (ii) your list of contacts to whom you wish to send a request for evaluation and/or (iii) other information about you.

Subject to the requirements of applicable law, the COMPANY may use multiple technologies that collect and provide information about how you view and use the APP, as well as demographic data relating to the APP’s users that can be obtained from third parties such as Google or the social networks you use (“USAGE DATA”). USAGE DATA may include the pages you have viewed, the amount of time you have spent viewing them, the product associated with the information or other content you have viewed, the display language, demographic information relating to you (like your age, gender and interests, if any) and the pages you viewed before arriving on the current page, so the COMPANY can get a better idea of

how its users interact with the APP’s services and features and therefore adapt and improve its services accordingly. In general, most of the USAGE DATA collected cannot be linked to you personally. However, if the COMPANY is able to link it to you, it will then consider it as your data, in accordance with this PRIVACY POLICY.

  • Purposes of the collection of personal data

 As a general rule, all data collected is used for the purposes for which you provided it, or for any other purpose stated at the time of collection or in this PRIVACY POLICY. These purposes are essentially as follows:

  • When you register for the APP: the personal data you provide is used to provide you with the benefits and services associated with the creation of a user profile, including the ability to receive the information and communications selected at the time of registration or automatically associated with your registration (for example: viewing your evaluation results as a dashboard, subscribing to a newsletter, etc.) ;
  • When you used the “Synchronise your contacts” feature: the personal data you provide is used to give you the opportunity to invite your contacts to evaluate you through the “Invite feedback to be created” feature;
  • When you have used the “Request Feedback” feature: the personal data requested for the single-use features (usually names, first names, telephone numbers and/or email addresses) are used just once (for example, to send the request) and are kept until the request to close your account;
  • When you have evaluated one or more users of the “5 Feedback” app: your name and surname may be communicated to the employer of this or these users, for purely statistical purposes, so this employer can find out which people are asked most often by his employees to evaluate their soft skills within the scope of their professional activity;
  • When using a contact form: your data is used to respond to your request or comment.

In addition to the purposes for which you have provided your personal data, you may also have the option (through a tick box or otherwise) to authorise the use of your data for an activity or a service that differs from the activity or initial service you request. If you decide to take advantage of these additional services, the COMPANY will use your data to provide these to you.

The COMPANY may also use your email address to send you transactional or administrative communications (for example, an email when you have used the “5 Feedback” app to evaluate another user or someone has evaluated one of your skills), as well as some service-related notifications (for example, notifications regarding updates to its PRIVACY POLICY, adding or removing features or programs on the APP).

The COMPANY may also use your personal and/or demographic data as part of its internal marketing and research studies, in order to constantly improve and personalise the services it provides, and to better meet your needs.

  • Refusal to communicate personal data

If you decide not to transmit your personal data when requested, you will not be able to access the features offered by the APP.

  • Disclosing personal data

The COMPANY undertakes to treat all the personal data to which it has access as confidential The COMPANY undertakes to obtain the same confidentiality commitments from its personnel and agents who would have or could have access to it in the exercise of their duties.

The COMPANY undertakes never to communicate your personal data to a third party intending to use it for direct marketing purposes, unless you have been expressly informed of this possibility and explicit authorisation has been received from you.

For the purposes set out in Article 4, the COMPANY may transmit your personal data to its subsidiaries, namely companies controlled directly or indirectly by the COMPANY.

The COMPANY may also share your personal data with third parties, but only in the following cases:

  • The COMPANY may use service providers, agents or suppliers to support the internal operations of the APP and help it manage them. These third parties must at all times guarantee the same levels of security as the COMPANY with respect to your personal data and are bound, where appropriate, by a legal agreement under which they are required to maintain the confidentiality and security of your personal data, and to process it only according to the specific instructions of the COMPANY;
  • When the COMPANY launches a joint or co-sponsored service with another company, another organisation or another third party on the APP, and collects and processes personal data in the context of this event, the COMPANY may share your personal data with its partner or sponsor. If your personal data is collected by (or shared with) a company other than the COMPANY as part of this promotion, the COMPANY will inform you of this when your personal data is collected;
  • The COMPANY may also disclose your personal data when required by law or if it considers in good faith that such an action is reasonably necessary to comply with court proceedings, to respond to any claims or to protect the security or the rights of the COMPANY, its customers or the public;
  • In the event of a merger or acquisition of the COMPANY, in whole or in part, by another company or if the COMPANY were to sell or dispose of all or part of its activities, the purchaser would have access to the information obtained by the COMPANY, and in particular to personal data, subject to the laws in force. Similarly, personal data may be transferred as part of a corporate restructuring, insolvency proceedings or other similar event, if permitted by applicable law and in compliance with this;
  • The COMPANY may share global information resulting from surveys or statistical information with third parties. However, this information is anonymous and contains no personal data. The global information shared in this way may include anonymised information collected through the use of cookies and other logs, as explained in Article 2.

The main service providers operating the APP are established in France. The transfer of data to these service providers is based on contractual terms, in accordance with the applicable laws. They are also bound by a contract which guarantees strict privacy protection standards and requires (among other things) that they act only according to the COMPANY’s directives and continuously implement all the necessary technical measures, to preserve the security of your personal data.

  • Duration of retention of personal data

The COMPANY retains your personal data as long as your user profile is active, when it has established a contract with you or, if necessary, to provide you with the services requested, respond to your queries or solve problems, or offer you new and improved services. The COMPANY may also need to keep your personal data for a reasonable period of time and, if necessary, in order to fulfil its legal and regulatory obligations, resolve any disputes, enforce its contracts and for other similar file management purposes.

The COMPANY may therefore keep your personal data for a reasonable period following the cessation of the use of its services or the APP. Beyond this period, your personal data will be deleted from all systems operated by the COMPANY.

If you want the COMPANY to stop using your personal data to provide you services (for example, refusing to receive emails), please contact the COMPANY as indicated in Article 10.

  • Security measures

The COMPANY takes the security of your personal data very seriously.

The COMPANY undertakes to take all the necessary technical and organisational measures to protect the confidentiality and security of your personal data collected on the APP, including your sensitive personal data. This entails: (i) storing your personal data in secure operating environments, only accessible to authorised employees of the COMPANY, as well as its agents and service providers; and (ii) verifying the identity of registered users, before allowing them to consult the personal data that the COMPANY keeps about them.

Employees of the COMPANY who have access to your personal data in the course of their duties, are bound to the COMPANY by confidentiality clauses in this regard.

However, no internet transmission or electronic storage method is 100% secure. Therefore, even if the COMPANY does everything it can to protect your personal data, it does not control the risks related to the operation of the Internet and draws your attention to the possible risks in terms of occasional loss of data or damage to the confidentiality of data transiting via this network. In all circumstances, the COMPANY undertakes to provide notice as soon as possible and, when it can, not later than 72 hours after it has become aware, of any violation of personal data, under the conditions set out in Articles 33 and 34 of Regulation (EU) 2016/679 of 27 April 2016, known as “GDPR”.

  • Links and interactions with third party sites

The APP may allow you to interact with third party sites or may contain links to other sites, mobile app and third party services that are neither owned nor controlled by the COMPANY (each being a “THIRD PARTY SERVICE“). The COMPANY is not responsible for the privacy practices or the content of THIRD PARTY SERVICES. Please note that the THIRD PARTY SERVICE may collect information about you. The COMPANY therefore requests that you read the terms and conditions and privacy policies of each THIRD PARTY SERVICE with which you choose to interact.

  • Right of persons with regard to personal data

You can consult your personal data processed by the COMPANY by directly contacting the appropriate department by email at the following address:

You may request that your personal data is corrected if it appears to be inaccurate, incomplete or out of date, or deleted.

In addition, you always have the option of not disclosing your personal data or opting out of its processing for any legitimate reasons. However, if you choose this option, you will not be able to use the service.

If you do not wish to receive newsletters, notifications or other communication and/or services from the APP, please do not consent to receive such communications or services when you register. If you have agreed to receive these, and subsequently wish to reconsider your decision, please click on the unsubscribe link that appears in all communications.

With each email sent to you, the COMPANY provides you with the option of no longer receiving subsequent communications (in other words, to unsubscribe). Just follow the unsubscribing procedure or instructions contained in the email.

  • Information regarding minors

The APP does not target children who have not reached the age of majority (“MINORS”), but is however not restricted to adults since it does not contain any content prohibited to MINORS.

If the COMPANY is informed that it has collected personal data from a MINOR, the COMPANY will take steps to delete this information as soon as possible.

  • Questions/Contact

 If you have any questions, complaints or comments regarding this PRIVACY POLICY or data collection and cookie management practices, please contact the COMPANY by sending a letter to the COMPANY or sending an email to

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