Here are the various actions we have put in place to help you comply with the GDPR.
The General Data Protection Regulation (GDPR) is a new set of legislation that aims to strengthen the protection of EU citizens' personal data while reinforcing the obligations of organizations to process such data in a transparent and secure manner. The GDPR applies not only to companies established within the EU but also to any company controlling or processing EU citizens' data.
At iAdvize, starting in 2017 we have created a dedicated GDPR team to work on improving our processes and our solution to help you be GDPR compliant.
This page is the place where you will find all the information about iAdvize product updates related to GDPR.
1. What information and data do we collect?
1.1 Visitor data collected BEFORE chat (functionality cookies):
Data collected
- The Visitor Unique Identifier (VUID) through cookie
Data associated with a visitor and stored in the visitor’s browser
The data are not collected through cookies but are associated with the VUID.
Purpose: Processing these data help ensure that the targeting rules are working properly
These are examples of targeting criteria that can be taken into account by the client to refine its targeting strategy:
- The number of pages viewed by the visitor (Page View)
- The Date/time of the new session (Connection Time)
- Browser language to contextualize the chat language (Lang)
- Duration of Navigation on the site (NavTime)
1.2 Data collected DURING the chats:
The visitor has validated the RGPD consent request at the beginning of the conversation.
User identification data:
- Surname, first name, alias, username
- Position held within the Customer
- Log in data, logs: Access-token (platform login credentials), refresh_token (platform login credentials), Platform (platform concerned)
Visitor’s data:
- Chats (number of chats, duration, date, response to satisfaction survey)
- Visitor's IP address
- If transmitted by the visitor: email address, phone number, identity
2. For what purpose(s) is the Data collected?
iAdvize User identification data: Collection of Users' personal data for management and authentication purposes.
Visitor Login Data: Collection of personal data from Visitors to e-commerce sites during real-time conversations between customer advisors and Visitors, via a conversational platform of engagement and customer relations.
Visitor Conversations: Collecting Visitor conversations to enable e-commerce site agents to interact directly with Visitors.
Visitor Trackers/Cookies: Data collection to provide Visitors with a conversation window.
3. How long is the Data retained?
The length of time conversations and associated data are stored varies depending on the channel used:
- Chat/Social media: 3 years (by default – unless the Customer specifies another duration) in active database
- Call/SMS: 12 months in active database
- Temporary archive: The retention of the temporary archive is 5 years. Stored personal data can no longer be processed by the operational services. They are now stored only for litigation purposes and are subject to restricted access (3 AWS Administrators at iAdvize + VP Engineering).
NB : The video stream is not recorded.
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TEMPORARY ARCHIVE
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Legal basis: Legal obligation to retain the data or legitimate interest of the data controller (interest in retaining evidence) for the duration of the applicable limitation/foreclosure period.
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Purpose: Personal data stored in this way can no longer be processed by iAdvize operational services. They are now stored only for litigation purposes and are only accessible to a limited extent.
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Retention Period: 5 years
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Storage: Amazon Web Services - Servers located in the Dublin area (Ireland)
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Restrictive access: Only AWS administrators at iAdvize (3 people) + VP Engineering
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Data Encryption: All data is encrypted - AES 256 Key
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Data access: The access is made only in 2 cases:
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4. Anonymization and deletion of Data :
At the end of the retention period of the conversations, only personal data is deleted and we save the anonymized data.
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Deleted
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Anonymized
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IP address of the Visitor
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Aggregate statistics
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Contain of the chat conversations
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The personal data contained in the Visitor file
E.g.: First name/last name; Email address; phone number…
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Call conversations
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5. Who has access to the Data?
The persons having access to the Data are the following:
- Users: There are three types of profiles: Advisor; Manager; Admin and, if applicable, ibbü Experts.
The Admin profile has access to the full iAdvize Solution:
- Consult all the Data stored in the Solution (Performance, KPIs, Conversations)
- Create/delete/modify profiles: a new Admin, a Manager, an Advisor, a bot
- Modify your account settings, for example: activate/deactivate the GDPR consent request, modify the rules of engagement of your visitors, modify the UX of your chatbox and chat notification, ...
The Manager profile only has access to the reports and advisers that are part of his group :
- Consult all the reports but with only the data of his group of respondents (KPI, conversation history,...)
- Create/delete/modify Advisor profiles that can only be associated to his group.
The Advisor / Expert profile only has access to the chat room.
- iAdvize support team
6. Is the Data shared with third parties?
No. Your personal data will not be passed on to third parties under any circumstances.
7. Where is the Data stored?
Chat conversations: the Data is hosted within the European Union (Frankfurt (Germany) with backup in Dublin (Ireland)) in accordance with the data processing contract signed with our service provider, AWS.
Calls: The Data is stored in the United States for the duration of the conversation. At the end of the call, the Data is deleted from the servers in the United States and then transferred to and hosted on AWS servers in the Frankfurt (Germany) area with backup in Dublin (Ireland).
SMS: the Data is hosted in the United States, in accordance with the data processing contract signed with Twilio.
For Social Networks (Facebook, Messenger, Twitter, WhatsApp): Clever Cloud, Paris region (France).
For Third Parties (Facebook, Messenger and Twitter) host them within the European Union (Ireland) and the USA (see special conditions relating to the protection of privacy defined by these third parties).
For videos: the metadata is hosted within the European Union (Frankfurt (Germany) with backup in Dublin (Ireland)) in accordance with the data processing contract signed with our service provider, AWS.
NB : The video stream is not recorded (peer-to-peer between agents and visitors).
Invalidation of the Privacy Shield on 16/07/2020 by the JCEU :
According to the decision of the JCEU, to ensure the compliance of a transfer from the EU to the USA, the exporter must ensure that the importer has put in place the best guarantees (appropriate technical and operational measures).
iAdvize has taken the following actions to ensure an adequate level of protection for data transfers:
- We have signed a Data Processing Agreement with our subcontractors which includes standard contractual clauses as validated by the JCEU.
- We have verified the numerous security measures implemented by our subcontractors, such as ISO 27001 certification or data encryption.
- We have also kept all of our subcontractors' technical white papers detailing these technical measures.
- As a reminder, our Customers' Data is well hosted in AWS Europe data centres in Frankfurt (Germany), with backups in Dublin (Ireland).
8. Privacy by Design
The iAdvize Solution is developed using a "Privacy By Design" approach to ensure the compliance of Personal Data processing. It consists in adapting appropriate organizational and technical measures from the project design stage and by default, to guarantee the protection of privacy and fundamental freedoms.
For example, the iAdvize Solution includes advanced confidentiality features that allow :
- hide form fields that the Customer considers sensitive (e.g. credit card number in a payment area on the Customer's site) in the Advisor console by adding the code "idz_hide" to the field in question; or
- to disable the mirroring feature (possibility for the Advisor to view the content of the page on which the Visitor is located);
It is up to the Customer, as data controller, to enable or disable these security features made available to it. These functionalities are described in the technical implementation documentation of the iAdvize Solution and in the iAdvize knowledge base to which the Customer has access.
9. Data Processing Agreement
The iAdvize contracts include a Data Processing Agreement as an appendix.
When you work with suppliers who will process personal data (customers, prospects, employees, ...) in the context of providing services, it is mandatory to conclude a Data Processing Agreement or DPA.
In the context of the GDPR, the implications are as follows:
- You, as Customer, are responsible for the processing (data controller) of these data. In particular, you decide which data is processed, what you do with it and why you use it. The GDPR provides this role with a series of obligations and responsibilities;
- In this context, iAdvize is the subcontractor (data processor) of this data. iAdvize processes your data solely on your behalf.
The GDPR requires all data managers and data processors to sign a DPA.
In addition to the fact that the DPA is required by law, the signature of this agreement is important for both parties.
10. Functionality Request of consent
11. Chat preview - Mirroring - Cobrowsing
- Preview of the chats:
This is the feature that allows an Agent to preview and thus anticipate the question of the Visitor on the Brand's website. This feature is only activated when the Visitor expressly agrees to chat with the Agent.
- Mirroring:
This is the feature that allows the Agent, when chatting with a Visitor, to view the page he is browsing in the background of his desktop.
The Visitor's consent to Mirroring is linked to the GDPR consent (when the consent feature is enabled): Thus, when the Visitor gives his consent to chat, he gives his consent to mirroring at the same time.
iAdvize collects proof of the Visitor's consent and can provide it upon request.
- Cobrowsing:
This is the feature that allows the Agent, when chatting with a Visitor, to take control of the Visitor's navigation to guide him through the site.
The Agent can ask the Visitor to take control of his navigation. This request is displayed in the discussion thread of the dialogue window on the Visitor's side, and is the subject of a specific consent form. The Visitor can thus accept or refuse the request to take control of his navigation.
The Visitor has the possibility to end the grip as soon as he closes the dialogue window on his side.
The Visitor has the possibility to end the grip as soon as he closes the dialogue window on his side. For more information: Viewing or taking control of the visitor's navigation (mirroring / cobrowsing)
The Visitor has the possibility to end the grip as soon as he closes the dialogue window on his side. For more information: Viewing or taking control of the visitor's navigation (mirroring / cobrowsing)
Related Articles: Request the deletion of personal datas
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