Privacy Policy

Holaspirit (the “Platform”), is a web platform that is accessible at, and is operated by Holaspirit, a French Joint Stock Company; share capital: 40,000 euros; registered address: 72, rue du Faubourg Saint-Honoré 75008 Paris, France; registered in Paris, France under number 818 592 511 (the “Company”).

The users of the Platform (the “ User(s) ”) can access a number of functionalities to manage governance issues and other related services (the “Service(s) »). They are given access to the Platform by a client of the Company that has signed a specific contract for services with the latter (the “Organisation”), for the entire duration of this contract, save in case of restrictions imposed by the Organisation itself.

In order to access the Platform, Users must disclose some personal data about themselves. The protection of your personal data is an absolute priority for the Company. The Company has accordingly adopted this Privacy Policy in order to preserve your trust.

All the personal data that you disclose to the Company shall be processed in accordance with this Privacy Policy and shall be governed by our General Terms of Use

1. The collected data

​In order to enable the Users to make the most of the Services and functionalities of the Platform, the Company collects various elements of information. Please note that by registering on the Platform, you implicitly agree to this information being gathered, whatever the country from which you are connecting. Moreover, any data that you disclose to the Company is disclosed on a purely voluntary basis. You have the option to oppose its gathering at any point in time, in accordance with the General Terms of Use of the Platform and this Privacy Policy, by configuring your parameters or by asking the Organisation to close your account, bearing in mind that the withdrawal of your consent shall not operate retroactively.

This data is gathered at various points in time using various methods :

The collected data

In order to become a User, you must provide some personal data, such as your first name, family name, e-mail address, password. Without this minimum of information, it is not possible to create an account. Unless you decide to share your governance in public and except the email and password, this data is only accessible to the other Users who are registered with the Platform of the Organisation using their personal email and password.

Using the Platform

When you use the Platform, the Company’s servers automatically record the information that is created and exchanged while using our Services. For instance, the Company is aware of all of your session data.

Log files, Internet Protocol (IP) address and information concerning your computer

When you connect to the Platform, the Company receives the link of the web site from which you reached the Platform, and it also receives the link that you follow upon leaving the Platform.

The Company also receives your IP address and information concerning the operating system of your computer and its web browser.


The Platform uses cookies, just like the vast majority of web sites. Cookies are small data files that are stored on the hard disk of your computer and that can be used to identify you as a User when you connect to the Platform. They enable you for instance to avoid having to key in your password whenever you connect to the Platform. You can however deactivate the use of cookies by modifying your preferences in your web browser. In that case, it is likely that some of the functionality of the Platform will no longer work.

Internet tags

We may occasionally use Internet tags (also known as "tags", or action tags, one-pixel GIFs) and deploy them through a specialized partner. These tags are placed both in online advertisements allowing you to access the website. This helps to evaluate the visitors' responses to the site and the effectiveness of its actions (for example, the number of times a page is opened and the information accessed). The external service provider may collect information about visitors to the site, compile reports on the site's activity.

2. Retention of the collected data

Once collected, data are stored on the servers of the Company or of a subcontractor of the Company with a view to processing it in connection with the use of the Services. It is kept for as long as necessary for the provision of the Services and functions offered by the Platform to the Organisation and for a period of seven (7) days following the termination of the contract between the Company and the Organisation, whatever the reason for this.

You shall at all times retain ownership over all personal data concerning you that you transmit over the Platform. In accordance with France’s data protection law no. 78-17 of 6 January 1978, as subsequently modified by law no. 2004-801 of 6 August 2004 , Regulation EU 2016/679 of 27 April 2016 and GDPR (General Data Protection Regulation), you shall therefore have a right to access, rectify, limit the processing and/or request the erasure of your personal data, as well as the right to oppose said processing and a right to request the portability of your personal data. To exercise your rights, please write to the Organisation at its address, which is shown in the page entitled “about” of the Platform, once connected using your personal access identifiers.

The processing of your personal data by computer has been declared to France’s CNIL under no. 1909920. You have the right to file a complaint for violation of your data protection rights with this regulating body.

3. Use of the collected data

The data that is collected shall be used to enable you to use the various services on offer on the Platform. When you create your account, you voluntarily and expressly accept the General Terms of Use of the Platform and this privacy policy that authorise the Company to process your data.

Because the Company considers the protection of your personal data to be vital, it undertakes not to sell, loan your personal data or make it available in any way whatsoever, except under the terms that are described in this privacy policy and in the General Terms of Use. of the Platform. However, there are a number of circumstances in which the Company may disclose or share your personal data with third parties, including:

  • with your express or implied consent;
  • in order to comply with the law, the prevailing rules and regulations, any legal proceedings, court rulings, or in any other case where disclosure is mandatory;
  • in order to protect the rights, the property or the security of the Platform, of its members or of the public;
  • as part of the provision of the various Services and functionalities proposed on the Platform, but only when this is necessary for the performance of its operations and the provision of these Services and functionalities.

4. The role played by the Company

When it comes to the processing of personal data, the Company shall merely act as a data processor of the Organisation, as per the definition of this term in Regulation EU 2016/679 of 27 April 2016.

Therefore, the Organisation alone shall determine the purposes and the means of the processing the Users’ personal data. The personal data shall only be processed by the Service Provider based on the written instructions of the Organisation, including with regards to any transfers of personal data to a third country or to an international organisation, unless the Service Provider has an obligation to process the data under EU law or the applicable national law; in that case, the Service Provider shall inform the Organisation about this legal obligation before starting the processing, unless the obligation involved prohibits any disclosure for important public interest reasons.

5. Your obligations

As a User of the Platform, you must comply with the obligations arising from this privacy policy and the General Terms of Use of the Platform, in addition to the applicable statutory and regulatory obligations.

The Company moreover calls upon you to act responsibly, bearing in mind that the Users are alone responsible for the information and content that they disclose, including information concerning racial origins, ethnic background, sexual orientation, political opinions, religious or philosophical beliefs, affiliation to a trade union or any health-related information.

6. Protection of minors

In order to protect minors, the User must be aged 18 or over and must have full legal capacity.

7. Security

In order to protect your personal data, the access to your account is protected by a password that you must keep confidential. You should immediately inform the Company in case of unauthorised use of your account or any breach of the confidentiality and security of your identifiers.

The Company shall take all reasonable measures to protect your data against any loss or misuse, and unauthorised access, disclosure, modification and destruction. Various hardware and software processes have been implemented in order to ensure the protection of your personal data.

8. Modification of the privacy policy

The Company shall be entitled to modify, amend or replace the provisions of this privacy policy. In case of a significant modification, the Company undertakes to display a notification on the Platform to inform Users about the changes made to the privacy policy.

9. Contact details

Should you have any questions, comments, suggestions or complaints, please contact Holaspirit SAS.