Data controller
Scale4win — SIRET 517 789 525 00022 — 59 boulevard Henri Dunant, 91100 Corbeil-Essonnes, France. Contact: contact@scale4win.fr.
Data collected on the site and purposes
- Contact form (Company page): name, e-mail, company, phone, message. Purpose: answering your request. Legal basis: our legitimate interest in answering requests sent to us and, where applicable, pre-contractual steps taken at your request.
- “Free audit” form: name, business e-mail, company, role, test tool, message, date of your consent and, if you attach it, your specification (PDF or DOCX, 10 MB maximum). Purpose: carrying out the audit and contacting you. Legal basis: your consent, which you may withdraw at any time by writing to contact@scale4win.fr. The specification is kept in our application, accessible only to the Scale4win team (administrator and sales staff), to carry out the audit; before any AI analysis, its personal identifiers are replaced (see below). As soon as you attach it, the form analyzes it in memory to show you the personal data that will be replaced: nothing from this analysis is kept. You can also download the anonymized document, free of charge and without sending a request: it is produced in memory by the same rules, without any call to AI, and nothing of it is kept; its layout is the original one, the data detected is covered, including in the images it contains (screenshots), read by character recognition on our servers. The data you add yourself to the “to anonymize” list (names, your client's name, project codes…) is sent to us with the request and will only be used to anonymize your company's documents.
- Report of an undetected type of data (audit form): name of the data and a format example, which we ask you to make up. Purpose: improving the anonymization tool. The report is kept by Scale4win until it is processed; it must not contain any real data.
- Online orders: e-mail, company, chosen offer and number of users. Purpose: fulfilling the order, creating your account and invoicing. Legal basis: performance of the contract. Payment is processed by Stripe: Scale4win does not receive your card details.
- Platform user account: name, e-mail, role, company, and a log of actions performed (traceability and security). Legal basis: performance of the contract and our legitimate interest in securing the service.
Messages from the contact form are sent to us by e-mail; they are stored neither on the server nor in a database of the site, except for messages sent to a community manager in the PostOkee directory (see below). Audit requests are recorded in our application so that we can follow them up, and are also sent to us by e-mail, with the specification attached.
Documents processed in the platform
Documents and data uploaded by our customers to the platform are processed on their behalf and according to their instructions: Scale4win then acts as a processor within the meaning of Article 28 GDPR, under section 15 of the terms of use. Before any call to an AI model, the following are automatically replaced: social security numbers, patient and case identifiers, FINESS numbers, e-mail addresses, phone numbers, dates of birth, IBANs, bank card numbers, IP addresses, passport and ID card numbers (including the name fields and machine-readable zone of an ID document), person names preceded by a title or a common first name (and every other occurrence, in the same document, of a name so detected), the names, postal addresses and phone numbers held in the named fields of an SAP flow example (IDoc, XML: NAME1, STREET, CITY1, TEL_NUMBER…), answers to questions on disability recognition (RQTH, BOETH), and the data specific to each customer company. This automatic detection is not guaranteed to catch everything. Only a company using an AI model installed on its own infrastructure can switch this replacement off. The AI provider is chosen by each customer company among those offered by the platform, or replaced by a model installed on its own infrastructure. Software vendors' release notes processed by Change synthesis are not pseudonymized: they must not contain personal data.
MailAgent: data from your Gmail mailbox and imported files
The online version of Scale4win MailAgent (/mailagent) lets you connect your Gmail mailbox, or import e-mails and documents, and query them in plain language. This section describes what we do with this data.
- Permission requested:
gmail.modify(read and search your messages, label them, move them to trash, create drafts and send messages). It is the narrowest Google permission covering these uses. It does not allow permanent deletion of a message. - Use: only to answer the requests you make in MailAgent, when you make them. No change to your mailbox (labelling, trash, sending) is made unless MailAgent has first shown it to you and you have confirmed it.
- What is kept: your Gmail address; the long-lived access token provided by Google, encrypted (AES-256) and never sent to your browser; your conversations with MailAgent (your questions, its answers and the list of actions performed), 10 at most, which you can delete at any time; your access request, if any (Gmail address, dates, answer). Your Gmail mailbox is not copied to Scale4win: its content is read again from Google for each question. A conversation keeps your questions and MailAgent's answers, which may quote excerpts of your messages, as well as the table used to restore masked names and numbers (see “Artificial intelligence”).
- Imported files (.eml, .msg, PDF, Word, Excel, text…, 25 MB and 20 files per conversation at most): they are read in memory and never stored as such. Only the text extracted from them (with, for an e-mail, its sender, recipients, date and subject) is kept, attached to the conversation, and deleted with it. It is only used to answer your questions in that conversation, read-only. Only import files you are entitled to process.
- Artificial intelligence: to answer, the relevant excerpts of your messages are sent to the AI model selected by Scale4win for MailAgent among its providers (Anthropic, Mistral AI, Microsoft Azure OpenAI or a model hosted by Scale4win), after e-mail addresses, sender and recipient names, person names detected in the text, phone numbers, IBANs, card and social security numbers, dates of birth, ID document numbers, patient identifiers and the terms your company has declared for masking have been replaced by placeholders; they are restored by our server, never by the model. This automatic detection is not guaranteed to catch everything. Scale4win does not use your Gmail data or your files to develop or improve AI models.
- What we never do: sell your Gmail data, use it for advertising or profiling, transfer it to third parties other than the providers needed for the service (hosting, database, AI provider), or let a person read it, except with your explicit consent for a given message, for security purposes (investigating abuse), or to comply with the law.
- Disconnect and delete: MailAgent's “Disconnect” button immediately revokes access at Google and deletes the stored token. You can also remove access from your Google account (myaccount.google.com/permissions). You delete a conversation, and the text of its files, from MailAgent; it is also deleted at your request (contact@scale4win.fr), after 12 months without activity and when your account is closed.
- Local version (Windows and macOS application): your messages are processed on your computer, by the AI installed on it; they do not go through Scale4win's servers. If you choose, in its settings, to use Anthropic's Claude model with your own key, the relevant excerpts of your messages go directly from your computer to Anthropic, without prior replacement of names and numbers, under your contract with Anthropic. Licence activation sends Scale4win the licence key and a random identifier created on the computer, nothing else.
Scale4win's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Data processed by specific products
In the products below, the customer using them is the controller of the data of its own clients, patients, applicants or employees, and Scale4win is its processor, unless stated otherwise.
- S4W for RH (applicant pre-screening): the recruiting company is the controller and informs applicants. Before AI analysis, in addition to the data above, age, family status, nationality, place and date of birth, postal address, LinkedIn profile and disability mentions detected in the CV are removed; clues may remain in free text. The AI takes no decision: every application is reviewed by a recruiter, and rejecting an application requires a reason entered by them. Applications are deleted at the end of the retention period set by the company for the campaign (24 months by default).
- MonStetto (healthcare): the practitioner is the controller of their patients' data. Patient records, notes and consultation transcripts are only kept in the version installed at the practice; the online version only keeps the patient's account and appointments, erased 12 months after their date. Transcription of a consultation only starts after the patient has been informed, the audio is never stored, the transcript is erased when the retention period set by the practitioner expires, and the text is pseudonymized before the AI model. Patients can delete their online account from their space. Appointment reminders by SMS are sent by Brevo.
- Godwish Hotel Manager (hotel booking): the hotel is the controller of its guests' data for their stay (booking, invoice, police registration form). The Godwish customer account, shared by the hotels of the platform, is managed by Scale4win, controller of that processing, so that you can book; you can delete it from your space, your bookings and invoices being kept by the hotel for its legal obligations. Payment is processed by the hotel's payment provider: neither Scale4win nor the hotel receives your card details.
- PostOkee (Instagram and TikTok posts): a linked Instagram or TikTok account is linked through an encrypted access token, with the account name and its statistics; “Disconnect” deletes it, as does a deletion request made at Meta. People approving posts at the client without an account are informed that their name, e-mail, decisions and comments, as well as their IP address and browser when opening and deciding, are recorded as proof of approval for the agency (the agency's legitimate interest). The public directory of community managers and the verification of training badges are the responsibility of Scale4win, as controller: a profile is only published with the community manager's consent, who can withdraw it at any time; a verified badge only shows the first name and the initial of the surname; messages sent to a community manager from the directory are recorded and forwarded to them.
- Invoicing & Prospects: client records, quotes, invoices and prospects are processed on behalf of the user company. The prospecting module uses company data from the public SIRENE register, including the names of their managers, excluding companies that have restricted its disclosure; each prospecting e-mail states where the contact details come from and how to object, and an objection is kept so that the company is no longer contacted.
- Project Management, Training, AI literacy: time entries and assessment results are processed on behalf of the employer, who informs its employees. A completion certificate can be verified by anyone holding its identifier: they see the holder's name and result.
- Immo: sellers' contact details are not sent to the AI model.
Recipients and service providers
Your data is intended for Scale4win. It is neither sold nor rented. We use the following technical service providers:
- Render (application hosting, Frankfurt region, EU) and Supabase (database, Ireland region, EU);
- Stripe (payment of online orders);
- Cloudflare (Turnstile), when the anti-bot check on downloading an anonymized document is switched on: your IP address and technical information about your browser are sent to it at the time of that download, to tell a person from a bot;
- the AI model providers offered by the platform (Anthropic, Mistral AI, Microsoft Azure OpenAI, Zhipu AI), for AI features, after pseudonymization;
- Brevo (MonStetto SMS reminders);
- Meta (Instagram, Facebook) and TikTok, when you link an account in PostOkee or choose to sign in with Facebook; Google, when you sign in with Google or link your Gmail mailbox;
- for Godwish Hotel Manager, the payment provider chosen by the hotel;
- our e-mail service provider (delivery of e-mails);
- Google: the Company page offers a Google Maps map, only displayed if you click “Show the map”; your IP address is then sent to Google. The site's fonts are hosted by Scale4win: no call is made to Google Fonts.
Some of these providers are established outside the European Union, notably in the United States (Render, Stripe, Anthropic, Google, Cloudflare) and, for Zhipu AI, in Asia. These transfers are covered by the safeguards provided by the GDPR: adequacy decision, including the EU–US Data Privacy Framework for companies certified under it, or European Commission standard contractual clauses. A customer company can exclude an AI provider by choosing another one or a model installed on its premises.
Retention periods
- Contact and audit requests: 3 years from our last exchange.
- Specification attached to an audit request: deleted 90 days after the request is closed, and one year after receipt at the latest.
- User account: for the duration of the contract.
- MailAgent: Gmail connection until you disconnect it; conversations, with the text of their imported files, until deleted, at the latest after 12 months without activity or when the account is closed (10 conversations at most); the security log keeps only volumes of imports and deletions, never a file name or content.
- Documents uploaded to the platform, extractions and test repository: for the term of the contract; deleted when the account is closed, after export if you ask for it.
- S4W for RH: applications deleted at the end of the period set for the campaign (24 months by default).
- MonStetto (online version): appointments erased 12 months after their date; patient account until deleted by the patient.
- PostOkee: messages sent to a community manager from the directory, 12 months; IP address and browser of approvers, 5 years, the limitation period for legal action.
- Prospecting: prospect data, 3 years at most after the last exchange; objection, 3 years.
- Accounting records and invoices: 10 years, as required by the French Commercial Code.
Cookies and browser storage
The site uses no advertising or audience-measurement cookies. Only items strictly necessary for its operation are used, which does not require your consent:
- session cookie
aphp_token, set when you sign in to keep you signed in; aphp_addin_sessioncookie (30 days), set only if you use our Office add-ins;- language preference (
aphp_lang), kept in your browser; - session data kept in the open tab and erased when it is closed.
Security
Data isolation per company, AES-256 encryption of accounts and access keys, encrypted connections (HTTPS), audit log of actions.
Your rights
You have the right to access, rectify, erase, restrict, object to and port your data, and to withdraw your consent at any time. To exercise these rights, write to contact@scale4win.fr. You may also lodge a complaint with the CNIL, the French data protection authority (cnil.fr).