Scaleway Privacy Policy changes — 20260811_rev01

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- Transfer of data to a sub-processor or partner for the performance of the service;

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- In the event of a business transfer (included merger or acquisition of the company);

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- To comply with our legal obligations (e.g., sharing data at the request of an authorized public body to identify fraud or as part of a criminal investigation);

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- To ensure the security of our services and infrastructure (e.g. sharing data with security-related service providers).

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## How we use your data?

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## How do we use your data ?

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Contracts management and customer relations

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Scaleway processes your data in order to manage contracts for the services you use. This includes the management of accounts, support and payment methods.

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| --- | --- | --- | --- | --- |

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| Management of contracts and customer relations (management of accounts, support and means of payment) | Identity data

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Billing data

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Consumption data

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Communication data

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Connection data | Execution of the contract | Duration of the contractual relationship plus an archiving period to meet our legal obligations and guarantee the defense of our legitimate interest | Scaleway Services

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Connection data | Execution of the contract

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Legal obligation (invoicing, accounting records, compliance)

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Legitimate interest (security, fraud prevention) | Duration of the contractual relationship plus an archiving period to meet our legal obligations and guarantee the defense of our legitimate interest | Scaleway Services

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Entitled Scaleway Partners for support and payment management

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Authorized third parties\* |

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| Management of contracts with our partners (service providers and suppliers) | Identity data

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Commercial relationship monitoring data (activity reports and, communications) | Execution of the contract | Duration of the contractual relationship | Scaleway Services

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Commercial relationship monitoring data (activity reports and, communications) | Execution of the contract

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Legal obligation (invoicing, accounting records, compliance) | Duration of the contractual relationship | Scaleway Services

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Entitled Scaleway Partner for the management of suppliers

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Authorized third parties |

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\*Means any public authority or administration authorized by a text to receive personal information

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Sales and Marketing

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Communication and Marketing

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Scaleway processes certain data in order to send its service offers to its customers or prospects, guests for events or even collect their opinions on products (processing may involve profiling techniques). These processing operations may be based either on legitimate interest, if the person is already a customer of the company, particularly if the proposals concern products or services similar to those already subscribed, or on consent. Scaleway mainly collects this data directly but can also obtain it indirectly via specialized data processors in conformity with all applicable legal requirements.

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| --- | --- | --- | --- | --- |

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| Commercial prospecting and communication campaigns relating to our products and services | Identity data

 The data collected for the operation of our services, where Scaleway acts as a processor, is governed by our [General Conditions of Services](https://www.scaleway.com/en/contracts/) as well as our [Data Processing Agreement (DPA).](https://www.scaleway.com/en/contracts/)
 ## What kind of personal data is processed ?
 Scaleway is required to process the following categories of data:
+- Data relating to identity: name, first name, customer number, signature, proof of identity.
+- Data relating to identity: Name, surname, postal address, email, telephone number, customer number, signature, proof of identity.
 - Billing data: bank details, terms of payment, invoices, etc.
 - Consumption data: history of services and products used, event logs etc.
 - Communication data: mails, emails, telephone number, history of exchanges with Scaleway, complaints, support tickets, etc.
 - Connection data: IP address, user ID, location data, connection and event logs etc.
 The categories of data used are indicated in each of the treatments in the following section. Any reference to "user account data" includes all account data.
 - Transfer of data to a sub-processor or partner for the performance of the service;
 - In the event of a business transfer (included merger or acquisition of the company);
 - To comply with our legal obligations (e.g., sharing data at the request of an authorized public body to identify fraud or as part of a criminal investigation);
 - To ensure the security of our services and infrastructure (e.g. sharing data with security-related service providers).
+## How we use your data?
+## How do we use your data ?
 Contracts management and customer relations
 Scaleway processes your data in order to manage contracts for the services you use. This includes the management of accounts, support and payment methods.
 | Purposes | Categories of data | Legal basis | Retention | Categories of recipients |
 | --- | --- | --- | --- | --- |
 | Management of contracts and customer relations (management of accounts, support and means of payment) | Identity data
 Billing data
 Consumption data
 Communication data
+Connection data | Execution of the contract | Duration of the contractual relationship plus an archiving period to meet our legal obligations and guarantee the defense of our legitimate interest | Scaleway Services
+Connection data | Execution of the contract
+Legal obligation (invoicing, accounting records, compliance)
+Legitimate interest (security, fraud prevention) | Duration of the contractual relationship plus an archiving period to meet our legal obligations and guarantee the defense of our legitimate interest | Scaleway Services
 Entitled Scaleway Partners for support and payment management
 Authorized third parties\* |
 | Management of contracts with our partners (service providers and suppliers) | Identity data
+Commercial relationship monitoring data (activity reports and, communications) | Execution of the contract | Duration of the contractual relationship | Scaleway Services
+Commercial relationship monitoring data (activity reports and, communications) | Execution of the contract
+Legal obligation (invoicing, accounting records, compliance) | Duration of the contractual relationship | Scaleway Services
 Entitled Scaleway Partner for the management of suppliers
 Authorized third parties |
 \*Means any public authority or administration authorized by a text to receive personal information
+Sales and Marketing
+Communication and Marketing
 Scaleway processes certain data in order to send its service offers to its customers or prospects, guests for events or even collect their opinions on products (processing may involve profiling techniques). These processing operations may be based either on legitimate interest, if the person is already a customer of the company, particularly if the proposals concern products or services similar to those already subscribed, or on consent. Scaleway mainly collects this data directly but can also obtain it indirectly via specialized data processors in conformity with all applicable legal requirements.
 | Purposes | Categories of data | Legal basis | Retention | Categories of recipients |
 | --- | --- | --- | --- | --- |
 | Commercial prospecting and communication campaigns relating to our products and services | Identity data
 | Organization of events to promote our services | Identity data
 Communication data
 Connection data
 Data relating to the professional background of the speakers | Legitimate interest
 Consent | Duration of the contractual relationship
 Account deletion request
+Prospects : deletion after 3 years of inactivity from the last contact | Scaleway Sales and Marketing Teams
+Prospects : deletion after 3 years of inactivity from the last contact | Scaleway teams involved in the event
 Entitled Scaleway Partners for the management of events
 Scaleway service concerned by the event
 Authorized third parties |
 | Management of third-party cookies from our websites ([learn more about our cookie policy](https://www.scaleway.com/en/cookie/)) | Connection data | Consent | Cookies are stored between 3 months and 1 year depending on the type of cookie used | Scaleway Sales and Marketing Teams
 Entitled Scaleway Partners for the cookies management
 Authorized third parties |
+| Tracking email opens and clicks for our marketing emails via a tracking pixel.
+These trackers can also be used to provide proof that a contact is active or has opened an email | Contact identifier or unique identifier associated with the pixel
+Communication data (email)
+Click data (link clicks)
+Connection data (IP address) | Legitimate interest
+Consent | Duration of the contractual relationship
+Contact activity period | Scaleway Sales and Marketing teams
+Scaleway partners for marketing analytics management
+Authorized third parties |
 | Carrying out satisfaction surveys or quality surveys on our services and the training of our teams | Identity data
 Billing data
 Consumption data
 Communication data
 Connection data
 Audio or video recording | Legitimate interest
 Authorized third parties |
 | Produce usage statistics | Connection data | Legitimate interest | Cookies: between 3 months and 1 year
 Service usage data kept during the contractual period or anonymized | Scaleway Sales and Marketing Teams
 Entitled Scaleway Partners for quality analysis
 Authorized third parties |
+Recruitment
+Recruitment and application management
 Scaleway also processes the personal data of candidates as part of its recruitment procedure.
 | Purposes | Categories of data | Legal basis | Retention | Categories of recipients |
 | --- | --- | --- | --- | --- |
 | Recruitment | Identity data
 Competent administrative authority |
 | Legal or administrative procedure management | Identity data
 User account information related to the case | Legal obligation | The necessary data is kept until the expiration of the legal remedies | Scaleway Legal Department
 Iliad Legal Department
 Competent administrative authority
 Entitled third parties (legal advisor etc.) |
+| Compliance with legal and regulatory obligations applicable to registrars (including ICANN). | Identification data
+Customer account dataw
+Billing data
+Technical data related to domain management | Legal obligation | The duration of the contractual relationship includes a necessary archiving period to ensure compliance with our legal obligations. | Domain Teams
+Payment providers
+Support tools
+Resellers
+Authorized Third Parties |
 Legitimate interest
 Scaleway processes some of your data in order to meet a legitimate interest. This is particularly the case in order to secure our services, ensure the management of unpaid debts and the training of our teams (processing relating to security or fraud may involve profiling techniques).
 | Purposes | Categories of data | Legal basis | Retention | Categories of recipients |
 - Anonymization of data when personal data is no longer necessary for processing in order to produce statistics or improve our services or marketing communication
 In accordance with our general conditions of service, we remind you that the customer is solely responsible for the management and security of its content as well as the environments and systems that it deploys on the infrastructures made available to it as part of the services offered by Scaleway. It is also up to the customer to make any backups of their content (or other means aimed at ensuring their longevity) that he considers necessary in order to protect against possible deletion, alteration or modification of said content.
 For more information regarding all of our security measures, you can consult our [Security and Resilience page.](https://www.scaleway.com/en/security-and-resilience/)
+For more information about all our security measures, please visit the following pages:
+- Scaleway: [Security and Resilience](https://www.scaleway.com/en/security-and-resilience/)
+- [Scaleway Trust Center](https://security.scaleway.com/)
+- Contract page: [Technical and Organizational Security Measures](https://www.scaleway.com/en/contracts/) (TOMs)
 If you have identified a vulnerability or would like to send us a security question, please send it to us at: [security@scaleway.com](mailto:security@scaleway.com)
 ## Data subjects rights & contact
 Scaleway informs you that you have the following rights depending on the purpose of processing:
 - Limit the use of your data
 - Oppose the processing of your data if it is processed on the basis of legitimate interest
 - Withdraw your consent at any time if the processing is based on this legal basis
 - Delete data that is no longer necessary for processing or to meet a legal obligation
 - Exercise your right to portability
+You can exercise your rights directly in the privacy section of your Scaleway account or via [privacy@scaleway.com](mailto:privacy@scaleway.com). If you believe that your rights have not been respected, you can also file a complaint [with the competent supervisory authority](https://www.edpb.europa.eu/about-edpb/about-edpb/members_fr).
+You can exercise your rights directly in the privacy section of your Scaleway account or contact our DPO via the following address : via [privacy@scaleway.com](mailto:privacy@scaleway.com). If you believe that your rights have not been respected, you can also file a complaint [with the competent supervisory authority](https://www.edpb.europa.eu/about-edpb/about-edpb/members_fr).
 ## Policy update
 This privacy policy may be updated to reflect changes in regulations or services offered by Scaleway, as well as to improve the transparency of our practices. Any changes will take effect from the date of publication.
+Last update : November 2025
+Last update : June 2026

Privacy Policy

Full text changes — 20260101_rev01 to 20260811_rev01