CONFIDENTIALITY AND PERSONAL DATA PROTECTION POLICY

As part of our activity and for the purposes of our offer, we collect and process the personal data of our users (hereinafter the "Users").

This confidentiality policy, which we have put in place, is intended to provide Users with summary and comprehensive information on the processing of personal data by Synneo.

We attach particular importance to respecting the privacy of Users and the confidentiality of their personal data, and we therefore undertake to process data in compliance with the applicable laws and regulations, and in particular Law no. 78-17 of 6 January 1978 relating to information technology, aux fichiers et aux libertés (hereinafter the "Data Protection Act"), and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR").

THE MAIN PRINCIPLES OF SYNNEO'S PRIVACY POLICY.

Privacy policies can be complicated to decipher. We've done our best to make ours as clear as possible. To help you, here is a summary of how we manage your personal data in our Privacy Principles below.

These principles illustrate our desire to protect your privacy and manage your personal data in the best possible way.

We only ask for or collect the personal data we need to provide you with the services, products and experiences you expect.

We give you control over the personal data we hold about you to ensure that it is accurate and consistent with your preferences.

We ensure that your personal data is always protected.

We are transparent about how we use the personal data we hold about you.

We will only use your personal data for the purposes for which you provided it.

We will never sell your personal data and will only share it as set out in our privacy policy or if you request us to do so.

We will respect your choices and inform you of any changes that may affect the management of your personal data.

We take responsibility for the personal data we hold about you.

PRIVACY POLICY - Definition

Personal data: personal data is any information relating to an identified or identifiable natural person, i.e. a person who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to that person.

Processing of personal data: the processing of personal data includes any operation or set of operations which relates to such data, regardless of the process used, and in particular collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

Cookie: a cookie is a piece of information placed on an Internet user's hard drive by the server of the site they are visiting. It contains several pieces of information: the name of the server that placed it, an identifier in the form of a unique number, and possibly an expiry date. This information is sometimes stored on the computer in a simple text file that a server accesses to read and record information.

DATA CONTROLLER

The person responsible for processing the personal data referred to herein is Marie-Cécile Maréchal of Synneo, a simplified joint stock company with capital of 30,270,350.80 Euros, registered in the Melun Trade and Companies Register under number 915 012 231 and whose registered office is at 40 Impasse Madeleine Brés 77127 Lieusaint, France.

You can contact the DPO by e-mail or post at the following addresses: dpo@synneo.fr or at SYNNEO/dpo - 40, impasse Madeleine Brès - Parc du Levant - 77127 Lieusaint, specifying "Personal rights" in the subject line and attaching a copy of your proof of identity.

COLLECTED DATA

We collect data from Users in order to provide them with the services they expect when they log on to the site and to perform the services they have chosen us to provide in the best possible way.

We collect the personal data you share with us when you contact us or interact with us on our website, applications, e-mail, telephone, stands and events or otherwise.

For example, you will provide us with data when you contact our sales advisers, place an order, complete a survey, enter a competition or questionnaire, update your preferences and account details...

Through these interactions, you may share with us: Your name, address, e-mail address, telephone number and bank details. In some cases, we will need this information to be able to provide you with a product or service that you have requested; for example, we need your bank details when you order a product, and your address to deliver it to you.

The compulsory or optional nature of the data provided is indicated at the time of collection by an asterisk.

The categories of data processed as part of the services are as follows:
- data relating to the identity of users (surname, first name, date and place of birth, etc.) ;
- users' telephone numbers
- users' e-mail addresses
- technical identifiers of the terminals used by users (IP address, type of browser, etc.).

We also like to interact with you on social networks. You can use them to contact us or tell others what you think about our company. We review publicly available social networks and websites to better understand what people are saying about us, our products, technologies and services and to assist customers who prefer to contact us in this way.

Information collected on social networks and websites, including Facebook, YouTube, Twitter, Instagram, Linkedin sometimes includes personal data posted online and publicly available. We ensure that any information used is properly credited to its source or anonymised.

These websites and social networks generally have their own privacy policies that explain how they use and share your personal data. You should carefully review these privacy policies before using these sites to ensure that you agree with how your personal data is collected and shared.

In addition, certain data is collected automatically as a result of the User's actions on the site (see the paragraph relating to cookies).

PURPOSE

The personal data that we collect in the course of providing services are necessary for the performance of contracts concluded with the User, or to enable us to pursue our legitimate interests in respect of the User's rights. Certain data may also be processed on the basis of the User's consent.

The data collected when using the site and accessing the services is processed in order to provide access to the resources published on the site, to identify users, to improve services, to compile audience and visitor statistics, to process requests and complaints from customers and prospective customers, and to distribute editorial content and commercial prospecting operations.

- The purposes for which we process data are as follows:
- Commercial and accounting management of the contract;
- Management of marketing activation and promotion;
- Detection of malicious behaviour (fraud, phishing, spam, etc.);
- Improving the user experience on the site;

DATA RECIPIENTS

The personal data collected is intended for Synneo's sales, marketing and accounting departments. It may be transmitted to our subcontracting companies, which we may use to perform our contracts and services.

In this context, personal data may be transferred to a country within or outside the European Union. We put in place safeguards to ensure the protection and security of this data, in compliance with regulations.

We do not sell or rent personal data to third parties for marketing purposes without the express consent of Users.

Apart from this, personal data may only be disclosed to third parties in the following cases:

With their authorisation;

At the request of the legally competent authorities, upon judicial requisition, or in the context of legal proceedings.

DATA RETENTION PERIOD

In order to comply with legal obligations or to have the elements necessary to assert our rights, we may archive data under the conditions provided for by the regulations.

Thus, personal data collected by Synneo relating to the identity and contact details of its Users is archived for a maximum period of 3 (three) years after termination of the contractual relationship for client Users, or from the date of collection by the data controller or the last contact from the prospect User for data relating to the latter.

Termination of the contractual relationship is understood to mean the express cancellation of the contract by the User.

USER RIGHTS

In accordance with regulations, Users have the right to access and rectify their personal data, allowing them to rectify, complete, update or delete data that is inaccurate, incomplete, equivocal, out of date or whose collection, use, communication or storage is prohibited.

The User also has the right to request the limitation of the processing and to object on legitimate grounds to the processing of his/her personal data. The User may also give instructions as to the fate of his/her personal data in the event of death.

Where applicable, Users may request the portability of their data or, where the legal basis for processing is consent, withdraw their consent at any time.

Users may exercise their rights by sending an email to dpo@synneo.fr or a letter to :

Synneo – Privacy policy -  40 Impasse Madeleine Brès 77127 Lieusaint - FRANCE

The User may unsubscribe from the Synneo newsletter or marketing emails by following the unsubscribe links in each of these emails.

In the event of a dispute, the User may lodge a complaint with the CNIL, whose contact details can be found at http://www.cnil.fr.

Users will be able to access detailed information on the use of their personal data, in particular concerning the purposes for which it is processed, the legal bases enabling us to process the data, how long it is kept, who receives it and, where applicable, any transfers of data to a country outside the European Union, as well as the guarantees implemented. To do this, the User may send a request by email to dpo@synneo.fr

COOKIES

The Synneo sites use cookies to facilitate navigation on the sites, to execute the service provided by Synneo, to measure the site's audience or to allow sharing of the site's pages.

TYPES OF COOKIES USED

Cookies required for site navigation

These cookies are necessary for the operation of the Synneo sites. They enable use of the site's main functions.

Without these cookies, Users cannot use the site normally.

Functional cookies

These cookies are used to personalise the User experience.

Analytical cookies

These cookies are used to track the use and performance of the site and to improve its operation by analysing the number of visitors to the information pages and by monitoring opening rates, click-through rates and bounce rates at an individual level.

Share button cookies

These social cookies enable users to share pages and content on third-party social networks via social sharing buttons.

COOKIE MANAGEMENT

Users have the option of accepting or refusing cookies on the site or refusing them once and for all by configuring their browser.

If the User chooses to refuse all cookies, navigation to certain pages of the site will be reduced.

Depending on the browser used by Users, the methods for deleting cookies are as follows:

On Internet Explorer

Click on the Tools button, then on Internet Options.
On the General tab, under Browsing History, click on Settings.
Click on the Show files button.
Select the cookies you wish to refuse and click Delete.

On Firefox

Click on the Browser Tools icon, select the Options menu
In the window that appears, select "Privacy" and click on "Show cookies".
Select the cookies you wish to refuse and click on delete.

On Safari

Click on the Edit icon, select the Preferences menu.
Click on Security and then on Show cookies.
Select the cookies you wish to refuse and click Delete.

On Google Chrome

Click on the Tools icon, select the Options menu, then click on the Advanced Options tab and access the "Confidentiality" section.
Click on the "Show cookies" button.
Select the cookies you wish to refuse and then click on delete.

Cookie lifetime

Cookies are stored on the User's terminal for a maximum period of 13 months from the date of the User's consent.

After this period, consent will be sought again.

SAFETY

We have taken all necessary precautions to protect the security of personal data and, in particular, to prevent it from being distorted or damaged or accessed by unauthorised third parties.

These measures include the following:

- Multi-level firewalls,
- Proven anti-virus and intrusion attempt detection, Encrypted data transmission using SSL/https/VPN technology,
- In addition, access to processing by our recipient services requires authentication of the persons accessing the data, by means of an individual access code and password that are sufficiently robust and regularly renewed.

Data transmitted via unsecured communication channels is subject to technical measures designed to render this data incomprehensible to any unauthorised person.

Any questions about the security of Synneo's websites can be sent to dpo@synneo.fr.

CHANGES TO THE PRIVACY POLICY

We reserve the right to change this Privacy Policy in order to comply with changes in applicable laws and regulations.

Any changes will be notified via our website or by email, wherever possible, at least thirty days before they come into force.

CONTACT

Any questions about our Privacy Policy can be sent by email to dpo@synneo.fr or by post to :

Synneo – Privacy Policy -  40 Impasse Madeleine Brès 77127 Lieusaint