The General Data Protection Regulation (GDPR), which entered into force on May 25, 2018, defines the principles to be observed when collecting, processing and storing personal data. They also guarantee the rights of the persons concerned.

This privacy policy defines and informs you of how our website uses and protects the information you transmit to us, if any, when you use this site accessible from the following URL: https: // www .transfer-id.com / fr / (hereinafter the “Site”). Please note that this privacy policy may be modified or supplemented at any time by TRANSFER-ID, in particular in order to comply with any legislative, regulatory, jurisprudential or technological developments. In such a case, the date of its update will be clearly identified at the top of this policy. These modifications commit the User as soon as they are put online. The User should therefore regularly consult this confidentiality and use of cookies policy in order to be aware of any changes.

I. PERSONAL DATA

In general, you can visit our Site without disclosing any personal information about yourself. In any event, you are in no way obliged to transmit information to TRANSFER-ID. However, in case of refusal, you may not be able to benefit from certain information or services that you have requested. As such, our Site may in certain cases ask you to enter your name, first name, email address, telephone number, company and function (hereinafter your “Personal Information”). By providing this information, you expressly agree that it will be processed by TRANSFER-ID, for the purposes indicated in point 2 below as well as for the purposes stated at the end of each form. In accordance with the General Data Protection Regulation adopted by the European Parliament on April 14, 2016, and the Data Protection Act of January 6, 1978 as amended, TRANSFER-ID informs you of the following points:

1. Identity of the controller

The data controller is TRANSFER-ID, with its registered office at:

35 rue de Malacussy

42100 Saint-Etienne

FRANCE.

Landline phone: + 33 (0) 967 04 74 21 - Mobile phone: + 33 (0) 649 21 52 84

2. Purposes of processing

TRANSFER-ID may process your Personal Information: (a) for the purposes of providing you with the information or services you have requested (in particular: sending the Newsletter, commercial offer, white papers or even the evaluation of your level of compliance via a quiz); and / or (b) for the purpose of collecting information enabling us to improve our Site, our products and services (in particular by means of cookies); and / or (c) for the purpose of contacting you regarding various events relating to TRANSFER-ID, including in particular product updates and customer support.

3. Recipients

Only TRANSFER-ID is the recipient of your Personal Information. These, whether in individual or aggregated form, are never transmitted to a third party, notwithstanding the subcontractors to which TRANSFER-ID uses (you will find more information about them in point 7 below). Neither TRANSFER-ID, nor any of its subcontractors, sells the personal data of visitors and Users of its Site.

4. Retention period

Your Personal Information is kept by TRANSFER-ID only for the time corresponding to the purpose of the collection as indicated in 2 above, which may not in any case exceed 24 months.

5. Computer Rights and Freedoms

You have the following rights regarding your Personal Information, which you can exercise by writing to us at the postal address mentioned in point 1 or by completing the personal data administration.

o Right of access and communication of data You have the right to access Personal Information concerning you. However, because of the obligation of security and confidentiality in the processing of personal data which is incumbent on TRANSFER-ID, you are informed that your request will be processed provided that you provide proof of your identity, in particular by the production of a valid electronic identification (in the event of a request using our dedicated electronic form) or a signed photocopy of your valid identity document (in the event of a written request). TRANSFER-ID informs you that it will be entitled, if necessary, to oppose clearly abusive requests (by their number, their repetitive or systematic nature). To help you in your process, in particular if you wish to exercise your right of access by means of a written request to the postal address mentioned in point 1, you will find by clicking on the following link a model letter developed by the National Commission for Computing and Freedoms (the “CNIL”). https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces

o Right to rectify data Under this right, the legislation entitles you to request the rectification, updating, blocking or even erasure of data concerning you which may prove to be inaccurate, erroneous or incomplete, if necessary. or obsolete. Also, you can define general and specific directives relating to the fate of personal data after your death. Where appropriate, the heirs of a deceased person may require the death of their relative to be taken into account and / or to make the necessary updates. To help you in your process, in particular if you wish to exercise, on your own account or on behalf of one of your deceased relatives, your right of rectification by means of a written request to the postal address mentioned in point 1, you will find by clicking on the following link a model letter developed by the CNIL. https://www.cnil.fr/fr/modele/courrier/rectifier-des-donnees-inexactes-obsoletes-ou-perimees

o Right of opposition The exercise of this right is only possible in one of the following two situations:

When the exercise of this right is based on legitimate reasons; or

When the exercise of this right is intended to prevent the data collected from being used for commercial prospecting purposes.

To help you in your process, in particular if you wish to exercise your right of opposition by means of a written request addressed to the postal address indicated in point 1, you will find by clicking on the following link a model letter developed by the CNIL. https://www.cnil.fr/fr/modele/courrier/supprimer-des-informations-vous-concernant-dun-site-internet

6. Response times

TRANSFER-ID undertakes to respond to your request for access, rectification or opposition or any other additional request for information within a reasonable period of time which may not exceed 1 month from receipt of your request.

7. Authorized service providers and transfer to a third country of the European Union

TRANSFER-ID informs you that it uses authorized service providers to facilitate the collection and processing of the data you have communicated to us. These service providers may be located outside the European Union and communicate the data collected through the various forms on the Site (with the exception of the form allowing you to exercise your Computer and Freedoms rights which is offered and used. by TRANSFER-ID). TRANSFER-ID has first ensured that its providers have implemented adequate guarantees and that strict conditions of confidentiality, use and data protection are observed. In particular, vigilance has focused on the existence of a legal basis for carrying out any transfer of data to a third country. As such, one of our service providers is subject to internal company rules (or “Binding Corporate Rules”) which were approved by the CNIL in 2016 when the others obey not only Standard Contractual Clauses but also the Privacy Shield.

8. Complaint to the competent authority

If you consider that TRANSFER-ID does not comply with its obligations with regard to your Personal Information, you can submit a complaint or request to the competent authority. In France, the competent authority is the CNIL to which you can send a request electronically by clicking on the following link: https://www.cnil.fr/fr/plaintes/internet.

II. COOKIES POLICY

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