SIG4 Engineering
PRIVACY AND COOKIE POLICY

LAST UPDATE: September 25, 2024

SIG4 Engineering, a SAS with a capital of €1,000, registered with the Marseille Trade and Companies Register (RCS 929 643 229) on June 10, 2024, and represented by its Manager, Julien Molinero-Perez (hereinafter « SIG4 Engineering », « we », « our », « us »), takes the protection of personal data very seriously. SIG4 Engineering carefully ensures compliance with personal data protection regulations, particularly the amended Law of January 6, 1978, known as the « Informatique et Libertés » law, the General Data Protection Regulation 2016/679 (« GDPR »), and the recommendations issued by the CNIL (hereinafter the « Applicable Legislation »).

1. ABOUT THIS PRIVACY POLICY

As the data controller for your personal data, SIG4 Engineering would like to explain in this privacy and cookie policy (« Privacy Policy ») how we may collect, use, and process personal data (« Personal Data ») provided during the use of our website(s) (the « Site ») or our services (the « Services ») by our clients or prospects.

2. HOW IS PERSONAL DATA COLLECTED?

We may collect your Personal Data directly from you:

• when you communicate with our customer service via email or during our telephone communications.

We may obtain information about you from other sources. For example, we may request a third-party provider to provide us with additional information about our existing clients, including information from your profile or posts on a third-party social network.

We may also collect information from your profile on a third-party social network (such as Facebook) if you authorize the social network to share it with us or if you post it publicly. This information may include general account information (e.g., name, email address, profile picture, gender, date of birth, current city, ID, friend list, etc.) and any other information or activity you authorize the third-party social network to share with us or post publicly on your profile. For example, we may receive your social media information (or part of it) when you download or interact with one of our applications on a social network site (such as Facebook). For more information on how your social media information may be obtained by us, please review the terms of use of the relevant third-party social network.

3. WHAT PERSONAL DATA DO WE COLLECT?

Personal Data includes any information about a person that can directly or indirectly identify that person.

The Personal Data we collect from users of the Site or clients or prospects using our Services includes:

• Your first and last name(s),
• Your date of birth,
• Your gender,
• Your postal address,
• Your email address,
• Your telephone number(s),
• Any other information you may provide while using the Site or our Services.

4. WHY DO WE COLLECT PERSONAL DATA?

The purposes and legal bases for processing your Personal Data are as follows:

5. WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?

Your Personal Data is intended for the relevant SIG4 Engineering departments handling your requests. We ensure that only authorized individuals have access to your Personal Data when necessary for the purposes mentioned above.

SIG4 Engineering is committed not to transfer or sell your Personal Data to non-partner third parties.

We may share your Personal Data with the following third parties, in compliance with the Applicable Legislation:

• With our affiliated entities to provide the requested Services.
• With our business partners, such as service providers for the reserved services or technical service providers. We take special care to ensure these third parties provide sufficient guarantees to protect and secure your Personal Data, particularly in the context of legal proceedings or data requests.

6. PERSONAL DATA SECURITY

As the data controller for your Personal Data, SIG4 Engineering implements all necessary technical and organizational measures to ensure the protection of your Personal Data and limits the amount of data processed in line with the purposes pursued. We have established procedures to address any suspected data breaches and will notify you and any competent supervisory authority of a suspected breach where we are legally required to do so.

However, data transmission over the Internet or data storage systems cannot be guaranteed 100% secure. If you believe that your interaction with us is no longer secure (for example, if you believe that the security of an account you have with us has been compromised), please notify us immediately by contacting us using the contact details provided above.

7. PROCESSING OF DATA OUTSIDE THE EUROPEAN UNION

We may transfer your Personal Data to countries outside the European Economic Area (EEA) solely for the purposes described in this Privacy Policy.

In case of a transfer of Personal Data outside the EEA, we will take appropriate measures to ensure that the recipient adequately protects your Personal Data in accordance with this Privacy Policy. These measures may include the following:

• (a) Requesting your consent;
• (b) Ensuring that there is an adequacy decision from the European Commission in case of transfer outside the EEA, meaning that the recipient country is deemed to provide adequate protection for such personal data;
• (c) Entering into a data transfer agreement within our group that complies with the European Union’s standard contractual clauses; or
• (d) Entering into the European Commission’s standard contractual clauses. These standard contractual clauses include certain safeguards aimed at protecting personal data.

8. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will retain your Personal Data only for as long as necessary to fulfill the purposes for which we collected it, including to comply with any legal or accounting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, whether we can achieve those purposes by other means, and the applicable legal requirements.

We retain the following information for the maximum periods listed below:

• 10 years from the last contact between the client and SIG4 Engineering.
• In the event of legal proceedings, until the proceedings are fully resolved.

Once these retention periods expire, the data will either be deleted or anonymized, particularly for statistical purposes. They may be retained in the event of pre-litigation or litigation. It is important to note that deletion or anonymization is irreversible, and SIG4 Engineering will no longer be able to restore the data afterward.

9. RIGHTS OF DATA SUBJECTS

As a data subject, you have various rights. These rights are not absolute and each is subject to certain conditions under the GDPR and applicable national laws.

• Right of access – You have the right to obtain confirmation from us as to whether or not we are processing your Personal Data, as well as certain other information (similar to that provided in this Privacy Policy) about how it is used. You also have the right to access your Personal Data by requesting a copy of the Personal Data we hold about you. This allows you to know and verify that we are using your information in accordance with data protection laws. We may refuse to provide information where doing so may reveal Personal Data about another person or negatively impact another person’s rights.
• Right to rectification – You can ask us to take steps to correct your Personal Data if it is inaccurate or incomplete (for example, if we have the wrong name or address).
• Right to erasure – Also known as the « right to be forgotten, » this right allows you to request the deletion or removal of your Personal Data when, for example, there is no compelling reason for us to continue using it or its use is unlawful. However, this is not a general right to erasure, and there are exceptions, such as when we need to use the information to defend a legal claim or comply with a legal obligation.
• Right to restrict processing – You have the right to « block » or prevent further use of your Personal Data when we are evaluating a request for rectification or as an alternative to erasure. When processing is restricted, we may still store your Personal Data, but we may not use it further.
• Right to data portability – You have the right to obtain and reuse certain Personal Data for your own purposes across different companies (which are separate data controllers). This applies only to Personal Data that you have provided to us, that we process with your consent and for the performance of a contract, and that is processed by automated means. In this case, we will provide you with a copy of your data in a structured, commonly used, and machine-readable format, or (where technically feasible) we will transfer your data directly to another data controller.
• Right to object – You have the right to object to certain types of processing, for reasons related to your particular situation, at any time, where such processing is for the purposes of legitimate interests pursued by SIG4 Engineering. We are permitted to continue processing your Personal Data if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or if we need the data for the establishment, exercise, or defense of legal claims. If you object to the processing of your Personal Data for direct marketing purposes, we will no longer process your Personal Data for such purposes.
• Right to withdraw consent – Where we process your Personal Data based on your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing that occurred before the withdrawal.
• Right to provide instructions regarding your Personal Data after your death – In France, you have the right to provide us with instructions regarding the handling (e.g., retention, deletion, and disclosure) of your data after your death. You may modify or revoke your instructions at any time.

If you have any questions regarding this Privacy Policy, how we process your Personal Data, or if you wish to exercise any of your rights, please email us at: jmolinero@sig4-engineering.fr

Any request will be reviewed within the timeframes set by applicable law. Please note, however, that certain personal data may be exempt from such requests in certain circumstances, particularly if we need to continue processing your Personal Data for our legitimate interests or to comply with a legal obligation. Exercising your right of access (or any other right) will not incur any fees. For your information, sometimes we may not be able to fulfill your request if it is manifestly unfounded or excessive.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

If you are not satisfied with our response to your complaint or if you believe that the processing of your Personal Data is not in compliance with applicable law, you may file a complaint with the relevant data protection authority. The Commission Nationale de l’Informatique et des Libertés (CNIL) is the lead data protection authority for SIG4 Engineering.

10. THIRD-PARTY SITES

The Site may contain links to other websites operated by third parties. Please note that this Privacy Policy applies only to the Personal Data collected by SIG4 Engineering. We are not responsible for the Personal Data that third parties may collect, store, and use on their own websites or applications. We encourage you to carefully read the privacy policy of each website and/or application you visit.

Additionally, SIG4 Engineering is not responsible for hyperlinks directing to the Site that third-party websites and/or applications may include, even if SIG4 Engineering has authorized the third-party publisher of the said website and/or application to place such a link.

11. COOKIES

11.1 What are cookies?

« Cookies » are small text files, often containing unique identifiers, that are sent by web servers to web browsers and that may then be sent back to the server each time the browser requests a page from the server.

Cookies are very useful and allow a website to recognize you, log you in when you visit a particular page, provide a secure connection to a website, and enhance your user experience by improving your browsing comfort and/or tailoring the content of a page to your interests.

11. COOKIES
11.1 What are cookies?

Cookies are small text files, often containing unique identifiers, that are sent by web servers to web browsers and may be sent back to the server each time the browser requests a page from the server.

Cookies are very useful and allow a website to recognize you, log you in when you visit a particular page, provide a secure connection to a website, and enhance your user experience by improving your browsing comfort and/or tailoring the content of a page to your interests.

11.2 How are cookies used?

The types of cookies used on our Site are as follows:

When prior consent is required for their use, the validity period of consent for the placement of cookies is 6 months. After this period, we will ask for your consent again.

The retention period for an audience measurement cookie that does not require consent is 13 months. However, the information collected through these cookies is retained by us for a maximum of 25 months, in accordance with applicable regulations.

11.3 How to block the use of cookies:

There are two ways to refuse the use of cookies.

During your first visit to our Site, your consent for the use of your data via cookies will be requested through an information banner that will be visibly displayed at the bottom of the page.

Using the « Accept » and « Refuse » buttons, you can either accept or refuse the global placement of cookies on your computer or device (cookies related to targeted advertising, certain audience measurement cookies, social network cookies generated in particular by their sharing buttons when they collect personal data).

However, if you wish to refuse the use of all types of cookies on a website, you can do so by adjusting your browser settings to block the use of cookies. Please note that if you block the use of cookies through these browser settings, you may not be able to use or view all or part of the website, including our Site.

Each web browser offers different ways to configure cookie management. Generally, these can be found in the help menu of each browser.

• Firefox: https://support.mozilla.org/fr/kb/cookies-informations-sites-enregistrent
  Click the menu button and select « Options ».
  Select the « Privacy & Security » panel.
  Set « History » to « Use custom settings for history ».
  Uncheck the « Accept cookies » box.
  Your changes will be saved automatically.

• Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7
  Click the « Tools » button, then « Internet Options ».
  Click the « Privacy » tab, then under « Settings », move the slider up to block all cookies or down to allow all cookies, then click OK.

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=fr
  Select the Chrome menu icon.
  Select « Settings ».
  At the bottom of the page, select « Show advanced settings ».
  In the « Privacy » section, select « Content settings ».
  Select « Block sites from storing any data ».
  Click OK.

• Safari: https://www.apple.com/legal/privacy/fr-ww/cookies/
  Click « Settings » > « Safari » > « Privacy » > « Cookies and website data ».
  Then select « Always block ».

Please note that if you block the use of cookies via your browser settings, you may not be able to use or view all or part of the website, including our Site.

Additionally, if you wish to block the use of analytical cookies, both of which are provided by third-party service providers, please visit the following URL to suspend the use of these cookies:

• Google Analytics: Opt-out for cookies

Description of cookies and their purpose:

• Google Analytics _ga;
• Google Analytics _gid – These cookies are used to distinguish users. https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage;
• Google Analytics _gat – These cookies are used to limit the number of requests. However, if Google Analytics is deployed via the Google Tag Manager, these cookies will be named: dc_gtm<property-id>. https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

Google Analytics is a web analytics service provided by Google LLC (« Google »). Typically, the information generated by the cookie regarding your use of the Site is transmitted to a Google server in the United States and stored there.

Google will use this information on our behalf to analyze your use of the Site, compile reports on Site activity, and provide us with additional services related to the use of the Site and the Internet. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

You can refuse the use of data generated by these cookies related to the use of our Site (particularly your IP address) as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB

12. CONTACT INFORMATION

If you have any questions or concerns about the Privacy Policy, you can contact us by email at: jmolinero@sig4-engineering.fr

13. CHANGES TO THIS PRIVACY POLICY

SIG4 Engineering may modify this Privacy Policy periodically to reflect changes in our practices. When we modify this Privacy Policy, we also update the « Last Updated » date at the top of the first page. We encourage you to review this Privacy Policy regularly to stay informed about how SIG4 Engineering protects your Personal Data.