S3PWeb (hereinafter “S3PWeb” or “we”) cares about the privacy of users of its services (hereinafter “you”), and implements all necessary measures to ensure the security and confidentiality of your personal information.
Some links or social media icons on the Website may redirect you to external websites that do not belong to S3PWeb (e.g. partners or social networks). These websites have their own data protection regulationsthat may differ from our own: it is your responsibility to be aware of this. We are not responsible for how these websites may use your personal information.
1. Your acceptance of our Policy
By using our Website you accept this Policy in its entirety. If you disagree with any of its terms, you may stop using the Website and/or
stop using our services.
You can quickly and easily access the Policy from the various pages of the Website (linked in the page footer). S3PWeb may also modify the Policy at any time. We recommend regularly checking this page to stay up to date with any changes. In the event of any major changes to the Policy, we will notify you of updates through all necessary means (e- mail, pop-up, etc.).
2. Our commitment to compliance
With this Policy, S3PWeb, registered with the Avignon Register of Trade and Commerce under SIREN no. 830 592 218, with registered head office at 90 rue Charles Nungesser – 29490 Guipavas, France, represented by Mr Emmanuel Messager in the capacity of GeneralDirector, undertakes to comply with all legal and regulatory requirements for the collection and processing of your personal data, in accordance with Regulation (EU) no. 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (known as “GDPR”) and Law No. 78-17 of 6 January 1978 on Data Processing, Data Files and Individual Liberties (known as the “Information Technology and Liberties Act”) in its current modified form (hereinafter referred to collectively as “the Regulations”).
S3PWeb will never use your personal data illegally or unfairly. It will also never sell or lend it to third parties under any circumstances.
The term “personal data” refers to any information relating to a natural person that could be used to identify them, directly or indirectly. This can include their name, surname, email address, postal address, telephone number, user name, password, etc. (hereinafter “Personal Data”). Under the Regulations, S3PWeb acts as Data Controller for Personal Data collected through the Website.
3. What personal data we collect and when
When you contact us and ask for information through our online forms and/or comments on our dedicated spaces, we collect Personal Data and other information you provide, including:
- Information relating to your identity, such as your name and surname;
- Information relating to your contact details, such as your phone number, e-mail address, postal address, and your position within the
company you represent;
- Information relating to the company you represent, such as the company name/trading name, head office, phone number, industry, and number of staff;
- Any other relevant information that may be contained in your message.
When you visit our Website we may also collect information relating to your web browser (IP address and logs). Subject to the choices you have expressed and that you may change at any time, “Cookies” may be installed on your device to remember your browsing preferences and measure traffic to our Website. Further information on these cookies is given in Article 10 of this Policy.
When you log into your personal account as a customer or partnerthrough our Website to the respective URLs https://app.s3pweb.io and https://partner.s3pweb.io, we also collect your connection information (IP address and logs).
4. Why we use your Personal Data
Personal Data collected through your contact with us
- To answer your questions, messages, and/or comments
- To send you newsletters, alerts, promotions, etc. and/or offers (by physical, phone, and/or email contact) about services you may be
Personal Data collected through your use of our Website
- To use your preferences to improve your experience
- To improve the quality of our services by analysing traffic to our Website.
Personal Data collected through your logins to your personal account
- To resolve any potential technical problems with our services
- To check our services are not being used illegally or fraudulently and to block fraudulent users if needed;
S3PWeb will only collect and process your Personal Data for the purposes specified above. Any use of your Personal Data for a purpose other than those above will require your express prior authorisation.
5. The legal bases on which we process your Personal Data
The collection of your Personal Data by S3PWeb when you use the Website is always on a legal basis. In accordance with the Regulations, your Personal Data can only be collected and processed in the following cases:
- When you have consented to the processing (e.g. by expressly accepting our cookies, or implicitly by entering your details into our
- When processing is required to execute a contract you have agreed with S3PWeb (e.g. to allow you to access your personal account);
- When the processing is justified by the need to protect our legitimate interests (e.g. to improve the quality of our services, or to check you are not abusing or fraudulently using our services);
- When we are required to carry out the processing by a legal or regulatory obligation (e.g. to ensure data security and prevent digital
6. Who we share your Personal Data with
The following are the only cases in which S3PWeb is permitted to share your Personal Data with third parties without your consent:
- When it is required in order to provide our services (e.g. shared with technical, hosting, or information security service providers)
- When it is legally required or required by a court (e.g. if we are required to do so by law, a regulatory requirement, or a court order, or if this sharing is necessary for an investigation, injunction, or legal process within France or overseas)
- When it is required in order to apply this Policy (including to detect possible breaches of this Policy) and to protect against any violation of the rights, assets, or security of S3PWeb and our service users, in application of and in accordance with the law (e.g. lawyers, bailiffs, etc.).
Furthermore, unless in receipt of your express refusal, S3PWeb also reserves the right to share your Personal Data with its sister companies (B2PWeb, S2PWeb and PFM Solutions) as well as its other commercial partners, and likewise for its marketing communications partners, in order to provide you with offers related to your use of S3PWeb services. S3PWeb undertakes to only communicate your Personal Data to trusted and authorised sub-contractors who will process it on our behalf and in accordance with our instructions, and in compliance with current Regulations.
7. How long we’ll store your Personal Data
Identification and contact information collected through your contact with us through our Website
3 years from the date of the last time you contacted us (or from the end of our commercial relationship if you were a customer) - unless
requested to remove it soonerNavigation data collected through your use of our Website
13 months from the date of collectionLogin data from your personal account
1 month from the date of collection
However, in some situations we may store your data longer, including to comply with applicable legislation, to manage claims and/or disputes, todefend our interests or assert our rights, or to comply with requests from competent authorities.
We will not store the data for any longer than necessary and when it is no longer needed, we will securely destroy it in accordance with our internal policy or render it anonymous.
8. How we keep your Personal Data secure
We employ organisational and technical measures to protect your Personal Data from unauthorised access, communication or publication; modification, alteration, damage, loss, and accidental or illicit destruction; and from any other form of illicit or unauthorised processing.
To do this, we require our staff and our technical service providers to comply with strict information security and protection measures (e.g. contractual confidentiality obligations, use of anonymisation and encryption techniques, implementation of physical security measures, etc.).
Our protective measures include the use of firewalls and other protective software measures; encryption and distributed storage of data;controlling technical access to our databases, including through the use of filtering and logging of access; and controlling physical access to our data centres.
Furthermore, we confirm that your Personal Data is stored on servers located within the European Union.
9. Your Personal Data rights
9.1 – Your rights
Any internet user whose Personal Data is processed by S3PWeb when using the Website has the following rights:
- Right of access (e.g. the right to check the Data we store relating to you and to receive a copy);
- Right to correction (e.g. the right to update or correct your Data if it is incomplete or incorrect);
- Right to limitation (e.g. in certain cases specified by law, if you question the processing of some of your Data you may request that we limit the use of it while our dispute is resolved);
- Right to portability (e.g. the right to recover your Data and/or require its transmission to third party providers);- Right to erasure (e.g. the right to have your Data erased as soon as possible, subject to our legal obligations to retain data);
- Right to object (e.g. the right to object at any time to the processing of your Data for certain purposes, including marketing activities);
- Right to not be subject to a decision based solely on automated processing which has a legal or similarly significant effect on you;
- Right to define general and specific guidelines for how you wish the aforementioned rights to be exercised after your death.
9.2 – Exercising your rights
You can exercise these rights at any time by sending your request to the addresses cited in Section 11 below. We may ask for proof of identity if there is any doubt over your identity. If you exercise these rights, we will endeavour to respond as soon as possible, and in any case, within the legal period of one month from the date your request is received. If necessary, and as permitted by law, this period may be extended to 2 months if your request to S3PWeb are complex or numerous. If necessary, you will be informed of this delay
and the reasons for it. If S3PWeb fails to act on your request, we will inform you of the reasons why and, if you deem it necessary, you can submit a claim to CNIL and/or begin legal proceedings.
9.3 – CNIL
To find out more about your rights or to submit a claim, you can contact the Commission Nationale de l’Informatique et des Libertés (“CNIL”) through its website https://www.cnil.fr.
10.1 - What is a cookie?
A cookie is a small text file added to the browser on an internet user’s device (e.g. computer, laptop, tablet, mobile phone) when they navigate a website. Cookies are used by most websites to ensure proper function and/or to enable the user’s experience to be improved. They also provide certain information to the owners of these sites, such as audience measurement. The information collected using cookies allows S3PWeb to analyse the use of its Website and to offer internet users a better experience. The information collected by these cookies is not used to send advertising messages to the internet user by email or by post. The cookies stored by us or by third parties when you visit our Website do not personally identify you as an individual, only the device you are currently using. Cookies simply provide information on your navigation so your device can be recognised later.When you access the Website you will be alerted to the existence of these cookies by a banner at the bottom of the homepage. You can configure these cookies using the “Manage my cookies” cookie manager a the bottom of the screen.
10.2 – Who applies the cookies and the ones used by us
(a) S3PWeb cookies (“first party” cookies)
These cookies are strictly necessary for our Website to function, such as saving the user’s preferred language. These cookies only collect data relating to the date, time, protocols used by the user’s device, and the page being viewed. S3PWeb does not provide this data to third parties, does not reuse it for purposes other than the functioning of the Website, does not link these with other processing including customer files, and does not store them for longer than thirteen (13) months.
(b) Third-party cookiesThese are marketing cookies applied by third-party companies such as YouTube, when a video is posted onto our Website. We have no control over the use of these cookies by third parties.
10.3 – Accepting or refusing cookies
You can express or modify your cookie preferences at any time using our cookie manager located at the bottom of our website, or through one of the methods described below:You can configure your device so that it automatically:
• Accepts all cookies; or • Informs you when a cookie is applied; or • Only refuses certain cookies; or • Never accepts any cookies. Please note that these settings may affect your access to our services, which require the use of certain cookies. If your browser is configured to refuse all cookies, you will not be able to use of some of the basic functions of our website.
If this occurs, we decline any responsibility for consequences related to decreased performance of our services due to the inability for us to apply or check the cookies required for them to function and that you have refused or deleted.
Configure your browser to manage the cookies in line with your preferences, while considering the purposes of the cookies mentioned above. Instructions on how to configure these settings are available from each browser’s website.
11. Contact us!
For any questions concerning this document and general inquiries about the collection and processing of your Personal Data by S3PWeb and its partners, you can contact our Data Protection Officer (DPO) as follows:
By email: firstname.lastname@example.org
By post: 90 Rue Charles Nungesser, 29490 Guivapas, France