Sidetrade SA, a French corporate entity registered in the registry of commerce , located 114, rue Galliéni, 92200 Boulogne-Billancourt, FRANCE, (hereinafter “Sidetrade”) processes Personal Data (as defined below) of people browsing the www.sidetrade.com website of Sidetrade (the “Site”).
Personal data (“Personal Data”) means any information relating to an identified or identifiable person. An identifiable person is a person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the person.
Non-Personal Data means any information that does not result in the identification of a person.
Sidetrade will be the data controller in respect of personal data relating to Sidetrade’s own activity, in particular its clients and prospects data. Sidetrade will comply with all relevant provisions of data protection laws (in particular the General Data Protection Regulation -GDPR) applicable to Sidetrade in its role as data controller.
2. DATA COLLECTED
In order to use certain functions and features of the Site, Sidetrade requires that You provide certain Personal Data when visiting or using the Site. Personal Data likely includes:
- first and last name,
- postal address,
- email address,
- telephone number(s),
- company, company size, department and job title,
- industry and industry sub-industry sectors,
- IP address, andany other Data as may be relevant for the purposes listed below.
In all cases, however, the Personal Data gathered is limited to data necessary to the purposes described under Article 4.
You are free to decide whether or not to provide all or part of Your Personal Data. However, if You choose not to provide all or part of this Personal Data, the purposes as described in Article 4 hereafter might not be achieved or not properly achieved, some areas and functions of the Site may not function properly and/or You may be refused access to certain pages on the Site.
With regard to clients, the provision of personal data is a contractual requirement. Processing is necessary for the performance of the contractual relationships with Sidetrade and personal data will be stored during the performance of the Agreement and the statutory periods of limitation.
With regard to prospects, processing is based on the legitimate interests pursued by Sidetrade in order to develop the knowledge of the Sidetrade Service on the market and personal data will be stored during three years from collection by Sidetrade or the last contact from the prospect.
Sidetrade, and its processors and partners entering into the performance of the Sidetrade Service, will be the recipients of the personal data.
3.METHODS AND PURPOSES OF COLLECTION OF PERSONAL DATA
As stated above, You provide Your Personal Data on a voluntary basis.
Personal Data is generally collected to carry out the business of Sidetrade, such as improving Sidetrade’s marketing and advertising efforts, better tailoring Sidetrade products and services to customers’ needs or complying with reporting obligations required by law, and similar activities.
Your Personal Data collected by Sidetrade on or through the Site is used by Sidetrade for the following purposes:
- enable You to request information,
- To provide You with a personalised interactive use of the Site,
- To ascertain Your requirements and interests and provide You with the most suitable products and/or services,
- To allow You to open and maintain an account in order to obtain specialised documentation and technical assistance,
- To enable You to subscribe to a commercial or support-type service,
- To access all the features and options offered by the Site, and
- Any other purposes associated with the above purposes.
By providing Your e-mail address, You hereby expressly authorize, Sidetrade and its subsidiaries to use it together with other relevant Personal Data to send You commercial or marketing messages.
Sidetrade might also use Your email address for administrative or other non-marketing purposes (for example, to notify You significant changes to the Site).
4. Special case of indirect collection
Without prejudice to the application of article 14-5-a and 14-5-b of the GDPR, article 95 of the GDPR and the doctrine of the CNIL in terms of electronic prospecting, it is specified that Sidetrade can obtain, from well-known third-party partners in the market and recognized for their expertise in the management of personal data, personal data of data subjects for the purposes of electronic prospecting “Business to Business”. In accordance with Recital 47 of the GDPR, Sidetrade may, in response to its legitimate interest of promoting awareness of its services, process such personal data for purposes of commercial prospecting. In such a case of indirect collection, it is specified that any person concerned has the rights governed by Article 14 of the GDPR and, more broadly, a right of access, rectification, deletion, limitation and the right not to be subject to a decision based solely on automated processing. It is expressly stated that it also has the right to object, at any time and freely, to the processing of his personal data for commercial prospecting purposes.
Cookies are text files stored and used to record non-personal and personal information concerning Your browsing of the Site.
- enabling a service to recognize your device so You don’t have to give the same information several times during one task,
- recognizing that You may already have given a username and password so you don’t need to do it for every web page requested,
- measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they are fast,
- analyzing data to help Sidetrade understand how people interact with services so Sidetrade can make them better.
Sidetrade uses two types of cookies: permanent cookies and temporary cookies. Temporary cookies disappear as soon as You log off from the Site. Permanent cookies remain after logging off from the Site in order to be used on subsequent visits to the Site.
You will be notified the first time You receive a cookie, and then You decide whether to accept it or refuse it. By continuing to use the Site in consideration of the above, You expressly authorize Sidetrade to use such cookies.
You can also configure Your browser software to refuse all cookies; if You do so, however, some areas and features of the Site may not function properly and/or You may not access some parts or services of the Site.
6. PERSONAL DATA PROCESSING AND STORAGE TERM
Processing of Personal Data includes using, storing, recording, transferring, adapting, summarizing, amending, reporting, sharing and destroying Personal Data as necessary under the circumstances or as otherwise required by law.
All Personal Data that will have been collected will be stored for a limited duration that is relevant to the purpose of such collection and for so long as required by applicable law.
7. LINKS TO WEBSITES NOT CONTROLLED BY SIDETRADE OR ITS SUBSIDIARIES
This Site might offer links to third party Websites which may be of interest to You.
Unless Sidetrade receives Your express authorization, Sidetrade does not share any Personal Data with these third parties. However, Sidetrade may provide them with Non-Personal Data.
Sidetrade does not exercise any control over the content of third party Websites or the practices of these third parties in connection with the protection of Personal Data that they might collect and are thus not in the control of Sidetrade. Consequently, Sidetrade declines all liability for the content of third party websites or the practices of these third parties concerning the protection of Personal Data.
It is therefore Your responsibility to inform yourself as to these third parties’ privacy policies.
8. TRANSFER OF PERSONAL DATA
You will have the opportunity to decide whether You authorize Sidetrade to use Your Personal Data for a purpose differing from the purpose for which it was originally collected.
Sidetrade will also disclose Personal Data to third parties if Sidetrade determines that such disclosure is necessary for technical reasons (such as hosting services by a third party) or to protect Sidetrade’s legal interests (such as in the event of acquisition or merger by a third company or total or partial liquidation of Sidetrade).). These transfers may be transmitted over the internet, via mail, via facsimile, or by any other method which Sidetrade determines is appropriate and in accordance with applicable law.
9. RIGHT OF ACCESS TO AND RECTIFICATION OF THE DATA
You have a right to access Your Personal Data. In addition, You have a right to request the rectification, completion, update or erasure of Your Personal Data. You also have a right to obtain a copy of the Personal Data conserved by Sidetrade, as well as the right to data portability as long as the conditions set forth in the GDPR are met. You have also the right to lodge a complaint with a supervisory authority.
Otherwise, You may exercise Your rights of access to and rectification of the data by sending an email to the following address: firstname.lastname@example.org.
Depending on the scope of the request, Sidetrade reserves the right to charge a reasonable fee to cover any out-of-pocket costs incurred in connection with such access, modification and deletion of Personal Data. Sidetrade may deny access to Personal Data in limited circumstances, defined by applicable laws and regulations.
10. DATA SECURITY AND RECIPIENTS
Sidetrade undertakes to ensure the protection and security of Personal Data that You choose to communicate, in order to ensure the confidentiality of Your Personal Data and prevent Your Personal Data from being distorted, damaged, destroyed or disclosed to unauthorized parties.
Sidetrade maintains reasonable physical, electronic, and procedural safeguards to protect Personal Data from loss, misuse and unauthorized access, disclosure, alternation and destruction. As part of those safeguards, Sidetrade employs sophisticated technology designed to protect Personal Data during its transmission and prevent transmission errors or unauthorized acts of third parties. However, while Sidetrade strives to protect Your Personal Data, in light of the inevitable risks of data transmission over the internet, Sidetrade can not guarantee full protection against any error occurring during the course of Personal Data transmission which is beyond Sidetrade’s reasonable control.
Since all Personal Data is confidential, access is limited to employees, contractors and agents of Sidetrade or Sidetrade Group Companies who have a need to know such data in carrying out their tasks. All the people who have access to Your Personal Data are bound by a duty of confidentiality and subject to disciplinary actions and/or other sanctions if they fail to meet these obligations.
11. DISPUTE RESOLUTION
Although Sidetrade has put in place reasonable safeguards to protect Personal Data, we recognize that there is no method of transmitting or storing Personal Data that is completely secure.
However, Sidetrade is committed to ensure the privacy of Personal Data: if You have a reason to believe that the security of Your Personal Data has been compromised or misused, You should contact Sidetrade via the following address: email@example.com.
Unauthorized access to Personal Data or the improper use of Personal Data may constitute offences under local law and under the regulations in force within each company in the Sidetrade group.