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PRIVACY POLICY

Last update: December 14th, 2023

The SATODEV Privacy Policy (this “Policy”) describes SATODEV’s (“we”, “us”, “our”, “SATODEV”) practices with respect to the collection, use, storage and disclosure of personal data we collect i) from online visitors of our website (“Website”), ii) when you use our software (collectively the “Services”) or otherwise iii) that are provided by our service providers.

We may modify this Policy from time to time. Such modifications, additions, or deletions shall be effective immediately upon notice thereof. Indeed, when we post changes to this Policy, we will revise the “last modified” date at the top of this page. We encourage you to periodically review this Privacy Policy to be informed of how we collect, use, protect and disclose your information. By accessing and/or using our Services, you signify your understanding of, and agreement with, this Policy. If you do not agree with our policies, please do not access our Services.

1. Important information and who we are

This privacy policy aims to give you information on how SATODEV collects and processes your personal data through your use of the Services. Our Website and Services are not intended for minors under the age of 16 and we do not knowingly collect data relating to minors.

It is important that you read this Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. Whatever the activity may be, we will only collect personal data to the extent deemed reasonably necessary to fulfill the objective pursued by French Act no.78/17 of 6 January 1978 on Information Technology, Data Files and Civil Liberties as well as the General Data Protection Regulation (GDPR) which takes effect on May 25, 2018.

We collect personal data only in the context of our activities, and in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 applicable from 25 May 2018 (‘the European Data Protection Regulation’ or ‘GDPR’) and French Law n°78/17 of 6 January 1978 relating to data processing, files and freedoms.
SATODEV is a French simplified joint-stock company, registered with the Trade and Companies Registry of Bordeaux, under number 521 626 580, with registered offices located at 58, Avenue Marcel Dassault – 33700 MÉRIGNAC, France.
SATODEV processes personal data concerning you as a Data controller. You can contact us either by email, at the following address: rgpd@satodev.fr, or by post, at the following address: SATODEV – 58, Avenue Marcel Dassault – 33700 MÉRIGNAC, France.

2. Types of data we collect and how we collect them

We collect two types of information about you: “Identifying Data” (personal data) and “Non Identifying Data”.
Identifying Data means any information (direct or indirect such as “first name”, “last name”, navigational data, etc.) about an individual from which that person can be identified.

It does not include data where the identity has been removed (anonymous data). It refers to information that lets us know the specifics of who you are.

We generally collect information in three ways: (A) you voluntarily provide information to us,
(B) we collect information automatically from your use of the Services, such as through cookies or our software, and
(C) other parties may provide information to us. Each of these methods is described in more detail below.

(A) Information you provide directly

We collect personal data about you when you voluntarily provide it to us and in particular when you:

Sign up to a newsletter;
Contact us about consumer comments or complaints;
Contact our customer service or technical support;
Send e-mail messages, submit forms, or transmit other information by telephone or letter;
Post any content/comment on SATODEV’s social networks.

In a general way, you provide us with the following personal date:

Last name;
First name;
Mailing address (including zip code);
E-mail address;
Job title and department;
Telephone and facsimile numbers;
Demographical information (such as your age, gender, the device you own etc).

This is not a comprehensive list, but it is representative of most cases.

When we collect your personal data which are necessary for the purposes as specified in Section 3 (A) below, please note that it is essential that you complete the fields marked with an asterisk (*). Otherwise, we may not be able to provide you with all or part of the Services. Fields not marked with an asterisk are optional, this information allows us to get to know you better and to improve the Services we offer you.

(B) Information we collect automatically

We automatically collect personal data when you use our Services. We typically aggregate this data and use it in statistical form rather than using it to identify individuals. If a combination of information that we collect does identify you as an individual, we will treat the combined information as personal data.

We also collect information through technologies such as web browsers, cookies, web beacons, etc. We use the information for purposes such as modifying or improving features, addressing technical issues, preventing misuse of our Services, and conducting data analytics. The type of information that we automatically collect may vary, but generally includes

Technical information about your computer, device, hardware, or software you use to access the Internet or our Services, such as IP address or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system related specifications);
Usage information and statistics about your interaction with the Services, which may include the URLs of our Website that you have visited, URLs of referring and exiting
pages, page views, time spent on a page, number of clicks, platform type, and other statistics relating to your use of our Services;
Crash reports, which may be automatically generated when a software crashes and includes information about your system and the crash;
Information that facilitates a safer and more personalized experience, such as user identification provided in connection with your use of our Services, and device identifiers or usage information for authentication and fraud prevention purposes; and
The location of your device, such as may be derived from your device’s IP address.

Cookies

Cookies are a feature of your web browser that allows websites to transfer bits of information to your device for record-keeping purposes. A cookie stored on your device can be used to “remember” things like that you have already registered. This allows us to speed up your future activities, saving the time you would normally spend entering information. In addition, SATODEV may use cookies to retrieve user information for marketing or security purposes. To find out more on the content of cookies and know how to exercise your rights relating to cookies, please click on the “Cookies” tab on our Website.

Internet protocol addresses

An Internet Protocol (“IP”) address is the unique number assigned to your server or Internet Service Provider (“ISP”). SATODEV may track such IP addresses for system administration, to report aggregate information, site tracking, security purposes, or to prevent our servers from being abused.

SATODEV may collect information in the form of logs: files that record website activity and gather statistics about web users’ browsing habits. For most websites, these entries are generated anonymously, and help SATODEV determine (among other things) how many and how often users visit our Website, which pages they visit, and other similar navigational data. However, certain log files may contain personal data which we may use in accordance with this Policy. Log files advise us to log technical data or information relating to the use of the Website. We may use the data stored in these files (for example, an IP address, along with your personal information) for the purpose of solving technical problems, ensuring online security.

Beacons

Web beacons are small pieces of data that are embedded in images on the pages on some of our Website. We may use beacons to analyze the traffic patterns on our Website, such as the frequency with which users visit various parts of our Website, or in HTML e-mails that we may send to our users to determine whether those e-mails are opened or whether the links in the e-mails are followed. Certain data obtained from beacons may contain personal data which we may use in accordance with this Policy.

We are also working closely with third parties including, for example, the owners of the software distributed by SATODEV, web and communications agencies, service providers for website management and hosting, social networks, etc. We may receive information about you from them. This may be combined with other information you provide to us, as described above.
Thus, we may collect personal data on third party network. In this context, those third parties inform you and validly collect your consent in accordance with the provisions of the GDPR, for the collection and transmission to SATODEV of your personal data via the application programming interface (API). This transmission will only take place if you consent to it via a positive act (e.g. by clicking on an “Accept” button) for the aim of processing of your personal data by SATODEV following this transmission.

Once SATODEV receives your data from third parties, we process them in accordance with this Policy, in our capacity as Data Controller.

The legal grounds of our data processing

We process personal data only if at least one of the following applies:

You give us your consent to the processing of your data, when necessary;
The existence of our legitimate interest, or that of a third party, which justifies that we process the personal data concerned;
The performance of a contract or pre-contractual measures between you and us require that we process the personal data concerned;
We are required to comply with legal and regulatory obligations, which require the processing of the personal data.

3. How we use and share information

As a general matter, we use (A) and share (B) the information we collect to help us customize, analyze, improve and provide the Services.

(A) Use

We may use personal data we collect about you for various purposes, such as to:

Allow you to use SATODEV’ Services;
Management of software development activities (such as to implement corrective solutions and improve the products);
Management of sales activities (such as to offer and provide products and services, and any solutions required);
Communicate with you, respond to your requests, or provide you with updates and information;
Conduct user satisfaction surveys;
Send you newsletter, advertising or other promotional material; as well as
Personalize your experience, save your preferences and provide similar user- experience features;
Track statistics about our Website and more generally speaking about our Services;
Ensure the security of the Website and/or Services;
Comply with legal obligations.

Unless relevant legal provisions mandate a different data retention period, we will store your personal data for the duration necessary to process it according to this Policy. We archive your personal data during the entire statutory period of limitations.

(B) Sharing

The personal data that we collect, as well as those that will be collected subsequently is intended for us in our capacity as data controller.
We ensure that only authorized persons have access to this data. Some personal data may be sent to third parties or to legally authorized authorities in order to meet our legal, regulatory or contractual obligations (as described below).

When sharing your information with our technical service providers and/or subcontractors for proper operation of our Website, we are committed to ensuring these technical service providers and/or subcontractors comply with the terms in this Policy. If SATODEV subcontracts all or part of the processing of personal data to processors, SATODEV will require that its processors provide contractual guarantees on the security and confidentiality of personal data by means of technical data protection measures and appropriate human resources.

SATODEV strictly supervises the exchange of data with its partners during our contractual commitments. We therefore favor providers located in France and from the European Union. We do not transfer data outside of EEA member states.

4. How we secure your information

Maintaining the security and confidentiality of your information is of utmost concern to us. That’s why we implement appropriate administrative, technical, and physical safeguards, with regard to the nature of the data we process and the risks of the processing, to protect your personal data from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or access / use by non-authorized third parties and other unlawful forms of processing, in compliance with data protection regulations. We also strive to limit access to personal data to those employees or contractors who need to know such information.

We carry out periodic reviews of our security procedures with a view to implementing new and updated technologies where appropriate. However, despite the wide range of initiatives and measures in place, no security protocol is perfect, infallible or impenetrable.

5. Your choices on collection and use of information

When necessary, we provide you with choices regarding certain personal data uses, particularly around communication and marketing. If you subscribe to our newsletter and indicate that you are interested in receiving offers or information from us, we may occasionally send you direct emails about our products and services that we feel may be of interest to you. If, at any time, you wish to opt-out of receiving information from us about new products, services, or promotions, you can do so. Just send an email to rgpd@satodev.fr. Be sure to type

“opt-out” in the subject line, and include your full name, and email address in the message. In addition, along with almost every communication sent to you, we provide you the opportunity to discontinue receiving future communications (i.e., unsubscribe).

Other examples of your choices include:

You can deactivate the saving of Cookies or adjust your browser to inform you about the placing of Cookies;
You can change your privacy settings on other parties’ websites, such as social networks, which will stop or limit our receipt of information from those other websites. You also may choose not to use social features we make available. If you choose to use these features, we recommend you avoid posting personal information that will be visible to others;
You may change your browser settings or take other steps to block, manage, or delete cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some parts of our Websites may not work properly.

You may also exercise and amend your choices by sending an email to us as detailed in the “How to Contact Us” section below.

6. Your rights

Data protection law provides “Data Subjects” with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their personal data. Data Subjects also have the right to lodge a complaint with the relevant data protection authority if they believe that their personal data is not being processed in accordance with applicable law.

Yours rights of access to and rectification of your data

You may request copies of your personal data. If you would like to make a subject access request (also called “SAR”) for copies of the personal data we hold about you, you may do so by writing to the Data Controller whose contact details are above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity.

You can ask us to, as the case may be, rectify or complete personal data that is inaccurate, incomplete, equivocal or expired.

The request must be unequivocal and we recommend that you specify the subject of your request: ‘access to my data’ / ‘rectification of my data’, while providing us with valid proof of your identity.

Your right to erasure of your data

You can ask us to erase your personal data where one of the following grounds applies: i) the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; ii) you withdraw the consent you have previously given; iii) you object to the processing of your personal data where there is no legal reason for such processing; iv) the processing of personal data does not comply with the provisions of the applicable laws and regulations.
However, the exercise of this right will not be possible when the retention of your personal data is necessary for compliance with laws and regulations and in particular for example for the establishment, exercise or defense of legal claims.

Your right to restriction of processing

You may request restriction of processing of your personal data in the following scenarios: i) if you want us to establish the data’s accuracy; ii) where our use of the data is unlawful but you do not want us to erase it; iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Your right to object to data processing

You have the right to object to the processing of your personal data.
You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on legitimate interests pursued by SATODEV, including profiling.
However, SATODEV may refuse your request:

If there are compelling legitimate grounds for processing the data or the data is necessary for the establishment, exercise or defence of legal claims;
If you have consented to the data being processed, you must withdraw that consent and not object;
In the event of a contractual relationship between you and us ;
If we are legally obliged to process your data;
If the processing is necessary to protect the vital interests of the data subject or of another natural person.

If you object to the processing of personal data for the purposes of commercial canvassing, you may do so without giving any reason and we will be obliged to comply with your objection.

Your right to data portability

You have the right to recover your personal data in a structured, commonly used and machine-readable format and have the right to transmit that data to another data controller without hindrance from the data controller to which the personal data have been provided, where the processing is carried out by automated means and the exercise of your right does not prejudice the rights and freedoms of third parties.

This right is limited to processing based on consent or contract as well as to personal data that you have personally generated.

Your right to withdraw your consent

When the data processing we carry out is based on your consent, you may withdraw it at any time. We will then stop processing your personal data but this will not affect the lawfulness of processing based on your previous consent.

The right to set guidelines after your death

You have the right to set guidelines for the storage, erasure, and communication of your personal data after your death in accordance with the applicable laws and regulations.

Your right to lodge a complaint with a supervisory authority

Regarding the protection of personal data, you have the right to lodge a complaint with the French data protection authority (CNIL) on the French territory without prejudice to any administrative or judicial remedy. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal data.
CNIL (COMMISSION NATIONALE DE L’INFORMATIQUE ET DES LIBERTÉS)
3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07 FRANCE
Tel. : +331 53 73 22 22 (du lundi au jeudi de 9h à 18h30 / le vendredi de 9h à 18h)
Fax : +331 53 73 22 00
Website : https://www.cnil.fr.
If you wish to introduce a complaint with the CNIL, you can complete the online form available at the following address: https://www.cnil.fr/fr/plaintes.

7. How to exercise your rights

All the rights enumerated above can be exercised by sending a request, together a copy of an ID document, to SATODEV by post to 25, Rue Marcel Issartier – 33700 MERIGNAC, France or email at rgpd@satodev.fr.

8. Links to other sites

This Policy only addresses the use and disclosure of information we collect from you. Other sites accessible through our Websites have their own privacy policies and data collection, use, and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties.

9. How to contact us

For any questions about this Policy, contact us by post to the following address:
SATODEV – 58, Avenue Marcel Dassault – 33700 MÉRIGNAC, France
E-mail : rgpd@satodev.fr

Unless specifically requested by you, the personal information sent to the email or postal address above will not be used to send you marketing communication.