PERSONAL DATA PROTECTION POLICY

SINEU GRAFF is mindful of the protection of the personal data of its customers, prospects and suppliers, as well as of any person who accesses its websites.

The purpose of this personal data protection policy and cookies is to inform you:

•   Of the types of personal data we collect about you
•   About the way in which your personal data is processed by SINEU GRAFF and any partners and subcontractors they may have
•   Terms and conditions for the use of your personal data and your rights in this regard, in compliance with European and French legislation applicable to SINEU GRAFF in France.

All operations on your personal data are carried out in compliance with the regulations in force and in particular with Regulation no. 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter the "Regulations"), and any national legislation applicable to data protection.

ARTICLE 1 – Definitions

The following terms, which begin with a capital letter, will have the following meaning:

"Personal data" - any information relating to an identified individual or one who can be identified, directly or indirectly, by reference to an identification number or to one or more elements which are specific to that individual.

"Processing of personal data" - any operation or any set of operations carried out or not using automated processes and applied to data, such as collection, recording, organisation, structuring, retention, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, reconciliation or interconnection, limitation, deletion or destruction.

"Data controller" - the individual or legal person, public authority, service or any other body which, alone or jointly with others, collects and processes personal data.

"Subcontractor" - the individual or legal person, public authority, service or any other body which processes personal data on behalf of the data controller.

ARTICLE 2 – Scope

This Policy applies to all data processing whose initiative, design and organisation are decided at the level of SINEU GRAFF SAS - 253A Route d'Epfig - 67230 Kogenheim.

ARTICLE 3 - Processing of personal data

Within the scope of the implementation of its services and the operation of its sites, SINEU GRAFF collects data about you.

 a) Legal basis for processing

Processing is based:

•   On the establishment and execution of service contracts or pre-contractual measures (such as a quote or commercial offer) at the request of the person concerned,
•   Or on the consent of the persons concerned,
•   Or on the need to satisfy the legitimate interests of SINEU GRAFF.

 b) Types of Data processed

SINEU GRAFF may collect the following data from you:

•          Identification data: title, surname, first names, postal address, telephone number (landline or mobile), email address;

•          Data relating to the commercial relationship: customer number, position, company, requests for quotes or documentation, products or services purchased, correspondence between the customer and the internal departments of SINEU GRAFF;

•          Professional data: professional email address, professional telephone number, application file (CV, cover letter, degree certificates)

•          Data relating to newsletter subscriptions: email address

•          Connection data via "My SINEU GRAFF": login, IP address, pages consulted by the user, date and time of consultation

b) Purposes

SINEU GRAFF may be required to collect and use your personal data to provide and access the services offered and to maintain current, correct and relevant information relating to you, in particular to meet one or more of the purposes listed below:

•    Managing requests for quotes, information, documentation

•   Operations relating to customer management (quotes, orders;  deliveries;  invoices;  accounting, management of customer accounts, monitoring of customer relations such as carrying out satisfaction surveys, management of complaints;  selection of customers to carry out studies, surveys and product tests, etc.)

•   Opening an online account via the SINEU GRAFF website

•    Sending requests, commercial and informative messages via email

•   Managing people's opinions on the products and services provided;
•   Managing supplier and professional partner files

•   Producing website traffic statistics

Furthermore, SINEU GRAFF may be required to collect personal data for other purposes, remaining mindful to obtain the prior consent of the persons concerned or on the basis of legitimate interest, subject to respecting fundamental rights and freedoms.

ARTICLE 4 – Data retention period

SINEU GRAFF will keep your personal data in a secure environment for the time necessary to achieve the purposes for which they were collected or for the maximum retention period provided for by the applicable legislation of your country.

These durations apply unless you request the deletion or cessation of use of your data before the expiry of these durations, for a legitimate reason not contrary to a legal obligation which is imposed on SINEU GRAFF.

ARTICLE 5 – Communication of personal data

Personal data collected is intended for the internal departments of SINEU GRAFF.

In the event that SINEU GRAFF entrusts the data processing activities to subcontractors, it will only use subcontractors which offer sufficient guarantees regarding the implementation of the appropriate technical and organisational measures, so that the processing meets the reliability and security requirements required by the applicable regulations and guarantees the protection of the rights of individuals. SINEU GRAFF may also be required to transfer data to countries recognised by the European Commission as having an adequate level of protection for data[AC1] .

In accordance with the regulations in force, data can be transmitted to the competent authorities on request and in particular to public bodies, exclusively to meet legal obligations.

ARTICLE 6 – Security measures

Taking into account the evolution of technologies, the costs of implementation, the nature of the data to be protected as well as any risks to the rights and freedoms of individuals, SINEU GRAFF implements all the appropriate technical and organisational measures to guarantee the confidentiality of the personal data collected and processed and a level of security that is appropriate and proportionate to the risk.

ARTICLE 7 – Rights of people

In accordance with Regulation (EU) 2016/679 on the protection of personal data, you have the right to request the data controller for access to the personal data that relates to you, its rectification or deletion or a limitation of the processing of your personal data and the right to the portability of this data.

For reasons relating to your particular situation, you can also object, for legitimate reasons, to the processing of data that relates to you.

For data which is not indicated as compulsory and which you have agreed to provide and allow to be processed, you have the right to withdraw your consent at any time.

You may also have additional rights provided for by the national legislation to which you are subject, such as the definition of directives relating to the storage, deletion and communication of your personal data after your death.

SINEU GRAFF has a Data Protection Officer who you can contact in the event of any problems.

To exercise your rights, you can contact SINEU GRAFF:

-          By letter – DPO SINEU GRAFF - 253 Route d'Epfig - 67232 Kogenheim

-          By email: rgpd@sineugraff.com

Please enclose a valid proof of identity to accompany these requests.

If you believe, after having contacted us, that your rights relating to your personal data have not been respected, you can address a complaint to the CNIL or to the supervisory authority in your place of residence.

ARTICLE 8 - Cookies

SINEU GRAFF uses cookies so it can adapt to the preferences of its users and optimise its Internet pages. Cookies or other technologies are used to allow you to connect to and customise the site and services. These cookies facilitate browsing and make websites more user-friendly. A cookie records information related to your computer browsing on our site (the pages you have consulted, the date and time of the consultation, etc.) that we can read during your subsequent visits. You can oppose the registration of cookies by configuring your browser settings, as explained below. Access to certain services and sections of the site may, in this case, be altered, or even impossible. The purpose of the cookies installed on the site is:

-          to  monitor audience statistics

-          to keep the My Sineu Graff session active

-          to make the online configurator available

-          to allow or facilitate electronic communication

-          to share content on social media sites

-          to record the selection to accept cookies

Refusing cookies:

You can oppose the registration of cookies by configuring your browser settings, as explained below:

    For Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

    For Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences

    For Google Chrome 4, Google Chrome 8 and above: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=fr

    For Safari: https://support.apple.com/fr-fr/HT201265

    For Opera: http://help.opera.com/Windows/10.20/fr/cookies.html

If necessary, the user is informed that access to certain services and sections of the site may, in this case, be altered, or even impossible.

The length of time cookies are kept varies depending on the type of cookie. We mainly use cookies which self-destruct after the end of the connection. These are so-called session or browsing cookies. A log file also allows us to log all access to our web pages or the downloading of the various files available on our sites, for a period of 6 months. Finally, information concerning your consent with regard to cookies is kept for a maximum period of 13 months. Cookies are used for internal use and are not accessible to a third party.

Google Analytics and Privacy

We use Google Analytics to track the audience on our sites, to find out the number of users who visit our pages and what content and pages are viewed. The analysis is anonymous. Google Analytics cookies are stored on your device and can be transferred to a Google server located in the USA where they will be saved. Google will use this information to exploit your use of the website, to compile reports on website activities for operators of the same website as well as to provide other services relating to website and internet usage. If necessary, Google will also pass this information on to third parties insofar as this is required by law and where these third parties will process this data on Google's orders.

ARTICLE 9 - Modification of this policy

In the event of modification of this Policy by SINEU GRAFF or if so required by the law, it will be published on our sites and will be effective from time of publication. Therefore, we ask that you look at it during each visit to ensure you are aware of the most recent version, which is permanently available on our websites and apps.