Our privacy policy

1. General / Who are we ?

PUBEO SAS :
- whose registered office is located at 14 rue Guyot, 50220 SAINT-QUENTIN-SUR-LE-HOMME - FRANCE,
- and whose offices are located at 07 boulevard Willy Stein, 50240 SAINT-JAMES - France
as data controller, attaches great importance to the protection and respect of your privacy.

This policy is intended to inform you of our collection practices, the use and sharing of information you provide to us through our site (the "Site") accessible from the website www.r1-agency.com.
PUBEO SAS and R1-AGENCY.COM will hereafter be referred to as "PUBEO", "R1-AGENCY", "we" or "us".

This policy (and our Legal Notice and any documents referred to therein as well as our page on Use of Cookies) sets out how we process the personal data we collect and that you provide to us. We invite you to read this document carefully in order to know and understand our practices regarding the processing of your personal data by us.

2. The information we collect

We may collect and process the following data :

2.1. The information you provide directly to us

When you use our sites, you may provide us with information, some of which may identify you ("Personal Information"). This is particularly the case when you fill in forms (requesting a quote, catalogues or via the contact page), but also when you contact us - whether by telephone, email or any other means of communication - or when you tell us about a problem.

This information includes the following data :

2.1.1. Data necessary for commercial exchanges. This data includes your first and last name, e-mail address and business telephone number, This information is mandatory. Otherwise, PUBEO SAS will not be able to respond to your request;

2.1.2. Postal addresses; Used for billing and delivery of our products.

2.1.3. A copy of all email exchanges between you and PUBEO SAS;

2.1.4.Details of commercial, financial and accounting operations (quotations / batches / deposits / invoices)

2.1.5. Data that we may ask you to provide when you make a specific request, or report a problem with our products or services, such as the purpose of your support request;

2.2. The data we collect automatically

2.2.1. In the event that you interact with our social networking pages made available to you, PUBEO SAS will have access to some of the data (in particular, your first name, last name, photograph, e-mail address and number of Facebook friends) from your account on the said social network in accordance with the general terms of use of the social network concerned. We may also collect some of your Personal Data when you interact with features of these social networks, such as "Like" features.

2.2.2. During each of your visits, we may collect, in accordance with applicable law and with your consent, if any, information relating to the devices on which you use our services or the networks from which you access our services, such as your IP addresses, connection data, types and versions of internet browsers used, types and versions of browser plugins, operating systems and platforms, data concerning your browsing path on our Platforms, including your path through the various URL pages of our Platforms, the content you access or view, the search terms used, download errors, the duration of the consultation of certain pages, your device's advertising ID, interactions with the page, and any telephone numbers used to contact us. Some of the technologies we use to collect this information include cookies (for more information on this, please refer to the page on the use of cookies).

2.2.3. Finally, we collect information relating to your company and the position you hold when you send us, for example, this information in the signature of our email exchanges, This information is collected and completed if necessary by consulting the database produced by the companies Linkedin (data publicly accessible in accordance with the general conditions of use of the professional social network) and Infogreffe.fr (data from the information transmitted directly from the commercial court registry).

3. How long we keep your data

3.1. With the exception of the categories of Personal Data referred to in articles 3.2. below, your Personal Data is archived after the following periods :

• 5 years after your last interaction with our company, if you have not made a request for deletion of the data ;
• 1 year after the request to delete your data

3.2. The following categories of Personal Data may be retained for different periods of time :

• Financial data (e.g. payments, refunds, etc.) are kept for the period of time required by applicable tax and accounting laws ;
• Content created by you on our sites (such as comments, reviews and ratings) are anonymised after the time periods mentioned in 2.3.1 but remain visible on our sites.

4. How we use the data we collect ?

We use the data we collect to :

5. Who are the recipients of the information we collect and why do we give them this information ?

5.1. We may share information about you, including Personal Information, with other Pubeo entities in accordance with this policy

5.2. We also work closely with third party companies who may have access to your Personal Information, including

• our business partners on whose websites we may advertise our services;
• Subcontractors we use for technical services, payment services, identity verification and analytical solution providers.

5.3. We only share your data with the third parties mentioned in 5.2. above in the following cases :

• 5.3.1. We publish the reviews that you write as part of our review system on our Platforms. These reviews, which contain your first name and the first letter of your name as well as your photograph, are visible to all visitors to our Platforms ;
• 5.3.2. When we use search engine and analytics providers to improve and optimize our sites
• 5.3.3. When we are legally required to do so or if we believe in good faith that it is necessary to (i) respond to any claim against PUBEO SAS, (ii) comply with any legal request, (iii) enforce any contract entered into with our members, such as the Terms and Conditions of Sale and Use and this Privacy Policy, (iv) in the event of an emergency involving the public health or physical safety of any person, (v) in connection with investigations and enquiries, or (vi) to protect the rights, property, and safety of PUBEO SAS, its members, and generally any third party ;
• 5.3.4. In the event that we sell or acquire a business or assets, in which case we reserve the right to share your Personal Data with the prospective seller or buyer of that business or assets.
• 5.3.5. If PUBEO SAS or all or part of its assets are acquired by a third party, the data in our possession will, if necessary, be transferred to the new owner.
• 5.3.6. In accordance with applicable law and with your consent where required, we may aggregate data about you that we receive or send to our business partners, including some or all of your Personal Information and information collected through cookies. This aggregated information will only be used for the purposes described above.

• 5.3.7. Please note that if you choose to give us access to some of your information, including Personal Information, through the connection services provided by our business partners, their privacy policies are also enforceable against you. We have no control over the collection or processing of your data by our business partners on their own platform.

6. Targeted advertising, emails and SMS that we send you

In accordance with applicable law and with your consent where required, we may use the data you provide to us on our Sites for marketing purposes (for example to (i) send you our newsletters, (ii) send you invitations to our events or other communications that may be of interest to you and (iii) display targeted advertisements on social media platforms or third party sites).

With regard to promotional emails : You may withdraw your consent at any time by (i) unchecking the relevant box in your account, (ii) clicking on the unsubscribe link provided in each of our communications or (iii) contacting us as described in Section 12 below.

With regard to promotional SMS : You may withdraw your consent at any time by sending STOP to the sender's number, or by contacting us as described at Article 12 below

With regard to targeted advertising :

• On social networking platforms (e.g. Facebook, Twitter): you can object to this processing at any time by configuring the advertising settings in your account;
• On third party sites: you can refer to our about Cookies to understand how to withdraw your consent.

7. Is your data secure and where is it stored ?

As a general rule, we store your Personal Data within the European Union (servers in Switzerland and France). However, to the extent that, for example, some of our service providers are located in countries outside the European Union ("Third Countries"), we may transfer some of your Personal Information to Third Countries. This may be the case in particular to Third Countries for which the European Commission has not taken an "adequate protection" decision. In such a case, we ensure that the transfer is carried out in accordance with the applicable regulations and guarantees a sufficient level of protection of the privacy and fundamental rights of individuals (in particular through the European Commission's standard contractual clauses).

Upon request to our Data Protection Officer (dpo@pubeo.fr), we can provide you with more information about these transfers (including the European Commission's standard contractual clauses).

Your Data is stored on secure servers protected by firewalls and antivirus software. However, due to the inherent characteristics of the Internet, we cannot guarantee the optimal security of information exchanges on this network. We strive to protect your Data, but we cannot guarantee the absolute security of information transmitted to the Site. You transmit your Data at your own risk. In this respect, we remind you that the security of your information is also your responsibility.

8. What are your rights regarding your personal data ?

8.1. You have the right to receive a copy of your Personal Data in our possession ("right of access").

8.2. You may also request the deletion of your Personal Data and the rectification of erroneous or obsolete Personal Data ("right of deletion and right of rectification"). Please note that we may retain certain information about you where we are required to do so by law or where we have a legitimate reason to do so.

8.3. You also have the right to object at any time, on grounds relating to your particular situation, to (i) the processing of your Personal Data for direct marketing purposes or to processing carried out on the basis of our legitimate interest ("right to object").

8.4. You have the right to limit the processing of your Personal Data ("right to limit"). Please note that this right only applies if (i) you challenge the accuracy of your Personal Data during the period of time required for us to verify its accuracy; (ii) in the event of unlawful processing by us and you request a restriction of their use rather than erasure; (iii) we no longer need the Personal Data for the purposes of processing but they are still necessary for you to establish, exercise or defend legal claims; (iv) in the event of your exercising your right to object for the duration of the verification as to whether the legitimate grounds we are pursuing prevail over yours.

8.5. You have the right to lodge a complaint with the competent supervisory authority or to obtain redress from the competent courts if you consider that we have not respected your rights.

8.6. You also have the right to the portability of your data, i.e. the right to receive the Personal Data you have provided to us in a structured, commonly used and machine-readable format and the right to transmit this data to another data controller ("portability right")

8.7. You also have the right to define directives concerning the fate of your Personal Data after your death.

8.8. To exercise these rights, you can contact our Data Protection Officer in the manner set out at Article 12 below.

9. Cookies and similar technologies

For more information, see our page on the use of cookies.

10. Links to other websites and social networks

Our websites may occasionally contain links to the websites of our partners or third party companies. Please note that these websites have their own privacy policies and that we are not responsible for the use made by these websites of the information collected when you click on these links. We encourage you to review the privacy policies of these sites before submitting your Personal Information to them.

11. Changes to our privacy policy

We may change this privacy policy from time to time. When necessary, we will notify you and/or seek your consent. You should check this page regularly for any changes or updates to our privacy policy.

12. Contacts and information requests

If you have any questions about this privacy policy or any requests relating to your personal data, you can contact us by :

• sending an email to our Data Protection Officer at dpo@r1-agency.com
• by filling in the online contact form
• or by sending us a letter to the following address :
  
  PUBEO SAS
  For the attention of the Data Protection Officer
  Espace Eco Michel Thoury
  7 boulevard Willy Stein
  50240 SAINT JAMES