Privacy Policy

Privacy Policy

Contents

PREAMBLE ARTICLE 1. PARTIES ARTICLE 2 DEFINITIONS ARTICLE 3 SCOPE OF APPLICATION ARTICLE 4 PERSONAL DATA 4.1 Identity of the data controller 4.2 Data collection 4.3 Respect for rights 4.4 Transfer of collected data ARTICLE 5 TRACKERS/COOKIES POLICY 5.1 Use of trackers/cookies 5.2 Purposes of trackers 5.3 Trackers used 5.4 Setting your cookie preferences 5.5 Maximum retention period for cookies 5.6 Opposition to the use of cookies ARTICLE 6. INTELLECTUAL PROPERTY 6.1 Legal protection of the Site Content 6.2 Contractual protection of the Site Content ARTICLE 7. FINAL STIPULATIONS 7.1 Modifications 7.2 Entirety 7.3 Non-waiver 7.4 Languages 7.5 Unfair terms ARTICLE 8. DISPUTES 8.1 Applicable law 8.2 Disputes 8.3 ArbitrationPREAM This privacy policy informs you of the manner in which Guerda International uses and protects the information that you transmit to us, if any, when you use this site accessible from the following URL: www.guerda-internationale.com (hereinafter the « Site« ). Please note that this privacy policy may be modified or completed at any time by Guerda Internationale, in particular in order to comply with any legal or technological evolution. In such a case, the date of the update will be clearly identified at the top of this policy. These modifications are binding on the user as soon as they are put online. It is therefore advisable for the user to consult this privacy policy regularly in order to take note of any changes.   ARTICLE 1. PARTIES The present privacy policy is applicable between the publisher of the Site, hereinafter « Guerda Internationale », and any person connecting to the Site, hereinafter « the Internet User ». ARTICLE 2: DEFINITIONS « Site Content« : elements of any nature published on the Site, whether or not protected by intellectual property rights, such as texts, images, designs, presentations, videos, diagrams, structures, databases or software. « Internet user »: any person connecting to the Site. « Site« : the Internet site accessible at the URL www.guerda-international.com, as well as the sub-sites, mirror sites, portals and variations of URLs relating to it. ARTICLE 3 – SCOPE OF APPLICATION This privacy policy is applicable to all Internet users. By simply connecting to and/or browsing the Site, you accept this Privacy Policy in full. Furthermore, clicking on « I accept » in the information banner relating to cookies displayed on the Site confirms your acceptance, while allowing you to customise the cookies that will or will not be applied to you. You also acknowledge that you have fully understood and accept them without restriction. The Internet user recognizes the value of proof of the automatic recording systems of Guerda International and, unless he/she can prove otherwise. Acceptance of this privacy policy assumes that Internet users have the legal capacity to do so or that they are at least 16 years old, or failing that, that they have the authorization of a guardian or curator if they are incapable, or of their legal representative if they are under 16 years old, or that they hold a mandate if they are acting on behalf of a legal entity. ARTICLE 4.

PERSONAL DATA In general, you may visit the Site without voluntarily communicating any personal information about yourself. In any case, you are in no way obliged to voluntarily transmit information to Guerda International. Nevertheless, in case of refusal, you may not be able to benefit from certain information or services that you have requested. In this respect, Guerda International may in some cases ask you to provide your surname, first name, e-mail address, telephone number, company and position. By providing this information, you expressly accept that it will be processed by Guerda International, for the purposes indicated in this document and for the purposes indicated at the end of each form. In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on April 14, 2016 and with the national legislation in force, Guerda internationale provides you with the following information: 4.1 Identity of the data controller The person responsible for the collection and processing of data on the Site is Guerda international, share capital: €10,000, registered with the Paris Trade and Companies Register under number 490 247 681, having its registered office at 42 avenue montaigne 75008 PARIS, represented by Guerda de HAAN in her capacity as Managing Director Telephone: +(33) 07 64 25 58 73  Email: contact@guerda-international.com VAT N°: FR 52490247681 CNIL N°: 1249414 4.2 Data collection by Guerda internationale 4.3.1 Data collected 4.3.1. 1 Data collected during browsing When browsing the Site, you consent to Guerda Internationale collecting information relating to: your use of the Site; the content you consult and click on; your demographic data; the device used and its software environment; your location, tracers, web beacons, web storage, unique advertising identifiers; your connection data (times, pages consulted, IP address, etc.) and the web pages visited before or after using the Site 4.3.1.2 Data collected when using the registration formThe use of the contact form by the Internet user implies the collection by Guerda Internationale of the following personal data: surname, first name, date of birth, bank details, copy of identity card, tax assessment (only for men). Internet users who do not wish to provide the information required for the use of the registration form will not be able to register directly from the Site. 4.3.2 Purposes of collecting personal data The data collected during browsing is subject to automated processing for the purpose of : – to verify the identity of Internet users; – to ensure and improve the security of the Site; – to develop, operate, improve, provide and manage the Site; – to send information and contact the Internet user, including by e-mail, telephone and push notification; – to initiate legal proceedings; – to conceptualise and improve the experience of the Internet user; – to target advertising content; – to prevent any illicit or illegal activity; – to ensure compliance with the terms and conditions relating to the use of the Site The data collected when using the registration form is subject to automated processing for the purpose of – to carry out the registration of the Internet user; – to execute contractual commitments; – to initiate legal proceedings; – to verify the identity of Internet users; – to send information and contact the Internet user, including by e-mail, telephone and push notification; – to target advertising content; – to prevent any illicit or illegal activity; – to ensure compliance with the conditions relating to use of the Site. 4.3.1 Legal basis for processing The data collected during browsing has the legal basis of the legitimate interest of

Guerda International, namely to carry out an analysis of behavior on the Site and to obtain improved security and operation of the Site. Some of these data, such as those resulting from the installation of certain cookies, may have as their legal basis the consent of the individuals. The data collected during the use of the registration form is based on a contractual relationship. 4.3.2 Recipients of the data The data collected is available only to Guerda International, and is never made freely available to a third party. 4.3.3 Duration of retention of personal data Personal data collected during navigation is retained for a reasonable period necessary for the proper administration of the Site and for a maximum of 13 months. The data collected during the use of the registration form is kept for the duration of the contractual relationship between Guerda International and the Internet user, and for the duration during which Guerda International may be held liable. After these retention periods, Guerda internationale undertakes to permanently delete the data of the persons concerned. 4.3.4 Security and confidentiality of personal data Personal data is kept in secure conditions, according to current technical means, in compliance with the provisions of the General Data Protection Regulation and national legislation in force. 4.3.5 Minimization of personal data Guerda international may also collect and process any data voluntarily transmitted by an Internet user. Guerda International will direct Internet users as much as possible when they provide unnecessary or superfluous personal data. Guerda International undertakes to keep and process only the data strictly necessary for its activities, and will delete any data received that is not useful as soon as possible. 4.1 Respect of rights You have the following rights concerning your personal data, which you can exercise by writing to us at our postal address or by filling in our online contact form. 4.1.1 Right to information, access and communication of data You have the right to access your personal data. Because of the obligation of security and confidentiality in the processing of personal data that is incumbent on Guerda International, your request will only be processed if you can prove your identity, in particular by producing a scan of your valid identity document (in the case of a request via our dedicated electronic form) or a signed photocopy of your valid identity document (in the case of a request sent in writing), both accompanied by the words « I certify on my honour that the copy of this identity document is in conformity with the original. Done at … on … », followed by your signature. To help you in your approach, you will find here a model letter drawn up by the Cnil. 4.1.2 Right to rectify, delete and forget data You can request the rectification, updating, blocking or deletion of your personal data which may be inaccurate, incorrect, incomplete or obsolete. You can also define general and specific directives concerning the fate of your personal data after your death. Where applicable, the heirs of a deceased person may require that the death of their

Close and/or to make the necessary updates. To help you in your approach, you will find here a model letter drawn up by the CNIL. 4.1.3 Right to object to the processing of data You have the possibility of objecting to the processing of your personal data. To help you in your approach, you will find here a model letter drawn up by the Cnil. 4.1.4 Right to data portability You have the right to receive the personal data you have provided to us in a transferable, open and readable format. 4.1.5 Right to limit processing You have the right to request that the processing of your personal data by Guerda International be limited. Thus, your data can only be stored and not used by Guerda International. 4.1.6 Response time Guerda international undertakes to respond to your request for access, rectification or opposition or any other additional request for information within a reasonable period of time which may not exceed one month from the date of receipt of your request. 4.1.1 Complaint to the competent authority If you consider that Guerda International is not complying with its obligations with regard to your personal information, you may submit a complaint or request to the competent authority. In France, the competent authority is the Cnil to which you can send a request here. 4.2 Transfer of collected data 4.2.1 Transfer to partners Guerda international informs you that we have recourse to authorized service providers to facilitate the collection and processing of the data you have communicated to us. These service providers may be located outside of the European Union and may have access to the data collected on the Site. Guerda Internationale has previously ensured that its service providers have implemented adequate guarantees and comply with strict conditions in terms of confidentiality, use and protection of data, for example via the US PrivacyShield. The Internet user consents to the data collected being transmitted by Guerda International to its partners and being processed by these partners in the context of third party services, namely