PRIVACY POLICY AND COOKIES

SITRAM publishes and operates the website accessible at the following URL: https://www.sitram.fr (hereinafter the SITE), a non-commercial website designed to present the company's lines and products.

When operating the SITE, SITRAM takes great care to protect the privacy and personal data of the users of the SITE (hereinafter the USER or USERS). SITRAM is committed to implementing appropriate measures to comply with the principles of the French Data Protection Act No. 78-17 of January 6, 1978 (as amended), as well as the European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

The purpose of the present Privacy and Cookie Policy is to inform USERS how their personal information may be collected and processed by SITRAM.

IDENTITY OF THE DATA CONTROLLER

The data controller in charge of processing personal data on the SITE within the framework of the SITRAM/USER relationship is:

SITRAM:

Head office: 36170 Saint-Benoit-du-Sault FRANCE

Tel. +33 2 54 01 53 00

Registered with the Trade and Companies Registry (RCS) of CHATEAUROUX under the number 816 320 436

Director of publication: Philippe Begué

COLLECTION AND PROCESSING OF DATA

SITRAM may, within the framework of the SITE's operation, collect certain personal data related to USERS. This data is processed in accordance with the purposes described in Article 3 of the present privacy policy.

SITRAM may collect personal data:

• To manage requests for information, complaints, or any other form of contact by a USER with SITRAM customer service;
• In the event of requests for information or emails addressed directly to SITRAM;
• When USERS access the SITE.

Regardless of the reason for the collection, SITRAM agrees to inform the USER of the purposes of the processing, the mandatory or optional nature of the data to be collected, any eventual consequences for the USER should he/she fail to provide the data, the recipients of the data, and the possibility of and procedures for exercising the USER's rights of access, rectification, and opposition to the processing of his/her data.

The following data may be collected and processed by SITRAM for the purposes described in Article 3 of the present privacy policy:

• identification data of USERS:

name, title, address, telephone number, email address, and if necessary, a copy of their ID to serve as proof of their identity during the exercise of their right of access, rectification, or opposition or to meet a legal obligation.

• the USER's connection data (IP addresses, technical data, etc.).

PURPOSES OF THE PROCESSING

Data is collected to ensure:

• the proper functioning of the SITE
• the proper handling of the various requests sent via the contact form
• the proper handling of claims to exercise the right to access, rectify, or object to the processing of personal data processed by SITRAM
• the generation of statistics designed to improve the functioning of the SITE.

SITRAM may be required by the law to share this data.

DATA RETENTION PERIOD

SITRAM agrees that it shall not save any personal data which makes it possible to identify USERS directly for any longer than the period necessary for the purposes for which the data was collected and processed.

Personal data relating to USERS may only be saved for the duration of the business relationship, with the exception of certain data which may be archived in accordance with applicable legal provisions (in particular those outlined in the French Commercial Code, the French Civil Code, and the French Consumer Code), when the retention of the data is necessary to establish proof of a right or a contract or to comply with a legal obligation.

In exceptional cases, identification data relating to USERS is kept for:

• Up to three (3) years after the end of the business relationship;
• And up to three (3) years after it was collected by SITRAM or the last contact by prospects.

At the end of this three (3) year period, SITRAM may contact the USERS to find out if they wish to continue receiving commercial offers. If the USERS no longer wish to receive these offers, their data will be deleted or archived as per applicable legal provisions.

RIGHTS OF USERS

As mentioned above, USERS whose personal data is processed by SITRAM have the right to access, rectify, or object to the processing of said data, as per Articles 38 et seq. of French law No. 78-17 known as the “French Data Protection Act” (as amended), and the European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Under certain conditions, USERS may also have their data erased or obtain and reuse their personal data for their own purposes (portability). In addition, as per French law No. 2016-1321 of October 7, 2016 ("Digital Republic Act"), USERS may provide specific instructions on what to do with their personal data after their death.

USERS may exercise any of these rights by simply writing to the head office of SITRAM or by sending an email to DPO@cargo-services.fr. They will be required to provide proof of their identity as well as a legitimate reason for exercising the right, if required by law.

In the event that copies of IDs are sent with the requests, these documents will be saved for one (1) year if the USER wishes to exercise his/her right to access or rectify his/her personal data or for three (3) years if the USER wishes to exercise his/her right to object to the processing of his/her personal data. The same is true for any other collected data when the USER wishes to exercise his/her right to object to the processing of his/her personal data.

DATA RECIPIENTS

SITRAM may be required to share the personal data collected on the SITE with internal services, subcontractors, or business partners who:

• produce advertising-related CONTENT
• perform commercial operations
• monitor the commercial relationship with USERS
• manage the SITE's hosting and maintenance services
• monitor SITRAM's activity (services responsible for internal control procedures, etc.)

SITRAM also reserves the right to transmit any personal data collected on the SITE in order to meet its legal obligations, and in particular if required by a court of law.

LOGIN DATA AND COOKIES

SITRAM uses connection data (date, time, Internet address, protocol of the USER's computer, page visited) and cookies (small files saved on the USER's computer) to identify the USER, to remember his/her preferences, and to generate analyses and statistics on the audience of the SITE, in particular regarding the pages viewed.

This SITE uses functional and technical cookies, mainly to improve your navigation. These cookies send data to our SITE and to your browser. This data includes information from forms (login, email address, etc.), the display preferences of your terminal (language, resolution, etc.), and security measures such as the expiration of your session.

Most browsers accept cookies from websites by default. However, you can configure your browser to:

• Accept or refuse the cookies on the SITE
• Systematically refuse all cookies
• Ask for your permission every time a website wishes to use a cookie on your computer.

The website of the CNIL (French National Commission for Information Technology and Civil Liberties) offers helpful tips on how to delete the cookies that are stored on your terminal (for each respective browser): http://www.cnil.fr/vos-droits/vos-traces/.

Please note that if you choose to refuse our cookies, you may not benefit from the SITE’s optimized navigation and features.

In any case, the cookies stored on your computer or any other elements used to identify you for statistical or audience measurement purposes have a lifespan of no more than 13 months, and this lifespan is not renewed each time you visit the SITE. After that time, the raw traffic data associated with a USER is either deleted or anonymized.

SECURITY

Given the nature of the data and the risks associated with its processing, SITRAM takes all the necessary precautions to protect the data and, in particular, to prevent it from being distorted, damaged, or accessed by unauthorized third parties.