Article 1 - Objective of the Privacy Policy

This confidentiality policy is established for the purpose of informing users of the Pro Entreprises site, owned and managed by the company ACCESSNET MEDIA LIMITED, a limited liability company under Irish law with capital of 100 euros whose head office is located at 20 Harcourt Street, Dublin 2 D02 H364, with registration number 752483, under the following conditions:

• Personal data collected by the website;
• The use made of this data;
• Access to this data;
• The rights of users of the site;
• The policy related to the use of cookies.

This confidentiality policy operates in parallel with the General Conditions of Use, the General Conditions of Subscription and supplements the Legal Notices of the Pro Entreprises site.

Article 2 - Personal Data

Personal data includes:

• Processed lawfully and transparently;
• Collected for specified, explicit, and legitimate purposes, and not further processed in a manner that is incompatible with those purposes;
• In accordance with Article 89(1) of the GDPR, the storage and processing of such data for archiving purposes in the public interest, for scientific or historical research purposes, or for statistical purposes shall not be considered incompatible with the initial purposes;
• Adequate, relevant, and limited to what is necessary for the purposes for which they are processed;
• Accurate, and where necessary, kept up to date. All reasonable steps shall be taken to ensure that inaccurate data, having regard to the purposes for which they are processed, are erased or rectified without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage.

The processing of collected data is lawful only if at least one of the following conditions is met:

• The data subject has given consent to the processing of their personal data for one or more specific purposes.
• The processing of data is necessary for the execution of a contract to which the data subject is a party or for the execution of pre-contractual measures taken at the request of the data subject.
• Processing is necessary for compliance with a legal obligation to which the controller, ACCESSNET MEDIA LIMITED, is subject.
• Processing is necessary to protect the vital interests of the data subject or of another natural person.
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, ACCESSNET MEDIA LIMITED.
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

Article 3 - Consent

By using the Pro Entreprises site, users agree to:

• All the conditions included in this privacy policy;
• The collection, use, and retention of the data listed in this privacy policy.

Article 4 - Personal Data Collected

The personal data collected as part of our activity includes:

• User's first and last name;
• Date and place of birth;
• Postal address and email address;
• Phone number
• Company name;
• SIRET number;
• VAT number;
• IP address;
• If applicable, payment information (bank details).

The collection and processing of this data serves the following purposes:

• Creation and operation of a prospect file;
• Management of customer accounts, usernames and passwords, invoicing and payments, sending information about the evolution of offers;
• Management of customer accounts (registration);
• Management of payments from subscribed customers;
• Performance of the obligations of Articles 15 and following of the GDPR.

No additional data is collected without prior notification.

Article 5 - Processing of These Data

Lorsque vous visitez le site Pro Entreprises, l’adresse IP est automatiquement collectée.

Other personal data is collected when creating a subscriber account, including data required to access services: first name, last name, gender, date and place of birth, postal address, email address, phone number, company name, SIRET number, VAT number, banking information;

The data is collected using cookies, trackers or equivalent technical means, in particular for the purposes of audience measurement and/or advertising targeting. These personal data identified above can only be communicated to Pro Entreprises by the Users concerned by the said personal data and each User is prohibited from communicating the personal data of another person and/or personal data which does not concern him.

Article 6 - Sharing of Collected Personal Data

The user is informed that the data controller may, if necessary, transfer personal data to a third country or to an international organization subject to a decision of adequacy by the European Commission. It is specified that, in the case of a transfer to a country or international organization that does not have an adequacy decision, this can only be done on the condition that appropriate safeguards are in place and that individuals concerned by the processing of personal data have enforceable rights and effective remedies, in accordance with the applicable regulations.

Article 7 - Storage and Protection of Personal Data

The retention periods for personal data of Users vary depending on the purpose of the processing and the nature of the relationship (prospect who has never contracted or client).

The table below specifies the main retention periods for personal data relating to Users of the Site:

Data categories	Purposes	Retention Period
Prospects
Set of Personal Data (including identification and contact data)	Establishment and operation of a prospects file	3 years from the last contact with the prospect
Identification and contact data	Management of customer account, IDs and passwords, orders, billing, and payments. Sending information about offers' evolution	Throughout the duration of the contractual relationship (as long as the User has not expressed his intention to no longer be a customer of Pro Entreprises) within the maximum limit of 3 years from the last withdrawal, at the end of which the data of a personal nature are no longer kept.
Banking Information	Management of payments from subscribed customers	Throughout the duration of the contractual relationship, with an additional retention period of 5 years for banking documents related to transactions (Article L.110-4 of the Commercial Code)
Data related to the exercise of a right by a User	Execution of the obligations of Articles 15 and following of the GDPR	The data is retained for the calendar year of the request, plus 5 years.

Article 8 - User Rights

In accordance with chapter 3, art 12-23 of the GDPR, users of the Pro Entreprises site have, with regard to their personal data, the following rights:

• Right of access;
• Right to rectification;
• Right to erasure;
• Right to restrict processing;
• Right to data portability;
• Right to object.

To exercise any of your rights, access your data, modify it, or delete it in any way, you can contact our data protection officer at the following address: support@pro-entreprises.com

Article 9 - Cookie Policy

A cookie is a file stored on a user's hard drive when they browse a website. This cookie allows us to better understand the data related to the user's browsing habits in order to offer a better user experience.

Cookies are used as part of the use of the site. The user has the option to disable cookies from their browser settings.

What browsing data is collected via cookies?

Through cookies, all data related to a device at a given moment can be collected, even if we do not directly know which device you are using or who you are, including:

Why are cookies present on our services?

• Cookies allow us, among other things:
• Overall, allow you to browse and consult our site, adapt the content or display of our services to your terminal to improve your navigation and optimize the Pro Entreprises site;
• To establish statistics and audience measurements on the traffic to our site;
• To optimize the distribution and assess the effectiveness of the advertising messages we send;
• To ensure the security of our services by detecting/tracing any attempt at malicious activity, computer intrusion, or violation of the terms and conditions of use (TOS);
• To fulfill our legal obligations, respond to possible requests from third parties authorized by law to ask us to communicate your Browsing Data and/or your Personal Data.

In accordance with the GDPR, you can choose to be notified every time a cookie is created or disable the transmission of cookies entirely through the site.

Article 10 - Security and Confidentiality

Le site Pro Entreprises met en œuvre des mesures organisationnelles, techniques, logicielles et physiques en matière de sécurité du numérique pour protéger les données personnelles contre les altérations, destructions et accès non autorisés. Toutefois, il est à signaler qu'internet n'est pas un environnement complètement sécurisé et le site Pro Entreprises ne peut pas garantir la sécurité de la transmission ou du stockage des informations sur internet.

Article 11 - Modification of the Privacy Policy

In order to remain in compliance with the law or to reflect any changes in our personal data management process, this privacy policy may change and be amended regularly. Users are advised to regularly check this policy to stay informed about our policy regarding the collection and processing of personal data.

Article 12 - Contact

Personal data is collected by ACCESSNET MEDIA LIMITED, an Irish limited liability company with a share capital of 100 euros, whose registration number is 752483, and whose registered office is located at 20, Harcourt Street, Dublin 2 D02 H364 (Ireland).

You have the option to inquire about your rights at the following address: support@pro-entreprises.com