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PRIVACY POLICY – FreewayTeam

Last updated on March 22, 2024

FreewayTeam is a simplified joint-stock company (SAS) duly incorporated and existing under French law, with its registered office located at 58 Rue de Monceau, 75008 Paris Cedex 08, registered with the Paris Trade and Companies Register under the number 927 714 022 (hereinafter referred to as “FreewayTeam”, “we”, “our”, or “us”).

We place the highest importance on the privacy and security of your (hereinafter “you”, “your”, or “yours”) personal data. This Privacy Policy aims to inform you about:

  • The (categories of) personal data we collect and process in the course of providing services through the website www.freewayteam.com (hereinafter, the “Platform”),
  • The reasons for collecting and processing your personal data, as well as the legal basis for such processing,
  • The retention period for your personal data,
  • Any potential disclosure of your personal data to third parties,
  • Any possible transfer of your data outside the European Union or to international organizations,
  • The rights you may exercise in relation to your personal data or its processing, and
  • The security measures we implement to ensure the protection and confidentiality of your personal data.

We recommend that you carefully read this Privacy Policy, which includes our Cookie Policy (the “Cookie Policy”), accessible here, which forms an integral part of this Privacy Policy.

1. GENERAL INFORMATION AND CONTACT

For the purposes of this Privacy Policy, we must be considered as the data controller of your personal data. This designation imposes certain obligations on us under applicable data protection law. This law includes:

  • The General Data Protection Regulation (EU) 2016/679 of April 27, 2016, or the “GDPR”,
  • The Belgian Law of July 30, 2018, regarding the protection of natural persons in relation to the processing of personal data,
  • The Law of June 13, 2005, on electronic communications, including its future amendments.

Collectively, these are referred to as the “Applicable Data Protection Legislation.”

If you have any questions about our Privacy Policy or the processing of your personal data, or if you believe your interests have not been adequately represented, you can always send us your questions, comments, or complaints by emailing contact@freewayteam.com.

You also have the right to file a complaint with the competent data protection authority or request further information from them. You will find all the relevant information in Article 8 below. However, if you have questions or concerns, or if you wish to file a complaint, we encourage you to first contact us so that we can address any issues you may encounter.

2. PERSONAL DATA COLLECTED AND PROCESSED

The personal data we collect and process about you will always be related to the specific purposes outlined below.

We may receive your personal data directly from you, for example, when you interact with us via email, create an account on the Platform, or through our contact form on the Platform. We may also receive your personal data through information technologies, including automated means, such as cookies. Please refer to our Cookie Policy for more information on this.

Below, we detail the various categories of personal data we collect and process, the purposes for which we process it, and how we process your personal data.

A. Processing of Personal Data When You Visit the Platform

  1. Cookies

  • Purposes:
    We use various types of cookies:

    • Technically essential and functional cookies: We use cookies such as ARRAffinity, firebase:sentinel, firebase-heartbeat-database, and others to manage the Platform and its content. These cookies are necessary for the proper functioning of the Platform. You cannot refuse these cookies if you wish to access our Platform.
    • Analytical cookies: We use tools like Google Analytics and Hotjar to analyze traffic on the Platform. These tools install cookies that allow us to quantify visits and gather data about the number of times a page has been viewed, which helps us improve our content.

  • Legal Basis:

    • Essential and functional cookies: Necessary for the performance of the service (Article 6.1(b) GDPR).
    • Other cookies (analytical and social media sharing): Use of these third-party cookies is subject to your prior consent (Article 6.1(a) GDPR).

    You may refuse these cookies, but access to the Platform will not be restricted. However, some features may not be available.

  • Data Categories:
    Please refer to our Cookie Policy for detailed information on the data collected based on your preferences.

  • Retention Period:
    Cookies typically have an expiration date. Some cookies are deleted automatically when you close your browser (session cookies), while others remain on your device for a longer period (persistent cookies).

  • Recipients:
    Facebook, LinkedIn, Instagram, and possibly our service providers and subcontractors (IT providers, hosts).

B. Processing of Personal Data When You Register on the Platform

  1. Account Creation
  • Purpose:
    If you wish to benefit from our services, we will process your data to create an account on the Platform.
  • Legal Basis:
    The processing of this data is necessary for the execution of the terms of use that bind you to the Platform (Article 6.1(b) GDPR) and to comply with our legal obligations (Article 6.1(c) GDPR).
  • Data Categories:
    Your identification data (name, surname, phone number, position, email address, IP address, company name).
  • Retention Period:
    Data is retained for 10 years from the closure of your account.
  • Recipients:
    These data will be communicated to the tax authorities. Additionally, communication with our service providers and subcontractors (IT providers, accountants, auditors) may be necessary.
  1. Administrative and Accounting Management
  • Purpose:
    The data you provide is processed for administrative, accounting, and fiscal management of your account or services you order from us.
  • Legal Basis:
    Necessary for the execution of the contract (Article 6.1(b) GDPR), including invoice generation, order tracking, and notification of any changes to our terms of use or Privacy Policy (including new purposes). Also necessary to comply with our legal obligations (Article 6.1(c) GDPR), particularly under the Economic Law Code and VAT Code.
  • Data Categories:
    Identification data (name, surname, email, address, phone number, business number, VAT number), invoices issued, payments, financial data (bank, account number).
  • Retention Period:
    Data is retained for 10 years from the closure of your account.
  • Recipients:
    Data will be communicated to tax authorities. Communication with our service providers and subcontractors (IT providers, accountants, auditors) may also be necessary.
  1. Newsletter and Alert Notifications
  • Purpose:
    If you subscribe to our alert service, we process your data to send you notifications related to these alerts.
  • Legal Basis:
    Data is processed based on the execution of the service contract (Article 6.1(b) GDPR).
  • Data Categories:
    Your name, surname, and email address.
  • Retention Period:
    Data is processed until you unsubscribe from the service.
  • Recipients:
    Communication with our service providers and subcontractors (IT providers, email services, direct mailing) may be necessary.

3. INTERNATIONAL DATA TRANSFERS

Our offices are located in France, and the personal data we collect is stored on servers in the Netherlands. However, for the purposes outlined in Article 2, your personal data may be transferred to jurisdictions outside the European Economic Area (EEA), and therefore not subject to the GDPR. Your data may also be hosted on servers outside the EEA.

When personal data is transferred to third parties in such jurisdictions, we implement appropriate safeguards in our agreement with these third parties to ensure that your personal data benefits from an adequate level of data protection, at least equivalent to the level you are entitled to under the GDPR. To this end, we assess the level of data protection in the transit or destination country, taking into account relevant decisions by the European Commission. We may use the Standard Contractual Clauses adopted by the European Commission and any other appropriate solutions as required or permitted by the Applicable Data Protection Legislation.

4. YOUR RIGHTS UNDER DATA PROTECTION LAW

Under the Applicable Data Protection Legislation, you have certain rights concerning the personal data we collect and process about you.

If you wish to obtain further information about your rights or wish to exercise them, please send an email to contact@freewayteam.com. When exercising your data protection rights, we ask you to identify yourself correctly so that we can respond to your request within the timeframes outlined below.

The exercise of your rights is free of charge and will be carried out within one (1) month from the receipt of your request. If your request is particularly complex, we may extend this period by two (2) additional months for a total of three (3) months. If we decide to extend the initial timeframe, we will inform you in a timely manner.

If we deem your request to be manifestly unfounded or excessive, we reserve the right to charge you administrative fees for the processing of your request.

5. SECURITY OF YOUR PERSONAL DATA

We use generally accepted and reasonable technical and organizational methods, in line with current technological developments in operational security, to offer protection against the loss, misuse, alteration, or destruction of all personal data that we store and process.

Our technical and organizational measures are frequently updated to adapt to new technical and organizational procedures and to ensure the continuous security of your personal data.

Our Platform contains links to other websites or online resources (collectively referred to as “Third-Party Sites”), which may also collect personal data, including through cookies or other technologies. We are not responsible for these Third-Party Sites, nor for their collection, use, or disclosure of your personal data, and we do not exercise control over them. We encourage you to review the privacy policies of these Third-Party Sites to understand how they collect and process your personal data.

6. CHANGES TO THE PRIVACY POLICY

We may update and modify our Privacy Policy from time to time, particularly to account for new practices in data protection and to allow you better control over your personal data.

We will always make our Privacy Policy available on the Platform in its most recent version. You may also request us to send you the current or previous versions of our Privacy Policy by emailing us at contact@freewayteam.com. You can check the date of the last modification of our Privacy Policy at the top of this document.

7. QUESTIONS AND REQUESTS

You agree to provide us with accurate personal data. You may modify the personal data we hold at any time by emailing us at contact@freewayteam.com. We cannot be held responsible for any failure in our services due to incorrect information you have provided to us.

If you have any questions about our Privacy Policy or if you feel that your interests are not adequately represented, you may send any questions to the email address mentioned above.

8. APPLICABLE LAW AND DISPUTE RESOLUTION

Our Privacy Policy is governed by and interpreted in accordance with French law, unless mandatory legal provisions stipulate otherwise.

You have the right to file a complaint with the competent data protection authority, namely the authority in the member state of your habitual residence, place of work, or the place of the alleged infringement of the Applicable Data Protection Legislation.

The main data protection authority is the French National Commission on Informatics and Liberty (CNIL), which can be contacted through the following means:

By following the instructions and filling out the form available via this link.

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