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PRIVACY POLICY AND PERSONAL DATA  

28/01/21

Data controller

Subteno IT, a limited liability company with a share capital of €196,160, having its registered office at 27 avenue Jean Mantelet, 61000 ALENCON, registered with the R.C.S. of Alençon under number 503 380 404.
In the course of its business, Subteno IT, whose registered office is located at 27 avenue Jean Mantelet, 61000 ALENCON, is required to collect and process information, some of which is qualified as "personal data". Subteno IT attaches great importance to the respect of privacy, and only uses data in a responsible and confidential manner and for a specific purpose.

Data collected and processed 

          1.1. Personal data

On the site  www.subteno.com , Subteno IT collects personal data, such as:
- your full name
- company or organization name
- telephone number
- your e-mail address
- your IP address
- personal information provided through the CV (first name, last name, date of birth, postal address, telephone number, e-mail address, education and professional background, license, hobbies, skills, family situation, photo).
On the site www.subteno.com , some of this personal data may be collected in two ways: 
    -   by the transmission of these data by the user through the forms of the website. The fields "name", "email", "subject" and "your question" are mandatory in the contact form. These data are used for the purpose of contacting you again and/or in the context of the request you made to us. Article 6, paragraph 1, point b) is the legal basis for the processing of these data.
    -   by the automatic collection of your data via our website. During your visits, once you have given your consent, we may collect "web analytics" type information relating to your browsing (the duration of your visit, your IP address, your browser type and version, etc.). For more information about the data collected by Google Analytics, you can consult the following link :   https://support.google.com/analytics/#topic=9143232  .The technology used is the cookie. Web analytics" data is collected by Google Analytics, and allows us to measure and analyze the audience of our website, the consultations in order to constantly improve the user experience. This data is used by Subteno IT, which is responsible for data processing, and will never be transferred to a third party or used for any other purpose than those detailed in this document.
Privacy Policy.

          1.2. Cookies and similar technologies
  
The website www.subteno.com  may use cookies and other similar technologies.
A cookie is a small text file of limited size that allows us to recognize your terminal, in order to better adapt our services.
Our site uses several types of cookies, each with a different functionality and purpose.
Subteno IT uses session and security cookies to authenticate users, protect their data, and enable the website to provide the services users expect, such as allowing them to download files. This type of cookie is necessary for the proper functioning of the site and cannot be disabled.
Subteno IT also uses preference cookies to remember the user's favorite look and feel on the website, such as your preferred language. This type of cookie also makes it possible, for example, to remember your consent to the use of cookies and thus no longer systematically ask for your consent. You have the option to disable this cookie, however your user experience may be degraded.
Subteno IT uses interaction history cookies to collect information about your interactions on the website, the pages you have viewed and any specific marketing campaigns that brought you to the site. We may not be able to provide you with the best service if you reject these cookies, but the website will work.
Subteno IT uses Google Analytics, a third-party web analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to help us improve your user experience. Google Analytics uses cookies that are stored on your device to analyze your use of our website. The information generated by the cookie about your use of our website is transmitted to Google Analytics and stored on Google Analytics servers in the United States. This service allows us to understand how users interact with our website.
You have the right to object, at any time, for reasons relating to your particular situation, to such data processing, by deactivating the sharing of usage data by contacting us in the manner set out in Article 1.6 of this Privacy Policy. To prevent the collection of data about your use of the website by the cookie and the processing of this data by Google Analytics, you can simply download the plug-in by clicking on the following link  https://tools.google.com/dlpage/gaoptout

For more information on the Google Analytics service, you can click on the following link :   https://support.google.com/analytics/#topic=9143232   

Cookie category
Objectives
Example
Session and security
​To authenticate users, protect user data, and enable the website to provide the services users expect, such as allowing them to download files.
The website will not function properly if you reject or delete these cookies.
session_id (Odoo) fileToken (Odoo)
Preferences
​To store information about the preferred look and feel of the website, such as your preferred language or region.
Your experience may be degraded if you delete these cookies, but the website will still function.
frontend_lang (Odoo)
History of the interaction
​Used to collect information about your interactions on the website, the pages you have viewed and any specific marketing campaigns that brought you to the site.
We may not be able to provide you with the best service if you reject these cookies, but the website will work.
im_livechat_previous_operator_pid (Odoo) utm_campaign (Odoo) utm_source (Odoo) utm_medium (Odoo)
Analytics
Understand how visitors interact with our website, via Google Analytics. Learn more about Google Analytics cookies and privacy information :
https://support.google.com/analytics/answer/6004245
The website will still function if you reject or delete these cookies.
Learn more about cookies and trackers :  https://www.cnil.fr/fr/cookies-et-traceurs-que-dit-la-loi
_ga (Google) _gat (Google) _gid (Google) _gac_* (Google)
You can manage your preferences in terms of cookies by clicking on the "Personalize" banner when you arrive on the site. Some cookies are essential to the proper functioning of the site and your navigation, such as session and security cookies, which you cannot deactivate.

          1.3. Duration of data retention

Your data is kept by Subteno IT only for the time necessary to achieve the purposes for which it was collected and recorded. The data will be saved for a maximum of 3 years. After this period, we will delete your personal data.  
We inform you that every 6 months, we will ask you again for your consent to process cookies.
If you wish to rectify, delete or withdraw your consent to the collection and processing of your personal data, you can contact us at the following email address :  contact@subteno.com  by indicating your choice concerning your personal data. We will delete your personal data within a maximum of one month. For more information on this subject, you can refer to the section "1.5 Rights under the GDPR" of this Privacy Policy.

          1.4. Access to your data 

According to article 4 of the RGPD, the recipient of data is the natural or legal person, public authority, department or any other body that receives personal data, whether or not it is a third party.
Subteno IT may share your data with other entities within the group and use it in accordance with this Privacy Policy, in particular with the following entities:
    - Subteno Group, a limited liability company with a capital of €1,000, having its registered office at 57 boulevard Lenoir Dufresne 61000 ALENCON, registered under the number 881 806 418 R.C.S. of Alençon;
    - Subteno IT Sàrl, a limited liability company with a capital of CHF 20'000, having its registered office at 2 rue de l'Horloge 5606 LUTRY, registered under the company identification number (IDE) CHE-271.724.118 in the commercial register of the canton of VAUD
    -  MDLB SERVICES (Subteno IT Paris Agency), a simplified joint stock company with a capital of €10,000, having its registered office at 24 Rue Alexandre, 14000 CAEN, registered under number 887 874 337 R.C.S CAEN.
In accordance with the provisions of Article 6 of the GDPR, Subteno IT has a legitimate interest in passing on this information for administrative purposes, including, for example, in order to be able to collect and review applications sent through our website.
You may object to the sharing of your personal data at any time by contacting us directly as provided in section 1.6 of this Privacy Policy.

          1.5. Rights under the GDPR

The European Data Protection Regulation gives you, but not limited to, the following rights:
- Right to withdraw your consent: you have the possibility to withdraw your consent in case you have given it regarding your personal data, at any time by contacting us. You may exercise this right by contacting us as set out in section 1.6 of this Privacy Policy.
- Right of access: You have the right to obtain from Subteno IT confirmation as to whether or not personal data concerning you is stored. You also have the right to know the origin of this information about you and to obtain a copy of it. You may exercise these rights by simple request as described in section 1.6 of this Privacy Policy.
- Right of Correction: Subteno IT strives to ensure that your personal data is accurate. In the event that your personal data is incomplete or incorrect, you may request that it be corrected, completed or updated.
In view of the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by providing an additional declaration.
- Right to object: you have the right to object at any time, for reasons relating to your particular situation, to the processing of your personal data for reasons that are legitimate to you at any time by request to in accordance with Article 1.6 of this Privacy Policy. Article 21 of the GDPR is the legal basis for this right of objection.
- Right to data portability: you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another controller without the controller to whom the personal data has been communicated having any objection, where:
       (a) the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, or on a contract pursuant to Article 6(1)(b) of the GDPR; and
(b) the processing is carried out using automated processes.
To exercise this right, you may contact us as described in Section 1.6 of this Privacy Policy.
- Right to erasure: you have the right to obtain the erasure, as soon as possible, of your personal data or to the limitation of the processing of the data. To exercise your rights, you may contact us as provided in section 1.6 of this Privacy Policy.
You also have the right to file a complaint with the supervisory authority: the CNIL.

          1.6. Contact   

To exercise your rights under the GDPR and for any questions regarding this Privacy Policy or the processing of data by Subteno IT, you may contact us at the following address contact@subteno.com 

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