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PRIVACY POLICY





1. PRIVACY POLICY

Sidetrade SA, French company registered in the corporate trade registry, located
114, rue Gallieni, 92200 Boulogne-Billancourt, France and/or any of its
affiliated companies (“Sidetrade”, “we”, “us”) are committed to protecting and
respecting your privacy. This Privacy Policy (together with any other documents
referred to in this document) sets out the basis on which:

 * The Personal Data (as defined below) of people browsing the
   dev-sidetrade.westeurope.cloudapp.azure.com website of Sidetrade (the “Site”)
   are processed by us.
 * The Personal Data collected indirectly by us are processed by Sidetrade.
 * The Personal Data of the data subjects visiting our offices are processed.

This Privacy Policy lets you know how Sidetrade collects and uses your Personal
Data and how you can control their use.

With respect to recruitment this Privacy Policy is supplemented by the
“Sidetrade Privacy Notice for Recruitment”.

With respect to cookies this Privacy Policy is supplemented by the “Sidetrade
Cookie Policy”.

1.1 SCOPE OF THIS PRIVACY POLICY

This Privacy Policy sets forth the principles and guidelines governing the
protection of the Personal Data (as defined below) collected on or through the
Site and concerning the Site’s visitors and users (“You” or “Your”), the
Personal Data collected indirectly by Sidetrade and/or the Personal Data of the
data subjects visiting our offices.

“Personal Data” means any information relating to an identified or identifiable
person. An identifiable person is a person who can be identified, directly or
indirectly, in particular, by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person.

“Non-Personal Data” means any information which is not a Personal Data.

Any Personal Data You provide on the Site or collected indirectly by Sidetrade
are subject to the terms of this Privacy Policy.

Sidetrade will comply with all local applicable provisions of data protection
laws (in particular the General Data Protection Regulation -GDPR).

1.2 PERSONAL DATA COLLECTED ON OR THROUGH THE SITE

In order to use certain functions and features of the Site, Sidetrade requires
that You provide certain Personal Data when visiting or using the Site. Personal
Data likely includes basic contact data such as:

 * title,
 * first and last name,
 * postal address,
 * email address,
 * telephone number(s),
 * company, company size, department and job title,
 * industry and industry sub-industry sectors,
 * IP address, and any other Personal Data as may be relevant for the purposes
   listed below.

In all cases, however, the Personal Data gathered is limited to data necessary
to the purposes described under Article 1.3 hereafter.

You are free to decide whether or not to provide all or part of Your Personal
Data. However, if You choose not to provide all or part of this Personal Data,
the purposes as described in Article 1.3 hereafter might not be achieved or not
properly achieved, some areas and functions of the Site may not function
properly and/or You may be refused access to certain pages on the Site.

With regard to clients, the provision of Personal Data is a contractual
requirement. Processing is necessary for the performance of the contractual
relationships with Sidetrade.

With regard to prospects, processing is based on the legitimate interests
pursued by Sidetrade in order to develop the knowledge of the Sidetrade services
on the market.

1.3 METHODS AND PURPOSES OF COLLECTION OF PERSONAL DATA COLLECTED ON OR THROUGH
THE SITE

We collect Personal Data in a variety of ways: Personal Data is collected
directly from You, either by You providing the information directly to us or You
acting in a manner that provides us with the information, for example: either
offline and online; through cookies, through Your use of a mobile application;
through Your device; if You browse our Sites, we may also collect information
about Your use of our services through Your browser to trace activity on our
Sites.

Personal Data is generally collected to carry out the business of Sidetrade,
such as improving Sidetrade’s marketing and advertising efforts, better
tailoring Sidetrade products and services to customers’ needs or complying with
reporting obligations required by applicable law, and similar activities.

Your Personal Data collected by Sidetrade on or through the Site is used by
Sidetrade for the following purposes:

 * To enable You to request information;
 * To provide You with a personalised interactive use of the Site;
 * To ascertain Your requirements and interests and provide You with the most
   suitable products and/or services;
 * To allow You to open and maintain an account in order to obtain specialised
   documentation and technical assistance;
 * To enable You to subscribe to a commercial or support-type service;
 * To access all the features and options offered by the Site;
 * to provide You with information about new products and services;
 * to respond to comments and questions and provide customer service;
 * to operate, maintain and improve our Sites, products and services;
 * for marketing purposes and market research;
 * to internally administer this Site and to help us improve our services; or
 * to comply with applicable laws or regulations and to protect, investigate and
   deter against fraudulent, unauthorized, or illegal activity,
 * and any other purposes associated with the above purposes.

By providing Your e-mail address, You hereby expressly authorize, Sidetrade, its
business partners to use it together with other relevant Personal Data to send
You commercial or marketing messages.

The Personal Data may also be processed by subprocessors involved in the
provisions of the Sidetrade services. Sidetrade takes great care in who is using
to process Your Personal Data have subprocessors agreements in place that
regulates how they handle our data.

1.4 INDIRECT COLLECTION OF PERSONAL DATA

Without prejudice to the application of articles 14-5-a and 14-5-b of the GDPR,
article 95 of the GDPR and the doctrine of the CNIL in terms of electronic
prospecting, it is specified that Sidetrade may obtain Personal Data, from
public databases; social media platforms, from its customers and from the
customers of its customers or from well-known third-party partners in the market
and recognized for their expertise in the management of Personal Data. Personal
Data likely includes basic contact data such as:

 * title,
 * first and last name,
 * postal address,
 * email address,
 * telephone number(s),
 * company, company size, department and job title,
 * industry and industry sub-industry sectors,
 * IP address, and any other Data as may be relevant for the purposes listed
   below.

In accordance with Recital 47 of the GDPR, Sidetrade may, in response to its
legitimate interest of promoting awareness of its services and/or in agreement
with the data subjects, process such Personal Data for purposes of commercial
prospecting and /or for the purposes of providing its customers with information
to target the right prospect with the right message. The personal data may also
be used by Sidetrade and its customers in the context of their usage of the
Sidetrade cloud services. In such a case of indirect collection, it is specified
that any person concerned has the rights governed by Article 14 of the GDPR and,
more broadly, the rights summarized in Section 9 below.

The Personal Data may also be processed by subprocessors involved in the
provisions of the Sidetrade services. Sidetrade takes great care in who is using
to process Personal Data have subprocessors agreements in place that regulates
how they handle these data.

1.5 COOKIES

Sidetrade may use cookies or other technologies which may collect or store
Personal Data under the conditions defined in the Sidetrade Cookies Policy.

1.6 PERSONAL DATA COLLECTED WHEN YOU ARE VISITING OUR OFFICES

Sidetrade may obtain Personal Data when You are visiting its offices. The
Personal Data includes the following data:

 * title,
 * first and last name,
 * email address,
 * telephone number(s),
 * company, company size, department and job title,
 * photographs, and images/sequences captured on video surveillance cameras or
   other video systems, and voice recordings,
 * and any other Data as may be relevant for the purposes listed below.

The Personal Data collected in the context of the data subjects visiting our
offices are processed for the following purposes:

 * To monitor the access to the premises.
 * To deter and assist in the prevention or detection of crimes and infractions.
 * To monitor security and identify actions which might result in disciplinary
   action.
 * for an eventual legal protection (judicial or extra-judicial) for the
   documentation and reconstruction of events.

The Personal Data may also be processed by sub processors involved in the
provisions of the above-mentioned purposes. Sidetrade takes great care in who is
using to process Personal Data have sub processors agreements in place that
regulates how they handle these data.

 

1.7 PERSONAL DATA PROCESSING AND STORAGE TERM

Processing of Personal Data includes using, storing, recording, transferring,
adapting, summarizing, amending, reporting, sharing and destroying Personal Data
as necessary under the circumstances or as otherwise required by applicable law.

All Personal Data that will have been collected will be stored for a limited
duration that is relevant to the purpose of such collection and for so long as
required by applicable law, and as necessary to pursue our legitimate business
interests, conduct audits, comply with our legal obligations, resolve disputes,
and enforce our agreements.

1.8 LINKS TO WEBSITES NOT CONTROLLED BY SIDETRADE OR ITS SUBSIDIARIES

This Site might offer links to third party Websites which may be of interest to
You.

Unless Sidetrade receives Your express authorization, Sidetrade does not share
any Personal Data with these third parties. However, Sidetrade may provide them
with Non-Personal Data.

These third parties use technological processes to send advertisements and links
appearing on the Site to Your browser software, via Your IP address. They may
also use other technologies (such as cookies, JavaScript or web beacons) to
assess the effectiveness of their advertisements and to personalize their
content.

Sidetrade does not exercise any control over the content of third-party Websites
or the practices of these third parties in connection with the protection of
Personal Data that they might collect and are thus not in the control of
Sidetrade. Consequently, Sidetrade declines all liability for the content of
third-party websites or the practices of these third parties concerning the
protection of Personal Data.

It is therefore Your responsibility to inform Yourself as to these third
parties’ privacy policies.

1.9 TRANSFER OF PERSONAL DATA

If You are accessing the Site from a location outside of the European Union,
with laws or regulations governing data collection, use, and disclosure that
differ from European Union, please note that through Your continued use of the
Site, which are governed by French law, the corresponding terms of use and this
Privacy Policy, You are transferring Your Personal Data to the European Union
and You consent to that transfer.

Sidetrade is able to use available technology to efficiently manage Personal
Data and obtain such Personal Data online or otherwise throughout its
international operations. Personal Data may be collected through the Site,
indirectly and/or in the context of our premises visits subsequently disclosed
to and used by an affiliate or subsidiary of Sidetrade (“Sidetrade Group
Companies”) and /or to business partners and/or suppliers and/or to customers
for the purposes stated in Articles 1.3 to 1.6 of this Privacy Policy.

We have put appropriate safeguards in place for transfers of Your Personal Data
outside the EEA, including the standard data protection clauses adopted by the
European Commission, available at
http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915 and
http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087.

Where Sidetrade has knowledge that a third party to which Sidetrade has provided
Personal Data for the purposes listed in Articles 3.3 to 3.6 above, is using or
disclosing Personal Data contrary to this Privacy Policy or to applicable laws,
Sidetrade will take reasonable steps to prevent or stop such use or disclosure.

Sidetrade will also disclose Personal Data to third parties if Sidetrade
determines that such disclosure is necessary for technical reasons (such as
hosting services by a third party) or to protect Sidetrade’s legal interests
(such as in the event of acquisition or merger by a third company or total or
partial liquidation of Sidetrade). These transfers may be transmitted by any
method which Sidetrade determines is appropriate and in accordance with
applicable law.

1.10 YOUR RIGHTS

Sidetrade will take reasonable steps to ensure that the Personal Data collected
is used for the purposes stated in this Privacy Policy and that such Personal
Data is correct and up to date.

You have a number of important rights. In summary, those include rights to:

 * access to your Personal Data;
 * correct any mistakes in your Personal Data which we hold;
 * request the erasure of Personal Data concerning you unless we have a
   legitimate ground to not delete the Personal Data.
 * object, at any time, to our processing of your Personal Data;
 * receive the Personal Data you have given us in a structured, commonly used
   format. Please note that this only applies to Personal Data that was given to
   us directly from you.
 * otherwise restrict our processing of your Personal Data in certain
   circumstances

Otherwise, you may exercise your rights by sending a request to one of the
following addresses, with a proof of your identity and address:

 * E-mail address: privacy@www.sidetrade.com.
 * Postal address: Sidetrade SA, Legal Department 114, avenue de Gallieni 92100
   Boulogne, France.

The General Data Protection Regulation also gives you right to lodge a complaint
with a supervisory authority in the EU member state where you live, work or
where an alleged infringement of applicable data protection law occurred.

1.11 DATA SECURITY AND RECIPIENTS

Sidetrade undertakes to ensure the protection and security of Personal Data, in
order to ensure the confidentiality of your Personal Data and prevent your
Personal Data from being distorted, damaged, destroyed or disclosed to
unauthorized parties.

Sidetrade complies with relevant industry standards to protect Personal Data
from loss, misuse and unauthorized access, disclosure, alteration and
destruction. As part of those safeguards, Sidetrade employs sophisticated
technology designed to protect Personal Data during its transmission and prevent
transmission errors or unauthorized acts of third parties.

1.12 CONTACT

For any additional question concerning this Privacy Policy, you may send an
email to the following address: privacy@www.sidetrade.com.

1.13 DATE OF ENTRY INTO FORCE OF THE PRIVACY POLICY AND CHANGES TO IT

This Privacy Policy may be updated according to Sidetrade’s requirements and
circumstances, or where required by applicable laws and regulations.

Last modification: The Privacy Policy has been modified on 25/01/2021.

 


2. VALIDITY AND DOCUMENT MANAGEMENT

The owner of this document is the legal department, who must check and, if
necessary, update the document.

When evaluating the effectiveness and adequacy of this document, the following
criteria need to be considered:

 * Compliance with applicable laws.

 

 

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PRIVACY OVERVIEW

This website uses cookies to improve your experience while you navigate through
the website. Out of these cookies, the cookies that are categorized as necessary
are stored on your browser as they are essential for the working of basic
functionalities...
Necessary
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly.
This category only includes cookies that ensures basic functionalities and
security features of the website. These cookies do not store any personal
information.
Functional
Functional
Functional cookies help to perform certain functionalities like sharing the
content of the website on social media platforms, collect feedbacks, and other
third-party features.

CookieDurationDescription__cf_bm30 minutesThis cookie, set by Cloudflare, is
used to support Cloudflare Bot Management.pll_language1 yearThe pll _language
cookie is used by Polylang to remember the language selected by the user when
returning to the website, and also to get the language information when not
available in another way.

Analytics
Analytics
Analytical cookies are used to understand how visitors interact with the
website. These cookies help provide information on metrics the number of
visitors, bounce rate, traffic source, etc.

CookieDurationDescription_ga2 yearsThe _ga cookie, installed by Google
Analytics, calculates visitor, session and campaign data and also keeps track of
site usage for the site's analytics report. The cookie stores information
anonymously and assigns a randomly generated number to recognize unique
visitors._gat_gtag_UA_29157906_21 minuteSet by Google to distinguish
users._gcl_au3 monthsProvided by Google Tag Manager to experiment advertisement
efficiency of websites using their services._gid1 dayInstalled by Google
Analytics, _gid cookie stores information on how visitors use a website, while
also creating an analytics report of the website's performance. Some of the data
that are collected include the number of visitors, their source, and the pages
they visit anonymously.BIGipServerPOOL-134.213.193.62-MUNCHKIN-80sessionNo
descriptionCONSENT2 yearsYouTube sets this cookie via embedded youtube-videos
and registers anonymous statistical data.visitorId1 yearSet by zoominfo.com to
track userswmc10 yearsNo description available.

Advertisement
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and
marketing campaigns. These cookies track visitors across websites and collect
information to provide customized ads.

CookieDurationDescription_mkto_trk2 yearsThis cookie, provided by Marketo, has
information (such as a unique user ID) that is used to track the user's site
usage. The cookies set by Marketo are readable only by Marketo.test_cookie15
minutesThe test_cookie is set by doubleclick.net and is used to determine if the
user's browser supports cookies.VISITOR_INFO1_LIVE5 months 27 daysA cookie set
by YouTube to measure bandwidth that determines whether the user gets the new or
old player interface.YSCsessionYSC cookie is set by Youtube and is used to track
the views of embedded videos on Youtube
pages.yt-remote-connected-devicesneverYouTube sets this cookie to store the
video preferences of the user using embedded YouTube
video.yt-remote-device-idneverYouTube sets this cookie to store the video
preferences of the user using embedded YouTube
video.yt.innertube::nextIdneverThis cookie, set by YouTube, registers a unique
ID to store data on what videos from YouTube the user has
seen.yt.innertube::requestsneverThis cookie, set by YouTube, registers a unique
ID to store data on what videos from YouTube the user has seen.

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