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Welcome to Trader’s SAS’s Privacy Policy.

Last updated: April 2018

What does this Privacy Policy Cover?

Trader’s SAS respects your privacy and is committed to protecting your Personal Data.We want to be transparent with you about how we collect and use your Personal Data in providing this website (“Site”), as well as in providing and promoting our products and services. We also want to tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

  • Who we are and how to contact us.
  • Your Rights relating to your Personal Data.
  • Marketing communications preferences.
  • What Personal Data we collect.
  • How we use your Personal Data and why.
  • What happens when you do not provide necessary Personal Data?
  • Personal Data from Third Party Sources.
  • How we use cookies and other tracking or profiling technologies.
  • Who we share your Personal Data with.
  • How we keep your Personal Data secure.
  • How long we store your Personal Data.
  • Our policy on children.
  • Third party links.

Incoming, EU-wide data protection legislation known as the “General Data Protection Regulation” or “GDPR” (a copy of which is posted here), will have effect from May 25th, 2018. The Privacy Policy is intended to meet our duties of Transparency under the GDPR, as well as existing data protection legislation implementing the EU Data Protection Directive

We will post any modifications or changes to this Privacy Policy on this page. It is imperative that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you. Doing so will enable you to be fully aware of how and why we are using your Personal Data. This Privacy Policy supplements such other notices and is not intended to override them.

 

Who we are and how to contact us.

Who we are.

Trader’s SAS is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either “Trader’s SAS”, “we”, “us” or “our” in this Privacy Policy).

Our address is: Trader’s SAS, 21 rue Rollin, Paris, 75005, France

How to contact us.

You can contact us by emailing: Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser. .

 

Your Rights relating to your Personal Data.

Your rights in connection with Personal Data

Under certain circumstances, by law you have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. It is imperative that the Personal Data we hold about you is accurate and current.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data. This right only exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent. This right only exists where we are relying on consent to process your Personal Data. If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

 

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details shown in the section entitled “Who we are and how to contact us.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at Cette adresse e-mail est protégée contre les robots spammeurs. Vous devez activer le JavaScript pour la visualiser. .

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for France, is the Commission nationale de l'informatique et des libertés.

 

Marketing communications preferences.

You can ask us to stop sending you marketing messages at any time by:

  • following the opt-out links on any marketing message sent to you; and/or
  • by contacting us at any time using the contact details shown in the section entitled “Who we are and how to contact us.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of any strictly necessary service-related communications (for example: emails relating to your and/or your employer’s use of our products and services).

 

What Personal Data we collect.

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.

It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).

However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

 

Category of Personal Data collected

What this means

Identity Data

First name, surname, maiden name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data

Your home address, work address, billing address, email address and telephone numbers.

Marketing and Communications Data

Your preferences in receiving marketing from us and our third parties and your communication preferences.

Technical Data

Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site.

 

Aggregated Data

We also collect, use and share “Aggregated Data”such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

 

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the details shown in the section entitled “Who we are and how to contact us”.

If we need to use your Personal Data for an unrelated purpose, we will notify you by updating this Privacy Policy and we will explain the legal basis which allows us to do so.

 

What is our “legal basis” for processing your Personal Data?

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

  • Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

Generally we do not rely on your “consent” as a legal basis for using your Personal Data. However, we may need and ask for your consent in relation to sending you third party direct marketing communications to you via email.

We have set out below, in a table format which of the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data – in addition, where relevant, we have also identified what our legitimate interests in that use might be.

 

Purpose

Category(ies) of Personal Data involved

Why do we do this

Our legal basis for this use of data

Account registration

  • Identity Data
  • Technical Data
  • Contact Data

To register you as a new user of our Site.

Contractual Necessity.

Site security and Fraud Prevention

  • Identity Data
  • Contact Data
  • Technical Data

To keep our Site, our services and associated systems operational and secure.

Necessary for our Legitimate Interests.

We have a legitimate interest in ensuring (a) the ongoing security and proper operation of our services, website and associated IT services and networks; and (b) that our products and services are not being used fraudulently.

Marketing

  • Marketing and Communications Data
  • Identity Data
  • Contact Data
  • Technical Data

To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

Necessary for our Legitimate Interests.

We have a legitimate interest in providing you with updates on our Sites and related offers where you have purchased or shown interest in similar services from us.

 

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).

In this case, we may have to stop you from using our Site or our products and services but we will notify you if this is the case at the time.

 

Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

 

Third party data source

Publicly available?

Category(ies) of personal data received.

Social Media sites

Yes

  • Identity Data
  • Contact Data

Our Affiliates (Trader’s SAS France and QSL Italia)

No

  • Identity Data
  • Contact Data
  • Marketing and Communications Data

Partners/Resellers/Customers

No

  • Identity Data
  • Contact Data
  • Marketing and Communications Data

Market Researchers/tools

No

  • Identity Data
  • Contact Data
  • Marketing and Communications Data

 

How we use cookies & other tracking or profiling technologies.

Cookies.

What are cookies?

We collect certain information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website.

 

Cookies we use

Our Site uses the following types of first party cookies for the purposes set out below:

 

Type of cookie

Expiry Date

Purpose

Information collected

Functionality cookies

15 minutes

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Technical Data.

 

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

If you choose to reject these cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device.

 

Who we share your Personal Data with.

The table below describes who we share your Personal Data with, what we share and why we share it.

Many of our external third parties are based outside the European Economic Area (“Europe”) so their processing of your Personal Data will involve a transfer of data outside to countries based outside of Europe.

We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data out of the Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented

 

Recipients

Category(ies) of Personal Data we share.

Why we share it

Location(s)

Partners and Resellers

  • Identity Data
  • Contact Data
  • Technical Data
  • Marketing and Communications Data

Our Partners and Resellers help us provide our service (including customer support and software delivery) as well as marketing our services and providing customer feedback.

Worldwide

Service Providers

  • Identity Data
  • Contact Data
  • Technical Data
  • Marketing and Communications Data

Our service providers provide us with IT and system administration services. Our Service Providers also market out services and provide us with customer feedback.

Worldwide

Companies within our wider group of companies (our “Affiliates”)

  • Identity Data
  • Contact Data
  • Technical Data
  • Marketing and Communications Data

Our Affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison etc.).

Worldwide

 

How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

How long we store your Personal Data.

We will only retain your Personal Data for so long as we reasonably require it to use it for the purposes set out above in the section entitled “How we use your Personal Data and why”, unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Category of Personal Data

Retention period

Technical Data

For so long as retention is necessary to fulfil the Purpose(s) for which it was collected.

Identity Data

For so long as retention is necessary to fulfil the Purpose(s) for which it was collected.

Contact Data

For so long as retention is necessary to fulfil the Purpose(s) for which it was collected.

Marketing and Communications Data

For so long as you remain a customer/prospect of ours or until we receive an opt-out request from you.

For information on how to opt-out see the section entitled “Marketing communications preferences.

 

Our policy on children.

This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.

Third party links.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.

 

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