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When you browse or use the site https://www.fairglow.fr/ (the “Site”) and as part of the management of our contractual relationships with our customers, we are required to collect personal data concerning you (“You” or the “Persons Concerned”).

The purpose of this policy is to inform you about the methods by which we process this data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (the “RPGD”) and the Data Protection Act (Act No. 78-17 of 6 January 1978 relating to information technology, files and to freedoms).

To find out more about how FAIRGLOW processes your personal data in terms of cookies, we invite you to consult the Cookie Policy https://www.fairglow.fr/cookies.

1 FAIRGLOW RESPONSIBLE FOR THE TREATMENT

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When you browse our Site or as part of the management of our contractual relationships with our customers, the data controller is the company LEMBAS, a simplified joint stock company, registered with the Paris RCS under the number 953 334 455, having its head office at 35 Quai de la Seine 75019 Paris, whose trade name is FAIRGLOW. On the other hand, when our customers use our services, we collect and process personal data in their name and on their behalf. Our customers are therefore responsible for data processing in accordance with Article 4 of the GDPR. We act as a subcontractor, as a service provider.

2 PURPOSES AND LEGAL BASES OF THE TREATMENTS IMPLEMENTED BY FAIRGLOW

This data is collected and processed by FAIRGLOW for the following purposes and on the following legal bases (see the bottom of the page table)

In addition, your data may be used to carry out technical operations related to the processing of your personal data, for the purposes set out above. This includes:

• technical operations related to address adjustment,

• technical, organizational or cybersecurity operations related to the detection of anomalies and the security of your data as well as our information systems from which your data are processed.

3 PERSONAL DATA PROCESSED BY FAIRGLOW

In addition to the personal data provided directly by the Data Subjects, FAIRGLOW also processes the following data:

• Information collected using cookies installed on the equipment of the Persons Concerned;

• Connection data and technical data to identify or authenticate you (connection logs, IP address, date and time of connection);

4 SHELF LIVES

Personal data relating to your account is kept for the duration of our contractual relationship. If necessary, some data may be subject to intermediate archiving, with limited access within FAIRGLOW, for the purposes of evidence in the event of litigation, for the duration of the legal prescription.

Data relating to the constitution of a file of customers and prospects are kept:

- For customers: for the duration of the contractual relationship.

- For prospects: for a period of 3 years from your last contact.

Data relating to the development of statistics (navigation, Site audience, etc.) and to improve the functionalities of the Site through the deposit of audience measurement cookies are kept for a period of 3 years.

Data allowing the distribution of personalized advertising through the deposit of advertising cookies is kept for 25 months.

5 DATA RECIPIENTS

FAIRGLOW shares the personal data it processes with a limited number of people.

Will have access to your personal data:

(i) Our company personnel;

(ii) Our subcontractors: hosting provider, service provider in charge of maintaining the Site, provider of audience measurement and analysis, electronic messaging service provider, cookie management tool;

(iii) Where applicable: public and private organizations, exclusively to meet our legal obligations.

6 DATA TRANSFERS OUTSIDE THE EUROPEAN UNION

Your data is kept and stored for the duration of processing on Google Cloud's servers, located in the European Union.

As part of the tools we use indicated in the article “data recipients”, your data may be transferred outside the European Union. The transfer of your data in this context is secured using the following tools:

• or the data is transferred to a country that has been the subject of an adequacy decision by the European Commission, in accordance with article 45 of the RGPD: in this case, this country ensures a level of protection considered sufficient and adequate to the provisions of the RGPD;

• or the data is transferred to a country whose level of data protection has not been recognized as adequate under the RGPD: in this case these transfers are based on appropriate guarantees indicated in article 46 of the RGPD, adapted to each service provider, in particular in particular in a non-exhaustive manner, the conclusion of standard contractual clauses approved by the European Commission, the application of binding corporate rules or under an approved certification mechanism.

• or the data is transferred on the basis of one of the appropriate guarantees described in Chapter V of the GDPR.

7 RIGHTS OF THE PERSON CONCERNED

Each Data Subject has a right to access, rectify, delete, delete, limit, limit, oppose, oppose, portability of their data, or withdraw their consent under the conditions and limits provided for by the RGPD and the Data Protection Act as well as the right to define advance directives relating to the fate of their data after their death.

A person can exercise their rights at any time by sending an email or by writing to the postal address at the contact details mentioned in the article below (e “FAIRGLOW contact”).

For the sake of confidentiality and the protection of personal data, FAIRGLOW will ask the Data Subject to justify their identity in order to respond to their request. To do this, in case of reasonable doubts about the identity of the person concerned, he may be asked to attach a copy of a valid official identity document, such as an identity card or passport, to support his request.

All requests will be processed as soon as possible and in accordance with applicable regulations. In some cases, personal data can only be deleted after a certain period imposed by current regulations and statutes of limitations. In this case, FAIRGLOW will keep this data until the planned total deletion date.

The Data Subject is informed that he cannot oppose the collection and processing of personal data whose processing is carried out in accordance with legal obligations that would weigh on FAIRGLOW. The Data Subject is also informed that in the event of refusal to provide their personal data or the exercise of their right of deletion or opposition, all or part of the services offered may be made inaccessible to them.

In the event of a dispute concerning the use of their data, the person concerned has the right to file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL).

8 UPDATES

FAIRGLOW may change this policy periodically. These changes will apply as of the effective date of the amended version.

The current version of this policy is always available online on the Site.

9 FAIRGLOW CONTACTS

For any questions concerning this policy or the processing of personal data implemented by FAIRGLOW in connection with the Site, you can contact us at the following coordinates:

LEMBAS

6 RUE D'ARMAILLE, 75017 PARIS 75019 Paris

E-Mail: contact@fairglow.fr