1. Introduction

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TRACKAP SAS, located at 165 Avenue de Bretagne, 59000 Lille, and represented by its President, Mr. Alexandre LUTERNAUER (hereinafter “THE COMPANY ”), is committed to a policy of upholding and maintaining high standards in the protection of personal data.

As part of its business operations, THE COMPANY collects and processes personal data relating to its customers and users, its employees, and its business partners, such as its service providers.

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Committed to fostering innovation while building a lasting relationship of trust based on shared values of social responsibility and respect for individuals, THE COMPANY has implemented the necessary technical and organizational measures to protect the personal data it collects and processes.

The purpose of this policy is to outline the Company’s commitments regarding the protection of personal data.

2. Fair and transparent fundraising

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In the interest of transparency, THE COMPANY takes care to inform its customers, users, website visitors, employees, and business partners about each instance of data processing that concerns them.

The COMPANY can be contacted at the following address for any further information regarding its personal data protection policy: privacy@trackap.com

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The collection of personal data is intended, in particular, to ensure the optimal management of its TRACKAP application for the geolocation of bike trackers, as well as to manage its professional relationships with its customers, prospects, employees, and business partners.

3. Lawful and proportionate data processing

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When THE COMPANY processes data, it does so for specific purposes: every instance of data processing carried out by THE COMPANY has a legitimate, specific, and explicit purpose.

When you sign up for our services, you voluntarily provide us with personal data—in particular when you agree to our Terms of Service—and thereby give us your consent to process your personal data, as defined exclusively in Article 4.

In accordance with the right to be forgotten, THE COMPANY ensures that data is retained in a form that allows for the identification of the data subjects only for as long as is necessary for the purposes for which it is processed.

4. Accurate and minimized data processing

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For each data processing operation carried out, THE COMPANY undertakes to collect and process only data that is adequate, relevant, and limited to what is necessary in light of the purposes for which it is processed.

When you agree to THE COMPANY’s terms and conditions of sale or enter into any other contractual agreement with THE COMPANY, you will be informed about the processing of personal data that is necessary for the provision of IT services.

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The data that may be collected by THE COMPANY and processed electronically are as follows:

• For employees of THE COMPANY: Last name, first name, date of birth, place of birth, mailing address, personal email address, work email address, phone number, Social Security number, IBAN number, tax information, driver’s license number, national ID number, marital status, resume.
• For THE COMPANY’s customers and prospects: Last name, first name, email address, business and/or personal phone number, employment status, business address, signature, cookies.
• For users of THE COMPANY’s app (TRACKAP): last name, first name, email address, phone number, date of birth, tracker location, bike passport (identification number, Bicycode, photo, invoice).
• For users' emergency contacts: personal phone number.
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• Data retention period:
• Prospects: 3 years from the last contact.
• Customers: 5 years from the end of the contractual relationship.
• Users: 3 years from the last time they used the app.
• Emergency contact: The duration of account use on the app.
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• Exceptions are provided for in cases of legal obligations or with respect to cookies (see Article 5). THE COMPANY ensures that data is updated as necessary and that procedures are in place to ensure that inaccurate data is deleted or corrected.

5. Cookie Management

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To ensure optimal performance, THE COMPANY has developed a website that uses cookies. These cookies are stored via the web browser and are used to enhance the browsing experience.

• Shelf life: 13 months
• Blocking: can be enabled in your browser settings.
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• Cookies are anonymous and are used solely to improve your browsing experience. You can delete them by following these steps:
• Firefox: Menu (three bars) > Options > Privacy > Delete specific cookies
• Internet Explorer: Gear icon > Internet Options > Privacy > Sites > Delete all
• Chrome: 3 dots > Settings > Advanced settings > Privacy > Content settings > Cookies > View/delete
• Safari: Safari menu > Preferences > Privacy > Clear all website data

6. Guaranteed data protection

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THE COMPANY implements technical and organizational measures to ensure data security, including:

• Protection against unauthorized access and accidental loss
• Securing the tools used for processing
• Compliance with the principles of “privacy by design” and “privacy by default”
• Pseudonymization and encryption techniques, as necessary
• Monitoring of service providers with the enforcement of equivalent safety standards
• Regular internal and external audits

7. Regulated access to data

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Strict access policies are in place to ensure that only authorized individuals can access the processed data. In the event of a transfer outside the European Union, THE COMPANY undertakes to comply with applicable legal and contractual requirements.

8. Respect for the rights of data subjects

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THE COMPANY acknowledges the following rights:

• Right to Information and Transparency
• Right of access and correction
• Right to erasure and restriction of processing
• Right to data portability and right to object
• Right to establish advance directives
• THE COMPANY also respects the right not to be subject to automated decision-making, including profiling.

9. Easier to get in touch

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THE COMPANY undertakes to respond to requests to exercise rights within the statutory time limits. Such requests should be sent to: privacy@trackap.com

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Information required: last name, first name, a copy of a valid ID, and the preferred mailing address.

Trackap SAS – Simplified joint-stock company with capital of €29,543 – 851 850 172 (Lille Métropole Commercial Register)

165 Avenue de Bretagne, 59000 Lille (France)