Privacy policy

1. The Personal Data that SteerFox collects and the reasons for collecting it,
2. How that personal data will be used,
3. Your rights as a person concerned by our data processing

This policy applies to all Steerfox services, whatever their nature (website, applications, services, etc.).

The contact details are as follows:

Postal address: 62 rue Caumartin – 75009 Paris, France

Telephone: 04 84 49 20 31

Email: produit@steerfox.com

Steerfox undertakes to take the protection of your personal data and privacy into account from the design stage of the services offered to you (Privacy by desing). To ensure security and guarantee respect for and proper exercise of your rights, measures to protect your personal data are implemented (Privacy by default).

Steerfox undertakes to collect only the data strictly necessary to provide the services offered. If optional data is requested from you, SteerFox will clearly inform you which personal data is necessary to provide the service. Personal data is collected directly from you and is used only for the purposes brought to your attention.

Personal data is used to offer you other services only if you have agreed to receive commercial communications.

SteerFox relies on the following legitimate bases to process personal data:

Performance of the contract

The legal basis for processing the personal data collected from the user is performance of the sales contract. In this regard, the user is required to provide the data necessary for its performance. If the user does not provide this data, the sale cannot be completed.

Legal obligations

The management and issuance of invoices is based on SteerFox’s legal obligation within its relationship with customers.

Consent

For the following purposes, the legal basis for processing the user’s personal data will be the user’s consent, where given:

1. Managing registration on the website and applications.
2. Managing the sending of information about products and services and personalised information tailored to the user’s profile.
3. Responding to the exercise of the user’s rights of access, modification, cancellation and objection, as well as to the user’s questions and complaints.

The user’s withdrawal of consent to these processing operations will not affect performance of the contract concluded by the person concerned with Steerfox.

Legitimate interest

For the following purposes, the legal basis for processing the user’s personal data will be SteerFox’s legitimate interest:

1. Creating profiles based on browsing of the website by a user registered on it, as well as by all users who have provided us with their data for any other purpose.
2. Creating profiles to send information about exclusive promotions, the latest news and personalised information tailored to the user’s profile.
3. Sending satisfaction surveys about products purchased or services used by Steerfox customers in order to ask for their opinion and improve them.

Our legitimate interest is to ensure that our website remains secure and to help Steerfox understand users’ needs, expectations and level of satisfaction, thereby improving services, products and brands. All these actions are carried out to improve customer satisfaction and provide a unique browsing and purchasing experience.

Some services may be used by minors. In this case, minors must obtain the consent of their parents or legal representatives.

Your data may be transmitted:

1. To Steerfox internal departments: the departments responsible for providing the subscribed services, in particular Customer Service and Sales Administration…
2. To external Steerfox service providers: technical providers, including subcontractors;
3. To Steerfox business partners after you have been informed in advance and given the opportunity to express your choices using a checkbox.

Steerfox carries out all processing of your Personal Data within the European Union (EU).

However, for certain specific services, Steerfox may use subcontractors established outside the EU. Some Personal Data may then be disclosed to them strictly as needed to perform their assignments.

In this case, in accordance with the regulations in force, Steerfox requires its subcontractors to provide the safeguards necessary to govern and secure these transfers, in particular by signing the European Commission’s standard contractual clauses.

The retention period for your Personal Data depends on the service subscribed to. Steerfox undertakes not to retain your Personal Data beyond the period necessary to provide the service, and thus for your use of the service, plus the retention period imposed by the applicable statutory limitation rules.

Steerfox undertakes to take all measures to ensure the security and confidentiality of Personal Data and, in particular, to prevent it from being damaged, erased or accessed by unauthorised third parties.

Furthermore, in the event of a security incident affecting your Personal Data (destruction, loss, alteration or disclosure), Steerfox undertakes to comply with its obligation to notify Personal Data breaches, in particular to the CNIL.

You may at any time exercise with Steerfox the rights provided for by the applicable regulations on personal data, subject to meeting the relevant conditions:

1. Right of access: you may obtain communication of your Personal Data processed by Steerfox;
2. Right to rectification: you may update your Personal Data or have Personal Data processed by Steerfox rectified;
3. Right to object, in particular to receiving commercial communications: you may express your wish no longer to receive commercial communications from Steerfox or request that your Personal Data cease to be processed;
4. Right to erasure: you may request deletion of your Personal Data;
5. Right to restriction: you may request suspension of the processing of your Personal Data;
6. Right to portability: you may ask Steerfox to retrieve your Personal Data so that you can have it.

When you subscribe to a service or when your Personal Data is collected, you are given the address (postal and/or email) to which to send your request to exercise your rights. Every request must be accompanied by proof of identity. SteerFox undertakes to respond to your requests to exercise your rights as soon as possible and, in all cases, within the statutory time limits.

The appointment of a Data Protection Representative demonstrates Steerfox’s commitment to protecting the security and confidentiality of its customers’ Personal Data. You may contact the Data Protection Representative at the following address:

Contact for the Data Protection Representative

To the Data Protection Representative

350 Rue Jean René Guillibert Gauthier de la Lauzière, Parc du Golf Bâtiment 7, 13290 Aix-en-Provence

Or by email: produit@steerfox.com

Updates to this Privacy Policy will be published here on the website steerfox.com

The Steerfox group websites and all their web pages use cookies to distinguish you from other users of the site. This enables us to improve services and optimise your user experience. A cookie is a string of information in text format transferred by a website to your computer’s hard drive so that the website remembers you. Cookies can help a website adapt content to your interests more quickly.

Most major websites use cookies. In general, a cookie contains the name of the domain from which it originated, the cookie’s “lifetime” and a value, namely a randomly generated unique number. On the Steerfox group websites, there are two types of cookies:

1. Temporary cookies, which remain in your browser’s cookie file until you leave the website
2. Persistent cookies, which remain in your browser’s cookie file for much longer (the duration depends on the lifetime of the cookie in question).

Temporary cookies are used:

1. To allow you to transfer information from one page of our website to another without having to enter it again
2. To allow you to access stored registration information.

Persistent cookies are used:

1. To help us identify you as a visitor (by means of a number, not personally) when you return to our website
2. To allow us to adapt content or advertisements to your interests, or to avoid showing you the same advertisements several times,
3. To allow us to adapt our communications with you
4. To compile anonymous aggregate statistics that enable us to understand how visitors use our website and help us improve its structure. We cannot personally identify you in this way.

You may accept or reject cookies by changing your browser settings. However, you may lose certain interactive features of the service if cookies are disabled. Below is a list of the main cookies we use and their functions.

Modernizr

Cookie type: Persistent

Cookie function: We use this technology to avoid display differences between visitors’ various browsers and devices.

nab Alternative

Cookie type: Persistent

Cookie function: This cookie allows us to display variants of certain content and ensure that a visitor sees the same variant on each visit.

Poptin

Cookie type: Persistent

Cookie function: This cookie allows us to display pop-ups to distribute temporary content on our website.

WordPress

Cookie type: Temporary

Cookie function: This cookie is not used for users who are not logged in to WordPress.

YouTube

Cookie type: Persistent

Cookie function: This cookie is used to store the user’s video player preferences using the embedded YouTube video

Authentication token

Cookie type: Persistent

Cookie function: This cookie is used only if you have asked the portal to remember you when you log in. It stores a token that identifies you.

Google Analytics / CA Audiences

Cookie type: Persistent

Cookie function: We use traffic tracking tools to compile anonymous aggregate statistics that enable us to understand how visitors use our website and help us improve its structure. These data do not identify you personally. For more information, see the pages www.google.com/policies/privacy/partners and https://tools.google.com/dlpage/gaoptout.

You can delete and block all cookies from the Steerfox group websites. To do so, change your browser setting to reject some or all cookies. Please note, however, that if you decide to block cookies through your browser, some parts of our website may not work properly.

We use analytics tools in the Steerfox application (Dashboard). These tools are used to compile anonymous aggregate statistics that enable us to understand how our customers use the applications for the purpose of continuous improvement. These data do not identify you personally. You can choose to disable the application’s analytics tools in your device settings.

Each capitalised term has the meaning given to it below.

“Privacy and Personal Data Protection Policy” and “Policy”: means this Policy describing the measures taken to process, use and manage your Personal Data and your rights as a person concerned by the processing.

“Personal Data”: means any information relating to you that enables you to be identified directly or indirectly.

“Processing”: means any operation or set of operations performed on your Personal Data.

“Controller”: means a person within the Steerfox company who carries out the processing of your Personal Data.

“Personal data breach”: means a breach of security leading, accidentally or unlawfully, to the destruction, loss, alteration, disclosure of or unauthorised access to your Personal Data.

“Recipient”: means the department or company to which your Personal Data is disclosed and which may access it.