PRIVACY POLICY AND USE OF COOKIES

SECTION 1. DEFINITION

Personal data
Any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an “identifiable natural person” is one 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 his or her physical, physiological, genetic, mental, economic, cultural or social identity.

Processing
Any operation or set of operations that may or may not be carried out by automated means on personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction

File
Any structured set of personal data accessible according to specific criteria, whether this set is centralized, decentralized or distributed in a functional or geographical manner.

Data controller
The natural or legal person, public authority, department or other body which, alone or jointly with others, determines the purposes and means of processing.

Sub-processor
The natural or legal person, public authority, department or other body that processes personal data on behalf of the controller.

Recipient
The natural or legal person, public authority, department or other body that receives personal data, whether or not it is a third party.

ARTICLE 2. DATA COLLECTED BY PAVAILLER EQUIPEMENT

The data controller is Mr. Sébastien AUDRAS – SEBP – 555 Rue Benoit Frachon – 26800 – Portes-Les-Valence, France, represented by its managing director, Mr. Eric SOQUET.

The data collected by SEBP is either required or optional. This is indicated on each form by an asterisk.
Your username and password are collected to ensure security and user authentication when you log in to your online account.
In accordance with Article 6-II of the Law on Confidence in the Digital Economy No. 2004-575 of June 21, 2004, and its implementing decree No. 2011-219 of February 25, 2011, SEBP collects identification data.
SEBP collects data regarding your browsing activity on the website and your behavior (number of pages viewed, pages viewed, IP address, etc.).
Subject to your consent and the choices you make through your device settings, SEBP may collect and process the following data:

Information relating to the statistics concerning the consultation of the pages of the web platform of Pavailler Equipement

• Information Regarding Statistics on Page Views on the SEBP Web Platform

Information about the device you are using

• Type of device and operating system used
• Your ISP (Internet Service Provider)
• The browser used
• IP address of the device used
• Advertising identifier linked to the operating system of the device used
• Geolocation data

ARTICLE 3. Legal basis for the processing of personal data

3.1. Processing necessary for the performance of the contract
In order to allow you to access the various services offered by SEBP, you have accepted the general terms of use and the general terms of sale.
These documents formalize your contractual relationship with SEBP and constitute the legal basis for the processing of personal data by SEBP.
The data collected is necessary for the performance of this contract.

3.2. Processing based on law
Pursuant to Decree No. 3022-219 of February 25, 2011, SEBP must retain data enabling the identification of any person who has contributed to the creation of content posted online (reviews, ratings, comments).

ARTICLE 4. Purposes Pursued

ARTICLE 4. Purposes Pursued

Data is collected for the following purposes: For Users:

• Registration
• Management of requests to exercise rights relating to personal data
• Fraud prevention
• Sale of products
• Management of unpaid invoices
• More specifically, regarding cookies, these allow:
• Secure access to your online account in order to authenticate you
• To implement security measures
• To establish statistics and traffic volumes and usage of our website and its various pages
• To count the number of views, identify content, and determine the number of people who clicked on each piece of content
• To adapt the presentation of our site to your device

ARTICLE 5. Retention Periods

Data relating to the sending of promotional emails is kept for a period of three (3) years from your last activity on the web platform, including the sending of an electronic message.
Audience measurement statistics and traffic data are kept for a period of THIRTEEN (13) months in accordance with the law.
Data relating to online reviews and ratings is kept for 3 years.
Data relating to your browsing and/or behavior on the SEBP website and to your declared/completed profile is kept for THREE (3) years from your last activity on the web platform.
Data concerning identity documents relating to the exercise of the rights of access, rectification, erasure, restriction and portability is kept for ONE (1) year from the date of receipt.
At the end of the relationship between SEBP and you, the data will then be subject to intermediate archiving in order to comply with tax and accounting obligations (Article L. 123-22 paragraph 2 of the French Commercial Code – TEN (10) years) or legal obligations such as the FIVE (5) year statute of limitations applicable to personal or movable property actions (Article 2224 of the French Civil Code).
In the event of legal proceedings, personal data concerning you will be kept in order to allow Pavailler Equipement to ensure its defense or to enable it to establish the facts if Pavailler Equipement is requested to do so.

ARTICLE 6. Information shared with third parties

In order to provide you with certain services, Pavailler Equipement shares certain of your personal data, strictly necessary, with its partners.

• Payment service providers
• Customer relationship management (CRM),
• Web analytics for audience analysis on the site
• Hosting providers
• IT service providers and webmaster
• The accounting firm

SEBP may be required to disclose your data to judicial authorities upon injunction.
In any event, SEBP does not transfer your personal data to third parties without your consent.
SEBP’s partners/sub-processors process your personal data on behalf of and under the instructions of SEBP, in compliance with this Privacy Policy as well as the security and confidentiality measures necessary to protect your personal data.

ARTICLE 7. Data Hosting

Personal data is hosted in France on secure servers and within the European Union.
In order to provide you with certain services, SEBP may be required to transfer certain data outside the European Union. SEBP takes every security and confidentiality measure to secure the transfer of this data and its receipt. SEBP contractually requires that the sub-processors concerned in the USA take appropriate technical and organizational measures, including by providing clauses compliant with the GDPR and the recommendations of the European Commission.

ARTICLE 8. Your Rights

8.1. Right of access
You have the right to obtain confirmation from Pavailler Equipement as to whether or not personal data concerning you is being processed. Where such data is being processed, you have a right of access to that data and to the following information:

a) the purposes of the processing;
b) the categories of personal data concerned;
c) the recipients or categories of recipients to whom the data have been or will be disclosed;
d) where possible, the envisaged period for which the data will be kept, or, if not possible, the criteria used to determine that period;
e) the existence of the right to request from SEBP the rectification or erasure of the data, or a restriction of processing, or the right to object to processing
f) the right to lodge a complaint with the CNIL;
g) where the personal data is not collected directly from you, any available information as to their source;
h) the existence of automated decision-making, including profiling, and, at least in such cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.
Furthermore, when personal data is transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards relating to the transfer.
SEBP will provide you with a copy of the data undergoing processing.
SEBP may charge a reasonable fee based on administrative costs for any additional copy you request.

If you request a copy of the data by electronic means, Pavailler Equipement will provide it in a commonly used electronic format unless you request otherwise.

Finally, the right to obtain a copy of personal data must not adversely affect the rights and freedoms of others.

8.2. Right to rectification
You have the right to request that SEBP rectify your data that is inaccurate, as soon as possible. You also have the right to have incomplete personal data concerning you completed, including by providing a supplementary statement.

8.3. Right to erasure
You have the right to erasure of your personal data as soon as possible where one of the following grounds applies:

a) The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
b) You withdraw the consent on which the processing is based and there is no other legal basis for the processing concerned. The withdrawal of consent applies for the future;
c) You exercise your right to object and there is no overriding legitimate ground for the processing;
d) The personal data has been unlawfully processed;
e) The personal data must be erased to comply with a legal obligation.
You are informed that the right to erasure may not apply if the processing is necessary to comply with a legal obligation or for the establishment, exercise or defense of legal claims.

8.4. Right to restriction of processing
You have the right to request the restriction of the processing of your personal data where one of the following applies:

a) Verification of your data following a challenge by you regarding the accuracy of your personal data;
b) The processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead;
c) SEBP no longer needs the personal data concerning you for the processing, but the data is necessary for you for the establishment, exercise or defense of legal claims;
d) You have objected to the processing and SEBP is verifying whether its legitimate grounds override your legitimate grounds.

8.5. Right to data portability
You have the right to receive the personal data you have provided to SEBP in a structured, commonly used and machine-readable format when:

a) The processing is based on consent or on a contract;
b) and the processing is carried out by automated means.
As part of the exercise of this right, you have the right to obtain from SEBP that your personal data be transmitted directly from SEBP to another controller where this is technically possible.
The right to data portability must not adversely affect the rights and freedoms of third parties.

8.6. Right to object
Pursuant to the right to object, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data based on SEBP’s legitimate interests.
SEBP will no longer process the personal data unless it demonstrates compelling legitimate grounds for the processing that override your interests and your rights and freedoms, or for the establishment, exercise or defense of legal claims.

Furthermore, with regard to personal data processed for prospecting purposes, you have the right to object at any time. To do so, you must click on the link included in each email sent by SEBP, free of charge, or by sending an email to SEBP at the following email address: saudras@pavailler.com

8.7. Fate of personal data post-mortem
In accordance with the law, you have the option to define your directives regarding the retention, erasure and disclosure of your personal data in the event of death.
You may communicate your directives to us or have them registered with a certified digital trusted third party. You may therefore designate the person of your choice who will be responsible for carrying out your directives. Failing this, this will be your heirs.

ARTICLE 9. How to exercise your rights

9.1. How to exercise your rights
You may send your requests to the following addresses:

SEBP, 555 Rue Benoit Frachon – 26800 Portes-Les-Valence – France
saudras@pavailler.com
You must attach to your request a copy of your identity document so that SEBP can ensure that the person exercising the right(s) is indeed the person concerned.

9.2. Response time
Pavailler Equipement has one (1) month to respond to you from receipt of your request. This period may be extended by two months given the complexity and number of requests. SEBP will inform the person within one month of their request.

In the event of the exercise of your right to erasure or your right to be forgotten, you are informed that SEBP may be required to retain your personal data in the form of archiving prior to deletion for the applicable period.

Regarding newsletters and promotional offers, you have the option to unsubscribe at any time by clicking on the hyperlink available in each of the emails sent by SEBP.
You also have the right to lodge a complaint with the CNIL, the supervisory authority (www.cnil.fr).

ARTICLE 10. Cookies

When visiting our web platform www.froid-cfi.fr, cookies are placed on your computer, mobile device or tablet. Cookies are used to improve the services intended for you. Some are strictly necessary for the operation of the site, others are used to improve its performance and your user experience, namely those intended for statistics, those for social networks, and finally those dedicated to advertising. There are therefore 4 types of cookies:

• Functional cookies, necessary for the proper functioning of the site. These are cookies placed by Pavailler Equipement on your device (computer, tablet or phone) for the purposes of navigating our web platform, your login session and browsing.
• Statistics cookies: Analytical cookies help gather a certain amount of information anonymously about users’ journeys on our site in order to improve every step between the first visit and the completion of an order, and to detect any potential issues.
• Advertising cookies: No advertising cookies are currently used on our web platform www.pavailler.fr
• Third-party cookies: Media and social networks. Cookies placed by third-party sites such as Facebook®, Twitter® or YouTube® when sharing buttons or videos are embedded on the web platform.

The Site may contain links to other sites, and other sites may reference or contain a link to our Site. We have no control over these other domains and websites. We invite our users to read the privacy policies of each website and each application with which they may interact. We do not endorse, verify, or approve, and are not responsible for, the privacy practices or content of such websites or applications. If you visit these other websites or applications, you do so at your own risk and are subject to their privacy policy.

The Site also contains links and interactive features with several social networks. If you already use these platforms, their cookies may have been placed on your device when you use our Site. You should be aware that personal data voluntarily provided and posted online on a publicly accessible blog, in a “chat”, on a social network, or online in any other way, or that you share on a forum, may be viewed and used by others without restriction. We are not able to control such uses of your data in connection with interactions with a social network, and you use such services in accordance with that third party’s privacy policy and your privacy settings on their site.

If you interact in any other way with the accounts or pages we have on social networks, we collect data available on your own profiles, in accordance with your privacy settings on these social networks. Please review your privacy settings on these social networks to understand what content would be shared and update them if you wish.
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Version of May 2026