1. Personal Data
TSI committed to the collection and processing of personal information, carried out within the Site, shall be made in accordance with Law No. 78-17 of 6 January 1978, as amended, relating to data processing, files and freedoms, hereinafter referred to ”Data Protection Act” and the General Data Protection Regulation of 27 April 2016 (hereinafter “GDPR”).
Therefore, TSI informs its Users of the following points :
1.1 Definition of personal data
"Personal data" means any information that may result in the identification of an individual.
1.2 Processing personal data
The “processing” of personal data includes any operation carried out manually or using automated processes applied to personal data. This may include collection, registration, organization, structuring, preservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of provision, reconciliation or interconnection, limitation, deletion or destruction of such data.
1.3 Treatment Manager
The controller is the company Trace Software International “TSI”, SAS with capital of 190,790 €, registered with the RCS of Le Havre under the number 507 704 716 and whose head office is located at Parc Eco Normandie 76430 Saint Romain de Colbosc – La France.
Telephone: +33 (0) 232794424.
1.4 Nature of data collected
Only necessary and relevant data to the aims pursued are collected (principle of proportionality).
These may include:
- first and last name
- email address
- Postal Code and Country
- Login and password
- any other personal data that may be useful for the purposes set out in Article 1.5 below.
The information that TSI collects comes from:
- Either voluntary registration of an e-mail address allowing the User to receive newsletters
- Either the entry of the user’s personal details during his contact request
- Either create an account via the e-shop
- Either data from the User’s navigation on the Platform through Cookies and other technologies.
In addition, TSI may use tools or software that may collect non-personal data through the User's terminal, in compliance with applicable laws.
"Non-personal data" means any information that does not result in the identification of an individual.
These data are anonymous, processed in aggregate form and is not linked to any of the User's personal data.
1.5 Purposes of the data collected
Personal data are generally collected for:
- Allow the user to open and manage an account
- Allow the User to request information
- Allow the User to acquire software, subscribe to a commercial service or a support service
- Allow TSI to contact the User and send him newsletters or business proposals
In this sense, TSI may also use the User's email address for administrative or other non-marketing purposes (for example, to notify the User of important changes to the Site or other reasons described in Article 1.9).
1.6 Storage Time
The data provided by the User are kept by TSI for the duration of the contractual relationship resulting from the creation of a User Account. The data is then stored for archiving purposes.
1.7 User rights
Under the current regulations, the User remains in control of his personal data, and is therefore free to control its existence, destination, content and extent at any time.
In application of the Data Protection Act and the GDPR, Users may exercise for free and at the service indicated below the following rights:
Right of access
The ability of the processing controller to obtain the confirmation that personal data is being processed and, where appropriate, the possibility to know the purpose of the processing, the category of data used, the recipients of the data, the duration of the data conservation or the criteria used to determine this duration, the rights to request rectification and deletion of data, the limitation of their treatment and the possibility of opposing it, the right to lodge a complaint with the CNIL, or the information relating to any transfer of personal data to a third country.
Right of rectification
Right to obtain from the controller the updating or rectification of inaccurate personal data.
Right to erasure
Right to obtain from the controller the erasure of personal data where such data are no longer necessary for the purpose for which they are processed, where the data subject withdraws his consent, when he objects to his right to oppose the treatment or where the processing of the data is unlawful.
Right of limitation
Right to obtain from the controller the limitation of processing where the processing of the data is unlawful, where the data are no longer necessary for the purpose of processing but still have utility for the finding, for the exercise or defense of a right in court or where the data subject has objected to the treatment by virtue of his right of opposition.
Right to data portability
Right to receive the data provided to the controller in a readable, structured and commonly used format and the ability to transfer them unhindered to another controller.
Right of opposition
Right to oppose at any time, for reasons related to his particular situation, the processing of his personal data, especially when these data are processed for purposes of prospecting, profiling, for historical, scientific or statistical research purposes. The controller may continue such processing if he proves that it is necessary because of a legitimate and compelling reason that prevails over the interests and rights and freedoms of the data subject.
These rights concern all the personal data of the User.
Users may exercise these rights by contacting:
- By post to the following address:
Trace Software International
User database management service
Parc Eco Normandie – 76430 Saint Romain de Colbosc – France.
• By mail to the following address: firstname.lastname@example.org
TSI has a period of one month from the receipt of the request to provide an answer
In some cases, the User may also exercise these rights directly:
- Being registered on the site: he can access his data at any time, modify or delete it by logging into his account
- If he has subscribed to one of TSI's newsletters: he can unsubscribe at any time by clicking on the link at the bottom of each email he receives.
- Regarding Cookies, he has direct grounds of opposition as specified above in section 2.4.
Furthermore, If the User considers that the processing of his personal data does not comply with the legal and regulatory provisions in force, they may lodge a complaint with the CNIL.
Note that if the User chooses to opt out of the newsletter or to exercisehis right to object to the processing of his personal data for prospecting purposes, the free use of the site will be suspended.
1.8 Data security and recipients
TSI is committed to ensuring the protection and security of the personal data that the User chooses to communicate, to ensure the confidentiality of these and to prevent them from being falsified, damaged, destroyed or disclosed to third parties not allowed.
The Company therefore uses physical, electronic and procedural safeguards in principle sufficient to protect such data against misuse, loss and against unauthorized access, disclosure, modification and destruction.
Nevertheless, even if TSI does its best to protect personal data, in view of the unavoidable risks of transmitting data over the Internet, it can not guarantee complete protection against any error occurring during the transmission of personal data that is outside reasonable control of TSI.
Since personal data may be confidential, their access is restricted to employees or service providers who need to know this data in order to perform their tasks.
All persons having access to Users’ personal data are bound by a duty of confidentiality and are subject to disciplinary sanctions and / or other sanctions if they do not comply with these obligations.
Note that the User is responsible for the confidentiality of his password and information appearing on his account. He therefore undertakes to keep this password and to communicate it to no one.
1.9 Transfer of personal data
TSI may disclose personal information to third parties if it believes that such disclosure is necessary for technical reasons (such as hosting services) or to protect the legal interests of the Company (in the case of an acquisition or merger with a third party company or full or partial liquidation, for example).
Therefore, by using the Site, the User agrees to TSI to send his personal data to the aforementioned third parties and acknowledges that these data will be processed in accordance with their own privacy policies.
TSI may also disclose such personal information if it constitutes a legal obligation or if it believes in good faith that such disclosure is necessary in the context of a legal action (warrant, subpoena or other order of a court, by example) or to protect the rights, property or personal safety of the Company, its customers or the public.
Such transfers may be made by any method that TSI deems appropriate and in accordance with applicable law.
1.10 Links to other websites
The Site may occasionally contain links to the websites of third parties. Since these websites have their own privacy policies, TSI declines all responsibility for the use made by these sites of the information collected when the user clicks on these links
2. Special case of cookies
2.1 Presentation of a cookie
A Cookie is a text file useful for browsing websites, placed in a dedicated space on the hard drive of a User’s terminal (computer, tablet, mobile phone or any other device optimized for the Internet), during the consultation of an online content or advertisement. It is used to customize the pages by adapting them to the profile of the User and contains collected data such as, as the case may be, the name, the e-mail address, the time and the day of connection, the operating system of the user, computer, pages of frequented sites…
Cookies can be permanent (and stay after disconnecting sites for later visits to sites) or temporary (and disappear when disconnecting sites).
2.2 Function of cookies
TSI uses 2 families of cookies on the Site :
- Session cookies that allow the User to stay connected to the Site without having to provide the same information several times (such as email address and password) to perform the same task and to save your shopping cart
- Statistical cookies that allow TSI to measure and analyze Site visits as closely as possible
Regarding statistical cookies The Company may use the services of third-party providers (currently Google Analytics)
2.3 Google Analytics
The data generated by cookies (including IP addresses) are transmitted and stored by Google on servers located in the United States.
Google uses the information collected to evaluate the use of the site, to compile reports on the activity of the site to TSI and to provide other services related to the activity of the site and the use Internet.
If Google may disclose this information to third parties in the event of a legal obligation, or where such third parties process such data on Google’s behalf, Google will not associate the users’ IP address with any of its other data.
2.4 Choice and terms of acceptance or opposition of cookies
When a user browses the website, cookies are activated by default and the data can be read or stored locally on their equipment.
The User will be notified the first time that he will receive a cookie and may thus decide to accept or refuse it. By continuing to use the Site, the User expressly accepts the use by TSI of such cookies.