PRIVACY POLICY FOR SMICERS

At SMICE, protecting your personal data is a priority.

When you use the https://smice.com/ website (the " Site ") and the SMICE application (together with the Site, the " Application ") and in the context of managing our contractual relations with our customers, we may collect personal data about you.

The purpose of this policy is to inform you about how we process such data in compliance with Regulation (EU) 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the " RGPD ") and Law No. 78-17 of January 6, 1978 on data processing, files and freedoms (together the " Applicable Regulations ").

1. Who is the data controller?

In the context of managing our contractual relations with our customers, the data controller is QCM SMICE, a société par actions simplifiée (simplified joint stock company) registered with the Nanterre Trade and Companies Register under number 483 620 381, whose registered office is located at 58 rue de Nanterre 92600 Asnières-sur-Seine (" We ").

2. What data do we collect?

Personal data is data that can be used to identify an individual, either directly or by cross-referencing with other data.

We collect personal data in the following categories:

Identification data (surname, first name, email address, postal address and delivery address if different from postal address, telephone number);
Connection data (connection logs, encrypted passwords) ;
Browsing data (IP address, pages viewed, date and time of connection, browser used, operating system, user ID, MAID);
Data related to the mission ;
Economic and financial data (RIB) ;
Any information you wish to send us as part of your contact request.

Mandatory data are indicated when you provide us with your data. They are indicated by any means.

3. On what legal grounds, for what purposes and for how long do we keep your personal data?

Objectives	Legal basis	Shelf life
Provide our services available on our Application via your account	Execution of pre-contractual measures taken at your request and/or execution of the contract you or your company have entered into with Us	When you have created an account: your data is kept for the duration of your account. Your connection logs are kept for 1 year. If your account is inactive for 2 years, your personal data will be deleted if you do not reply to our reactivation email. In addition, your data may be archived for evidentiary purposes for a period of 5 years.
Build a file of customers and prospects	Our legitimate interest in developing and promoting our business	For customers: data is kept for the duration of the contractual relationship. For prospects: data is kept for a period of 3 years from your last contact.
Send newsletters, solicitations and promotional messages by email	For customers: our legitimate interest in building loyalty and informing our customers of our latest news For prospects: your consent	Data is kept for 3 years from your last contact with us or until your consent is withdrawn.
Responding to your requests for information	Our legitimate interest in responding to your requests	Data is kept for a period of 3 years from the date of your last contact.
Processing applications for tests and assignments in the event of successful tests	Execution of contractual measures	Your data is kept in an active database for the duration of the test, until the recruitment decision is made. If your application is rejected, your data may be kept for 3 months after the end of the test, so that we can provide you with explanations as to why your application was rejected. Your data may be kept in an intermediate archive for evidentiary purposes for 5 years from the date of the test.
Managing requests to exercise rights	Our legitimate interest in responding to your requests and keeping track of them	If we ask you for proof of identity, we keep it only for the time needed to verify your identity. Once verification has been completed, the proof of identity is deleted. If you exercise your right to object to receiving prospecting: we keep this information for 3 years.

4. Who will receive your data?

We will have access to your personal data:

Our staff ;
Our subcontractors: hosting service provider, newsletter dispatch service provider, e-mail service provider and data processing service provider.
Our partner for the management of gift vouchers acts as data controller. We accept no responsibility for the processing of personal data by our partners and invite you to consult their privacy policy;
Where applicable: public and private bodies, exclusively to meet our legal obligations.

5. Will your data be transferred outside the European Union?

Your data is kept and stored for the duration of processing on the servers of the company Online (FREE), located in France.

In the context of the tools we use (see article on recipients concerning our subcontractors), 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 deemed 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 to the RGPD: in this case such transfers are based on appropriate safeguards indicated in Article 46 of the RGPD, tailored to each provider, including but not limited to 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 RGPD.

6. What are your rights regarding your data?

You have the following rights with regard to your personal data:

Right to information : this is precisely why we have drawn up this policy. This right is provided for in Articles 13 and 14 of the RGPD.

Right of access : you have the right to access all your personal data at any time, pursuant to Article 15 of the RGPD.

Right of rectification: you have the right to rectify inaccurate, incomplete or obsolete personal data at any time in accordance with Article 16 of the GDPR.

Right to limitation : you have the right to obtain the limitation of the processing of your personal data in certain cases defined in Article 18 of the RGPD

Right to erasure : you have the right to demand that your personal data be erased, and to prohibit any future collection of it for the reasons set out in Article 17 of the RGPD

Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a breach of the applicable texts, in accordance with Article 77 of the RGPD.

The right to set up instructions for the storage, deletion and communication of your personal data after your death.

Right to withdraw your consent at any time : for purposes based on consent, Article 7 of the RGPD states that you may withdraw your consent at any time. This withdrawal will not call into question the legality of the processing carried out prior to the withdrawal.

Right to portability : under certain conditions specified in Article 20 of the RGPD, you have the right to receive the personal data you have provided to us in a standard machine-readable format and to demand its transfer to the recipient of your choice.

Right to object : pursuant to Article 21 of the RGPD, you have the right to object to the processing of your data Note however that we may continue to process them despite such objection, for legitimate reasons or the defense of legal rights.

You can exercise these rights by writing to us using the contact details below. We may ask you to provide additional information or documents to prove your identity.

7. Contact to exercise your rights

Contact email: contact@smice.com

Contact address: 58 rue de Nanterre 92600 Asnières-sur-Seine.

8. Modifications

We may modify this policy at any time, in particular in order to comply with any regulatory, legal, editorial or technical developments. These modifications will apply as of the effective date of the modified version. You are therefore invited to consult the latest version of this policy on a regular basis. Nevertheless, we will keep you informed of any significant changes to this privacy policy.

Effective date: November 1, 2023