Privacy Policy

La présente politique vise à exposer les obligations et résolutions du groupe Sulo constitué par SULO SAS et ses filiales (« Sulo ») en vue d’un traitement de vos données à caractère personnel sûr et conforme aux dispositions réglementaires applicables, notamment au Règlement (UE) 2016/679 dit Règlement général pour la protection des données ou « RGPD ».

1. Scope

This policy is intended to apply to all processing of personal data in connection with the site www.sulo.com implemented by SULO.

2. Responsibility of SULO

SULO, whose registered office is 104 avenue des Champs-Elysées 75008 Paris, France, is the data controller within the meaning of the GDPR, for the collection and processing of personal data carried out on the site subject to the URL address: www .sulo.com, (“the Site”).

The site ensures the collection and processing of personal information with respect for privacy in accordance with law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms as well as the new European legislation in protection of personal data.

Your requests for information or to exercise rights can be sent to our Data Protection Officer at the following address:

3. Processing of your personal data

During your visit to our site, we may collect the following data:

your IP addresses
information about your browser (cookies)
HTTP response codes
your identity (surname, first name, telephone number, e-mail address) if you voluntarily communicate it to us
the data appearing in your CV if you respond to a SULO ad

SULO collects and processes your data in particular in the following cases:

when you contact us directly to obtain information about our products and services in which you are interested or for any other question;
when you become a customer and use our products.
when you respond to our marketing campaigns, for example, by filling in a response card or by filling in the contact form offered on the site;
when you apply for one of our jobs vacancies;
to optimize the functioning of the site

4. Legal basis for processing your data

We only process your data if a legal provision authorizes us to do so. We process your data in particular on the basis of the provisions of articles 6 and 9. 9 of the GDPR, as well as on the basis of a consent obtained in accordance with article 7 of the GDPR. The processing of your data is based, among other things, on the following legal provisions (non-exhaustive list):

Purpose	Legal basis
Consideration of your application for a position within SULO	Pre-contractual agreement
Consideration of your requests for commercial information	Contractual and pre-contractual agreement
Subscription to our newsletters and other marketing actions	Consent
Compliance with our legal obligations	Legal obligation
Exercise and defense of our rights, particularly in terms of intellectual property	Legal obligation and legitimate interest
To identify other products or services that may be of interest to you and to notify you	Consent
Operation of the website	Legitimate interest or consent

5. Security measures

We use numerous security measures to protect and maintain the confidentiality, integrity and availability of your data. We nevertheless draw your attention to the fact that there are security risks inherent in the transmission of data via the Internet, in particular the risk of intrusion.

We, our contractors and business partners work to maintain physical, electronic and procedural safeguards of your data in accordance with applicable data protection requirements. We use, among others, the following measures: Data encryption, connection security, access restriction, implementation of firewalls and anti-virus.

All your information is stored on secure servers (or secure paper media), either ours or those of our subcontractors or business partners, accessible and used subject to compliance with our security policies and standards (or equivalent security standards). our subcontractors or business partners).

6. Retention of your data

We keep your data for as long as necessary for the purposes for which you communicated them to us. Access to your information is limited to employees who have the appropriate authorizations and who have a defined need to access this information for the purposes indicated above.

Purpose	The duration of the conversation
Consideration of your job application	2 years from application
Consideration of your commercial requests sent	2 years from last contact
Subscription to our newsletters and other marketing actions	36 months from last contact
Compliance with our legal obligations, exercise and defense of our rights, particularly in terms of intellectual property	Duration of legal proceedings or termination of legal obligation
To identify other products or services that may be of interest to you and to notify you	36 months from last contact
Operation of our site	Management of cookies according to the table below

Cookie name	Suppliers	Purpose	Cookie lifetime	Privacy policy
Cookies essential to the operation of the site
Borlabs Cookie	Owner of this website	Acceptance of cookies in accordance with the GDPR	6 months	https://sulo.fr/politique-de-confidentialite/
WPML	Owner of this website	Stores the current language.	1 day	https://sulo.fr/politique-de-confidentialite/
Audience measurement
Matomo	Owner of this website	Statistical cookies collect information in an anonymous way. This information helps us to understand how our visitors use our website.	6 months	https://sulo.fr/politique-de-confidentialite/


Personalized advertising cookies
Non-existent
External averages
YouTube	Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland	Used to unlock content from YouTube.	6 months	https://policies.google.com/privacy?hl=en&gl=en

Your data may be kept for a period exceeding those referred to above, in particular to enable us to comply with a legal obligation or, in the event of legal action, for the representation of our rights. In both cases, we do not keep your data beyond the applicable legal requirements, in particular with regard to the limitation period and the extinction of any legal action.

7. Data transfers

We are prohibited from disclosing, assigning, transferring, or communicating all or part of your information to third parties, except:

of the SULO group
service providers and business partners to the extent strictly necessary for the provision of products and services on our behalf:
- Geo Targetly*
- Microsoft for messaging
- Mittwald CM Service GmbH & Co. KG
for whom we are obliged to provide information for legal or regulatory purposes: police and judicial authorities in particular.

We take care to minimize any data transfers outside the European Union as much as possible. In all cases, we make sure that our service providers and partners agree to apply the same level of protection as that required in France. In the event that a transfer outside the EU should be carried out, we will ensure that the appropriate legal guarantees are implemented according to the particular situation of the place of receipt of the data.

8. Automated decision

We do not carry out any automated processing of personal data, in particular with a view to profiling.

9. Your rights under the GDPR

As a data subject, you have the following rights:

the right of access to your data
the right to rectify your data
the right to erasure of your data
the right to limit the processing of your data
the right to the portability of your data
the right to oppose the processing of your data
the right to withdraw your consent for processing that requires it the right to organize the fate of your data after your death

These rights can be exercised by sending a request to this effect to our data protection officer, either by email to the following address:

Or by post to the following address:

Sulo SAS, 1 rue du Débarcadère building A - IMM Perspective Défense

92700 COLOMBES

For the attention of the Data Protection Officer

We always strive to respond within 30 days. However, this period may be extended if necessary, for reasons related to the specific law of the party concerned or the complexity of your request.

Before granting your request and in the event of reasonable doubt as to your identity, it will be possible for us to request the production of proof of identity allowing us to remove this doubt.

In the event that it is not possible for us to grant your request, we will inform you of its rejection and the reasons for this rejection.

10. Control authority

If you believe that we have not adequately responded to your complaints or concerns, you have the right to file a complaint with the CNIL:

www.cnil.fr

Or by mail:

3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07

11. GEO-Redirecting

When a person visits a web page that contains a Geo Targetly script, the script will route the visitor through Geo Targetly servers. We then obtain the IP address of the visitor, referrer URL, current browser URL, browser screen size and other available information in the request header to Geo Targetly server. Using the IP address, we determine the approximate location of the visitor's device and along with the other mentioned information gathered from the visitor, we serve geo personalized content, redirects, popups, notification bars and other forms of output onto sulo.com website for the particular visitor.

It is important to note that none of the information extract from the visitor is stored in Geo Targetly database. Geo Targetly don't profile or store a list of the visitors as we merely 'process' the visitors information on the go to determine the relevant geo personalized output required for the visitor.