Privacy

Introduction: We at Super SARL respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share your personal information when you use our e-commerce services, in compliance with the EU General Data Protection Regulation (GDPR) and applicable French laws (including ePrivacy rules). We aim to present this information in a clear and accessible way, following the GDPR’s transparency requirements. By using our website or services, you agree to the practices described in this Policy. If you do not agree, please refrain from using our services.

1. Controller and Data Protection Officer (DPO) Contact

Controller: The data controller responsible for your information is Super SARL (trading as "cabinet7"), a French société à responsabilité limitée, located at 1 Rue de Commerce, 75001 Paris, France. You can reach us by email at dpo@super-sarl.com or by mail at the address above. Data Protection Officer: We have appointed a Data Protection Officer (DPO) to oversee compliance. You may contact our DPO with any questions or requests regarding your personal data at dpo@super-sarl.com. The DPO can assist you in exercising your rights or addressing any concerns about how we process your data.

2. Definitions

The data protection declaration of the Super SARL is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, inter alia, the following terms:

a) Personal data Personal data means any information relating to an identified or identifiable natural person (“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 the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
We occasionally use generative-AI tools (OpenAI, Gemini, Claude) with pseudonymised data to draft support replies and product descriptions; no automated decisions with legal effects are taken.

f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

In the event of a consumer dispute, personal data relevant to the case may be shared with the designated mediation body Sas Médiation Solution (France), solely for the purpose of resolving the dispute. The legal basis is Article 6(1)(f) GDPR (legitimate interest in extrajudicial conflict resolution).

j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

3. Name and Address of controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Super SARL
135 Route de Bordeaux
Le Moulin de L'Abbaye
16400 La Couronne
France

Email: dpo@cabinet7.com

Website: www.cabinet7.com

5. Cookies & Tracking Technology

The Internet pages of the Super SARL use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the dats subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, the Super SARL can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

We value your privacy. We use cookies and similar technologies to make our site work, to measure performance and to show you relevant offers. Non-essential cookies (analytics & marketing) are disabled by default and will only be set if you consent. You can change or withdraw your choice at any time via “Cookie consent” in the left bottom corener of the website. See below for details (cookie name, provider, purpose and expiry date).

In accordance with the ePrivacy Directive and CNIL guidelines, non-essential cookies (such as analytics, personalization, or advertising cookies) are only activated after you have given explicit consent via our cookie banner. These cookies are blocked by default and will only be stored in your browser after you click “Accept” or manage your preferences. You can withdraw or change your consent at any time by clicking on Cookie consent in the left bottom corner.

6. Collection of general data and information

The website of the Super SARL collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, the Super SARL does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Super SARL analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

Children’s Data

Our services are intended for adults only. We do not knowingly collect or solicit personal data from anyone under the age of 18 (the “legal drinking age” in France). If you are under 18, please do not attempt to register on our site, place an order, or send us any personal information.

If we learn that we have inadvertently collected personal data from a person under 18 without verification of parental consent, we will delete that information as quickly as possible. Our newsletter is intended for persons aged 18 years or over. We do not knowingly collect or process personal data relating to minors. If you believe we might have any information from or about someone under 18, please contact our DPO at dpo@super-sarl.com so we can remove it.

7. Subscription to our newsletter

On the website of the Super SARL, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

The Super SARL informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances.

Newsletter tracking

The newsletter of the Super SARL contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Super SARL may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. The Super SARL automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. Contact possibility via the website

The website of the Super SARL contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address) and ata provided in the submission form. If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

9. Rights of the data subject

a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• the purposes of the processing;

• the categories of personal data concerned;

• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

• the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;

• the existence of the right to lodge a complaint with a supervisory authority;

• where the personal data are not collected from the data subject, any available information as to their source;

• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (Right to be forgotten)

• Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

• The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

• The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.

• The personal data have been unlawfully processed.

• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

• The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

• In accordance with Article 85 of the French Data Protection Act (Loi Informatique & Libertés), you have the right to define instructions relating to the retention, erasure, and communication of your personal data after your death. These instructions can be general (registered with a certified digital trusted third party) or specific (sent directly to us). You may also designate a person responsible for executing these instructions. If no such instructions are given, your heirs may exercise certain rights, including access or deletion, if necessary for the settlement of your estate.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Super SARL, he or she may, at any time, contact any employee of the controller. An employee of Super SARL shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Super SARL will arrange the necessary measures in individual cases.

e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

• The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.

• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.

• The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Super SARL, he or she may at any time contact any employee of the controller. The employee of the Super SARL will arrange the restriction of the processing.

f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any employee of the Super SARL.

g) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
The Super SARL shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If the Super SARL processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Super SARL to the processing for direct marketing purposes, the Super SARL will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Super SARL for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of the Super SARL. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Super SARL shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Super SARL.

i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Super SARL.

If you believe that your data-protection rights have been infringed, you may lodge a complaint with the French supervisory authority, the Commission Nationale de l’Informatique et des Libertés (CNIL – 3 Place de Fontenoy, 75007 Paris; www.cnil.fr).

j) We respond to data-subject requests within one month of receipt. In complex cases or if we receive numerous requests from you, we may extend this period by up to two additional months; if so, we will inform you within the initial one-month period.

10. Personal Data we collect and how we use it

International Transfers and Safeguards

Some of our service providers, partners, or technical infrastructure may be located outside the European Economic Area (EEA), including in countries that do not benefit from an adequacy decision by the European Commission.

In such cases, we ensure that appropriate safeguards are in place to protect your personal data in accordance with Article 46 of the GDPR. These safeguards may include:

• Standard Contractual Clauses (SCCs) adopted by the European Commission
• Participation in the EU-U.S. Data Privacy Framework (for U.S. providers)
• Supplementary technical and organizational measures when required

You may request a copy of these safeguards or further information by contacting us at info@cabinet7.com.

11. Data protection provisions about the following applications

12. Legal basis for the processing

Art. 6 (1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6 (1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6 (1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 (1) lit. d GDPR. Finally, processing operations could be based on Article 6 (1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

13. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6 (1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

14. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period, as per section 12. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

15. Data Security and Breach Notification

We take the security of your personal data seriously and have implemented appropriate technical and organizational measures to protect it against unauthorized access, accidental loss, destruction, or disclosure. This includes physical safeguards at our warehouse, such as restricted access, CCTV, alarm systems, and fire protection.

In the unlikely event of a personal data breach, we will assess the situation promptly. If the breach is likely to result in a risk to your rights and freedoms, we will notify the relevant data protection authority (e.g. CNIL) within 72 hours as required by Article 33 of the GDPR. If the breach is likely to result in a high risk to you, we will also inform you without undue delay as per Article 34.

We maintain a breach response protocol and document all incidents, even if no notification is legally required. If you have concerns or suspect misuse of your data, please contact us immediately at info@cabinet7.com.

16. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

17. Data retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, contractual and accounting obligations.

18. Legal Basis

Under the EU General Data Protection Regulation (GDPR), we must identify a lawful basis for each purpose for which we process your personal data. The table below explains what those purposes are and the legal bases we rely on.

19. International Data Transfer

Some of our service providers are located outside the European Economic Area (EEA), principally in the United States and the United Kingdom. When we transfer your personal data to these providers, we rely on one of the safeguards recognised by the GDPR to ensure an adequate level of protection.

We review these safeguards regularly and will update this list if our providers change or if new adequacy decisions are adopted. Where a provider’s EU‑US Data Privacy Framework certification lapses, we rely on the 2021 Standard Contractual Clauses together with supplementary measures (encryption, pseudonymisation, Transfer‑Impact‑Assessment). You can request further details by contacting our Data Protection Officer (see “Contact” section).

Service Providers / Data Processors

We use carefully selected third‑party service providers (“processors”) to help us deliver our services. Each provider processes personal data only on our documented instructions and is bound by a Data Processing Agreement (DPA) that meets GDPR requirements.

We conduct due‑diligence checks on every processor and sign a DPA before any personal data is transferred. You can request a complete up‑to‑date list of sub‑processors by contacting our DPO.

Version

v2.0 — Effective 12 September 2025