This document explains the principles and our commitments for the protection of your personal data and aims to inform you about :
- The personal data that SteerFox collects and the reasons for this collection,
- How this personal data will be used,
- Your rights as a data subject of our data processing operations.
This policy applies to all Steerfox services, whatever their nature (site, applications, services, etc.).
The person responsible for processing your data
The contact details are as follows :
Postal address: S350 Rue Jean René Guillibert Gauthier de la Lauzière, Parc du Golf Bâtiment 7, 13290 Aix-en-Provence, France
Telephone: 04 84 49 20 31
E-mail: produit@steerfox.com
How SteerFox protects your personal data
Steerfox is committed to taking into account the protection of your personal data and your privacy right from the design stage of the services offered to you (Privacy by design). To ensure security and guarantee that your rights are respected and properly exercised, measures to protect your personal data are implemented (Privacy by default).
What personal data does SteerFox use ?
Steerfox undertakes only to collect data that is strictly necessary for the provision of the services offered. If you are asked for optional data, SteerFox will clearly inform you of the personal data required to provide the service. Personal data is collected directly from you and is only used for the purposes for which you have been informed. Personal data is used to offer you other services only if you have agreed to receive commercial communications.
What is the legitimate basis for our processing ?
SteerFox relies on the following legitimate grounds in order to be able to process personal data:
Performance of the contract
The legal basis for processing the user’s personal data collected is the performance of the sales contract. In this respect, the user is obliged to provide the data necessary for the performance of the contract. If the user does not provide this data, it will not be possible to complete the sale.
Legal obligations
The management and issuing of the invoice is based on SteerFox’s legal obligations in the context of its relationship with customers.
Consent
With regard to the following purposes, the legal basis for the processing of the user’s personal data will be the user’s consent, if given:
Management of registration on the site and applications.
Management of the sending of information on products and services and personalised information tailored to the user’s profile.
Responding to the exercise of rights of access, modification, cancellation and opposition, as well as to questions and complaints from the user.
Withdrawal of consent to these treatments by the user will not condition the execution of the contract concluded by the person concerned with Steerfox.
Legitimate interest
With regard to the following purposes, the legal basis for the processing of the user’s personal data will be the legitimate interests of SteerFox:
The preparation of profiles by means of navigation on the site on the part of a user registered on it, as well as all users who have provided us with their data for any other purpose.
Creation of profiles to send information on exclusive promotions, the latest news and personalised information tailored to the user’s profile.
Sending satisfaction surveys on products purchased or services used by Steerfox customers in order to ask their opinion and improve them.
Our legitimate interest is to ensure that our site remains secure, and to help Steerfox understand user needs, expectations and satisfaction levels in order to improve services, products and brands. All these actions are carried out with the aim of improving customer satisfaction and ensuring a unique browsing and shopping experience.
What about minors’ personal data ?
Certain services may be used by minors. In this case, minors must obtain the consent of their parents or legal representatives.
Who may receive your personal data ?
Your data may be passed on:
Steerfox’s internal departments: the departments responsible for carrying out the services subscribed to, in particular Customer Service, Sales Administration, etc.
Steerfox’s external service providers: technical service providers, including sub-contractors;
Steerfox’s commercial partners, after informing you in advance and allowing you to express your choices by ticking a box.
Can your personal data be transferred outside the European Union ?
Steerfox processes all your Personal Data within the European Union (EU).
However, for certain specific services, Steerfox may use subcontractors established outside the EU. Certain Personal Data may then be communicated to them strictly for the purposes of their missions. In this case, in accordance with the regulations in force, Steerfox requires its subcontractors to provide the necessary guarantees to supervise and secure these transfers, in particular by signing the European Commission’s standard contractual clauses.
How long does Steerfox keep your Personal Data ?
The length of time your Personal Data is kept depends on the service subscribed to. Steerfox undertakes not to retain your Personal Data beyond the period necessary for the provision of the service, and therefore for your use of the service, plus the retention period imposed by the applicable rules on legal prescription.
Is your Personal Data protected ?
Steerfox undertakes to take all measures to ensure the security and confidentiality of Personal Data and in particular to prevent it from being damaged, deleted or accessed by unauthorised third parties.
Furthermore, in the event of a security incident affecting your Personal Data (destruction, loss, alteration or disclosure), Steerfox undertakes to comply with the obligation to notify violations of Personal Data, in particular to the CNIL.
What are your rights regarding your Personal Data ?
At any time, you have the right to exercise with Steerfox the rights provided for by the regulations in force applicable to personal data, provided that you meet the conditions:
- Right of access: you may be informed of your Personal Data being processed by Steerfox;
- Right of rectification: you may update your Personal Data or have your Personal Data processed by Steerfox rectified;
- Right to object, in particular to receiving commercial communications: you may express your wish to no longer receive commercial communications from Steerfox or request that your Personal Data no longer be processed;
- Right to erasure: you may request the deletion of your Personal Data;
- Right to limitation: you may request the suspension of the processing of your Personal Data;
- Right to portability: you may ask Steerfox to recover your Personal Data in order to dispose of it.
When subscribing to a service or collecting your Personal Data, you will be given the address (postal and/or electronic) to which you can send your request to exercise your rights. All requests must be accompanied by proof of identity. SteerFox undertakes to respond to your requests to exercise your rights as quickly as possible and in any event within the legal time limits.
The appointment of a Data Protection Officer demonstrates Steerfox’s commitment to the protection, security and confidentiality of its customers’ Personal Data. You can contact the Data Protection Officer at the following address
Data Protection Officer
350 Rue Jean René Guillibert Gauthier de la Lauzière, Parc du Golf Bâtiment 7, 13290 Aix-en-Provence, France
Or by email: produit@steerfox.com
Changes to this policy
Updates to this Privacy Policy will be posted here on steerfox.com.
Cookie policy
Steerfox Group sites and all its web pages use cookies to distinguish you from other site users. This allows us to improve services and optimise your user experience. A cookie is a text-only string of information that a website transfers to your computer’s hard drive so that the website can remember who you are. Cookies can help a website tailor content to your interests more quickly. Most major websites use cookies. In general, a cookie contains the name of the domain from which the cookie originates, the “lifetime” of the cookie and a value, i.e. a unique number created at random. There are two types of cookie on Steerfox group sites:
temporary cookies, which remain in the cookie file of your browser until you leave the site
Persistent cookies, which remain much longer in the cookie file of your browser (the length of time depends on the lifetime of the cookie in question).
Temporary cookies are used :
To enable you to transfer information from one page to another on our site without having to re-enter it
To allow you to access stored registration information.
Persistent cookies are used :
- To help us identify you as a visitor (using a number, not personally) when you return to our website
- To enable us to tailor content or advertisements to your interests, or to avoid showing you the same advertisements repeatedly,
- To enable us to tailor our communications to you
- To compile anonymous aggregate statistics that allow us to understand how visitors use our site and help us improve the structure of our website. We cannot identify you personally in this way.
You can accept or refuse cookies by changing the settings on your browser. However, you may lose some of the interactive features of the service if cookies are disabled. Below is a list of the main cookies we use and their functions.
- Modernizr
Type of cookie: Persisten
Cookie function : We use this technology to avoid differences in display between visitors’ different browsers and devices. - nab Alternative
Cookie type: Persistent
Cookie function: This cookie allows us to display variants of certain content and to ensure that a visitor is exposed to the same variant on each visit. - Poptin
Cookie type : Persistent
Cookie function: This cookie allows us to display pop-ups in order to display temporary content on our site. - WordPress
Cookie type : Temporary
Cookie function: This cookie is not used for users who are not logged in to WordPress. - YouTube
Cookie type: Persistent
Cookie function: This cookie is used to store the user’s video player preferences using the embedded YouTube video. - Authentication token
Cookie type: Peristent
Cookie function: This cookie is only used if you have requested that the portal remember you when you log in. It stores a token that identifies you. - Google Analytics / CA Audiences
Type of cookie: Persistent
Cookie function: We use traffic tracking tools to compile anonymous aggregate statistics that allow us to understand how visitors use our website and help us improve the structure of our website. This data does not identify you personally. For more information, visit www.google.com/policies/privacy/partners and https://tools.google.com/dlpage/gaoptout.
You can delete and block all cookies from Steerfox group sites. To do this, change your browser setting to refuse some or all cookies. Please note, however, that if you decide to block cookies via your browser, some elements of our website may not function properly.
Steerfox applications
We use analysis tools on the Steerfox application (Dashboard). These tools are used to compile anonymous aggregate statistics that allow us to understand how our customers use the applications for the purpose of continuous improvement. This data does not identify you personally. You can choose to disable application analysis tools in your device settings.
Glossary
Each term beginning with a capital letter has the meaning given to it below.
“Privacy and Personal Data Protection Policy” and “Policy”: means this Policy describing the measures taken for the processing, use and management of your Personal Data and your rights as a data subject.
“Personal Data”: means any information relating to you and enabling you to be identified directly or indirectly.
“Processing”: Refers to any operation or set of operations applied to your Personal Data.
“Data Processor”: Refers to a person in the Steerfox company who carries out the processing of your Personal Data.
“Personal Data Breach”: Refers to a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to your Personal Data.
“Recipient”: Refers to the department or company that receives communication and may access your Personal Data.
