FLEET – PROTECTION OF PERSONAL DATA OF USERS

1. Fleet takes the utmost care in the management and protection of personal data.
2. As part of its activities (the “Services”), Fleet provides IT equipment for professionals (the “Clients”) which it can maintain and repair.
3. Fleet collects, via its website https://fleet.co (the "Site") and in the context of the performance of its Services, personal data on individuals using the functionalities of the Site, individuals using the computer equipment provided by Fleet and individuals acting on behalf of Customers (the users ").

This document is intended to inform any User on how Fleet collects, uses, processes and transmits personal data.

1. The data controller is Fleet, a simplified joint-stock company, registered with the Paris Trade and Companies Register under number 848 427 449, whose head office is located at 45 rue de Maubeuge 75009 Paris.
2. Fleet undertakes to comply with the provisions of Regulation (EU) No. 2016/679 of 27 April 2016 relating to the protection of personal data.

1. The data collected by Fleet may be transmitted directly by the User when browsing the Site, when placing an order and when placing an order for computer equipment (the “Order”).
2. This information is in particular: surnames, first names, postal address, e-mail address, telephone number, profession, professional address.
3. The personal data collected by Fleet about a User may also be transmitted through a Client, as the User's employer and in the exclusive context of the execution of the commercial relationship.
4. Fleet invites all Users to consult the personal data management policies of their employer to be aware of the personal data that may be transmitted by them.
5. This information may in particular concern: surnames, first names, professional email address, the individual's professional position and any other data whose exclusive purpose is the strict performance by Fleet of the Services.
6. On the occasion of the execution of maintenance and repair operations, Fleet may collect the information directly transmitted by any User and in particular: the answers communicated by the User or the history of the use of the computer equipment provided by Fleet.
7. Similarly, during a remote repair operation, Fleet may intervene on the User's computer equipment and be exposed to personal data that is not kept by Fleet.
8. Fleet also collects data through Cookies. A cookie does not personally identify a User but allows its issuer to recognize the User's terminal and to collect a certain amount of information relating to the navigation carried out from this terminal. The User is invited to consult the section below devoted to Cookies.
9. Fleet may also collect data through standard Internet technologies such as Scripts and then Pixels. These technologies make it possible to collect information relating to the use of the Fleet Site, the presence of cookies on the User's Terminal, whether or not the e-mails sent by Fleet are read and the clicks made on the links contained in these emails.

A/ Legal bases of processing

Fleet collects and processes personal data in accordance with the legal bases provided by the laws and regulations in force, in particular:

1. Performance of a contract – example: performance of the Services provided by Fleet for Customers;
2. Performance of a legal obligation – retention of invoices;
3. Legitimate interests pursued by Fleet – such as processing for the purposes of optimizing the Services or for the purposes of fraud prevention and, in any event, in compliance with your fundamental rights and freedoms which prevail over the legitimate interests of Fleet;
4. User Consent.

B/ Purposes of Fleet

Fleet may collect and save Users' personal data to carry out the following processing:

For the processing of data requiring the consent of the User, the latter has the option of withdrawing his consent by making a request here client@fleet.co

In the event that the User's consent has not been obtained beforehand, Fleet does not carry out the processing mentioned.

A/ General

1. Personal data collected and processed by Fleet may be transmitted to:
• Fleet partners who can process them on their behalf (the "recipients")
• partners of Fleet who may process them on behalf of and according to instructions from Fleet (the “processors”).
2. The recipients are:
• The duly authorized professional collaborators of the User;
• The financial partner of Fleet who contributes to the provision of the Equipment for the benefit of the Customer;
• The police authorities in the context of legal requisitions concerning the fight against fraud;
• Potential business partners such as marketing and advertising agencies.
3. Fleet may use subcontractors for the following operations:
• Secure payment on the Site;
• The fight against fraud and the recovery of unpaid debts;
• The management of instant messaging, telephone calls, their possible recordings and the sending of postal mail;
• The execution of maintenance and repair operations with a third-party service provider mandated by Fleet;
• The personalization of the content of the Site;
• The performance of maintenance operations and technical developments of the Site and the Fleet information system;
• The collection of User opinions;
• Sending commercial prospecting emails.
4. Fleet may also share personal data in the event of a subsequent change in the structure of the Fleet company, in particular in the event of a sale, transfer or merger of the company or part of it. Fleet will then ensure that the other party complies with the laws and regulations in force relating to the protection of personal data.

B/ Transmission outside the EU

1. The data collected by Fleet is stored in the European Union
2. However, for the purposes of the purposes set out above, personal data may be transmitted to companies located in countries that are not members of the European Union.
3. In this case, Fleet takes care to only transfer personal data, outside the European Union, only to third countries ensuring an adequate level of protection and recognized as such by the European Commission, to companies certified under the Privacy Shield or companies guaranteeing an adequate level of protection through the existence of binding corporate rules, otherwise known as Binding corporate rules.
4. For example, the use of personal data in connection with social networks may give rise to a transfer to the United States.
5. Users are invited to consult the pages of social networks relating to the protection of personal data.

1. In order to provide Users with the control and visibility necessary for the processing of their personal data, Fleet guarantees the proper exercise of the rights available to them.
2. Thus, any natural person has the right to exercise the following rights:
• Right of access to processing
• Right to object to processing
• Right to rectification of processing
• Right to restriction of processing
• Right to object to profiling
• Right to data portability
• Right to erasure
3. The persons concerned by the processing of personal data can exercise their rights with the company Fleet:
• By post: 45 rue de Maubeuge 75009 Paris
• Electronically: client@fleet.co
4. The request must be accompanied by proof of identity.
5. Fleet has one month to respond from receipt of the request. An extension of the 2-month period is possible given the complexity and the number of requests, provided that the person concerned has been informed within the initial period of one month.
6. In the event of the exercise of a right of opposition to marketing profiling, the User is informed that he will continue to receive commercial solicitations but these will be less relevant and will no longer be targeted according to his centers of interest.
7. In the event of no response or an unsatisfactory response, the data subject has the option of contacting the supervisory authority of his country of residence (CNIL.FR)

1. The User has the right to define directives relating to the storage, erasure and communication of his data after his death. These guidelines may be general (concerning all processing of personal data) or specific (concerning only specific data processing).
2. The User may send the advance directives he has formulated to the following address: client@fleet.co.

1. The data processed are kept for a period not exceeding that necessary for the purposes for which they are processed.
2. The starting point of the retention period for personal data is set at the later of the date of a Customer's Order and the date of the User's last activity.
3. Certain types of processing are subject to a specific retention period. For example, invoices are kept for 10 years; data relating to the execution of an order are kept for up to 5 years after the end of the execution of the obligations; personal data collected while browsing the Site is kept for 9 months from the last activity.

1. As data controller, Fleet carefully monitors the security and confidentiality of the data collected and processed.
2. Fleet benefits from appropriate security measures to ensure the physical security of the buildings housing our systems, the security of the computer system to prevent external access to personal data and the fact of having secure copies of User data.
3. Fleet takes care to select processors based on their ability to ensure the security of processing through appropriate measures.

1. Fleet may propose to use social networks to improve the commercial relationship and offer you targeted advertising offers on these networks.
2. The use of social networks to interact with Fleet is likely to lead to exchanges of data between Fleet and these social networks.
3. Fleet invites all Users to consult the personal data management policies of the various social networks to find out about the personal data that may be transmitted by them.

Fleet may use your contact details to send you targeted advertising, in particular by email and SMS.

A/ Prospecting by email and SMS

1. The prior and express collection of the User's consent is necessary for any commercial prospecting sent by electronic means.
2. Except as detailed below, Fleet will not send you personalized solicitations by email or text message if you have not consented to them.
3. In any case, the User has the possibility of opposing, at any time, the receipt of these solicitations by carrying out the following actions:
• For email solicitations, by clicking on the unsubscribe link inserted in each email;
• For requests by SMS, by sending a message containing only the words "Stop SMS" to the number indicated in it.

B/ Advertising retargeting

1. Fleet may use the services of companies whose role is to identify Internet users who have already visited the Site and to send them personalized e-mails.
2. These companies may use cookies to distinguish Users and then to personalize the advertisements that these Users receive based on their browsing history.
3. This mechanism explains why a User who has browsed the Site can receive an advertising email without having entrusted his email address to Fleet.
4. This processing involves partners who have already collected your email address, as well as your consent to authorize the sending of advertising. You can object to this type of processing by contacting client@fleet.co.

A/ General

1. Cookies are tracers placed on your terminal (computer, tablet, smartphone, etc.), in particular when consulting a website or reading an e-mail and which allow navigation monitoring or behavioral analysis to be carried out. of the Internet user in order to facilitate navigation and activate certain functionalities.
2. There are two types of cookies:
1. First party cookies deposited by Fleet for the purposes of navigation and operation of the Site;
2. Third party cookies deposited by third party partner companies in order to identify your areas of interest and to send you personalized offers on our Site. These trackers are directly managed by the companies that publish them and which must also comply with data protection regulations.

Purposes of the use of cookies, tags and tracers

Fleet may use first party cookies or third party cookies for the following purposes:

• Allow the use of the main functionalities of the Site (Fleet cookies essential to the use of the Site);
• Adapt the presentation of our Site according to the terminal used and/or according to the affinities of each User;
• Memorize information relating to a form that you have completed on our Site;
• Allow Users to access reserved and personal spaces on the Site;
• Implement security measures;
• Establish statistics and volumes of visits and use of the elements making up our services (audience measurement cookies);
• Share information with advertisers on other websites and offer relevant advertisements in line with your areas of interest (advertising cookies);
• Sharing information on social networks (sharing cookies to social networks);

Configuration of the deposit of cookies, tags and tracers

1. Fleet collects your consent prior to any deposit of advertising cookies, audience measurement and sharing to social networks.
2. At any time, the User can modify his preferences in terms of cookies as follows:
1. browser settings:
• Safari™
• Chrome™
• Firefox™
• Opera™
2. browser settings:
• iOS
• Android
3. setting cookies with a tool offered by Fleet