Privacy Policy and Protection of Personal Data

The use of the website www.transpare.fr (hereinafter referred to as "TRANSPARE")
implies the provision by the service provider and the Shipper, users of TRANSPARE
(hereinafter referred to as "the User") of a certain number of personal data.

In order to preserve the confidence of the User, the TRANSPARE publishing company
invites him to read its policy on the subject, which describes the data collected, the use
made of it, and the rights available to the User, as far as they are concerned.

IT IS STRONGLY RECOMMENDED TO READ THIS DOCUMENT BEFORE USING
TRANSPARE.

ACCEPTANCE OF THIS PRIVACY AND PRIVACY POLICY CONDITIONS ACCESS TO
TRANSPARE.

Responsibility of Data Management

The website www.transpare.eu is published by TRANSPARE, the simplified share
company registered with the RCS Marseille under the number 851 056 807 whose
registered office is 48 rue Grignan, 13001 Marseille - France.

Hereinafter referred to as "the Company"

In connection with the use of TRANSPARE, a certain number of personal data
concerning the User are collected and processed by the Company.

The Company is therefore responsible for processing within the meaning of EU
Regulation 2016/679 on the protection of personal data.

I. Commitments of the Company

Respect for the identity and rights of Users is a major concern of the Company which is
committed to compliance with French and European regulations in this area, particularly
in Data Protection Act of 6 January 1978 and the EU Regulation 2016 / 679 of April 27, 2016.

The personal data concerning the User are processed in the strict framework defined by
this Privacy Policy and do not give rise to any further processing for other purposes.

The Company implements a variety of security measures to safeguard the security of the
User's personal information.

Only employees who need to do specific work (for example, customer service) have
access to personally identifiable information. Computers and servers used to store
personally identifiable information are kept in a secure environment.

II. Data Collected as part of the User Account and Related Purposes

The Company collects, via TRANSPARE, and more specifically through the creation of a
User Account, only the personal data that is strictly necessary for the proper performance
of the TRANSPARE services offered, namely:
• online posting of the request (s) of the shippers via a precise form gathering all
the useful and necessary information allowing the service provider to establish a
fair tariff;
• online posting of the various offers received by the service providers in response
to the request (s) of the shipper;
• direct connection between the shipper and the service provider whose offer has
been accepted by the shipper;
• once the offer has been accepted, a workspace is used as a chat cell and allows
the provider and the charger to exchange files.
The Company may also use the personal data collected for the purposes of statistical
reprocessing and improvement of its services. These treatments are completely
anonymized, and thus not covered by the aforementioned Law and Regulation.

If this information is not communicated, the User will not be able to access the
TRANSPARE services.

The User undertakes to provide complete and accurate information in order to allow
the proper performance of TRANSPARE's services.

1: Through the heading "REGISTERING", TRANSPARE collects data relating to
the business name of the User, his SIRET number, his VAT number, his APE
code, his EORI number, his complete address, his number telephone number,
his fax number, the name and surname of his representative, the function of the representative, the representative's email address and finally his username and
password whether he is a service provider or a charger.
This data is collected to allow TRANSPARE to create a Shipper or Service
Provider User account so that it can file a request in the first case and offer an
offer in response in the second.
2: Through the "CONTACT" section, TRANSPARE collects data relating to the last
name, first name, email address, telephone number of the User, as well as the
message he wishes to send to it.
This data is collected in order to allow TRANSPARE to manage its client and
prospect file, and to hold information in order to contact the User in return and
provide them with an answer.
3: In addition, if the User consents to commercial prospecting under the conditions
of Article VII "Commercial Prospecting" of this Privacy Policy, TRANSPARE collects
and uses the User's email address in order to provide him with information about
TRANSPARE, its services, and to administer a contest, promotion or investigation.
4: In addition, TRANSPARE uses cookies that improve its access and identify
regular visitors. In addition, these cookies improve the user experience by tracking and
targeting their interests. However, this use of cookies is in no way linked to identifiable
personal data on TRANSPARE.
For more information on cookies, please see the "COOKIES POLICY" section.

III. Legal Basis of Management / Consent

The data is collected in a fair and lawful manner and will be used to allow access and
implementation of the services offered by TRANSPARE.
The legal basis for collection and processing is the User's consent to this Privacy
Policy. This consent is manifested by an acceptance of this privacy policy by ticking the
box provided for this purpose on the website www.transpare.eu.
The User may at any time withdraw his consent by sending a request for withdrawal of
consent to the following coordinates:
• By mail: TRANSPARE - 48 rue Grignan, 13001 Marseille - France
• By email: contact@transpare.fr
Any request will be accompanied by a copy of the identity document of the User to
avoid any fraud and / or illegal access to his data.
The withdrawal of the User's consent does not in any way affect the lawfulness of the
processing carried out on his personal data prior to his request for withdrawal.

IV. Recipient of the Data

The recipients of the data collected on TRANSPARE are:
• the duly authorized personnel of the Company;
• the Shipper Users have access to all the profiles of the Provider Users whose
only visible information before acceptance of an offer are: name and first name
of the person who files the application, company name to which it is attached,
city and country of establishment of the company;
• Providing Users have access to all the profiles of Shipper Users whose only
visible information before acceptance of an offer are: surname and first name of
the person who submits the application, the name of the company to which it is
attached, city and country of establishment of the company;
• once the offer of the Supplier Provider USer is accepted by the Shipper User,
both have access to all information about them in addition to those visible on
their profile namely: SIRET number, VAT number, APE code, EORI number,
name of the legal representative, function of the legal representative and finally
email of the legal representative.

The personal information of the User will never be sold, exchanged, transferred or
given to another company for any reason whatsoever, without his consent, apart from
what is necessary to respond to a request from him.
Anonymised data, however, may be provided to other parties for marketing, advertising
or other uses.
No data is transferred outside the European Union or a country in accordance with the
European Union's personal data protection regulations.

V. Data Management Outsourcing

As part of the data processing carried out, the Company uses subcontractors who are:
• INFOMANIAK Network SA, which provides accommodation for all personal
data, and is located at 33 Quai du Mont-Blanc, Swiss Post Box: 106407, CH1201 Geneva - Switzerland (i);
• Different providers who provide corrective and evolutive maintenance of
TRANSPARE(ii).
(i) The Company guarantees that its subcontractor INFOMANIAK Network SA will host
the data within a country in accordance with the EU regulations on the protection of
personal data. Consequently, its subcontractor provides sufficient guarantees for the
implementation of appropriate technical and organizational measures so that the
processing meets the requirements of Regulation EU 2016/679 and the Data
Protection Act.
(ii) The Company warrants that in the course of TRANSPARE's maintenance
operations, its subcontractors provide sufficient guarantees for the implementation of
appropriate technical and organizational measures so that the processing meets the
requirements of the EU Regulation 2016 / 679 and the Data Protection Act.
INFOMANIAK Network SA and G.L.A.M may themselves be authorized to subcontract
all or part of their operations subject to strict compliance with the provisions of Article
28 of the EU Regulation 2016/679.
Notwithstanding the above, as the controller, the Company remains the sole
interlocutor of the User.

VI. Business Development

The User may object at any time to the use of his email address for purposes of
commercial prospecting by electronic means:
• via the link provided for this purpose in all emails he will receive (detailed
unsubscribe instructions are included at the bottom of each of our emails), or,
• via the link provided for this purpose in the "My Profile" section of TRANSPARE.

VII. Right of Access, Opposition, Limitation and Rectification of Data

In accordance with the regulations in force, the User has a right of access, rectification,
limitation, deletion and opposition to the processing of his personal data.
To do this, the User must write to the address of the Company stating, in the subject of
his letter or email, that it is a request for information or a complaint relating to his
personal data.

Any request to this effect should be addressed to the following contact information:
By mail: TRANSPARE - 48 rue Grignan, 13001 Marseille - France
By email: contact@transpare.fr
Any request will be accompanied by a copy of the identity document of the User to
avoid any fraud and / or illegal access to his data.

IX. Right to Data Transferability

The User has a right to the portability of his personal data which, at his request, must be
returned to him in a structured format, commonly used and machine readable.
Any request to this effect should be addressed to the following coordinates:
By mail: TRANSPARE- 48 rue Grignan, 13001 Marseille - France
By email: contact@transpare.fr
Any request will be accompanied by a copy of the identity document of the User to avoid
any fraud and / or illegal access to his data.

X. Right to Lodge a Complaint with the CNIL

The User is informed of his right to refer to the CNIL in case of non-compliance with legal
and regulatory provisions by the Company in the context of the management of his
personal data.
To do this, the User can contact the CNIL from the following link:
https://www.cnil.fr/fr/plaintes

XI. Data Retention Period and Archiving

The personal data collected on TRANSPARE are only kept for a period strictly necessary
for the management of the commercial relationship.
Insofar as the User is a mere prospect of the Company, the data collected about him on
TRANSPARE are retained by the Company for a period of three (3) years after his last
contact with the Company emanating from him.
Insofar as the User is already a customer of the Company or works on behalf of a
corporate legal person of the Company, the data collected on him / her on TRANSPARE
shall be retained for a period of five (5) years following the year in which the term of the
contract binding or binding the legal person who hires him to the Company intervenes.
This duration corresponds to the statutory limitation period. On the other hand, the User's
data may only be used for commercial prospecting purposes for a period of three (3)
years after the end of the business relationship.

In the case of the exercise of the right of access or rectification, the data relating to
identity documents shall be kept for the period provided for in Article 9 of the Code of
Criminal Procedure, ie one (1) year.

In case of exercise of the right of opposition, the data relating to identity documents may
be filed during the limitation period provided for in Article 8 of the Code of Criminal
Procedure, ie three (3) years.

In case of exercise by the User of his right of opposition to receive commercial
prospection, the data necessary to take into account the exercise of his right, such as his
email address, are kept three (3) years from the exercise of his right and may not be
used for any other purpose.
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