Privacy Policy - GDPR

TOPSOLID PRIVACY POLICY

We are dedicated to offering you high-quality services while respecting your privacy and personal choices. We have developed this Privacy Policy to be transparent with you about the policies and practices that we apply to the personal data you provide to or share with us through any points of contact you use to interact with us (e.g. Customer Department, social networks, digital apps, events).

The aim of this personal data protection charter (hereinafter the “Policy”) is to provide you with clear and complete information about how we collect and use your personal data, as well as the rights you have regarding the processing of such data.

As such, we inform you that we collect and process your personal data in accordance with the French Act N° 78-17 dated 6th January 1978 on Information Technology, Data Files and Civil Liberties, also known as the French Data Protection Act, as well as the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter the “GDPR”).

This Policy supplements the provisions of the General Terms and Conditions of Use of the Site to which you can refer for more information on the use of the Site.

Please read this Policy carefully.

In this Policy, you will find information on:

• Who we are;
• What data we may collect about you;
• How we collect or receive your data;
• For what purposes we may use your data;
• For how long we may store your data;
• Who we may share your data with;
• How we protect your data and ensure their confidentiality;
• What are your rights under the “GDPR” European regulation;
• How to contact us if you have any questions or concerns about our use of your personal data;
• How we manage cookies.

WHO ARE WE?

When we say “TopSolid”, “we”, “us” or “our”, we refer to:

TOPSOLID SAS, a French simplified joint stock company with headquarters located at 7, Rue du Bois Sauvage, 91 055 Évry Cedex - France, registered in the Évry Trade and Companies Register under number 329 109 227 and represented by Richard LAMURE, acting as CEO of TOPSOLID SAS, is the publisher of the website www.topsolid.com/ (hereinafter the “Site”).

TopSolid may also collect your personal data when you apply for a position at TopSolid, on its “Careers” website (hereinafter the “Careers Site”) which can be accessed from www.topsolid.com.

WHAT DATA DO WE COLLECT ABOUT YOU?

“Personal data” refers to any information that identifies you either directly (e.g. your name) or indirectly (e.g. through a unique customer ID number).

Depending on the data you provide to or share with us, personal data may include information about:

• Your identity, title and company
• Your contact details (email address, mailing address, phone number)
• Your family status and relatives
• Your online purchases
• Your online browsing (topsolid.com, social networking pages, partner websites)
• Your requests via our Customer Department
• The TopSolid events you attend

In the context of a job application, we may collect the following information:

• Your identity
• Your contact details
• Your Curriculum Vitae
• Your cover letter

We invite you to keep us regularly informed in writing of any change in your contact details.

HOW DO WE COLLECT OR RECEIVE YOUR DATA?

As part of our relationship, we may collect and receive data from you in the following contexts:

• Account creation and management
• Subscription to our newsletter and commercial communications
• Online purchases
• Internet browsing
• Marketing surveys
• User-generated content
• Use of digital apps
• Information requests
• Participation in an event we organize
• Application for a job

Via the following contact points:

1. Browsing on www.topsolid.com
2. Relationship with our staff
3. Relationship with us during an event we organize
4. Customer Department relationship
5. Online forms you complete
6. Digital apps you use
7. TopSolid social media pages you visit or comment/like
8. Internet media advertisements you click on
9. Search engine advertisements you click on

Data are collected by TopSolid either directly (1) or indirectly (2).

1. Data collected directly: Information collected directly is essential to respond to your requests. Such information that you provide voluntarily, such as your name and contact information, is marked with an asterisk on data entry forms.
2. Data collected indirectly: TopSolid also collects browsing data indirectly using data collection tools (cookies, tags, beacons, and any other appropriate means) which are installed on the Site and enable the use of certain of its features.

You may choose to disable these tools via your Internet browser as described in this Policy.

FOR WHAT PURPOSE ARE YOUR PERSONAL DATA USED?

We process your data in order to manage our customer relationships.

Depending on the context in which your data are collected, we may use your data for:

• Performing tasks and services
• Managing your orders (customer file management, billing)
• Managing our digital communications for you
• Managing your profile*
• Managing your requests
• Managing events which you register for/attend
• Managing your job application
• Managing our website and digital apps
• Improving our products and services
• Sending information or marketing materials
• Establishing statistics

Depending on the context in which your data are collected, the legal basis for processing your data may be:

• Your consent;
• The performance of a contract (e.g. fulfilling properly the missions that we are entrusted with);
• A legal obligation where processing is required by law;
• Our legitimate interest which may be to (i) inform our customers, (ii) expand our business, (iii) tailor our communications, (iv) improve our products and services, (v) prevent fraud, (vi) secure our tools.

* Please note that when we send or post customized communications or content, we may use “profiling” techniques to evaluate and predict your personal preferences and/or interests. Based on this analysis, we send or post communications and/or content tailored to your interests/needs.

Please note: You have the right not to provide personal information. You will be informed of the possible consequences of your refusal when providing personal data is mandatory.

HOW LONG DO WE KEEP YOUR DATA?

We only keep your personal data for as long as we need it to fulfill the desired purpose, to meet your needs, or to comply with our legal obligations.

As a general principle, your personal data will be retained in our customer database for a period not exceeding:

• If you are a “prospect” (i.e. you have never purchased a TopSolid product but you are interested in TopSolid brand), we keep your data for 3 years.
• If you are a “customer” (i.e. you have already purchased a TopSolid product), we keep your data for the duration of our business relationship, plus 10 years.
• If you are a “job applicant” (i.e. you apply for a job offered by TopSolid), we keep your data for 2 years after your application.
• If cookies are stored on your computer, we keep them for a period not exceeding 13 months.

WHO MAY ACCESS YOUR DATA?

The sole recipients of the personal data collected by TopSolid are the departments responsible for client relations, communications and marketing as well as subsidiaries of the company that may be located outside the European Union. Personal data shall only be disclosed to third parties with the prior consent of the Users unless the communication of such information is strictly necessary to the provision of the service requested or where access is requested by a public or legal authority. In any case, TopSolid shall provide your personal data to a third party only where:

• You have given us your prior consent to share this information;
• TopSolid needs to share this information with third parties to provide you with the service you are requesting;
• TopSolid is ordered by a legal authority or any other public authority to provide the information.

WE ONLY SHARE INFORMATION:

• ON A NEED TO KNOW BASIS;
• WHERE POSSIBLE IN A PSEUDONYMISED FORM (not allowing direct identification);
• FOR LEGITIMATE PURPOSES (to provide you with requested services, to meet our legal obligations, to prevent fraud and/or to secure our tools, to improve our products and services, or after having obtained your consent to do so);

To:

• Other entities of the TopSolid group, some of them acting as data processors, to provide you with the same personalized service worldwide;
• Our trusted third-party providers.

For example, we may entrust services to:

• Third parties providing digital and e-commerce services;
• Advertising, marketing, digital communication and social media agencies*;
• Third parties in charge of delivering a product to you;
• Third parties providing IT services;
• Payment service providers and credit analysts;
• Third parties assisting us for customer care;
• Third parties assisting us in the organization of our events;
• Third parties securing transactions made on www.topsolid.com against fraud and identity theft;
• Third parties in the event of a change of control, for legal reasons, or with your prior consent.

You may also choose to disclose your personal data to our partners, advertisers and affiliates by following a link to and from their websites. Please note that these websites have their own privacy policies which we do not control. We may also offer you the opportunity to use your social network login data. Please be aware that in such case you are sharing your profile information with us. The personal data shared depends on the configuration of your social media platform. Please note that these social networks have their own privacy policies.

HOW DO WE PROTECT YOUR DATA AND ENSURE THEIR CONFIDENTIALITY?

We take all reasonable precautions to keep your data secure.

We contractually require that trusted third parties to whom we entrust the processing of your personal data on our behalf do the same.

We ensure that your personal data are not transferred to, accessed from, and stored outside the European Union.

YOUR RIGHTS UNDER THE “GDPR” EUROPEAN REGULATION

Please find hereunder a summary of the rights you have under the GDPR:

• The right to be informed;
• The right of access;
• The right of rectification;
• The right to erasure/right to oblivion;
• The right to object to direct marketing, including profiling;
• The right to withdraw consent at any time for data processing based on consent;
• The right to oppose data processing based on legitimate interests;
• The right of appeal to a supervisory authority;
• The right to data portability;
• The right of restriction;
• The right to deactivate cookies.

PLEASE CONTACT US ACCORDING TO THE TERMS OF THE CONTACT SECTION BELOW IF YOU WISH TO EXERCISE THESE RIGHTS.

Please note that we may ask for proof of your identity and the full details of your request before processing.

HOW TO CONTACT US

If you have any questions or concerns regarding the processing of your personal data, or if you wish to exercise any of your rights above, please contact us:

• by calling our Customer Department at +33 (0)1.60.87.20.20
• or by sending us an e-mail to contact@topsolid.com 
• or by means of the online contact form available here
• You can also contact our Data Protection Officer by e-mail to privacy@topsolid.com

TRANSFER OF DATA IN THE EVENT OF A CHANGE OF CONTROL OF THE COMPANY

In the event of a change of control of the company, bankruptcy proceeding or the transfer of the company's assets, the personal data collected by TopSolid may be transferred.

CHANGES TO THIS POLICY

TopSolid reserves the right to change or update this Policy at its sole discretion and without notice. In such event, the updated version of the Policy shall be published immediately on the Site and all browsing activity thereon, from the time of publication of the said updated version of the Policy, shall be entirely subject to it.

INFORMATION ABOUT COOKIE MANAGEMENT

This section is dedicated to our policy for managing cookies on the www.topsolid.com website.

It has been designed to provide you with information on the origin and use of browsing data processed when you use our website, together with your rights.

WHAT IS A COOKIE?

When you visit our website, we may, depending on your choice, store a text file on your device (computer, smartphone, tablet, etc.) through your web browser.

This text file is a cookie. For as long as it is valid and stored on your device, it will enable TopSolid to identify your device when you visit the website in the future.

Only the entity issuing the cookies is able to read or modify the information they contain.

Below you will find information about the cookies that may be stored on your device when you visit pages on the www.topsolid.com website, either by TopSolid or by third parties, and how you can delete or refuse installation of these cookies.

WHAT ARE THE PURPOSES OF THE COOKIES ISSUED ON WWW.TOPSOLID.COM?

There are several categories of cookies. Some of them are issued directly by TopSolid and its service providers, and some may be issued by third-party companies.

I. Cookies issued by TopSolid and its service providers

Different types of cookie may be stored on your device when you browse our website:

(i) "Essential" cookies

These cookies are essential for browsing our website, including to ensure that the ordering process runs smoothly. Deleting these cookies may cause problems when browsing our website and make it impossible for you to place an order. They may be installed on your device by TopSolid or by its service providers.

(ii) "Analysis and Customization" cookies

These cookies are not essential for browsing our website, but they may help you, for example, to search more effectively and help us better target your requirements, improve our offer and optimize the functioning of our website.

II. Cookies issued by third-party companies

Cookies are issued and used by third parties on our website in accordance with these third parties’ privacy protection policies.

These cookies are not essential for browsing our website.

We might include cookies on our website applications produced by third parties, which enable you to share our site content with other people or to tell other people what content you have been browsing or your opinions of it. This is true of the “Share” and “Like” buttons for social networks such as Facebook, Twitter, Instagram and Pinterest.

Social networks that provide these application buttons might be able to use them to identify you, even if you did not use the button when browsing our website. This type of application button can enable the social network concerned to track your browsing of our website, simply because you were logged into your account with the social network on your device (you had an open session) while you were browsing our website.

We have no control over the process used by social networks to collect information relating to your browsing of our website and linked to the personal data they hold. We encourage you to read these social networks’ privacy protection policies to find out for what purposes, including advertising, they use the browsing information they might collect using these application buttons. These privacy protection policies must give you the option to inform the social networks of your choices, including by configuring your user accounts with each of them. To read the privacy protection polices of the aforementioned social networks, visit their websites.

III. Managing the cookies stored on your device

You can decide whether cookies are stored on your device.

Using your web browser settings, you can at any time simply and at no cost choose to accept or block the storage of cookies on your device. You can configure your web browser as you wish, so that cookies are (a) accepted and stored on your device, or conversely (b) blocked.

If your web browser is configured to allow cookies to be stored on your device, the cookies embedded in the pages and content you browse will be routinely stored on your device.

You can configure your web browser so that:

• you are given the option to accept or refuse cookies on a case-by-case basis, before a cookie is likely to be stored on your device;
• it always refuses to store cookies on your device.

Please note: Any adjustments you make to your web browser’s cookie acceptance or blocking settings may change your web browsing experience and the process of accessing services that require the use of these cookies.

If you choose to refuse to allow cookies to be stored on your device or if you delete cookies that are stored on it, we decline all responsibility for any consequences relating to the degraded performance of our services resulting from the fact we are unable to register or consult the cookies needed for these services to operate and which you might have blocked or deleted.

The configuration process varies from one type of browser software to another. It is usually described in the browser’s help menu. We suggest you find out how to configure your browser and change your cookies preferences.

Last updated: 20/03/2019