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Protection of Personal Data and Privacy
Parties and Object
Last updated: September 13, 2023
Tractafric Equipment Africa (hereinafter "Tractafric" or the "Data Controller")
Address: TWIN CENTER T.A ETG 10 ANG AL MASSIRA ET ZERKTOUNI CASABLANCA - Morocco
ICE (Tax Identification Number): 000081632000067
Commercial Registry (RC): 222767 (CASABLANCA)
Fiscal Identification Number (IF): 40223352
Phone: +212 522 438 222
Its representative within the European Union:
Address: Tour INITIALE - 1 Terrasse BELLINI
CS 70384, 92935 PARIS LA DEFENSE CEDEX - France
The term "User" refers to any user, whether a natural or legal person, who visits or interacts with the Site in any way.
In this regard, Tractafric determines all technical, legal, and organizational means and purposes of processing Users' personal data. Tractafric commits to taking all necessary measures to ensure that the processing of personal data complies with the General Data Protection Regulation (GDPR) and any other applicable local laws.
Tractafric is free to choose any natural or legal person to process Users' personal data on its behalf (hereinafter the "Processor"). Where applicable, Tractafric undertakes to select a Processor that provides sufficient guarantees regarding the technical and organizational security measures for processing personal data, in accordance with the GDPR and any other applicable local laws.
Processing of Personal Data
Users' use of the Site may involve the disclosure of personal data. The processing of this data by Tractafric, as the Data Controller, or by service providers acting on behalf and for the account of Tractafric, will comply with the General Data Protection Regulation (GDPR) and any other applicable local laws.
Personal data will be processed by Tractafric, in accordance with the purposes listed below, through:
- the contact request form with the sales teams;
Purpose of Processing Personal Data
In accordance with Article 13 of the General Data Protection Regulation (GDPR), the purposes of processing personal data are communicated to the User and are as follows:
- Facilitate the connection between the User and Tractafric's sales teams in the event of a contact request;
- Conduct marketing and promotional activities, only with the prior consent of the User and until the revocation of this consent, such as sending promotions on products, services, and events offered by Tractafric;
- Generate statistics to improve the website, the services offered, and Tractafric's internal organization.
Personal Data That May Be Processed
- Information voluntarily provided by the User: This includes, but is not limited to, information such as the name, surname, email address, and telephone number that Users provide when filling out contact request forms with the sales teams or when contacting Tractafric by phone, email, or any other means.
- Information collected automatically during browsing: Regarding each of the Users' visits to the Site, certain information may be collected automatically, including:
- The User's IP address,
- The type and model of the browser used,
- The time zone,
- The operating system,
- Details about the pages the User viewed on the Site, such as the URL, time spent on each page, clicked links, etc.
The User has the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent given before withdrawal.
Retention Period of User's Personal Data
In accordance with Article 13 §2 of the Regulation, Tractafric Equipment Africa, as the Data Controller, only retains personal data for the time reasonably necessary to achieve the purposes for which they are processed.
The retention period for this data is set at 6 months.
Recipients of Data and Disclosure to Third Parties
The personal data collected during Users' interactions with the Site are exclusively intended for Tractafric Equipment Africa and its subsidiaries within the Tractafric Equipment / Optorg group. The use of this data is strictly limited to the scope of managing our customer relationship, for administrative purposes, or to address specific needs related to Users' requests. The retention period for this data is strictly limited to the aforementioned processing requirements.
Tractafric Equipment Africa ensures that this data will be processed in accordance with the intended purposes, discreetly and securely. No disclosure to third parties for direct marketing or prospecting purposes will be made without prior notice and the User's consent.
In accordance with Regulation 2016/679, known as the General Data Protection Regulation (GDPR), the User has the right to be informed, to access, rectify, delete, object to, restrict processing, and port their data, as well as the right to determine the fate of their data after death. To exercise these rights, the User can contact the company at the following address: email@example.com.
Data Protection Officer (DPO)
The following person is appointed as the Data Protection Officer (DPO): Zineb Sassi.
The role of the DPO is to ensure the proper implementation of national and supranational provisions regarding the collection and processing of personal data.
The DPO can be contacted as follows:
Rights of Users
At any time, the User can exercise their rights by sending an email to the following address: firstname.lastname@example.org, or a letter by postal mail to the following address, including a copy of their identity card: Tour INITIALE - 1 Terrasse BELLINI, CS 70384, 92935 PARIS LA DEFENSE CEDEX - France.
a. Right of Access
In accordance with Article 15 of the Regulation, Tractafric Equipment guarantees the User's right of access to their personal data. The User has the right to obtain access to such personal data, as well as 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 established in third countries or international organizations;
- 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 automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
The Data Controller may require the payment of reasonable administrative costs for any additional copies requested by the User.
When the User makes this request electronically (via email, for example), the information will be provided in a commonly used electronic format, unless the User requests otherwise.
A copy of their data will be provided to the User no later than one month after receiving the request.
b. Right to Rectification
Tractafric Equipment and the subsidiaries of the Tractafric Equipment / Optorg group guarantee the right to rectify and erase personal data to the User.
In accordance with Article 16 of the Regulation, incorrect, inaccurate, or irrelevant data can be corrected or erased at any time. The User should first make the necessary changes themselves from their user account or other means, unless such changes cannot be made autonomously, in which case the request can be made to Tractafric Equipment and the subsidiaries of the Tractafric Equipment / Optorg group.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data have been disclosed of any rectification of personal data, unless this proves impossible or involves disproportionate effort. The Data Controller shall provide the data subject with information about those recipients if requested.
c. Right to Erasure
The User has the right to obtain the erasure of their personal data in the cases listed in Article 17 of the Regulation.
When the Data Controller has made personal data public and is obliged to erase them in accordance with the preceding paragraph, the Data 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 the erasure by such controllers of any links to, or copy or replication of, those personal data.
The two preceding paragraphs shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3) of the Regulation;
- for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the Regulation in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise, or defense of legal claims.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data have been disclosed of any erasure of personal data or restriction of processing carried out, unless this proves impossible or involves disproportionate effort. The Data Controller shall provide the data subject with information about those recipients if requested.
d. Right to Restriction of Processing
The User has the right to obtain restriction of processing in the cases listed in Article 19 of the Regulation.
In accordance with Article 19 of the Regulation, the Data Controller shall notify each recipient to whom personal data have been disclosed of any restriction of processing carried out, unless this proves impossible or involves disproportionate effort. The Data Controller shall provide the data subject with information about those recipients if requested.
e. Right to Data Portability
In accordance with Article 20 of the Regulation, Users have the right to receive their personal data, which they have provided to Tractafric Equipment and the subsidiaries of the Tractafric Equipment / Optorg group, in a structured, commonly used, and machine-readable format. Users have the right to transmit those data to another controller without hindrance from Tractafric Equipment and the subsidiaries of the Tractafric Equipment / Optorg group where the processing is based on consent.
When exercising the right to data portability in accordance with the previous paragraph, Users have the right to have personal data transmitted directly from one controller to another, where technically feasible.
The exercise of the right to data portability is without prejudice to the right to erasure. This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right to data portability does not adversely affect the rights and freedoms of others.
f. Right to Object and Automated Individual Decision-Making
Users have the right to object at any time to the processing of their personal data based on their particular situation, including automated data processing carried out by Tractafric Equipment and the subsidiaries of the Tractafric Equipment / Optorg group. In accordance with Article 21 of the Regulation, Tractafric Equipment and the subsidiaries of the Tractafric Equipment / Optorg group shall no longer process personal data unless there are compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the User, or for the establishment, exercise, or defense of legal claims.
Where personal data are processed for direct marketing purposes, Users have the right to object at any time to processing of personal data concerning them for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where the data subject objects to processing for direct marketing purposes, personal data shall no longer be processed for such purposes.
g. Right to Lodge a Complaint
As Tractafric Equipment and the subsidiaries of the Tractafric Equipment / Optorg group are established outside the European territory, European nationals visiting the website may file a complaint with their local data protection authorities.
It is recommended to consult the website of your country or region's data protection authority for more information.
Data Protection Authorities of EU Member States:
- Germany: Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
- Austria: Österreichische Datenschutzbehörde
- Belgium: Autorité de Protection des Données
- Bulgaria: Commission for Personal Data Protection
- Cyprus: Commissioner for Personal Data Protection
- Croatia: Croatian Personal Data Protection Agency
- Denmark: Datatilsynet
- Spain: Agencia Española de Protección de Datos
- Estonia: Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
- Finland: Office of the Data Protection Ombudsman
- France: Commission Nationale de l'Informatique et des Libertés (CNIL)
- Greece: Hellenic Data Protection Authority
- Hungary: National Authority for Data Protection and Freedom of Information
- Ireland: Data Protection Commission
- Italy: Garante per la protezione dei dati personali
- Latvia: Data State Inspectorate
- Lithuania: State Data Protection Inspectorate
- Luxembourg: Commission Nationale pour la Protection des Données (CNPD)
- Malta: Office of the Information and Data Protection Commissioner
- Netherlands: Autoriteit Persoonsgegevens
- Poland: Urząd Ochrony Danych Osobowych
- Portugal: Comissão Nacional de Protecção de Dados
- Czech Republic: Office for Personal Data Protection
- Romania: The National Supervisory Authority for Personal Data Processing
- Slovakia: Office for Personal Data Protection of the Slovak Republic
- Slovenia: Information Commissioner of the Republic of Slovenia
- Sweden: Datainspektionen
For specific information on how to file a complaint, it is recommended to visit the website of the competent authority in your country or region directly.
a. General Understanding
A "Cookie" is a small file temporarily or permanently stored on the user's device during their visit to our website. Its purpose is to facilitate future navigation by allowing the server to recognize the user's device.
It should be noted that third parties with whom we collaborate may also install cookies on your device.
While some cookies are essential for the optimal operation of our site, others help us enhance and personalize the user experience.
b. Types of Cookies and Purposes
Various types of cookies are used by Tractafric on the Site:
- Technical cookies: These are necessary for the operation of the website, allow the communication of entered data, and are intended to facilitate user navigation;
- Statistical and audience measurement cookies: These cookies enable user recognition and are used to count the number of Users of the website over a certain period. Since they also indicate browsing behavior, they are an effective means to enhance the user's navigation experience by displaying relevant suggestions and offers. They also allow Tractafric to identify any potential bugs on the website and correct them;
- Functional cookies: These cookies make it easier to use the website by retaining certain input choices (e.g., username or language);
- Tracking cookies: Tractafric uses tracking cookies through Google Analytics to measure user interaction with the website's content and produce anonymous statistics. These statistics enable Tractafric to improve the website. Google provides an explanation of these cookies at the following address: https://policies.google.com/privacy
c. Cookie Retention Period
Cookies are retained for the time necessary to achieve the intended purpose. The cookies that may be stored on the user's hard drive and their retention period are as follows:
- __utma: This cookie is used to distinguish unique visitors to your site. It is updated with each page view. - 2 years
- __utmb: This cookie is used to track the user's visit session. This cookie expires when the user remains inactive on your site for more than 30 minutes. Using this cookie in conjunction with the utmc cookie allows tracking of visits (sessions) on a given site. Note that the cookie's lifespan can be adjusted to your needs and specifications by calling the _setSessionCookieTimeout() function. - 30 minutes
- __utmc: This cookie works in conjunction with the __utmb cookie to determine whether there is a new visit by the current unique visitor. - Undefined. It expires at the end of the session.
- __utmz: This cookie stores all the information needed to identify a source of traffic. It includes information such as the traffic source, the medium of that traffic source, and the keyword entered if the user accesses the site from a search engine, and more. By default, this cookie has a lifespan of 6 months, but you can modify this limit using the _setCookieTimeout() function. - 6 months
- __utmv: This cookie is typically not present in the default tracking code configuration. The __utmv cookie refers to information provided when calling the setVar() function. Note that the utmv cookie is an optional cookie and is used only by the setVar function. - 2 years
- __utmt: This internal cookie created by Google Analytics is used to process user requests and generate statistics on website traffic. - 10 minutes
- CONSENT: These third-party cookies are used by Google Analytics to generate maps (for locating our products) and to generate CAPTCHA images to help protect our sites from spam. - Entire lifespan
- NID: These third-party cookies are used by Google Analytics to generate maps (for locating our products) and to generate CAPTCHA images to help protect our sites from spam. - 6 months
- 1P_JAR: Google advertising cookie used for user tracking and ad targeting. - 1 minute
d. Cookie Management
If the user disables certain cookies, they accept that the website may not function optimally. Some parts of the website may not be usable or may be partially usable.
If the user wishes to manage and/or delete certain cookies, they can do so using the following link(s):
- Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
- Microsoft Edge: http://windows.microsoft.com/en-gb/windows-10/edge-privacy-faq
- Chrome: https://support.google.com/accounts/answer/61416?hl=fr
- Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
- Safari: https://support.apple.com/kb/ph21411?locale=fr_FR
If the user wishes to prevent the use of Google Analytics cookies, they are invited to adjust their browser accordingly on the following website: http://tools.google.com/dlpage/gaoptout
Controller's Limitation of Liability
Individuals with parental authority must expressly consent to a minor under the age of 16 sharing information or personal data on the site. We strongly recommend that parents and guardians of minors promote responsible and secure use of the Internet. The Controller shall not be held liable for the collection and processing of information or personal data of minors under the age of 16 without the proper consent of their legal representatives or for incorrect data, including age, provided by minors.
The Controller disclaims all liability in case of loss, corruption, or theft of personal data caused, in particular, by viruses or cyberattacks.
Security and International Transfers
In accordance with the requirements of the GDPR, the Data Controller implements organizational and technical measures to ensure an appropriate level of security, especially regarding the processing of personal data transferred outside the borders of the EU.
These measures are designed taking into account the current state of technology, implementation costs, as well as the nature, context, and purposes of processing personal data. They are intended, in particular, to prevent risks associated with the transfer of data outside the European Union.
The Data Controller uses recognized and proven encryption technologies in the IT sector, especially during the transfer or collection of data on the Site, to ensure the protection and confidentiality of user information, even during international transfers.
Applicable Law and Competent Jurisdiction