PRIVACY POLICY

BOONE COMENOR METALIMPEX

FOREWORD

This Privacy Policy is addressed to you, in your capacity as a user of the https://metalimpexgroup.com/
WEBSITE (hereinafter the “WEBSITE”), and is intended to inform you of the manner in which your personal
information may be collected and processed by the BOONE COMENOR METALIMPEX company.
BOONE COMENOR METALIMPEX, a simplified joint stock company with a share capital of 864,993 euros, registered in the Lille Trade and Companies Register under number B 316 917 392, whose registered office is located at 45 rue Pasteur – 59520 Marquette-lez-Lille, in the person of its legal representative duly authorised to act for the purposes of this document (hereinafter referred to as the OPERATOR), produces and operates the
Internet platform accessible at the following address: https://metalimpexgroup.com/
The OPERATOR publishes and operates the WEBSITE which presents the services of the “BCM DIGITAL PLATFORM” offer and enables the USER to request contact or a quote. The “BCM DIGITAL PLATFORM” offer is a set of services that enable the viewing of activity and revenue data from the subjects in question, providing market index monitoring and access to the catalogue of materials offered by BCM, as well as a contact channel. BOONE COMENOR METALIMPEX is committed to respecting your own privacy and that of your personal data.
The purpose of this Privacy Policy is to provide information about the personal data processing mechanisms
implemented on the WEBSITE. BOONE COMENOR METALIMPEX undertakes in any event to adhere to the following two (2) essential principles:
– You remain in control of your own personal data;
– Your data is treated transparently, confidentially and securely.
The processing of personal data is governed:
– By France’s Data Protection Act n°78-17 of 6 January 1978 relating to electronic processing, data files
and individual liberties (hereinafter the “DPA”);
– By Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, which entered into force on 25 May 2018 (hereinafter the “GDPR”).

ARTICLE 1. DEFINITIONS

The terms mentioned below have the following meaning in this Privacy Policy:
“USER”: means any legal entity accessing and browsing the WEBSITE.
“WEBSITE”: refers to the Internet WEBSITE https://metalimpexgroup.com/;
The WEBSITE includes all the web pages, electronic elements and features offered to USERS.
“PROCESSOR”: means the person processing personal data on behalf of the DATA CONTROLLER, acting under the authority of the DATA CONTROLLER and on the instructions of the DATA CONTROLLER.

ARTICLE 2. CNIL FORMALITIES

The processing of your personal data is recorded in processing sheets which are included in the OPERATOR’s processing register.

ARTICLE 3. PURPOSE OF THE PROCESSING

Your various data may be collected by the OPERATOR in order to ensure:
– The proper functioning and continuous improvement of the WEBSITE and its features;
– The ability to reply to USERS who request contact via the contact or quote forms.
These purposes are detailed in sections 4 and 5 of this Privacy Policy.
The OPERATOR shall also be entitled to use such data for the purpose of fulfilling any legal or regulatory
obligations. In any event, and for each defined purpose, the OPERATOR will do everything in their power to ensure the security and confidentiality of the personal data entrusted to them, in compliance with the laws and regulations in force.

ARTICLE 4. USE OF THE WEBSITE

4.1. Identity of the controller

For the purposes of provision of the WEBSITE, the OPERATOR shall be considered as the data controller.

For more information:
If you have any questions about the management and use of your personal data, you can contact us:
– Either via the contact form on our website https://metalimpexgroup.com/
– Or by sending a letter to the following address:
BOONE COMENOR METALIMPEX – Direction Digital
45 rue Pasteur
59520 Marquette-lez-Lille

To find out more about your rights, you can visit the CNIL website, accessible at the following address https://cnil.fr

4.2. Collection and processing of personal data

In connection with use of the WEBSITE, the OPERATOR may collect personal data relating to USERS. This data is processed in accordance with the purposes specified at the time of collection.
In particular, the OPERATOR may collect personal data:
– Upon a request from the USER via the contact form.
In addition, data relating to your browsing on our website may also be used to target your needs and interests and
to target our commercial and advertising offers accordingly.
Whatever the method of collection, SUEZ undertakes to inform you of the purpose of the processing, whether the answers to be provided are required or optional, the possible consequences you may face as a result of a failure to answer, the recipients of the data, the existence of your rights of access, rectification and objection to the processing of your data, and the means by which you may exercise these rights. Where necessary in accordance with the French Data Protection Act (DPA), the OPERATOR undertakes, depending on the case, to obtain your consent and/or to allow you to object to the use of your data for certain
purposes.

More details & legal basis:
In any event, the OPERATOR undertakes to process all data collected in accordance with the amended Act No.
78-17 of 6 January 1978, which defines PERSONAL DATA as being: “any information relating to a natural person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to that person. In order to determine whether a person is identifiable, it is necessary to consider all the means of identification available or accessible to the controller or to any other person. ” You can find more details on how we manage the cookies that enable us to achieve this purpose in our Cookie Management Policy:
https://metalimpexgroup.com/cookies/

4.3. Consent

As data controller, SUEZ must obtain the consent of the USERS of the WEBSITE to collect and process their
personal data. In accordance with the provisions in force, the USER’s consent must be free, given for each designated purpose, informed and unequivocal. It is given by a declaration or by a positive action, which constitutes the USER’s consent to the processing of personal data. In this case, any USER whose data is collected for the above-mentioned purposes has:
– Agreed to the Cookie Management Policy by clicking on the corresponding cookie banner.
https://metalimpexgroup.com/cookies/

For more information:
All data concerning you is collected directly from you, during our various exchanges (online contact requests, online quote requests, mail, telephone calls, etc.). In addition, data relating to your browsing activity on the WEBSITE may also be used to target your needs and interests and to target our commercial and advertising offers accordingly. In any event, you are informed of the purposes for which your data is collected by us via the various online data collection forms, your customer account or via our cookie management policy https://metalimpexgroup.com/cookies/

Where necessary, the OPERATOR undertakes, as applicable, to obtain your consent and/or to allow you to object to the use of your data for certain purposes, such as, for example, the possibility of sending you commercial
prospecting materials or depositing third-party cookies on your devices (mobile phone, computer, tablet) for the purposes of measuring our website’s audience and our application, and to present you with commercial offers and advertisements targeted according to your areas of interest.

ARTICLE 5. RECIPIENTS OF THE DATA

Only the persons mentioned below may have access to USERS’ data:
– Authorised personnel of the various departments of BOONE COMENOR METALIMPEX (authorised
personnel of the marketing, sales and digital departments, those responsible for customer relations and prospecting, and those responsible for oversight);
– Companies responsible for managing the WEBSITE;
– Authorised personnel of our processors (where applicable);
– Where appropriate, the relevant courts, mediators, accountants, auditors, lawyers, bailiffs, debt collection agencies,
– Third parties who may place cookies on your devices (computers, tablets, mobile phones, etc.) when you
consent to them (For more details, see our Cookie Management Policy here) https://metalimpexgroup.com/cookies/. Your data will not be passed on, exchanged, sold or rented to anyone other than the parties mentioned above.

ARTICLE 6. DATA RETENTION PERIOD

The OPERATOR undertakes to ensure that the data collected is retained in a form that enables you to be identified for a period that does not exceed the period necessary for the purposes for which the data is collected and
processed. However, data processing may be required to provide evidence of an entitlement or a contract. This data may also be retained for the purpose of complying with a legal obligation, or kept in files in accordance with applicable laws
and regulations.

USERS’ data will be retained by the OPERATOR for a period of three (3) years from the date of the contact request.
Finally, in order to ensure the proper functioning and ongoing improvement of the WEBSITE and its features, the raw traffic data associated with a set of login credentials is retained for a period of thirteen (13) months. After this period, they are deleted or anonymised. For further information
For commercial prospecting  : Three (3) years from the date of your last contact with us. For audience
measurement and statistics : Six (6) months, then your data is deleted or anonymised

To ensure the proper functioning and continuous improvement of the
WEBSITE : Thirteen (13) months, then your data is deleted or anonymised.

ARTICLE 7. YOUR RIGHTS

In accordance with the Data Protection Act and the GDPR, you have the following rights: Right to access (Article 15 GDPR), rectify (article 16 GDPR), update and complete your data.

Right to block or erase your personal data (Article 17 GDPR), where they are inaccurate, incomplete, ambiguous, out of date, or in cases where their collection, use, disclosure or retention is prohibited (read more). Right to withdraw your consent at any time (article 13-2c GDPR)
Right to restrict the processing of your data (Article 18 GDPR)
Right to object to the processing of your data (Article 21 GDPR) (read more)
Right to portability of the data you have provided to us, where your data is subject to automated processing based on your consent or on a contract (Article 20 GDPR)
The right to determine what happens to your data after your death and to choose whether or not we pass your data on to a third party that you have previously designated (read more). In the event of your death and in the absence of instructions from you, we undertake to destroy your data, unless its retention is necessary for evidential purposes or to meet a legal obligation.

These rights can be exercised by simple request:
– Either via the contact form on our website https://metalimpexgroup.com/
– Or by sending a letter to the following address:
BOONE COMENOR METALIMPEX – Direction Digital 45 rue Pasteur
59520 Marquette-lez-Lille by providing your contact details (surname, first name, address) and a legitimate reason where required by law (in particular in the event of objection to processing). In the event of difficulties, you can send your request by email to the Data Protection Officer (DPO) of SUEZ RV France, to which BCM is legally attached: privacy.france@suez.com .. If you continue to experience difficulties, you can lodge a complaint with France’s Commission Nationale de
l’Informatique et des Libertés (CNIL) data protection authority. To find out more about your rights, you can visit the CNIL website at the following address: https://cnil.fr.

The OPERATOR uses connection data (date, time, Internet address, visitor’s computer protocol, page viewed) and cookies (small files saved on your computer) on its WEBSITE to identify you, record your visits, and make use of audience measurements and statistics for the WEBSITE, particularly relating to the pages viewed. By browsing the WEBSITE, you consent to the OPERATOR’s installation of this type of so-called “technical”cookies, whose sole purpose is to allow or facilitate electronic communication between your browsing equipment and our site, making it easier to manage and navigate. We will therefore only access or record information stored on your browsing equipment under the following circumstances:
– To enable or facilitate communication by electronic means;
– Where required for the provision of our online communication service at your express request.
As with other data, you may exercise your right of access to this connection data by sending a request by email to
privacy.france@suez.com or by post to the following address:
BOONE COMENOR METALIMPEX – Direction Digital
45 rue Pasteur
59520 Marquette-lez-Lille

If your browser provides such an option, you can deactivate these cookies at any time by following the procedure specified by the browser. However, the OPERATOR informs you that the result of such deactivation may be to slow down and/or disrupt access to the WEBSITE. In addition, the OPERATOR informs you that it uses the services of Google Analytics to measure the audience for the WEBSITE. You may opt out of having your browsing on the WEBSITE tracked via the Google Analytics tool by downloading and installing the Google Analytics Opt-out Browser addon for your current browser on the WEBSITE, which is accessible at the following address: https://tools.google.com/dlpage/gaoptout?hl=fr.

 To find out about the nature of the cookies and other trackers implemented on the WEBSITE, the USER is invited to view the OPERATOR’s Cookie Management Policy, provided for this purpose and accessible at the following address https://metalimpexgroup.com/cookies/. To find out more about cookies (how to manage, delete and identify them), you can visit the CNIL PLATFORM: https://www.cnil.fr/vos-droits/vos-traces/les-cookies/#c5554

ARTICLE 8. LOGIN DATA AND COOKIES

The OPERATOR uses connection data (date, time, Internet address, visitor’s computer protocol, page viewed) and cookies (small files saved on your computer) on its WEBSITE to identify you, record your visits, and make use of audience measurements and statistics for the WEBSITE, particularly relating to the pages viewed. By browsing the WEBSITE, you consent to the OPERATOR’s installation of this type of so-called “technical”cookies, whose sole purpose is to allow or facilitate electronic communication between your browsing equipment and our site, making it easier to manage and navigate. We will therefore only access or record information stored on your browsing equipment under the following circumstances:
– To enable or facilitate communication by electronic means;
– Where required for the provision of our online communication service at your express request.
As with other data, you may exercise your right of access to this connection data by sending a request by email to
privacy.france@suez.com or by post to the following address:
BOONE COMENOR METALIMPEX – Direction Digital
45 rue Pasteur
59520 Marquette-lez-Lille

If your browser provides such an option, you can deactivate these cookies at any time by following the procedure specified by the browser. However, the OPERATOR informs you that the result of such deactivation may be to slow down and/or disrupt access to the WEBSITE. In addition, the OPERATOR informs you that it uses the services of Google Analytics to measure the audience for the WEBSITE. You may opt out of having your browsing on the WEBSITE tracked via the Google Analytics tool by downloading and installing the Google Analytics Opt-out Browser addon for your current browser on the WEBSITE, which is accessible at the following address: https://tools.google.com/dlpage/gaoptout?hl=fr.

 To find out about the nature of the cookies and other trackers implemented on the WEBSITE, the USER is invited to view the OPERATOR’s Cookie Management Policy, provided for this purpose and accessible at the following address https://metalimpexgroup.com/cookies/. To find out more about cookies (how to manage, delete and identify them), you can visit the CNIL PLATFORM: https://www.cnil.fr/vos-droits/vos-traces/les-cookies/#c5554

ARTICLE 9. DETAILS OF THE DATA PROTECTION OFFICER

Our Data Protection Officer (DPO) is available to respond to all your requests, including requests to exercise your rights relating to your personal data. You can reach the DPO via this contact form available here https://metalimpexgroup.com/ or by email at privacy.france@suez.com, or by post at the following address:
BOONE COMENOR METALIMPEX – Direction Digital
45 rue Pasteur
59520 Marquette-lez-Lille

ARTICLE 10. SECURITY

The OPERATOR and any applicable processors undertake to implement all technical and organisational measures
to ensure the security of our processing of personal data and the confidentiality of your data, in accordance with
the French Data Protection Act (Loi informatique et Libertés) and the European Data Protection Regulation (GDPR)
and Law No. 2018-133 of 26 February 2018 “containing various provisions for adapting to European Union law in
relation to security.”
In this respect, the OPERATOR takes the necessary precautions, with regard to the nature of your data and the
risks presented by our processing, to ensure the security of the data and, in particular, to prevent said data from being distorted, damaged or accessed by unauthorised third parties (physical protection of the premises, authentication process for our customers with personal and secure access via confidential logins and passwords, logging of connections, encryption of certain data, etc.).

ARTICLE 11. TRANSFERS OUTSIDE THE EU

The OPERATOR undertakes not to transfer USERS’ data outside the European Union. In the event that the OPERATOR should do so, it shall inform the USERS, specifying the measures taken to control this transfer and to ensure that the confidentiality of their data is maintained.

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