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Last updated : September 21, 2024
The privacy policy implemented by the company Pro XY – Legal – SAS au capital de 500 € (SIRET : 984 534 339 00010) (hereinafter « Pro XY – Legal ») is accessible from the « Legal Notice » or « Terms and Conditions » page of the website https://www.proxy-legal-domain.com (hereinafter the « Site »).
Pro XY – Legal protects the privacy of visitors to its Site in its capacity as data controller within the meaning of Law No. 78-17 of 6 January 1978 as amended (hereinafter the « Data Protection Act ») and the General Data Protection Regulation No. 2016/679 (hereinafter « GDPR »).
The purpose of this document, called « Privacy Policy », is to inform you about the processing of Personal Data that is related to the Site organized by Pro XY – Legal in its capacity as Data Controller.
This document informs you about :
You agree to read the General Terms and Conditions of Use of the Site (hereinafter the « GCU ») and other contractual documents concluded with Pro XY – Legal in the context of the use of the Site, which together with this Privacy Policy form a contractual whole that is binding on You.
Consequently, We also invite you to read this Privacy Policy carefully, which contains important information on how we collect, use and communicate some of your Personal Data in order to meet your needs but also to improve the quality of the services we offer you. This Policy concerns all types of Personal Data, whatever the form (e.g. electronic, paper, etc.) as well as all types of processing, manual or automated.
The terms defined below shall have the following meaning, whether used in the singular or plural :
« Client » means any natural or legal person acting in the context of their activity for professional purposes, on their behalf and that of their Users.
« Informed Consent » means any freely given, specific and informed indication of the Data Subject’s agreement to the processing of their Personal Data.
« Personal Data » means, with regard to Article 4 of the GDPR, « any information relating to an identified or identifiable natural person (hereinafter referred to as « data subject »); an « identifiable natural person » is deemed to be a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity ». Personal Data includes in particular data allowing the identification of Users. We inform you for information purposes only that the electronic identification data allowing the identification of your Connection Terminal or the pages consulted on the Site during your navigation are generally insufficient on their own to identify you by name.
« Sensitive Data » or « Special Categories of Data » include Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union affiliation, as well as the processing of genetic data, biometric data intended to identify a natural person, data relating to health or data relating to a natural person’s sex life or sexual orientation.
« Business Partners » means Pro XY – Legal’s partners.
« Applicable Regulation » means all existing or future regulations and standards that are applicable to Users and the Site and in particular the legislation and regulations concerning the protection of Personal Data, including the Data Protection Act and the GDPR.
« Data Controller » means (Pro XY – Legal) when it determines the purposes and means of processing Personal Data.
« Site » : means the site(s) whose URL address is as follows: (https://www.prox-legal-domain.com).
« Solution » concerns the provision to the Client of a SaaS platform developed and marketed by Pro XY – Legal under the registered trademark Exadvize.
« Terminal » refers to the different media through which the Site will be accessible. Terminals include Smartphones, tablets, microcomputers via the Internet (PC or Apple) and any object connected/connectable to another object as well as to the Internet.
« Third Party » refers to a third party or business partner who, as part of your current or potential use of the Solution, communicates Personal Data to us on your behalf or receives or accesses Personal Data on our behalf, for example suppliers, subcontractors and other service providers.
« You », « Yours », « User(s) » refers to any person accessing the Site (for example visitors) and whose Personal Data may be collected during their visit to the Site.
When you visit the Website or when we contact you, for example, to inquire about the Solution, we act as the data controller of your Personal Data within the meaning of the Legislation in Force, i.e. we determine the means and purposes of the Processing. These purposes are detailed below. When you create a Customer Account or a User Account and use your login details (login and password) to use the Solution, we act as the data controller.
When your Personal Data is processed as part of the operation of the Solution and the provision of the Related Services, the data controller is the Customer or Partner whose use of the Solution involves the processing of your Personal Data, and we act as a subcontractor on behalf of this data controller (the Initial Processing).
In certain cases also concerning your Personal Data processed in the context of the operation of the Solution and the provision of the Related Services, we act as data controller, for example, when we process data for the purposes of preventing and detecting fraud and malware, managing security incidents, creating statistics, and improving the Solution (Further Processing). This Further Processing is compatible with the Initial Processing taking into account (among other things) the link that exists between these two processes (use and improvement of the Solution), the nature of the Personal Data involved (absence of Sensitive Data), the limited consequences of the Further Processing for the Data Subjects, and the existence of appropriate guarantees that we implement in the context of this processing.
This Policy only governs the processing that we carry out as data controller. The processing that we carry out as a subcontractor is governed by the Data Processing Agreement annexed to the Conditions.
The Personal Data collected by Pro XY – Legal could be transferred to third parties in the context of a change of control of the company, an acquisition, a collective procedure or a sale of the company’s assets.
The Solution and the Site are provided to you by the company Pro XY – Legal («we», «our» or «us»). You can contact our data protection officer at the following email address: contact@proxy-legal-domain.com.
As part of our business, we collect Personal Data :
The processing of Personal Data carried out by Pro XY – Legal through the Site has the following specific purposes:
| Purpose | Legal basis |
|---|---|
| Opening of User access and navigation on the Solution | Execution of the CGSU |
| Managing our relationship with our prospects (eg inform you about our company and our Solution, for example by sending you our newsletter or by defining and communicating the applicable price to you, answering your questions, by email, telephone, video conference or instant messaging, inviting you to join Pro XY – Legal, allowing you to make an appointment directly with us or register yourself directly on our Website, giving you a demonstration of the Solution, improving our sales process). | Pre-contractual measures Legitimate interest |
| Management of commercial relationships with our Customers and Partners. (eg informing you about our company and our Solution, for example by sending you our newsletter or by defining and communicating the applicable price to you, informing you of changes to the General Conditions). | Execution of the General Conditions |
| Order and invoicing management | Execution of the General Conditions |
| Management of our administrative and accounting needs | Compliance with a legal obligation |
| Management and animation of our Website | Legitimate interest |
| Analysis of your browsing on our Website (cookies) | Consent |
| Analysis of your browsing on the Solution for the improvement of our services | Legitimate interest |
| Improving prevention and detection of fraud, malware and security incident management in the context of Further Processing | Execution of the General Conditions |
| Conducting statistics, surveys and polls regarding the use of the Solution, improving the Solution and Related Services and suggesting such improvements to customers as part of Further Processing. | Execution of the General Conditions |
| Personalized advertising based on your browsing, your profile and the information you have provided to us | Legitimate interest |
| Meet our legal and regulatory requirements, for example by providing our stakeholders with a whistleblower system or managing requests from the competent authorities or jurisdictions | Compliance with a legal obligation |
| Management of requests for the right of access, erasure, portability, limitation, rectification and opposition | Compliance with a legal obligation |
| Managing our relationship with our suppliers | Pre-contractual measures Execution of a supplier contract |
Personal data will not be processed later in a way that is incompatible with these purposes.
We use cookie technologies on the Website to enable us to evaluate and improve the functionality of the Site and the Solution. We may also use cookies for advertising or analytics purposes, subject to your consent and as you choose, using our cookie setting tool. For more information on how we use cookies, please see our Cookie Policy.
We protect the Personal Data collected, used, stored and disclosed by respecting the technical and organizational measures necessary to ensure their security, integrity and absolute confidentiality. Technical and organizational measures in accordance with industry standards are implemented to prevent accidental or unlawful destruction or loss, alteration, disclosure or unauthorized access, or any other form of unlawful or unauthorised processing. We implement these measures at the earliest stages of the design of processing operations, so that privacy and data protection principles are protected from the outset (“Privacy by design”). By default, we ensure that Personal Data is processed to ensure privacy (for example, by limiting access to those who need it), so that the Personal Data is not accessible to an undetermined or too large number of people (“Privacy by default”).
We select service providers and partners that offer sufficient guarantees to implement at least equally protective technical and organisational measures.
Where required by the Applicable Legislation, we will notify the User and any Data Subject as well as the competent supervisory authority of any breach of Personal Data within the legally required time after becoming aware of it. We are committed to putting in place the technical and organisational security measures to limit the impact of any breach of Personal Data and ensure that it does not happen again.
In order to comply with the regulations in force, the collected Personal Data are kept for a specified period. The retention period of information must be proportionate to the purposes described above.
The purposes of this archiving and the corresponding retention periods are :
The Personal Data collected is deleted following the occurrence of one of the following events:
Your Personal Data may be processed by our employees and our subsidiaries, within the limits of their respective responsibilities and exclusively in order to achieve the purposes set out in this Policy. In this case, our employees and subsidiaries undertake to respect the confidentiality of Your Personal Data.
Personal Data is disclosed to Third Parties only to the extent that there is a legal justification for such sharing (e.g. the data subject has given consent, disclosure is necessary to perform a contract, Pro XY – Legal is pursuing a legitimate purpose that does not infringe the data subject’s fundamental rights, including the right to privacy). Disclosure is made on a strictly limited “need-to-know” basis in relation to the legal basis. If disclosure is necessary to comply with a legal obligation (for example, for a government agency or police force/security service) or as part of legal proceedings, Personal Data may generally be provided as long as disclosure is limited to what is legally required and, if permitted by law, the Data Subject has been informed of the situation.
We rely on industry-leading service providers for server, hosting and infrastructure management. These hosting services offer industry-leading scalability, data availability, security and performance, with a documented business continuity plan. For the purposes set out in this Policy, we also use services provided by several companies specializing in customer relationship management (e.g. Salesforce, Ringover, Modjo, Calendly, Europhone), email campaigns (e.g. Hubspot, Outreach), database management (Metabase, Amplitude, Segment, Stitch), internal communication and documentation tools (e.g. Google, Notion, Slack), product improvement tools (e.g. Maze, Screeb), application performance monitoring and analysis tools (e.g. Datadog, Sentry) (non-exhaustive list).
In order to ensure the processing purposes described in this Policy, Pro XY – Legal may have recourse to service providers located outside the European Union. If the transfer takes place to a third country in which the legislation has not been recognized as offering an adequate level of protection of Personal Data, Pro XY – Legal ensures that adequate measures are put in place in accordance with the Legislation in Force, and in particular, where necessary, that standard contractual clauses or equivalent ad hoc clauses are incorporated into the contract concluded between Pro XY – Legal and the subsequent processor.
Finally, Pro XY – Legal may be required to communicate Personal Data in the context of a requisition.
The Solution and the Site may contain hypertext links to third-party websites (including social networks and merchant partners). Please note that if you follow these links, the websites and services provided will be governed by their own terms of use and privacy policies. We cannot be held responsible for the non-conformity of their terms of use and privacy policies with the Applicable Law. We advise you to read the privacy policies and terms of use applicable to these websites before providing your Personal Data and using these websites.
Pro XY – Legal takes all reasonable precautions and follows industry best technical and organizational practices to ensure that Your Personal Data is not lost, misappropriated, accessed, disclosed, altered or destroyed in an inappropriate manner in compliance with ANSSI recommendations and ISO 27001, although no method of transmission over the Internet or electronic storage is 100% secure.
Procedures for the physical and electronic safeguarding of Personal Data collected on the Site are implemented in accordance with current French legislation on the protection of Personal Data.
However, Pro XY – Legal does not control all the risks associated with the operation of the Internet and draws Your attention to the existence of possible risks in terms of occasional loss of data or breach of confidentiality of data transiting via the Internet network. The information provided on the Site may be interrupted in the event of force majeure or other circumstances beyond the control of Pro XY – Legal, or due to events beyond Our control.
You declare that you are fully aware of the importance of the accuracy of the Personal Data concerning You and provided through the Site.
You also undertake to provide only accurate Personal Data throughout your use of the Site, updating it immediately if one or more of these Personal Data changes during your use of the Site.
Accordingly, You may make a request to access, rectify or delete all or part of Your Personal Data, as set out in the article “Your rights of access to Your Personal Data” of this Privacy Policy.
In accordance with the provisions of Article 13 of the RGPD, You have a general right of access, rectification and deletion of Your Personal Data processed by Pro XY – Legal.
You may exercise this right by sending Your request to Pro XY – Legal’s Data Protection Officer by e-mail (contact@proxy-legal-domain.com) or by post to the contact details below, specifying Your request and enclosing proof of identity: Pro XY – Legal – DPO, 143 rue des seinches – 30240 Le Grau du Roi.
You have the right to limit the processing of Your Personal Data and the right to object to Your Personal Data being processed for legitimate reasons (with the exception of canvassing, for which You may object without legitimate reasons).
You also have the right to lodge a complaint with a supervisory authority.
The Site is not intended for minors.
The Site’s forms and questionnaires are not intended to collect information about minors. If any information is collected on a minor via the Site, the minor’s legal representative may contact Pro XY – Legal to rectify, modify or delete this information.
By using the Site, You agree to abide by the terms of this Privacy Policy.
As such, You are and shall remain responsible for any breach of the present Privacy Policy and in particular for the confidentiality of Your Site Identification data and any unauthorized use of the Site.
For this purpose, You shall be liable for any financial penalty that may be imposed on Pro XY – Legal, in particular by any decision of a French administrative or judicial court, or by an independent administrative authority such as the Commission Nationale de l’Informatique et des Libertés (CNIL), following a breach by You of Your obligations under this Privacy Policy.
Furthermore, Pro XY – Legal shall not be held liable in the event of :
In the event that one of the clauses of the present Privacy Policy should become null and void, in particular as a result of a change in legislation or a court decision, this shall in no way affect the validity of and compliance with the other clauses of the present Privacy Policy.
This Privacy Policy is governed by French law. All Users acknowledge the jurisdiction of the French courts for any dispute relating to their content, whether at first instance or on appeal.
Pro XY – Legal reserves the right to update the present policy and will indicate any update through its Website.