Personal Data & Privacy Policy

Thank you for visiting the website https://www.proximis.com (the “Site”).

At Proximis, we understand that the protection of the privacy of visitors to our Site is very important and that information concerning your private life is particularly sensitive. This is why we have taken the necessary measures to meet the requirements for the protection of your personal data.

Proximis is committed to a continuous approach to the protection of personal data and complies with all French and European regulations and legislation relating to the protection of such data. In this respect, we comply with the requirements of the amended French Data Protection Act of 6 January 1978 (hereinafter the “Act”) and the EU Regulation “Global Data Protection Regulations” with regard to the processing of personal data of individuals dated 27 April 2016 (hereinafter the “Regulation”).

This policy describes and informs, for the purposes of transparency on the processing carried out, of the way in which Proximis, in its capacity as Data Controller, undertakes to collect, use and protect your personal data with all due care and exclusively for the legitimate purposes for which it was collected.

1. What is the origin of the data collected by Proximis?

Proximis generally collects personal data about you that you agree to provide directly.

Prior to collecting your data, Proximis undertakes to obtain your consent and/or to allow you to object to the use of your data for certain purposes (see for instance for Hubspot interface).

In all cases, you will be informed of the purposes via the various data collection forms presented during your browsing (cookies, registration form, etc.).

In the event that some of your data is collected not directly from you, Proximis undertakes to inform you of this in the form and within the timeframe stipulated by the Regulation.

2. What personal data is collected?

When you browse the Site, Proximis may collect the following personal data:

Name, first name and e-mail address in order to contact a Proximis representative and/or to receive the Proximis newsletter (remember that you can refuse the sending of newsletters at any time by clicking on the corresponding link in the newsletter or by sending a message. The e-mail address will then be deleted from the Proximis distribution list);

Browsing data such as IP address, user agent of your browser, access time;

Leave a comment on our website, not only the data entered in the comment form, but also your IP address and browser user agent are collected to help us detect unwanted comments.

3. For what purposes is your data collected by Proximis?

Most of the services on our Site do not require any form of registration, which allows you as a user to visit without having to identify yourself.

However, some services may require the communication of some of your personal data.

The purposes of each processing of your personal data on our site are described and defined at the time of collection. This data is used to :

  • Contact us by form, in order to answer your questions;
  • Contact you in the context of managing our commercial relationship if it exists;
  • To compile statistics relating to the use of our Site, in order to enable us to improve it and offer you an optimal browsing experience;
  • To inform you of news, events and other activities related to Proximis’ corporate purpose;
  • To offer you our services and products;
  • To manage your subscription to our newsletters;
  • Testify on our blogs.

An anonymised string created from your email address (also called a hash) may be sent to the Gravatar service to check whether you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After validation of your comment, your profile picture will be publicly visible next to your comment.

A description of the purposes of the processing will be provided when you enter personal data so that you clearly understand the purposes for which we use them.

Proximis undertakes to process your personal data in strict compliance with these purposes. Under no circumstances will Proximis use your personal data for any other purpose.

4. On what legal basis does Proximis process personal data?

We collect, use and share the data in our possession in the ways described below:

  • To the extent necessary to comply with our terms of use;
  • In accordance with your consent, which you may revoke at any time;
  • To the extent necessary to fulfill our legal obligations;
  • To the extent necessary for the existence of a contract between you and Proximis;
  • To the extent necessary for our legitimate interests, unless those interests are overridden by your interests or freedoms and rights under the Act and the Regulations.

5. What categories of data are collected?

The personal data that Proximis collects is only the data necessary to achieve the purposes of the processing carried out. Proximis undertakes not to collect more data than necessary.

If you do not fill in the corresponding fields, you will not be able to use the services offered (e.g. subscription to newsletters, registration on the sites, publication of comments, etc.). The compulsory or optional nature of the personal data requested and the possible consequences of a failure to reply will be indicated at the time of collection by an asterisk.

6. Who is the recipient of your data?

Proximis will never pass on your personal data to third parties for other purposes such as commercial and/or promotional purposes without your consent.

Your personal data will be hosted by Proximis on servers under its responsibility and will be processed by tools under Proximis’ responsibility (including the Hubspot interface).

Proximis reserves the right to transmit personal data to subcontractors (service providers), in full compliance with the Law and the Regulation and exclusively in order to achieve the purposes described.

Proximis also uses the services of several specialised companies (mailing, audience analysis) and reserves the right to transmit personal data as a service provider, in full compliance with the Law and the Regulation and exclusively in order to achieve the purposes described.

The list of service providers can be communicated to the persons concerned on request to contact@proximis.com. If these companies use servers outside the European Union, we have concluded specific contracts with them and standard contractual clauses established by the European Commission to govern and secure the transfer of your data to these service providers.

7. How does Proximis manage the transfer of data to other countries?

Personal information about you controlled by Proximis may be transferred or transmitted, or stored and processed, by Proximis (or its subcontractors) in other countries outside the country in which you reside, for the purposes described above in this policy.

Proximis does not share or transfer your personal data outside the European Union. If this should eventually be the case, Proximis will ensure that this transfer is made in strict compliance with the rules described in the Regulation and that the recipient countries outside the European Union provide the appropriate and sufficient security guarantees required under the Regulation.

Proximis may share and transfer your personal data with any other (existing or future) Proximis entity.  The above rules apply.

8. How long is your data kept?

Your personal data is kept only for as long as is necessary for the purposes for which it was collected, in accordance with legal requirements.

Once this period has elapsed, your data will be deleted or archived in accordance with the applicable legal regulations.

9. How is your data secured?

Proximis protects your personal data by implementing all technical and organisational measures to ensure the security of personal data processing and the confidentiality of such data.

In this respect, Proximis takes all the necessary precautions, in view of the nature of the data and the risks presented by the processing, to preserve the security of the data and, in particular, to prevent them from being distorted, damaged or accessed by unauthorised third parties (physical protection of the premises, authentication procedures with personal and secure access via confidential identifiers and passwords, logging of connections, encryption of certain data, etc.)

However, we remind you that you are responsible for the data concerning you that you transmit to Proximis and that, as such, you contribute to the protection of your personal data by complying with good practice in the use of your IT tools.

You are informed that without adequate security measures (e.g. secure configuration of your web browser, updating of anti-virus programs, firewall software, not using software from dubious sources, etc.), you run the risk that the data and passwords you use to protect your data may be disclosed to unauthorised third parties.

10. What rights do you have over your data and how can you contact Proximis?

In accordance with the Regulation and the Law, you have the :

  • Right to consult and access, update, complete and rectify your data;
  • Right to erase and delete your data if it is inaccurate, incomplete or ambiguous;
  • The right to withdraw your consent to the collection of your personal data at any time;
  • Right to limit the processing of your personal data;
  • Right to object to the processing of your personal data;
  • The right to portability and transfer of your personal data where such data is subject to automated processing based on your consent; 
  • Right to define the fate of your data after your death and to choose the third party to whom Proximis should or should not communicate them.

In the event of your death and as soon as Proximis is informed of it, Proximis undertakes as soon as possible to transmit the data to the designated third party or, failing that, to destroy it. However, Proximis may keep a copy of your personal data if this is necessary for evidentiary purposes or to meet a legal obligation.

To find out more about your rights, you can find more information on the CNIL website

To exercise any of these rights, please send your request to our Data Protection Officer (DPO), using the following contact details

Cabinet HAAS Avocats
32 rue La Boétie, 75008 Paris 
Tel: +33 1 56 43 68 80
contact@haas-avocats.com

Finally, you may also file a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), Proximis’ main supervisory authority (https://www.cnil.fr/fr/plaintes)

11. What are cookies and how can they be managed?

A cookie is a small text file that is sent to your computer, smartphone or tablet through your Internet browser and saved on the hard disk of your terminal when you visit our site. Cookies enable Proximis, during their period of validity, to recognise you each time you access our Site. The period of validity and conservation of cookies varies according to the type of cookie. Cookies may be temporary (session cookies) or permanent. Session cookies are active only for the time of your visit and are deleted when you close the browser. Permanent cookies remain on your terminal’s hard drive when you leave the site and remain there until you manually delete them or the browser purges them after a certain period of time.

A cookie records anonymous information relating to the navigation of your terminal on our site (the pages consulted, the date and time of access, the Internet access provider, the operating system) which can be read throughout its period of validity and used solely for statistical purposes.

11.1 Browser cookies

Browsing cookies make it possible to improve Proximis’ performance in order to provide a better use of the Site. These Cookies do not require the user’s information or prior consent to be deposited on the terminal.

Browsing cookies allow us to :

  • To adapt the presentation of the Site to the display preferences of the terminal (for example, language used, display resolution, operating system used, etc.) during Users’ visits to the Site, according to the hardware and the display or reading software that the terminal has;
  • To memorise the user preferences, display settings and readers that users use in order to facilitate their navigation during their next visit to the Sites. In particular, they allow access to a reserved area subject to an identifier or a password;
  • To memorise the information entered on certain forms on the Site in order to avoid having to fill them in again during their next visit.

11.2 Statistical cookies

In order to adapt the Site to the User’s needs, Proximis measures the number of visits, the number of pages consulted and the User’s activity on the Sites and the frequency of their return. These Cookies make it possible to establish statistics for analysing the number of visits, from which the content of the Sites is improved according to the success of a given page with users.

The results of these analyses are processed anonymously and exclusively for statistical purposes.

11.3 List of navigation and statistical cookies

NameOwnerPurposeRetention period
cluidClicky AnalyticsThis cookie is used for the internal performance of the server and the session identification.Session (strictly necessary)
_first_pageviewClicky AnalyticsThis cookie is set on the first page view of a session. It is used to make the Clicky tracking code more efficientSession
_gidGoogle AnalyticsThis cookie is used to store a unique ID that is used to generate statistical information.1 day
eqy_sessionidGoogleThis cookie is used for the internal performance of the server and the session identificationSession (strictly necessary)
_gat_gtag_ua_137362090_1Google AnalyticsFunctionality. to store a unique user ID. Purpose. Statistics1 day
_jsuidClicky AnalyticsThis cookie aims to store first visit to the site.
Purpose : Statistics
Session (strictly necessary)
axeptio_cookiesAxeptioThis cookie aims to collect your consent and preferences regarding the cookies on the site, according to the applicable regulations.6 months (strictly necessary)
axeptio_all_vendorsAxeptioThis cookie aims to collect your consent and preferences regarding the cookies on the site, according to the applicable regulations.6 months (strictly necessary)
axeptio_authorized_vendorsAxeptio This cookie aims to collect your consent and preferences regarding the cookies on the site, according to the applicable regulations.6 months (strictly necessary)
IDEGoogle doubleClickThis cookie is used to track ad clicks / views to measure ad performance.390 days
_gaGoogle AnalyticsThis cookie is used to analyze information about how a user is using the website. 24 months
_hstcHubSpotThis cookie aims to store time of visite.
Purpose: marketing/tracking
13 months
_hssrcHubSpotThis cookie is used when HubSpot changes the session cookie, this cookie is also set to determine if the visitor has reset their browser.Session (strictly necessary)
_hsscHubSpotThis cookie is used to determine whether HubSpot should increase the session number and timestamp data in the cookie30 minutes
hubspotutkHubSpotThis cookie aims to store and track a visitor’s identity.
Purpose: Marketing/tracking
13 months

Proximis may process the information contained in the cookies about your visit in order to improve the content of our Site, to identify the pages of the Site that require maintenance, to analyse user behaviour patterns and to optimise your browsing experience. They facilitate navigation on the site and improve its usability.

Proximis uses performance analytics cookies to monitor the performance of its Site, for example to determine the number of times a page is viewed and the number of unique users on its website. Web analytics services may be designed and operated by third parties.

Proximis uses third-party solutions (including Google Analytics) to collect information about site visitors through these cookies. This information may be used by the providers of these solutions.

As a user, you are informed that cookies are used during your connections to the Site and you can refuse to accept cookies on our Site or set the parameters of the cookies concerned by going to the home page of the Site or to the “Cookies” tab on the Site.

The information concerning your consent or refusal to use cookies is kept for a maximum period of 6 months.

12. Changes to this policy

Proximis reserves the right to modify or adapt the terms of this policy at any time and without prior notice, provided that it does not violate the Law and the Regulations.