6. Cookies

We use cookies to:

♦ Save the browsing language

♦ Ensure the site works properly, in particular the online shop

♦ Measure audience (via our own statistics server, with no data transferred to third parties)

You can manage your cookie preferences at any time via the consent management tool (to be added if needed).

7. Data recipients

Your personal data is processed by IT CyberWall, and the authorised entities of the Pioneer Humani group, in particular the relevant regional subsidiary, its regional division and the parent company, may, depending on your location, have access to your personal data.

This access is strictly limited to what is needed to provide the services, to comply with legal or regulatory obligations and, where applicable, for marketing activities carried out in accordance with current data protection legislation.

No data is transferred to commercial third parties. Statistics are hosted on our own internal servers.

8. International data transfers and location of processing

IT CyberWall undertakes to comply with all applicable regulations on personal data protection and international transfers, in accordance with the General Data Protection Regulation (GDPR) for European clients, as well as the local legislation applicable in other territories.

♦ For our clients located in the European Union, personal data is exclusively hosted and processed on servers located within the European Economic Area (EEA). No data is transferred outside the EU, unless:

⇒ It is necessary to perform a service explicitly requested by the user;

⇒ Or it meets a justified and regulated legal or contractual obligation.

♦ For our clients established outside the European Union, in particular in Africa, Asia or South America, data is hosted as locally as possible, that is:

⇒ Either in the client’s country, when the available infrastructure complies with security standards and local legislation;

⇒ Or in a third country recognised as providing an adequate level of protection, or in which appropriate legal safeguards (standard contractual clauses, BCRs, etc.) are in place.

♦ In all cases, IT CyberWall ensures that any cross-border transfer strictly complies with the legal frameworks in force, and implements appropriate technical and organisational measures to guarantee the security, confidentiality and integrity of the data processed.

Example: Data collected from clients located in Africa is not transferred to Europe or any other jurisdiction without first checking compliance with local laws and without an adequate legal framework.

You can request information about these safeguards via our DPO contact.

9. Regulations by region

Users based in Morocco

In accordance with Law 09-08 on the protection of personal data, IT CyberWall undertakes not to transfer the personal data of Moroccan users outside the national territory without authorisation from the CNDP. Services, technical data and business data are hosted locally or on infrastructure located in Morocco or in countries recognised as adequate by the CNDP.

Users located in other African countries

We comply with the applicable local regulations on data sovereignty. Wherever possible, we host the data and services of our African clients on local or regional infrastructure, and we avoid any transfer of sensitive data outside the continent without consent or a justified contractual need.

Users based in Brazil

In accordance with the LGPD, the data of Brazilian users is only transferred abroad if the destination country (such as the European Union) guarantees an adequate level of protection, or on the basis of explicit consent. IT CyberWall hosts the services and sensitive data of its Brazilian clients locally, unless otherwise provided by contract.

Users based in Mexico

Under the LFPDPPP, IT CyberWall informs Mexican users that some data needed to manage orders (for example, billing data) may be processed in the European Union. No sensitive data is transferred without explicit consent or a legal obligation.

Users located in Asia

We comply with the local regulations in force, such as the Indian data protection law (DPDPA 2023) or equivalents. IT CyberWall makes sure to host the services and data of Asian clients on regional or local infrastructure. No international transfer is made without a legal basis or informed consent.

Users based in China

In accordance with the PIPL, no personal data collected in China will be transferred abroad without a prior data security assessment and, where applicable, authorisation from the competent authorities. Chinese services and data are hosted exclusively on servers located in China.

10. Your rights

Under the GDPR, you have the following rights:

♦ Right of access, rectification and erasure,

♦ Right to restriction of processing,

♦ Right to object, including to marketing without justification,

♦ Right to data portability,

♦ Right to withdraw your consent at any time,

♦ Right to set post-mortem instructions (retention, deletion or transfer of your data after death).

To exercise your rights or for any question about your personal data, you can:

♦ contact our Data Protection Officer (DPO) via this dedicated page.

♦ Send an email to [email protected]

♦ Send a letter by post: see contact details in section 1.

You can also lodge a complaint with the CNIL in France (www.cnil.fr).

11. Data security

We implement all the technical and organisational measures needed to ensure the confidentiality, integrity and security of your data:

♦ SSL/TLS encryption,

♦ Secure hosting,

♦ Strict access management,

♦ Regular internal audits.

12. Changes to the policy

This policy may be updated at any time. The version in force is the one published on this site.