Privacy policy
Last updated :
This policy describes how WB SYNERGY Société par actions simplifiée (SAS) processes personal data collected through this site, in accordance with Regulation (EU) 2016/679 (GDPR) and French Law No. 78-17 of 6 January 1978 as amended.
1. Data controller
WB SYNERGY Société par actions simplifiée (SAS), 4 bis, rue du Colonel Fabien, Bât. C2, 94460 Valenton, France - RCS Créteil 879 551 992.
Contact for any question relating to personal data: contact@wbsynergy.eu.
Given its size and the nature of its activities, WB SYNERGY is not required to appoint a data protection officer within the meaning of Article 37 GDPR.
2. Processing operations
| Item | Detail |
|---|---|
| Purpose | To handle and respond to contact enquiries submitted through the site's form. |
| Data collected | Full name, organisation, business email address, telephone number (optional), subject of enquiry, message content, browsing language. |
| Legal basis | Article 6(1)(b) GDPR - steps taken at the request of the data subject prior to entering into a contract; and, for non-precontractual enquiries, Article 6(1)(f) - the legitimate interest of the company in responding to enquiries addressed to it. |
| Retention period | 36 months from last contact, then deletion. Enquiries giving rise to a contractual relationship are retained in accordance with the statutory periods applicable to commercial records. |
| Mandatory fields | Fields marked with an asterisk are necessary to handle the enquiry. Without them, the enquiry cannot be processed. |
| Purpose | To send WB SYNERGY publications to people who request them. |
|---|---|
| Data collected | Name and email address. |
| Legal basis | Article 6(1)(a) GDPR - consent, obtained through an unticked checkbox, separate from submission of the form. |
| Retention period | Until consent is withdrawn, and at the latest 36 months after last contact. An unsubscribe link is included in every mailing. |
| Purpose | To measure site traffic in aggregate form in order to improve the content. Tool: Matomo, for the sole account of WB SYNERGY. |
|---|---|
| Data collected | Pages viewed, referring page, device type, language, and an IP address whose last two bytes are truncated before anything is recorded. No directly identifying data, no visitor profile, no cross-site identifier. |
| Legal basis | Article 6(1)(f) GDPR - the legitimate interest of WB SYNERGY in understanding how its own site is used. Access to your terminal falls under the consent exemption CNIL provides for audience measurement (Article 82 of the French Data Protection Act); no cookie is placed. You may object at any time, without giving a reason and without consequence, from the cookie policy. |
| Retention period | 13 months maximum. |
3. Recipients and processors
Data is neither sold, rented nor transferred to third parties for commercial purposes.
It is accessible only to authorised persons within WB SYNERGY, and to the following processors, acting on the controller's documented instructions:
| Processor | Role and location |
|---|---|
| Netlify, Inc. | Site hosting and collection of contact form submissions. Company established in the United States, with infrastructure available in Europe. |
| GitHub, Inc. | Hosting of the site's source code. No form data is processed there. |
| InnoCraft Ltd (Matomo Cloud) | Site audience measurement. A company established in New Zealand, with the data hosted in the European Union. No form data is processed there. |
4. Transfers outside the European Union
Some of the processors listed above are established in the United States. Any transfers of data to those recipients are governed by the standard contractual clauses adopted by the European Commission, supplemented where applicable by the processor's certification under the EU-US Data Privacy Framework.
The processor responsible for audience measurement is established in New Zealand, a country recognised as providing an adequate level of protection by a decision of the European Commission; the audience-measurement data is in any case hosted in the European Union.
A copy of the applicable safeguards may be obtained on request at the address given in section 1.
5. Security
The site is served exclusively over HTTPS. The applicable security headers (content security policy, framing protection, referrer control) are configured at host level. Access to form submissions is restricted to authorised persons and protected by two-factor authentication.
Typefaces, images and all static assets are hosted on the site's own domain. Exactly one request is made to an external domain when pages load: the audience-measurement script described in section 2, which receives your IP address and truncates its last two bytes before anything is recorded. If you object to audience measurement, that request is not made at all, and your IP address is then disclosed to no external provider.
6. Your rights
You have the rights of access, rectification, erasure, restriction of processing and portability, together with the right to object to processing based on legitimate interest and the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out beforehand.
To exercise these rights, write to contact@wbsynergy.eu or to the postal address in section 1. A response will be provided within one month of receipt of the request. Proof of identity may be requested where there is reasonable doubt as to the identity of the requester.
You also have the right to lodge a complaint with the French data protection authority, the Commission nationale de l'informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, www.cnil.fr.
7. Cookies
Cookie management is covered by a dedicated policy.
8. Changes to this policy
This policy may be amended to reflect legal, technical or organisational developments. The date of last update appears at the top of this page.