SITEW offers a service of design, modification, and hosting of websites, by the provision of an intuitive web design tool for users.

SITEW also offers various optional (and paying) services, such as the registration and management of custom domain names, a website SEO tool, an electronic messaging service, or a commercial emailing tool; all of which are designed to optimize the use and performance of the website.

This Privacy Policy describes, in accordance with Article 13 of the GDPR, how users' personal data are collected and processed by SITEW when users visit SiteW.com, or subscribe to services offered by SITEW, as well as their rights and the means to exercise them.

This Policy, as well as any modification of it, is published on SiteW.com and must be accepted by all users when they create a user account or when they fill in the contact form.

This Policy does not describe the processing by SITEW, in its capacity as a subcontractor (in particular as a host) of personal data hosted on the users' websites: the rules relating to this processing are described in the personal data annex of the General Terms and Conditions of Use (GTCU) / General Terms and Conditions of Service (GTCS).

For the purposes of this Policy, the following terms are defined as follows:

• Subscription: contractual commitment consisting of the subscription to the Service by the Client, for a period and a functional scope specified in the order; and in return for a financial consideration for SITEW;
• Content: all types of files, information or data, regardless of their nature (text, image, visual, video, multimedia, etc.), published by the user on its website;
• Data: personal data, within the meaning of Article 4 of the GDPR, linked to users, whatever their nature (texts, images, visuals, videos, etc.), processed by SITEW in the context of the subscription and use of the Service;
• Newsletter: electronic document containing information on SITEW's products and services sent by e-mail to users;
• Messaging: electronic messaging service provided by SiteW.com, based on the domain name(s) of the Site or any other domain name chosen by users;
• Tool: software tool, made available to the Client within the framework of the contract, and allowing the rapid creation, without specific training, of a website, within the limits of the technical characteristics specified in the order;
• Page: internal web pages of the website, created by the Client and edited under its responsibility,
• Service: additional services that may be subscribed to by the customer at the time of the order, such as, but not limited to: the registration and management of custom domain names, the provision of a website SEO tool, an electronic messaging service, or an emailing tool;
• SiteW.com: Website designed, created and developed using the tool provided by SITEW within the framework of this contract, and intended for the Client's digital communication
• Support: SITEW's website, on which the various Service subscription packages are presented;
• User: services to assist in the creation or use of the Site, provided by SITEW to the Client, under the conditions set out in these General Conditions and in the Order.
• Optional Services: natural or legal person who has subscribed to the Service – whether for a fee or free of charge – or a simple visitor of SiteW.com

The data controller is SITEW.COM, a limited liability company with a capital of 1,500 euros, registered in the Aurillac Trade and Companies Register under number 518 057 310, whose registered office is located at 92, rue de Marmiesse - 15000 AURILLAC - France.

All requests concerning this Policy and the GDPR can be sent by post to its registered office or by e-mail to the following address: rgpd@sitew.com

The data subjects, as defined in Article 4 of the GDPR, and subject of this Privacy Policy, are the Users, as defined in Article I.

For the purpose of providing the Service, or in the context of visiting SiteW.com, the following personal data are processed by SITEW:

1. Contact form:
   • E-mail address
   • Type of request and full text of the request;
2. Creation and Management of the User Account:
   • Name, first name
   • Phone number (optional)
   • Email address
   • Home address (optional)
   • Date of birth (optional)
   • Place of birth (optional)
   • For Professional Users:
     • SIRET number
     • registered office
     • contact email address, name, first name and phone number of the contact at the User's premises;
     • VAT number (optional)
3. Subscription to a Newsletter:
   • User's email address
4. Visits to SiteW.com:
   • User's IP address,
   • Visited pages, time stamp information, duration of visit, touch actions, mouse cursor actions, keyboard actions, public information about the browser and computer used, browser errors, etc.
   • Cookies (see art. X).
5. Use of the Service:
   • Date and time of connection to the Site Administration Tool,
   • Pages created;
   • Publication of Content;
6. Support Data:
   

   Messages sent to the Support service by the User, answers given, and all exchanges with the Support service.

7. Email:
   • Emails received and sent
   • Saved contacts
   • Recorded calendar events
   • Date and time of connection to email servers
   • User's IP address

We have decided to list the purposes of the processing, for each type of data processed under section IV.

Contact form data	Response to the User's request for information about SiteW.com or the Services in general,
User Account Data	Creation of the User Account and subscription to the Service; Management of preferences, including subscriptions to Newsletters Management of Subscriptions and subscription to Optional Services; Management of payment methods; Registration of domain names on behalf of the User
Newsletter	To provide Users with up-to-date information on SITEW's Services and the company's activity;
Data on visits to SiteW.com	Audience and statistical measurements Promotion of our service
Service usage data	To enable the proper use of the Service and in particular the publication of the User's Content; To allow the deletion of illicit Content and the identification of their authors;
User Support Data	To manage Users' Support requests; To ensure the proper functioning of the Service.
Messaging Data	To enable the proper use of the Service and in particular the possibility to send and receive emails and to manage contacts and events. To allow the deletion of illicit Content and the identification of their authors;

Once again, we thought it would be clearer to present such a legal basis for each type of data processing.

Contact form data	The User has consented to the processing The processing is necessary to take pre-contractual measures at the request of the User (e.g., replies to requests for information, or on the prices of the Services)
User Account Data	The User has consented to the processing The processing of the Data is necessary for the execution of the contract concluded with the User (GTCU / GTCS)
Newsletter	The User has consented to the processing;
Data on visits to the Site	The processing of the Data is in accordance with our legitimate interest as it allows us to measure the audience of SiteW.com and to promote our service
Data on the use of the Service	The processing is necessary to comply with our legal obligations (Decree No. 2011-219 of 25 February 2011 on the retention and communication of data identifying any person who has contributed to the creation of content posted online); The processing of data is in line with our legitimate interest as it allows us to create User profiles, with a view to offering them custom content
User Support Data	The processing is necessary for the execution of our contractual obligations and to maintain the Service in operational conditions
Messaging Data	The processing is necessary for the execution of the Contract concluded with the User for the provision of the Messaging service
Google Workspace Data	Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

We host the SiteW.com website ourselves, without using subcontractors.

The following security measures are applied to the Data processed by SiteW.com and described in this document: redundancy of the servers, use of different hosting services, servers located in several data centres, daily backup of the Data.

The technical maintenance of the Site is carried out internally, with the occasional support of external service providers.

Contact form data	The data is kept for a period of 3 years from the last contact with the User, in accordance with the CNIL's reference framework on commercial management;
Data from the User Account	The Data is processed until the closure or deletion of the User's Account, regardless of who initiated this closure. The User's identification Data is kept for one year from the closure or deletion of the User's account, in accordance with the provisions of Decree No. 2011-219 of 25 February 2011 on the conservation and communication of data allowing the identification of any person having contributed to the creation of content published online.
Newsletter	The Data is processed until the User unsubscribes from the Newsletter;
Data on visits to the Site	Data is processed for 13 months from the first date of collection
Data on the use of the Service	The Data is kept for one year from the closure or deletion of the User's account, in accordance with the provisions of Decree No. 2011-219 of 25 February 2011 on the retention and communication of data identifying any person who has contributed to the creation of content published online
Support Data	The Data is kept until the closure of the User Account, and for 5 years after the closure, in order to justify the execution of its contractual obligations of Support by SITEW;
Messaging Data	The Data is kept: 30 days after the deletion of the address concerned by the User; 12 months after the closure of the Account, or the non-renewal of the associated domain name, in order to allow the User to request an export of his Data if he so wishes.

We do not sell, trade or transfer to third parties your Personal Data, or any type of content that you may upload to the Site for which you are responsible (text documents, videos, photos, etc.), unless specifically requested to do so by the competent legal authorities, by judicial or administrative decision, and except in the context of service contracts concluded with subcontractors, for the sole purpose of ensuring the proper performance of the Service.

The list of subcontractors is shown in the table in the appendix to this document. These subcontractors provide sufficient guarantees as to the implementation of appropriate technical and organizational measures so that the processing meets the requirements of the GDPR. Under no circumstances may they process the subcontracted Data for personal purposes, or for purposes other than the performance of the service entrusted to them.

The list of cookies used by SiteW.com appears on the first visit of the website. The User can set the parameters according to their necessity or not.

At the date of this document, we use the following cookies:

Technical cookies

• SiteW
• Google Tag Manager

Statistics cookies

• Google Analytics
• Hotjar

Advertising cookies (conversion tracking and retargeting)

• Google Ads
• Affilae
• Facebook Ads
• Linked In Marketing solutions

Cookies from integrated services

• Tawk.to (chat service)

A pop-up consent box is displayed when you access the site, allowing you to accept or decline these cookies.

They can also be deactivated at any time through your browser settings.

1. User's rights on personal data

As a User, you have the right to obtain from us:

• confirmation that personal data relating to you is or is not being processed and, if necessary, access to such data; by means of an export of our database in .csv format or any other commonly used format;
• rectification or updating of your personal data that is inaccurate or incomplete;
• the deletion of your personal data, under the conditions provided for in Article 17 of the GDPR: you may, for example, delete your User account directly on the Site, which will put an end to the processing of all personal data, subject to the exceptions provided for in section VIII;

You may also, at any time, object to the processing of your data, if you have a legitimate reason or revoke your consent to the processing, for example by unsubscribing from our Newsletter.

2.How to exercise them

You can unsubscribe from an Information List by clicking on the “unsubscribe” link on any email, or by changing your settings on the mailing list homepage.

You may delete your account on the Site.

For any other request, please email us to the following address: rgpd@sitew.com indicating the subject of your request, your first and last name(s).

A photocopy of both sides of your identity card or passport may be requested, if there is any doubt about your identity, to enable us to verify your identity and process your request.

We will reply as soon as possible, at the latest within one month of receiving your request.

We remind you that you have the right to lodge a complaint with the CNIL if you feel that your rights have not been respected. For more information on your rights concerning your data, please consult the following web page: https://www.cnil.fr/fr/plaintes.

Annexes. Third party services used

Subcontracted service	Identity of the subcontractor
Hosting	OVH, H8l.io, Scaleway
Domain names	OVH, BookMyName, Hexonet
Maintenance and support	Google workspace, Tawk.to
Messaging	OVH, A2Hosting
Emailing	Mailjet, Lemlist
Site statistics	Google Analytics
Backups	OVH, H8l.io, Scaleway
Financial management	VosFactures, Paypal, Sogénactif, Pennylane
Financial analysis	Fincome
Ux analysis	Hotjar
Commercial promotion	Facebook Ads, Google Ads, Affilae, Linked In Marketing solutions
Payment	Société Générale (sogenactif), PayPal, Stripe