PRIVACY POLICY

INTRODUCTION

As part of the protection of personal data, SARL Xbline, registered under
number 802 731 182, is committed to ensuring total transparency regarding the collection,
analysis, and purpose of the processing of its clients’ personal data.
By “personal data,” we mean any information collected and recorded in
a format that allows you to be personally identified, either directly (e.g., name) or
indirectly (e.g., phone number) as a natural person. Before providing us with this
information, we recommend that you read the rest of this
document describing our policy regarding the protection of our clients’ privacy.
This privacy policy is an integral part of the general terms and conditions governing
our hospitality services. By accepting our general terms and conditions, you expressly accept
the provisions of this document.

COLLECTION OF PERSONAL DATA

Xbline undertakes to comply with the provisions of Law No. 78-17 of January 6, 1978, and the
General Data Protection Regulation of April 27, 2016.
At various times, we may ask you, as a client of
SARL Xbline, for information about yourself and/or your family members, such as:

• Contact details (for example: name, first name, phone number, email, etc.);
• Personal information (for example: date of birth, nationality, etc.);
• Information about your children (for example: first name, date of birth, age, etc.);
• Your bank details, credit card number (for transaction purposes);
• Your preferences and interests (for example: mobile – landline extensions, preferred brand,
payment habits, cultural interests);
• Your questions/comments following an installation or maintenance of your infrastructure.
We do not voluntarily collect sensitive information, such as racial or ethnic origins,
political opinions, religious and philosophical beliefs,
union membership, health details, or sexual orientation.

Personal data may be collected on various occasions, including:
• Commercial Activities:
> Visits to your premises;
> Registration and payment;
> Telephone conversations or email exchanges;
> Requests, complaints, and/or disputes.
• Participation in marketing programs or events:
> Contribution to satisfaction surveys;
> Subscription to newsletters to receive offers and promotions by email;
• Transmission of information from third parties:
> Companies providing lead lists, partners, clients, and associates of Xbline.
• Internet Activities:
> Connection to the Xbline website (IP address, cookies, web trackers);
> Online collection forms (online contact page, questionnaires, SARL
Xbline social media pages, login devices such as Facebook Login, etc.).

PURPOSE OF PERSONAL DATA
PROCESSING

Xbline will not keep personal data longer than is
necessary for the purposes for which it was collected or longer than
provided for by applicable law.
We collect your personal data for the purpose of:
• Fulfilling our obligations to our clients.
• Managing our clients’ IT requests and maintaining their infrastructure.
> Preparation and retention of legal documents in compliance with accounting
standards;
• Improving our IT service, including:
> Processing your personal data within the framework of client marketing programs in order
to carry out marketing operations, brand promotion, and to have a better
understanding of your needs and wishes;
> Adapting our products and services to best meet your requests;
> Personalizing commercial offers and relationship messages for you;
> Informing you of special offers and any new services created by our company;
• Improving SARL Xbline’s services, including:
> Conducting studies and analyzing client questionnaires and comments;

RETENTION OF PERSONAL DATA

Data may only be kept for the duration necessary for the
purposes for which it is processed. The minimum retention period is 1 year.

CONDITIONS FOR ACCESS BY THIRD PARTIES

Within SARL Xbline: in order to provide you with the best service, we may share your
personal data and provide access to our authorized personnel, including:
> Reception, accounting, and sales administration staff;
> Technical staff;
> Sales staff;
> Business partners and marketing services;

RIGHT OF ACCESS, MODIFICATION, AND ERASURE

We undertake to recognize your right of access and rectification should
you wish to consult, modify, or even delete information concerning you.
This right can be exercised by contacting the company directly.
All requests will be processed as quickly as possible and in accordance with applicable
law.

RIGHT TO OBJECT

We undertake to guarantee you a right to object regarding your personal
information.
The right to object is understood as the possibility offered to clients to refuse to have
their personal information used for certain purposes mentioned during
collection.
All requests will be processed as quickly as possible and in accordance with applicable
law.

SECURITY

We undertake to ensure the proper application of security measures relating to the
processing of our clients’ personal data, in particular to protect the
data against unauthorized or unlawful processing, loss, destruction, accidental
damage, or disclosure to unauthorized persons.
To ensure the security of personal information, we use the
following measures:
• Incremental IT backup on dedicated servers
+ copy of the backup on NAS
• Physical firewall (Stormshield)
> VPN access via Microsoft authorized by user/Active Directory for
viewing data outside the premises
> Encrypted EBP software with document access based on the user.
> External Exchange system (Microsoft 365) for messaging