**Responsible for the Collection of Personal Data**

For the personal data collected while browsing the site www.spoagency.com by the visitor, the data processing manager is: SPOA. The site www.spoagency.com is represented by Aurélien SIMON, its legal representative. As the data processing manager, SPOA commits to respecting the legal provisions in force. It is responsible for establishing the purposes of its data processing, providing full information on the processing of personal data, and maintaining a register of processing activities that is in line with reality. Whenever www.spoagency.com processes personal data, SPOA takes all reasonable measures to ensure the accuracy and relevance of personal data with respect to the purposes for which www.spoagency.com processes them.

**Purpose of Data Collected**

The website www.spoagency.com is likely to process all or part of the data:
1. To allow navigation on the site and manage and track services ordered by the visitor.
2. To prevent and combat computer fraud.
3. To improve navigation on the site.

SPOA does not sell personal data of visitors, which are only used out of necessity or for statistical and analysis purposes.

**Right of Access, Rectification, and Opposition**

In accordance with the European regulations in force, visitors to www.spoagency.com have the following rights:
1. Right of access (article 15 GDPR) and rectification (article 16 GDPR), updating, and completeness of visitor data, right of blocking or deletion of visitors' personal data (article 17 of the GDPR), when they are inaccurate, incomplete, ambiguous, outdated, or where their collection, use, communication, or storage is prohibited.

2. Right to withdraw consent at any time (article 13-2c GDPR).

3. Right to limit processing of visitor data (article 18 GDPR).

4. Right to object to processing of visitor data (article 21 GDPR).

5. Right to data portability provided by visitors, where such data are subject to automated processing based on their consent or a contract (article 20 GDPR).

6. Right to define what happens to visitors' data after their death and to choose if www.spoagency.com should or should not communicate their data to a third party they have previously designated.

If no instructions have been given, SPOA commits to destroying the visitor's data unless its retention is necessary for probative purposes or to meet a legal obligation.

If the visitor wishes to know how www.spoagency.com uses their personal data, requests to rectify it, or oppose its processing, the visitor can contact SPOA in writing at the following address: SPOA – Personal Data, Communication Team, 60 avenue Victor Hugo 75016 Paris. Requests for the deletion of personal data will be subject to the obligations that are imposed on www.spoagency.com by law, particularly regarding document storage or archiving.

Finally, visitors to www.spoagency.com can submit a complaint to supervisory authorities, such as the CNIL (https://www.cnil.fr/fr/plaintes).

**Non-Disclosure of Personal Data**

The site www.spoagency.com is prohibited from processing, hosting, or transferring the information collected on its visitors to a country outside the European Union or recognized as "non-adequate" by the European Commission without informing the client beforehand. However, SPOA remains free to choose its technical and commercial subcontractors, provided they offer sufficient guarantees in terms of the requirements of the General Data Protection Regulation (GDPR: n° 2016-679). SPOA commits to taking all necessary precautions to preserve the security of information and ensure it is not communicated to unauthorized persons.

However, if an incident affects the integrity or confidentiality of a visitor's information and is brought to the attention of www.spoagency.com, it must promptly inform the visitor and communicate the corrective measures taken. Furthermore, SPOA does not collect any "sensitive data."

The visitor's personal data may be processed by subsidiaries of www.spoagency.com and subcontractors (service providers) exclusively to achieve the purposes of this policy. Within the limits of their respective attributions and for the purposes mentioned above, the main people likely to have access to visitors' data on www.spoagency.com are mainly our communication and IT service agents.

**Incident Notification**

​Regardless of the efforts made, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, we cannot guarantee absolute security. If we become aware of a security breach, we will notify the affected visitors so they can take appropriate actions. Our incident notification procedures take into account our legal obligations, whether they are at the national or European level. We are committed to fully informing our visitors of any issues regarding the security of their account and providing them with all necessary information to help them comply with their own regulatory reporting obligations.

No personal information of the visitor of the site www.spoagency.com is published without their knowledge, exchanged, transferred, assigned, or sold on any support to third parties. Only the purchase of www.spoagency.com and its rights would allow the transmission of said information to the potential acquirer who would, in turn, be held to the same obligation of retention and modification of data with respect to the visitor of the site www.spoagency.com.

**Security**

To ensure the security and confidentiality of personal data, www.spoagency.com uses networks protected by standard devices such as firewalls. When processing personal data, www.spoagency.com takes all reasonable measures to protect it from loss, misuse, unauthorized access, disclosure, alteration, or destruction.

**Cookies, Hypertext Links, and Internet Tags**

The site www.spoagency.com contains a number of hypertext links to other sites, set up with the authorization of SPOA. However, www.spoagency.com does not have the possibility to check the content of the sites visited, and therefore it accepts no responsibility for this fact.

**Cookie Policy**

Cookies

A "cookie" is a small information file sent to the visitor's browser and stored on the visitor's terminal (e.g., computer, smartphone), (hereinafter "Cookies"). This file includes information such as the visitor's domain name, the visitor's Internet service provider, the visitor's operating system, and the date and time of access. Cookies do not risk damaging the visitor's terminal in any way. The site www.spoagency.com is likely to process visitor information concerning their visit to the site, such as pages viewed, searches performed. This information allows www.spoagency.com to improve site content and visitor navigation.

Cookies facilitating navigation and/or the provision of services offered by the site, the visitor can configure their browser so that it decides whether to accept them or not, so cookies are stored in the terminal or, conversely, rejected, either systematically or according to their issuer.

​**Navigation**

The visitor can configure their browser software so that acceptance or refusal of cookies is offered punctually, before a cookie is likely to be recorded in their terminal. The site www.spoagency.com informs the visitor that, in this case, not all the functionalities of their browser software may be available. If the visitor refuses the storage of cookies in their terminal or browser, or if the visitor deletes those that are recorded there, the visitor is informed that their navigation and experience on the site may be limited. This could also be the case when www.spoagency.com or one of its providers cannot recognize, for technical compatibility purposes, the type of browser used by the terminal, the language and display settings, or the country from which the terminal appears to be connected to the Internet. If so, www.spoagency.com disclaims any responsibility for the consequences related to the degraded functioning of the site and any services offered by www.spoagency.com, resulting (i) from the refusal of cookies by the visitor (ii) from the inability of www.spoagency.com to record or consult cookies necessary for their operation due to the visitor's choice.

​For the management of cookies and visitor choices, the configuration of each browser is different. It is described in the browser's help menu, which will inform you how the visitor can change their wishes regarding cookies. At any time, the visitor can choose to express and modify their wishes regarding cookies.

The site www.spoagency.com may also use the services of external providers to help collect and process the information described in this section.

Finally, by clicking on the dedicated social network icons for Facebook, Instagram, and LinkedIn appearing on the site of www.spoagency.com or in its mobile application, and if the visitor has accepted the deposit of cookies by continuing their navigation on the website or mobile application of www.spoagency.com, Facebook, Instagram, and LinkedIn may also deposit cookies on your terminals (computer, tablet, mobile phone). These types of cookies are only placed on your terminals if you consent, by continuing your navigation on the website or mobile application of www.spoagency.com. At any time, the visitor can nevertheless withdraw their consent for www.spoagency.com to place this type of cookie.

​**Internet Tags**

​The site www.spoagency.com may occasionally use Internet tags (also known as "tags" or action tags, single-pixel GIFs, transparent GIFs, invisible GIFs, and one-to-one GIFs) and deploy them through a partner specialized in web analytics that may be located (and therefore store the corresponding information, including the visitor's IP address) in a foreign country. These tags are placed both in the online advertisements allowing Internet users to access the site and on various pages of it. This technology allows www.spoagency.com to evaluate visitors' responses to the site and the effectiveness of its actions (e.g., the number of times a page is opened and the information viewed), as well as the use of this site by the visitor. The external provider may collect information about visitors to the site and other websites using these tags, compile reports on site activity for www.spoagency.com, and provide other services related to the use of the site and the Internet.

**Applicable Law and Jurisdiction**

Any dispute related to the use of the site www.spoagency.com is subject to French law. In cases where the law does not allow otherwise, exclusive jurisdiction is granted to the competent courts of France.