Privacy Policy

ARTICLE 1: PREAMBLE

This privacy policy aims to inform users of the infrawire.fr website:

• On how their personal data is collected. Personal data is considered to be any information that can identify a user, such as: first and last names, age, postal address or email, location, IP address (non-exhaustive list);
• On the rights they have regarding this data;
• On the person responsible for processing the collected and processed personal data;
• On the recipients of this personal data;
• On the site's cookie policy.

This policy complements the legal notices and General Terms of Use available at the following address: https://infrawire.fr/terms and https://infrawire.fr/conditions.

ARTICLE 2: PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA

In accordance with Article 5 of European Regulation 2016/679 (GDPR), personal data are:

• Processed lawfully, fairly and transparently;
• Collected for specified, explicit and legitimate purposes, and not further processed in a manner incompatible with those purposes;
• Adequate, relevant and limited to what is necessary;
• Accurate and, where necessary, kept up to date. Inaccurate data are corrected or erased without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes;
• Processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing, loss, destruction or accidental damage, by appropriate technical and organizational measures.

Processing is lawful only if one of the following conditions is met:

• Explicit consent of the user for one or more purposes;
• Necessity for the performance of a contract or pre-contractual measures;
• Compliance with a legal obligation;
• Protection of vital interests of the user or another person;
• Performance of a task carried out in the public interest or in the exercise of official authority;
• Legitimate interest pursued by Infrawire Networks SAS or a third party, unless the fundamental rights and freedoms of the user prevail.

ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED

Article 3.1: Data collected

Personal data collected on infrawire.fr includes:

• Name, first name, email address, phone number;
• Connection information (IP, browser type, pages viewed);
• Information related to subscribed services (order history, preferences).

Purposes of collection and legal bases (GDPR):

• Contract performance : Customer account management, orders, billing and technical support (Article 6.1.b GDPR)
• Legal obligation : Retention of accounting and tax data (Article 6.1.c GDPR)
• Consent : Sending commercial information and newsletters (Article 6.1.a GDPR) - you can withdraw your consent at any time
• Legitimate interest : Service improvement, site security, fraud prevention (Article 6.1.f GDPR)

Article 3.2: Collection method

Data is collected:

• Automatically : via cookies, server logs and analytics (IP, browser type, pages visited, date and time of access)
• Via forms : during registration, contact request, purchase or subscription to a service.

Retention period: Personal data is retained for the following periods:

• Customer account data: duration of the contractual relationship + 3 years after the end of the contract (commercial prescription);
• Billing data: 10 years (legal accounting obligation);
• Navigation data (cookies): maximum 13 months (in accordance with CNIL recommendation);
• Contact data (forms): 3 years from the last contact.

After these periods, data is either deleted or irreversibly anonymized.

Article 3.3: Data hosting

The site is hosted by:

Article 3.4: Transmission of data to third parties

In accordance with GDPR, personal data may be transmitted to third parties only in the following cases:

• Contractual partners for service provision (hosts, payment providers, technical support services);
• Legal and regulatory obligations (judicial, tax, administrative authorities);
• With your explicit consent for specific purposes.

All our partners are subject to strict confidentiality and security obligations in accordance with GDPR. Data is never sold to third parties for commercial purposes.

Article 3.5: Cookies and trackers

The infrawire.fr website uses cookies and other trackers in accordance with the ePrivacy Directive and GDPR. Cookies are small text files placed on your device when visiting the site.

Types of cookies used:

• Strictly necessary cookies : essential for the site's operation (authentication, security)
• Performance cookies : to analyze site usage and improve user experience
• Functionality cookies : to remember your preferences (language, region)

You can configure, refuse or delete cookies at any time via your browser settings. However, refusing certain cookies may affect the site's operation.

ARTICLE 4: DATA CONTROLLER AND DATA PROTECTION OFFICER

Article 4.1: Data controller

Personal data is collected by:

Article 4.2: Data Protection Officer (DPO)

In case of non-compliance with your rights, you can file a complaint with the CNIL (National Commission on Informatics and Liberty) at the following address: https://www.cnil.fr

ARTICLE 5: USER RIGHTS

In accordance with GDPR, you have the following rights:

• Access, rectification, erasure of data;
• Limitation of processing, objection;
• Data portability;
• Right not to be subject to an automated decision;
• Right to determine the fate of data after your death;
• Right to file a complaint with the CNIL.

To exercise your rights:

The user may be asked to provide identification information to enable processing of their request.

ARTICLE 6: POLICY MODIFICATIONS

Infrawire Networks SAS reserves the right to modify this policy at any time to ensure compliance.

Modifications do not affect previous purchases, which remain subject to the policy in force at the time of the transaction.

The policy was published on November 23, 2025 and updated on November 23, 2025.