Privacy Policy

1. Introduction

THE PACKENGERS is a French company with subsidiaries in the United States, the United Kingdom, and the European Union (EU).

THE PACKENGERS places a high value on protecting its users' privacy. This policy will help you understand how we collect and process personal information of people who visit our website or use our facilities and online services. Our policy was designed and created to ensure THE PACKENGERS' affiliates, not only our commitment but also the fulfillment of our obligation to respect and exceed existing privacy protection standards.

We reserve the right to modify this policy at any time. To ensure you are aware of the latest changes, we encourage you to frequently visit this site. If THE PACKENGERS decides to use personal data contained in a file in a way significantly different from that stated at the time of initial data collection, the user or users will be quickly informed by email. Users will have the opportunity to allow or disallow their data to be used in this different manner.

This policy applies to THE PACKENGERS and governs data collection and usage by us. By using our site, you consent to the data collection practices described in this policy. Please note that this policy does not govern the collection and use of data by companies that THE PACKENGERS does not control, nor by individuals not employed or managed by us. If you visit a website mentioned or linked by us, ensure you review its privacy policy before providing information. It is highly recommended that you review the privacy policies of any site you choose to use or frequent, to better understand how websites collect, use, and share gathered information.

2. This policy informs you about the following:

i. What personally identifiable information is collected from you through our website;

ii. The purposes for which we collect personally identifiable information and the legal basis for this collection;

iii. How we use the information collected and with whom it may be shared;

iv. Choices available to you regarding the use of your data; and v. security procedures in place to protect against misuse of your information.

vi. To whom do we transfer the data you entrust us with?

vii. Right to file a complaint viii. How and where to exercise your rights

3. The information we collect:

• You are always free to provide or withhold personally identifiable information. However, if you choose not to do so, we reserve the right not to register you as a user or provide you with products or services. This website collects various types of information, such as:

• Information voluntarily provided, which may include your name, address, email address, billing information, and/or credit card information, etc., used when you purchase products and/or services and to provide the services you requested.

• Information automatically collected when visiting our website, which may include cookies, third-party tracking technologies, and server logs.

Rest assured that this site only collects personal information knowingly and voluntarily provided by you through surveys, completed membership forms, and emails. This site intends to use personal information solely for the purpose for which it was requested, and for any other specifically provided use mentioned in this policy.

4. Specific data collected

• Connection and navigation data - When you visit the website, THEPACKENGERS records your IP address and data related to the mobile device you use.

• Customer data - When you place an order, you must register on the website as per the terms set out in our general sales conditions.

For this registration, THE PACKENGERS collects the following personal data:

• Email

• Full Name

• Phone Number

- Data collected when placing an order: When placing an order on the website, THE PACKENGERS collects the following data:

• Address,

• First Name,

• Last Name,

• Email,

• Phone Number

As part of the service payment, THE PACKENGERS also collects financial data related to your bank account and/or credit card.

5. Purposes

You have consented to this processing for the following purposes:

• Access, operation, and use of the platform;

• Management of your orders, including tracking and billing; • Payment service operation;

• Management of after-sales service and support;

• Verification, identification, and authentication of data you provide us;

• Verification of your identity;

• Sending personalized or non-personalized commercial and advertising information

• Ads personalized or not;

• Data analysis, audits, and identification of usage trends;

• Conducting marketing and statistical analyses;

• Monitoring and preventing fraud and malware, and managing security incidents;

• Dispute processing;

6. Why do we collect information?

We collect your data for various reasons:

• To better understand your needs and provide you with the services you requested;

• To respond to our legitimate interest in improving our services and products;

• To send you promotional emails containing information we think may interest you when we have your consent for this; to contact you to answer surveys or participate in market studies when we have your consent to do so;

• To customize our website according to your online behavior and personal preferences.

7. How long do we keep data?

According to existing data protection regulations, we are required to keep this data for a defined and limited period. When we determine that the data we hold is no longer necessary for the purposes for which it was collected, we delete or anonymize it.

Customer data is retained during the commercial relationship. They may be stored for prospecting purposes for a maximum of 3 years from the end of the commercial relationship.

Information stored on users' terminals (e.g., cookies) or any element used to identify users and allowing user retrievals is retained for no longer than 6 months. Data used for newsletters are retained until the user unsubscribes.

Every 13 months, we seek visitors' consent to our website for cookie processing.

The duration of retention of this information will be determined based on the following criteria:

• how long your personal information remains relevant;

• how long it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations;

• any statutory periods during which claims can be made;

• any statutory retention period recommended by regulators, professional bodies, or associations;

• the type of contract we have with you, the existence of your consent, and our legitimate interest in retaining this information as stated in this policy.

8. Use of collected information

THE PACKENGERS does not sell or lease its customer lists and/or names to third parties. THE PACKENGERS may collect and use personal information to facilitate the operation of its website and ensure the provision of the services you need and request. Sometimes, we may find it necessary to use personally identifiable information to keep you informedabout other products and/or services which may be offered by THE PACKENGERS. THE PACKENGERS may also contact you to complete surveys and/or research questionnairesrelated to your opinion on current or potential services that may be offered.

9. Disclosure of information

THE PACKENGERS may not use or disclose the information you provide, except in the following circumstances:

⚬ If it is necessary to provide the services or products you requested;

⚬ If you have consented;

⚬ Together with other information such that your identity cannot be reasonably determined;

⚬ If required by law, or in response to a subpoena or search warrant;

⚬ To external auditors who have agreed to keep the information confidential

⚬ If necessary to comply with the service's terms and conditions;

9. Non-commercial purposes

THE PACKENGERS greatly respects your privacy. We retain your data and reserve the right to contact you if necessary for non-commercial purposes (such as bug alerts, security breaches,account issues, and/or changes to THE PACKENGERS products and services). In certain circumstances, we may use our website, newspapers, or other public means topublish a notice.

10. Children under 13

THE PACKENGERS website is not intended for children under thirteen (13) in the United States and under fifteen (15) in the European Union, and does not knowingly collect personal identifiable information from them. If such information is inadvertently collected on persons under thirteen (13) in the United States and fifteen (15) in the European Union, we will promptly take the necessary measures to ensure that such information is deleted from our system's database or alternatively obtain verifiable parental consent for the use and retention of such information. Any person under thirteen (13) in the United States and fifteen (15) in the European Union must seek and obtain their parent or guardian's permission to use this website.

11. Unsubscribe or Opt-out

All users and visitors to our website have the option to discontinue receiving communications from us by email or newsletters. To terminate your subscription or unsubscribe from our website, please send an email indicating that you would like to unsubscribe from the services. If you wish to unsubscribe or opt-out from a third-party website, you must go to that specific website to unsubscribe or opt-out. THE PACKENGERS will adhere to this policy with respect to any personal information previously collected.

12. Links to other websites

Our site contains links to affiliate and other websites. THE PACKENGERS does not claim nor accept responsibility for the policies, practices, and/or procedures of these other websites. Therefore, we encourage all users and visitors to be aware when they leave our website and read the privacy statements of each website that collects personally identifiable information. This privacy policy agreement applies solely and exclusively to information collected by our website.

13. Transfers outside the European Union

The data you entrust us with is subject to transfers outside the European Union, hereafter " EU". In this context, THE PACKENGERS undertakes to comply with the provisions of the General Data Protection Regulation "GDPR" regarding transfers of data outside the EU. According to the GDPR, in the event of a transfer of personal data to a country outside the EU, consideration is given to whether the country belongs to the list of countries offering a sufficient level of guarantee, including the possibility of including standard contractual clauses in data transfer contracts outside the EU, or even binding corporate rules called "BCR".

14. Security

THE PACKENGERS takes precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Whenever we collect sensitive information (e.g., credit card data), such data is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser or looking for "https" at the beginning of the address of the web page. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (e.g., billing or customer service) are granted access to personally identifiable information. The computers and servers in which we store personally identifiable information are kept in a secure environment to avoid any loss, misuse, unauthorized access, disclosure, alteration, or destruction of the user's personal information under our control.

The company also employs SSL (Secure Socket Layer) protocol for authentication and private communications, enhancing users' trust in the internet and the use of the website by providing a simple and secure way to communicate credit card and personal information. The website is also secured by VeriSign.

15. Acceptance of terms

By using this website, you accept the terms and conditions stipulated in the privacy policy agreement. If you do not agree with our terms, you should refrain from using our sites. Furthermore, continuing to use our website after the posting of any updates or changes to our terms means that you accept those changes.

16. Exercise your rights

According to applicable personal data regulations, you have the following rights:

i. Right to information

You can learn about the personal data THE PACKENGERS processes about you. To this end, we provide users of our services with information that meets regulatory requirements,when we collect their personal data on our data collection documents.

ii. Right of access

If you wish to access your data, you can submit your request to us. We will respond promptly, and no later than within one month from receiving your request. If we have difficulty responding to your request within this timeframe, it may take an additional 2 months.

iii. Right to Rectification

If your personal data is inaccurate, you can ask us to rectify it. Likewise, if we have transmitted it to a third party, we will also forward the requested rectification to that third party.

iii. Right to Object

In certain cases, you can object to the use of your personal data. We will review your objection request and determine if processing your personal data causes you undue harm, and if this harm obliges us to cease it. Generally, you cannot object to the processing of your personal data if:

⚬ We have a legal obligation to do so o The processing is necessary for the execution of a contract between you and us.

iv. Right to Restrict Processing

You can contact us to obtain the restriction of our use of your personal data if:

⚬ You believe your personal data is inaccurate;

⚬ We are processing your data in an inaccurate manner;

⚬ We no longer have a reason to keep the data, but you want us to retain it for other purposes;

⚬ You have objected to the use of your data;

⚬ Based on our legitimate interests.

v. Right to Portability

You can ask us to transfer your personal data either to you directly or to an organization.

vi. Right to Erasure

With regards to the use of the personal data you entrust to us, we are required to retain it for a defined period to comply with applicable laws and regulations. However, this right can only be validly exercised at the end of the applicable legal and/or regulatory periods. If no legal or regulatory period is applicable, the right to erasure can be exercised if you withdraw your consent. To exercise these rights, contact us directly. For security reasons and to prevent fraudulent requests, this request must be accompanied by proof of your identity.

15. Automated Processing

THE PACKENGERS does not perform automated processing of personal data.

16. Exercising Your Rights?

If you wish to exercise your rights, you can send a written request to the Data Protection Officer (DPO) at the following email address: dpo@thepackengers.com.

You can send us your request as precisely as possible. Ideally, you should send us a copy of your ID to confirm your identity. If your request is compliant, we will send you a response within one month. In case of refusal, a reasoned response will be sent to you as soon as possible.

17. Right to File a Complaint.

If you are not satisfied with our response, you can directly address a complaint to us. If you are not satisfied with our response, you can contact the supervisory authority in your country. In France, you can contact the National Commission on Informatics and Liberty (CNIL) - 3 place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 www.cnil.fr

18. Updating this Privacy Policy

THE PACKENGERS reserves the right to modify this privacy policy at any time. In case of modification, THE PACKENGERS commits to publish the new version on the website and inform you by email. If you disagree with the new formulation of the Privacy Policy, you retain the right to request the deletion of all personal Data concerning you.