Privacy Policy

The purpose of this Privacy Policy is to inform users of the website orizonex.com (hereinafter the "Website") of the conditions under which ORIZONEX TRADING collects, uses, stores and protects their personal data.

It is established in accordance with Regulation (EU) 2016/679 of 27 April 2016 (GDPR) and Law No. 78-17 of 6 January 1978, as amended, relating to information technology, data files and civil liberties.

This policy applies to all personal data processing carried out via the Website. It supplements the Legal Notice and the Terms of Use.

The data controller is:

• Company name: ORIZONEX TRADING
• Legal form: SASU
• Registered office: 9 Parc d'Activité de la Calarde, 95500 GONESSE, France
• SIREN: 102 496 023
• Legal representative: Mr Karim Ben Azouz, President
• Email (general contact): contact@orizonex.com

As of the date of this policy, ORIZONEX TRADING is not legally required to appoint a Data Protection Officer (DPO) within the meaning of Article 37 of the GDPR.

Any question relating to the protection of personal data may be addressed to:

• Privacy / personal data contact: dpo@orizonex.com
• Postal address: ORIZONEX TRADING — 9 Parc d'Activité de la Calarde, 95500 GONESSE, France

ORIZONEX TRADING undertakes to process personal data in accordance with the following principles: lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality and accountability (Article 5 of the GDPR).

Depending on the features used on the Website, ORIZONEX TRADING may collect the following categories of data:

• Identification and contact data: name, surname, company, job title, email address, country;
• Request-related data: nature of the need, message, product family, product description, quantities, frequency, incoterm, lead time, indicative budget;
• Browsing and technical data: IP address, browser type, operating system, pages viewed, timestamps, server logs;
• Preference data: chosen browsing language;
• Cookie consent data: choices expressed via the cookie banner.

ORIZONEX TRADING does not collect sensitive data within the meaning of Article 9 of the GDPR (racial origin, political opinions, health data, etc.), unless expressly and voluntarily provided by the user in a free text message — in which case processing will be strictly limited to handling the request.

Data is collected:

• Directly from you, when you complete a form (contact, quote request), write to us by email or interact with the Website;
• Automatically, during your browsing (technical logs, cookies/trackers);
• Indirectly, via third-party services integrated into the Website (e.g. Google Maps, Google Fonts), under the conditions specific to those services.

Purposes: ensure display of the Website, its security, error management, prevention of abuse and fraud, and storage of the chosen language.

Legal basis: Article 6(1)(f) GDPR — legitimate interest of ORIZONEX TRADING in operating a secure and functional website.

Data concerned: server logs, IP address, technical identifiers, language preference.

Purposes: receive, process, qualify and respond to your information or commercial contact request; manage preliminary commercial relationship follow-up.

Legal basis: Article 6(1)(b) GDPR — pre-contractual measures taken at your request; and/or Article 6(1)(f) GDPR — legitimate interest in responding to professional enquiries.

Data concerned: name, company, email, nature of the need, message.

Mandatory fields: fields marked as mandatory in the form are necessary to process your request. Without them, ORIZONEX TRADING may not be able to respond appropriately.

Purposes: analyse your supply requirement, prepare a commercial response, draft a proposal or quote, and manage commercial relationship follow-up.

Legal basis: Article 6(1)(b) GDPR — pre-contractual measures; Article 6(1)(f) GDPR — legitimate interest in developing B2B commercial activity.

Data concerned: professional contact details, company type, country, product family, detailed description, quantities, frequency, incoterm, lead time, indicative budget, additional information.

Optional fields: certain fields (indicative budget, incoterm, lead time) are optional, but their absence may limit the accuracy or speed of the commercial response.

The Website uses a consent management banner (vanilla-cookieconsent) and the following trackers:

Legal basis: Article 6(1)(f) GDPR (legitimate interest) for strictly necessary trackers; Article 6(1)(a) GDPR (consent) for any non-essential tracker activated subsequently.

ePrivacy compliance: in accordance with CNIL guidelines, non-essential cookies are placed only after consent via the banner.

Future changes: if ORIZONEX TRADING activates audience measurement cookies (Google Analytics, Matomo, etc.), advertising cookies or social network cookies, this policy will be updated and prior consent will be collected.

The Website integrates or loads the following third-party services:

• Google Maps (Google Ireland Limited / Google LLC) — map display on the contact page. May involve processing of IP address and technical data by Google. Policy: policies.google.com/privacy
• Google Fonts (Google Ireland Limited / Google LLC) — typographic fonts loaded dynamically via the Google CDN (fonts.googleapis.com / fonts.gstatic.com). This loading may involve processing of technical data (including IP address) by Google. Policy: policies.google.com/privacy

Legal basis: Article 6(1)(f) GDPR — legitimate interest in improving user experience, subject to applicable consent obligations for the relevant trackers.

Transfers outside the EU: certain providers (notably Google) may process data in the United States or other countries. See section 15.

If you refuse to provide certain mandatory data or if you exercise a right limiting processing:

• ORIZONEX TRADING may be unable to process your contact or quote request;
• Certain Website features may not function correctly (e.g. language storage);
• Refusal of non-essential cookies does not affect access to the main features of the Website.

Your data is accessible, within the limits of their duties and on a need-to-know basis, to:

• Authorised personnel of ORIZONEX TRADING;
• IONOS SE — Website and email hosting provider (processor, Art. 28 GDPR);
• Google (Google Ireland Limited / Google LLC) — mapping (Google Maps) and typographic fonts (Google Fonts via CDN), as separate data controllers for their respective services.

ORIZONEX TRADING does not sell your personal data. Data may be disclosed to administrative or judicial authorities where required by law.

Data collected via the forms is primarily hosted in Europe via IONOS SE.

However, certain providers integrated into the Website (notably Google) may process data outside the European Economic Area (EEA), particularly in the United States.

Where such transfers occur, ORIZONEX TRADING ensures that they are governed by appropriate safeguards within the meaning of Articles 44 to 49 of the GDPR, such as:

• An adequacy decision of the European Commission;
• Standard Contractual Clauses (SCCs);
• The EU-US Data Privacy Framework, where applicable.

Upon expiry of these periods, data is securely deleted or anonymised, unless a longer legal retention obligation applies.

ORIZONEX TRADING implements appropriate technical and organisational measures to protect your data against accidental or unlawful destruction, loss, alteration, disclosure or unauthorised access, including:

• Secure hosting with a recognised provider (IONOS);
• Restricted access to data for authorised personnel;
• Validation and sanitisation of data submitted via forms (server side);
• Anti-spam mechanisms (honeypot, rate limiting).

In the event of a data breach likely to result in a high risk to your rights, ORIZONEX TRADING will notify the CNIL and, where applicable, the data subjects in accordance with Articles 33 and 34 of the GDPR.

In accordance with the GDPR and the French Data Protection Act, you have the following rights:

• Right of access (Art. 15) — obtain confirmation of processing and a copy of your data;
• Right to rectification (Art. 16) — correct inaccurate or incomplete data;
• Right to erasure (Art. 17) — request deletion of your data, subject to legal retention obligations;
• Right to restriction (Art. 18) — request temporary suspension of processing;
• Right to object (Art. 21) — object to processing based on legitimate interest, including prospecting;
• Right to data portability (Art. 20) — receive your data in a structured format, where processing is automated and based on consent or a contract;
• Right to withdraw consent (Art. 7) — at any time, for processing based on consent, without affecting prior lawfulness;
• Right to define directives relating to the fate of your data after your death (France).

To exercise your rights, please send a request:

• By email: dpo@orizonex.com (subject: "Exercise of my GDPR rights")
• By post: ORIZONEX TRADING — 9 Parc d'Activité de la Calarde, 95500 GONESSE, France

Your request must specify the right you wish to exercise and, where necessary to prevent impersonation, be accompanied by a copy of an identity document.

ORIZONEX TRADING undertakes to respond within one (1) month of receipt. This period may be extended by a further two months in the case of a complex or numerous request, with prior notification.

If you consider, after contacting us, that your rights are not being respected, you may lodge a complaint with the competent supervisory authority:

• CNIL — Commission Nationale de l'Informatique et des Libertés
• 3 Place de Fontenoy — TSA 80715 — 75334 Paris Cedex 07
• Website: www.cnil.fr

ORIZONEX TRADING does not take any decision based solely on automated processing producing legal effects or similarly significant effects concerning you, within the meaning of Article 22 of the GDPR.

The Website is intended for a professional clientele. ORIZONEX TRADING does not knowingly collect personal data concerning minors under 16 years of age without the consent of the holder of parental responsibility. If you believe a minor has transmitted data to us, please contact us to request its deletion.

ORIZONEX TRADING may in the future implement new processing activities, including:

• Newsletter or commercial email campaigns;
• Audience measurement tools (analytics);
• CRM or sales management tool;
• Client area or document downloads;
• Online chat or appointment booking.

Each new processing activity will be subject to prior information and, where applicable, an update of this policy and collection of consent where required.

This policy may be amended at any time to reflect changes to the Website, processing activities or regulations. The date of the last update appears at the top of the page.

In the event of a material change, ORIZONEX TRADING may inform you by any appropriate means (banner on the Website, email if an ongoing relationship exists).

As of the date of this policy, information relating to cookies and trackers is included in this Privacy Policy, supplemented by the consent management banner displayed on the Website.

If ORIZONEX TRADING activates non-essential cookies (analytics, advertising, social networks), the publication of a separate, more detailed Cookie Policy is recommended, in addition to this policy.