Confidentiality Charter

Who are we?

The TROPHY company, registered with the Versailles Trade and Companies Register under number 538 081 860, having its registered office at 1, Avenue Eiffel, 78420 Carrières-sur-Seine, is responsible for processing your personal data for the purposes listed in the table below.

TROPHY has appointed a Data Protection Officer (the law firm Ernst & Young) who can be contacted by email dpo@trophy-group.com or by post at the following address: SHARK HELMETS - DPO, 110, Route de la Valentine, 13011 Marseille.

Purposes & Legal basis

Purposes: Contact request management
Legal basis: Our legitimate interest (responding to your requests and getting to know you better)
Purposes: User account access management (secure access)
Legal basis: Our legitimate interest (ensure the security of the E-Protect-Air website and application)
Purposes: Management of INFINITY Offers, REFLEX Offers and/or e-Calling Service.
Legal basis: The performance of the contract between us or our legitimate interest (providing adequate customer service) for data that would exceed what is strictly necessary for the performance of contractual obligations
Purposes: Management of connected airbag and e-Calling Services and the E-Protect Application
Legal basis: The performance of the contract between us or our legitimate interest (providing adequate customer service) for data that would exceed what is strictly necessary for the performance of contractual obligations
Purposes: Management of the Stop & Go option
Legal basis: The performance of the contract between us
Purposes: Airbag Gilet inspection
Legal basis: The performance of the contract between us
Purposes: Management of withdrawals
Legal basis: Compliance with regulatory obligations
Purposes: Geolocation
Legal basis: Your consent. If you do not consent to this processing, we will not be able to provide the connected airbag or E-calling services.
Purposes: Management of legal warranties of conformity and hidden defects
Legal basis: Compliance with regulatory obligations
Purposes: Management of after-sales service and complaints
Legal basis: The performance of the contract between us or our legitimate interest (improving our offers and customer experience) for data that would exceed what is strictly necessary for the performance of contractual obligations
Purposes: Measuring traffic on the online sales site
Legal basis: Our legitimate interest (to manage and boost visits to our site) or your consent if required by law (depending on the type of cookie)
Purposes: Follow up on areas of interest via cookies
Legal basis: Your consent
Purposes: Sales prospecting activities
Legal basis: Our legitimate interest (to promote our offers) or your consent if required by law
Purposes: Management of a loyalty program and promotional operations (promotional games)
Legal basis: The performance of the contract between us or our legitimate interest (promote our offers) for data that would exceed what is strictly necessary for the performance of contractual obligations
Purposes: Statistical data processing
Legal basis: Our legitimate interest (improve our offers)
Purposes: Management of customer reviews and satisfaction surveys
Legal basis: Our legitimate interest (promote and improve our offers)

Purposes	Legal basis
Contact request management	Our legitimate interest (responding to your requests and getting to know you better)
User account access management (secure access)	Our legitimate interest (ensure the security of the E-Protect-Air website and application)
Management of INFINITY Offers, REFLEX Offers and/or e-Calling Service	The performance of the contract between us or our legitimate interest (providing adequate customer service) for data that would exceed what is strictly necessary for the performance of contractual obligations
Management of connected airbag and e-Calling Services and the E-Protect Application	The performance of the contract between us or our legitimate interest (providing adequate customer service) for data that would exceed what is strictly necessary for the performance of contractual obligations
Management of the Stop & Go option	The performance of the contract between us
Airbag Gilet inspection	The performance of the contract between us
Management of withdrawals	Compliance with regulatory obligations
Geolocation	Your consent If you do not consent to this processing, we will not be able to provide the connected airbag or E-calling services.
Management of legal warranties of conformity and hidden defects	Compliance with regulatory obligations
Management of after-sales service and complaints	The performance of the contract between us or our legitimate interest (improving our offers and customer experience) for data that would exceed what is strictly necessary for the performance of contractual obligations
Measuring traffic on the online sales site	Our legitimate interest (to manage and boost visits to our site) or your consent if required by law (depending on the type of cookie)
Follow up on areas of interest via cookies	Your consent
Sales prospecting activities	Our legitimate interest (to promote our offers) or your consent if required by law
Management of a loyalty program and promotional operations (promotional games)	The performance of the contract between us or our legitimate interest (promote our offers) for data that would exceed what is strictly necessary for the performance of contractual obligations
Statistical data processing	Our legitimate interest (improve our offers)
Management of customer reviews and satisfaction surveys	Our legitimate interest (promote and improve our offers)

TROPHY has set up a partnership with INTER MUTUELLE ASSISTANCE SERVICES (IMA), which handles e-Call emergency calls.

IMA records the calls, TROPHY does not have access to them. We invite you to read IMA's Data Protection Policy, which is appended to this document.

What data do we process?

TROPHY processes the following categories of personal data: identification data (airbag Gilet serial number, surname, first name, contact details, telephone number, etc.), data relating to the condition of the airbag Gilet (batteries, cartridge, etc.), data relating to your interests, as well as data relating to contracts and payments and, if you subscribe to the e-Calling Service, your geolocation data.

TROPHY collects information that is essential for the purposes described above. This information is marked with an asterisk on the form. If you do not fill in these mandatory fields, TROPHY will not be able to provide you with the relevant Service.

Personal data is collected directly by TROPHY from the persons concerned, or may have been transmitted to us by our commercial partners.

Who can access your personal data?

Your personal data is mainly communicated/accessible to TROPHY personnel in charge of sales and marketing, information systems security and the Heads of Finance and Legal affairs.

Outside TROPHY, your data will be shared with:

TROPHY's IT service providers (in charge of maintenance and IT hosting)
IMA, who is in charge of managing e-Call emergency calls, and its operational and technical subcontractors involved in handling emergency calls.
Sub-contractors involved in payment management
Companies who are part of the same group as TROPHY (2-RIDE Group)
Auditors involved in certification and/or labeling processes

Subcontractors acting on TROPHY's instructions will be required to implement appropriate protection measures.

If any of TROPHY's partners are located outside of the European Union, we will ensure that transfers are carried out in accordance with French regulatory requirements (e.g. implementation of contractual clauses adopted by the European Commission). You can contact TROPHY's Data Protection Officer to obtain further information on these subjects and a copy of the relevant documents.

How long do we keep your private data?

Personal data processed by TROPHY is stored in accordance with data protection regulations and for the legally prescribed periods. For example:

Data relating to prospective customers is kept for 3 years from the last commercial contact;
For the e-Calling Service, unless the airbag system is triggered by an impact, the e-Protect Application only stores the last 10 GPS points taken every 20 seconds.

What are your rights?

You have the right to request access to your personal data.
You have the right to ask for your personal data to be corrected.
You have the right to request that we restrict the processing of your personal data, (i) if you dispute the accuracy of your data for the period of time necessary for us to verify its accuracy, (ii) if you consider that we are processing your data unlawfully and you request that we restrict its use rather than delete it, (iii) if we no longer need your data for the purposes mentioned above, but it is still required for the establishment, exercise or defense of your legal rights, (iv) if you exercise your right to object to our processing of your data, for the duration of the verification as to whether the legitimate reasons we are pursuing prevail over yours.
You have the right to ask us to delete your personal data.
You have the right to exercise your right to object to the processing of your personal data for reasons relating to your personal situation.
You have the right to object, at any time and without justification, to commercial prospecting.
You have the right not to be subject to a decision based exclusively on automated processing that has produced legal effects concerning you or significantly affecting you.
You have the right to exercise your right to data portability, which gives you the right to obtain a copy of your data or transfer it to a third party in a structured and commonly used machine-readable format.
You have the right to withdraw your consent at any time where the processing of your data is based on that consent.
You also have the right to formulate directives concerning the conservation, deletion and disclosure of your personal data after your death.

These rights may be exercised at any time by sending an e-mail to dpo@trophy-group.com or by post to the following address: SHARK HELMETS - DPO, 110, Route de la Valentine, 13011 Marseille.
You may also - if you wish - lodge a complaint with the French Data Protection Authority – la Commission Nationale de l'Informatique et des Libertés (CNIL). Further information is available on its website www.cnil.fr.

APPENDIX – IMA DATA PROTECTION POLICY

Inter Mutuelles Assistance Services (IMA SERVICES), a simplified joint stock company with capital of 3,553,329 Euros, having its registered office at 118 avenue de Paris - CS 40 000 - 79 033 Niort Cedex 9, registered in the Niort Trade and Companies Register under number 430.336.552, in its capacity as Data Controller, collects the following data in connection with the processing of alerts:

data relating to the identification of the service beneficiary: identity and contact details of the person using the airbag vest, the make, model, type of power and registration of the vehicle;
location data: the place where the alert was triggered, previous positions to reconstruct the route taken before the alert was triggered, and subsequent positions for 2 hours in the event of a new alert, on the understanding that routes are not tracked;
time-stamping data and classification of the beneficiary's emergency situation.

These data are used:

receiving accident detection alerts, qualifying them and, if necessary, putting the beneficiary who is in an emergency situation in contact with the emergency services;
handling appeals, claims and disputes;

compiling statistics, technical studies and marketing analyses, in particular to optimize business processes, enhance customer experience by optimizing the customer’s pathway, provide offers better adapted to the market and monitor the quality of services provided;
operations relating to customer management, in particular relationship follow-up (e.g. satisfaction surveys, recording of calls);

implementation of anti-fraud measures. If an anomaly, inconsistency or alert is detected, a list of people considered to be a risk of fraud may be drawn up;
responding to official requests from a duly authorized public or judicial authority;
deployment of anti-corruption measures;
management of rights requests (access, opposition, etc.).

emergency services;
judicial authorities on their official request;
technical sub-contractors for IT administration and maintenance operations;
companies in the IMA Group acting as subcontractors for the above-mentioned purposes;
TROPHY for activity reporting purposes.

They may be transmitted outside the European Union following an event occurring outside this territory and/or accessed from countries outside the European Union as part of IT administration and maintenance operations.

Telephone conversations are recorded in order to build up factual elements that may be used in the prevention and resolution of disputes, litigation and pre-litigation.

These recordings can also be used for:

improving employee skills;
monitoring customer advice and the quality of the customer relationship;
protecting employees in the event of verbal aggression or incivility towards them;
experimentation with quality management and monitoring objectives, as well as conversation analysis using artificial intelligence techniques;
managing requests to exercise your rights;
the implementation of control systems, particularly in the fight against fraud and corruption.

Data is kept for the duration of the contractual relationship, plus any applicable statute of limitations. It is then rendered anonymous for statistical purposes.

Under the conditions laid down by law, the beneficiary has a right of access, correction, deletion, limitation, portability and opposition. They may exercise these rights, subject to providing proof of identity, by writing to the following address: IMA GIE - Legal Affairs Department – 118 avenue de Paris – 79000 Niort – dpo@ima.eu.

The beneficiary has the right to lodge a complaint with the competent personal data protection supervisory authority if they consider that the processing of their personal data constitutes a breach of the law.

Version CGU TRO-EPROTECT-230406-06