Policy on cookies and the protection of personal data2020-09-01T15:22:39+00:00



The site is published by SMART STRATEGY, a company with a capital of €10,000, registered in the Toulon Trade and Companies Register under number 821 151 883 00013, having its registered office at 1041 avenue de Draguignan 83130 La Garde, France (hereinafter referred to as “the Company”).
Browsing the website https://smartstrategygroup.net/ hereinafter referred to as the “Site” may cause cookies to be installed on your device.
A terminal is any computer, smartphone, tablet or video game console connected to the Internet.
A cookie is a small file that does not allow the user to be identified, but does record information about how a device navigates a website.
The data thus obtained are intended to facilitate subsequent navigation on the website, and are also intended to allow various measures of attendance.
Cookies used on the Site are stored by the Company or by third parties.
The Company only deposits cookies on the Site that are strictly necessary for navigation on the Site and allow the use of the main functionalities of the Site. In addition, the Company deposits feature cookies whose purpose is to optimize the operation of the Site and to adapt the presentation of the Site to the terminal you are using.

Other cookies not strictly necessary for browsing the Site are used:
– Google Analytics audience measurement
– Social network sharing buttons
– Display of sponsored content targeted on social networks
– Targeted advertising tracers

Cookies that are not strictly necessary can be disabled by following the instructions given in the “SETTING” section below.
Cookies strictly necessary to provide a service on the Site expressly requested by you do not require your consent. However, cookies that are not strictly necessary for browsing the Site require your consent. Until you have given your consent, these cookies cannot be placed or read on your device. You are informed by the appearance of a blindfold. You can withdraw your consent to store or read certain cookies on your device at any time.
The validity period of this consent is thirteen (13) months. At the end of this period, your consent will be obtained again.

Cookies are stored on your device for a maximum of thirteen (13) months. After this period, cookies are permanently deleted from these devices. This period is in no way extended in the event of a new visit to the site.
You may oppose cookies through an objection mechanism by sending a request to the following address: rgpd@alteor.com
In the event of the exercise of such a right, no data concerning you is collected.
You are informed that the refusal to install a cookie may prevent you from accessing certain services on the Site.


These analytical cookies are used by Google Analytics. They make it possible to know the use and performance of the Site, the volumes of visits to the Site and the use of its various contents, to establish statistics, in order to improve the functionalities and ergonomics of the Site.
Given the partner implementing these cookies, personal data may be transferred to countries outside the European Union, whose legislation in this area differs from that of the European Union. The Company shall implement all appropriate technical and organisational measures to ensure the security of personal data, and in particular that such data transfers are carried out under conditions and under guarantees designed to ensure data confidentiality and security.
Refusing or deleting such cookies does not affect your browsing on the Site. However, this may prevent the Company from ensuring optimal quality of the Site and its services. You can access more information, including how to disable analytical cookies, from the following link: https://support.google.com/analytics/answer/6004245?hl=frhttps://support.google.com/analytics/answer/6004245?hl=fr


Computer applications from third parties, such as Facebook or Twitter, are included on the Site. These allow you to share content from the Site with others or to share with them your views or comments about our Site or its content. In case of refusal to install such cookies, you will have to authenticate yourself during each sharing operation to the networks concerned.
However, you are informed that such an application button may allow the social network to track your browsing on the Site, solely because your account on the relevant social network is activated on your device during your browsing on the Site, even though you did not use the sharing button.
You are invited to consult the privacy policies of these social networks in order to learn about the purposes of use and the browsing data they may collect. These protection policies must allow you to make your choices on these social networks, in particular by setting up your user accounts. They are accessible from the links below:
– Facebook: https://fr-fr.facebook.com/policies/cookies/
– Twitter: https://twitter.com/privacy?lang=fr


The Company may process your browsing data when you browse the Site in order to provide you with advertising content tailored to your interests. These ads may be displayed on other sites on which you are browsing, including social networks.
The proposal of advertising content adapted to your interests may also be made by combining navigation data from your device collected on the Site or other sites published by the Company or its partners, with the data you may provide when using certain services on these sites.
The refusal of these advertising cookies has no impact on the navigation on the Site. In the event of refusal, the advertising content you receive is not adapted to your interests.


In order to refuse the installation of cookies that are not essential for browsing the Site, you can configure the settings of your Internet browser as follows:

– under Firefox: “Firefox/Preferences” tab. Click on “Privacy” and choose “Never” in “Accept third-party cookies”. You can also choose to keep cookies only until Firefox closes.

– under Safari: “Safari/Preferences” tab. Click on “Privacy” and choose “Always block” in “Cookies and website data”. At the end of the navigation you can also click on “Delete all website data”. You can also choose to activate the “do not follow me” function.

– under Edge: “Internet Options” tab, then “Privacy”, where you can set the Internet zone and limit cookie access by choosing the “High” privacy option, which blocks cookies with insufficient privacy policies and cookies that record information without user consent.

Please note, however, that the consideration of your consent is based on a cookie. Thus, if you delete all cookies stored on your device through your web browser, the Company will not be able to know that you have chosen this option.

Warning: if you systematically refuse to install all cookies on your device, including those strictly necessary for navigation, via the “block all cookies” options, your browsing on the Site may be limited, and access to certain services may be impossible.Pour plus d’informations, vous pouvez consulter le site de la CNIL via le lien suivant : https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.


  1. Data controller

The person responsible for processing personal data: ALTEOR, a simplified joint stock company with a capital of €1,000,000, registered in the Trade and Companies Register of Aix en Provence under number 438 790 842, having its registered office at 180 rue Louis Armand PAAP 13290 Aix en Provence, France (hereinafter referred to as “the Company”).

In the context of the use of the Site and the various services and functionalities offered on it, the Company collects and processes personal data concerning you in accordance with Act No. 78-17 of 6 January 1978 as amended and EU Regulation 2016/679 of 27 April 2016.

The Company therefore processes personal data within the meaning of the aforementioned Law and Regulation.

As such, the Company is responsible for the processing of personal data collected from you during an application.

  1. Data collected and purposes

Through a form, the Company collects data relating to your surname, first name, title and company.

The information of these data is mandatory so that the Company can edit and send you one of the commercial information identifying you by email.

However, the provision of this data is not mandatory and is at your own discretion. In addition, and if you expressly consent, the Company may, on the basis of this information, carry out commercial prospecting operations corresponding to you under the conditions of Article 4 below.

  1. Legal basis of the processing operation

The data will be collected and processed in a fair and lawful manner, and will be used for the performance of the services offered by the Application.

The legal basis for the collection of the User’s personal data is Article 6, paragraph 1, point a) of EU Regulation 2016/679.

Thus, data are collected and processed according to the methods described in this data protection policy, insofar as you consent to it.

  1. Commercial prospecting

You may consent to or object to the use of your email address, at the time you provide your data, in order for the Company to communicate to you by email, its newsletter, promotional offers, its sales department, its advertising.

You can also oppose this prospecting at any time via the link provided for this purpose in all emails you receive.

  1. Destinataire des données

The Company is the recipient of all data collected and processed. Only duly authorized personnel of the Company may, if necessary, become aware of it.

The Company’s subcontracted IT service providers may have access to the data during their maintenance operations, but may under no circumstances perform any other data processing operation, such as modification or use of the data.

The Company may also use subcontractors for its trade missions.

  1. Subcontracting of processing

In the context of the data processing operations carried out, the Company uses subcontractors who are:

– OVH, which hosts the Site and all personal data, and which is located at 2 rue Kellermann – 59100 Roubaix – France

– The EXPRIMER Company, which ensures the maintenance of the Site, located at 180 rue Louis Armand, 13290 Aix en Provence

The Company guarantees that its subcontractors host the data within the European Union and provide sufficient guarantees as to the implementation of appropriate technical and organisational measures so that the processing complies with the requirements of EU Regulation 2016/679 and the Data Protection Act.

In any event, any subcontracting carried out by the Company shall be in strict compliance with this document. Consequently, the Company guarantees that its subcontractors, in particular those with a commercial mission, do not in any way exceed the processing methods defined in this document.

The subcontractor may itself be authorised to subcontract all or part of its operations subject to strict compliance with the provisions of Article 28 of EU Regulation 2016/679 and this document.

Notwithstanding the above, as the controller, the Company remains your sole contact.

  1. Commitments of the Company

The Company undertakes to preserve the strict confidentiality of the personal data collected from you and to take all necessary and sufficient measures to preserve the security of the personal data collected.

The Company undertakes to do the same with the recipients of the data.

The Company undertakes to give access to the processed data only to the duly authorised persons of its staff, and of the staff of its subcontractors mentioned above.

The Company undertakes not to use the data collected for purposes other than those specified in this document, and in particular not to transfer, transfer or make available in any way personal data to third parties, subject to what is expressly provided for in this confidentiality and data protection policy.

The Company undertakes that all recipients and subcontractors mentioned in this document will strictly comply with its terms and conditions.

  1. Rights of access, opposition, limitation, deletion and rectification of data

In accordance with the regulations in force, you have the right to access, rectify, limit and oppose the processing of your data and their use for prospecting purposes. You also have the right to withdraw your consent at any time, without this withdrawal affecting the lawfulness of the processing operations carried out prior to this withdrawal.

To exercise these rights, you must write to the Company’s address, specifying in the subject line of your letter or e-mail that it is a request for information or a complaint relating to your personal data, and provide you with proof that your request has been received.

Any such request should be addressed to the following address:

– By email: rgpd@alteor.com

– By post: Alteor, 180 rue Louis Armand, 13290 Aix en Provence

All requests will be accompanied by a copy of your identity document in order to avoid any fraud and/or illegal access to your data.

  1. Right to data portability

You have a right to the portability of your data, which must be returned to you by the Company in a structured, commonly used and machine-readable format, if you so request.

Any such request must be accompanied by a copy of your identity document and sent to the following address:

– By email: rgpd@alteor.com

– By post: Alteor, 180 rue Louis Armand, 13290 Aix en Provence

  1. Right to formulate advance instructions

In accordance with the regulations in force, you may formulate advance instructions on the use of your data after your death.

You can communicate these instructions, with a copy of your identity document, to the following address:

– By email: rgpd@alteor.com

– By post: Alteor, 180 rue Louis Armand, 13290 Aix en Provence

  1. Right to file a complaint with the CNIL

You are informed of your right to have recourse to the CNIL in the event of non-compliance with legal and regulatory provisions on the part of the Company in the management of your personal data.

To do so, you can contact the CNIL from the following link: https://www.cnil.fr/fr/plaintes

12. Data retention and archives duration

These data are filed by the Company for a period not exceeding three (3) years from their collection.

In the event that you have consented to the Company’s commercial prospecting, your data will be kept for a period of three (3) years from the date of collection or the last contact made by you (for example, a request for documentation or a click on a hypertext link contained in an email constitutes a contact made by you. However, the opening of an email cannot be considered as a contact from you). At the end of this three (3) year period, the Company may contact you to find out if you wish to continue to receive commercial solicitations. In the absence of a positive and explicit answer from you, the data will be deleted.

It is also recalled that the storage period for cookies is thirteen (13) months without a new visit to the site extending the duration.

In addition, the Company may retain anonymous or anonymized data in an irreversible process for an unlimited period of time for statistical reprocessing purposes. Given the anonymous nature of these data, they are not considered as personal data within the meaning of EU Regulation 2016/679.

In the event of exercise of the right of access or rectification, data relating to identity documents shall be kept for the period provided for in Article 9 of the Code of Criminal Procedure, namely one (1) year.

In the event of exercise of the right of objection, data relating to identity documents may be archived during the limitation period provided for in Article 8 of the Code of Criminal Procedure, i.e. three (3) years.

In the event that you exercise your right to object to receiving commercial prospecting, the data necessary to take into account the exercise of your right, such as your e-mail address, is kept for three (3) years from the exercise of your right and may not be used for any other purpose.