Politique de confidentialité

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us.

This privacy notice explains how we collect and use your personal data, during and after your relationship with us, in accordance with our obligations under data protection legislation. It also covers who we share it with and what rights you have with regards to your personal data and how you can exercise those rights.

Who we are - companies and websites within scope

For the purposes of the General Data Protection Regulation (“GDPR”) Comatec is the Data Controller. The scope also includes personal data that is collected through our websites, by telephone, through Live Chat and through any related social media applications. This means that we determine what data is collected, how this data is going to be used and how this data is protected.

If you have questions about how we process personal data, or would like to exercise your data subject rights, please use the information supplied in the Contact Us section below.

Collection of personal data

We collect personal data from you for one or more of the following purposes:

•  To fulfil a contract that we have entered into with you or with the entity (or organisation) that you represent. In these circumstances it may be your entity (or organisation), rather than yourself, that has provided us with your personal data
•   To initiate and complete commercial transactions with you, or the entity (or organisation) that you represent, for the purchase of products and/or services
•   To deliver product you have purchased directly or indirectly from us
•   To communicate with suppliers of goods and services
•  Keeping accounts and other business records
• To carry out marketing, electronic or otherwise
• Complying with legal or regulatory requirements including health and safety obligations
• Dealing with complaints or queries from our customers and our suppliers
•   Generating data analytics to monitor and improve the performance of our website
•   To ensure the security and safe operation of our websites and underlying business infrastructure
• To create and manage your account
• To answer your questions
• To examine your application to a job

Job Offers

Job offers are published on our website. This processing is carried out on the basis of our legitimate interest in recruiting staff for the needs of our business activities. The data is intended for the departments responsible for recruitment and will be retained for two years. If you do not wish your application to be kept in our CV database for this two-year period, please send us an email at rgpd@comatec.fr or a letter by post to the address mentioned above.

Technical and Cookie information

In addition, to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

• Technical information, including the IP (Internet Protocol) address used to connect your device to the Internet
• Your login information, browser type and version, cookies, time zone setting, browser plug-in types and version
• Operating system and platform
• Information about your visit, including the URL (Uniform Resource Locators) clickstream to, through and from our site

On What Legal Basis and For How Long Are My Personal Data Processed?
The processing of your personal data is based on various legal grounds, depending on how we use the data. Below, you will find the legal bases and retention periods that apply to our main data processing activities.

Legal Bases for Processing
The applicable legal bases include:

·        Contract: The processing of personal data is necessary for the performance of a contract to which you have consented.

·        Consent: You agree to the processing of your personal data through express consent (checkbox, click, etc.). You may withdraw your consent at any time.

·        Legitimate Interest: [Entity] has a commercial interest in processing your data, which is justified, balanced, and does not infringe on your privacy.

·        Legal Obligation: The processing of your personal data is required by a legal or regulatory provision.

In particular, with regard to contracts and legitimate interest: the legal basis of the contract is used when the contract is concluded directly with you. When the contract is concluded with the entity you represent, we rely on our legitimate interest in taking the necessary steps to perform the contract.

Retention Period for Your Data

We will retain your information only for as long as strictly necessary to meet our needs. This period is defined based on the needs of our services, our legal obligations, and any applicable statutory limitation periods. Regardless of the retention period, we ensure that your data is protected with appropriate security measures. For example, data required for managing your product and service orders are kept for 5 years from the end of our business relationship. They are retained for 10 years for accounting purposes.

Recipients of your data

The data collected is intended for the relevant internal departments when necessary for the performance of the aforementioned processing activities. This may include, for example, the accounting department for invoicing management, the human resources department for recruitment processes, the logistics and transportation departments for order delivery, or the sales administration department for order and complaint management.

Your data may also be accessed by our subcontractors (e.g., hosting providers, maintenance service providers, etc.) within the scope of their contractually defined responsibilities. Data sharing is carried out strictly on a "need-to-know" basis. Your data may also be disclosed in the context of business acquisitions or sales of companies or assets.

We implement the necessary safeguards to ensure that your personal information is protected and appropriately handled when shared with third parties.

International transfer

We are a global organisation and use third parties located in other countries to help us run our business. This includes countries outside the “EU” and to countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data.

Security measures

We will implement measures to protect your data, including appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those individuals, agents, contractors and other third parties who have a business need to know. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.

Do you have to provide your personal data to us?

You are never required to provide personal data to us, but you may need to do so when you enter into a contract for the provision of our services or products. We will not be able to provide our services or products unless you provide us with the personal data, we need to do so.
In addition, you will be required to provide certain personal data if you contact us to exercise your rights under GDPR.

Automated decision-making and Cookies

We may carry out automated decision-making when you use our website. The automated decision making involves providing content to you based on your online behaviour obtained using Cookies. If consent is given for Cookies which are more than those required for essential use of the website, we will be able to display content that is relevant to you.

You can adjust cookies through the cookie preference settings.

Our Lyra Collect Payment Module and Data Processing Activities for which Lyra Collect is the Controller

Payments for orders made through our website are processed by our payment service provider, Lyra Collect.

LYRA COLLECT is a simplified joint-stock company (SASU) with a share capital of €1,500,000, headquartered at 109 rue de l’Innovation, 31670 Labège, France, and registered with the Toulouse Trade and Companies Register under number 817 491 236.

As a licensed payment institution, Lyra Collect carries out personal data processing operations for which it acts as an independent data controller. These include:

·        Handling claims and disputes

·        Fulfilling its obligations regarding anti-money laundering and combating the financing of terrorism (AML/CFT)

·        Providing evidence of payment transactions and the execution of services

·        Preventing external fraud

·        Acquiring payment transactions

·        Maintaining records of payment operations and service execution

Depending on the payment method used, the following data may be collected: Connection data (IP address, logs, etc.), Banking data (IBAN, encrypted credit card number, expiration dates, transaction amounts),  Email address, Full name and address as provided on SEPA direct debit mandates.

Personal data is retained for the duration of the contract unless specific legal obligations require longer retention periods. In particular:

Data collected for AML/CFT purposes is retained for five (5) years after the end of the contractual relationship with the merchant, in accordance with Article L561-12 of the French Monetary and Financial Code

Data related to the management of payment accounts is retained for ten (10) years, pursuant to Article L123-22 of the French Commercial Code

Additionally, Lyra Collect may disclose personal data to official bodies, administrative authorities, or judicial authorities, particularly in connection with AML/CFT obligations. These processing activities are necessary for the performance of the contract and compliance with legal obligations to which Lyra Collect is subject.

Lyra Collect has appointed a Data Protection Officer (DPO), who can be contacted at dpo@lyra-collect.com. You may also exercise your rights by submitting a request via the dedicated page: https://www.lyra.com/gdpr/

Do we use your personal data for marketing?

Yes, we may use your personal data to carry out marketing. We will only contact people who want to receive marketing as well as for our own legitimate interests. If you object to marketing, whether electronic or otherwise, please let us know and we will stop contacting you for marketing. We may still need to contact you for the purposes of providing services and products.

Your rights as a data subject

As a data subject whose personal data we hold, you have certain rights. If you wish to exercise any of these rights, please use the information supplied in the Contact Us section below. To process your request, we will ask you to provide a valid form of identification for verification purposes. Your rights are as follows:

• The right to be informed
  As a Data Controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy notice/policy and any related communications we may send you.
• The right of access (also known as a ‘data subject access request’)
  You have the right to request a copy of the personal data we hold about you (or having it transferred to another organisation) free of charge.
• The right to rectification (the ‘right to erasure’)
  You have the right to ask us to rectify or correct any of your personal data you think is inaccurate. You also have the right to ask us to complete data you think is incomplete. This may be used with the right to restrict processing to make sure that incorrect/incomplete data is not processed until it is corrected/complete.
• The right to erasure (the ‘right to be forgotten’)
  You have the right to request that we erase/delete your personal data in certain circumstances, for example where no overriding legal basis or legitimate reason continues to exist for processing personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
• The right to restrict processing
  You have the right to ask us to stop processing your personal data. We will still hold the data but will not process it any further. This right is an alternative to the right to erasure.
• The right to data portability
  You have the right to request your set of personal data be transferred to another Data Controller or Processor, provided in a commonly used and machine-readable format. This right only applies to data you have given us, the original processing was on the basis of consent/explicit consent/fulfilment of a contractual obligation and the processing is by automated means (is held electronically).
• The right to object
  You have the right to object to our processing of your personal data where
  a) Processing is based on legitimate interest (including profiling);
  b) Processing is for the purpose of direct marketing; or
  c) Processing is for the purpose of a task carried out in the public interest.
• The right to withdraw consent
  In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law
• Right to human intervention
  If the personal data is being  used to make automated decisions about you as the data subject (e.g. profiling), to be told what logic the system uses to make those decisions and to be able to request human intervention to override any such automated decisions

Cookies consent management

We use cookies, which are small text files placed on your computer by websites that you visit, to make our website work properly, to monitor its usage and to display content that we believe will be relevant to you. If you register with us or if you continue to use our site, we may ask if we can collect additional data from you automatically through cookies or similar technology. You will be asked to agree to our use of them through our cookie consent tool. It is accessible on all pages at the bottom left. 

You can also block cookies by adjusting your browser settings. However, if you choose to block all cookies you may not be able to access all, or parts, of our site and some features will not work properly.

Contact us

Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to rgpd@comatec.fr

Alternatively, you can contact us at the following postal address for our registered office: COMATEC, ZI Lannolier, Bd François-Xavier Fafeur, 11000 Carcassonne - FRANCE.

Complaints

We have appointed a Data Protection Privacy Champion to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal data, please contact us. If you have any concerns about our use of your personal data, we would like the opportunity to respond to your concerns.  You can make a complaint to us using the contact details above.

You have the right to contact the Cnil if you are unhappy with our response to your concerns. The Cnil is the independent regulatory office dealing with the Data Protection Act 1978 and the General Data Protection Regulation across France. Cnil website: https://www.cnil.fr/fr/plaintes.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time; this policy was last updated on July 2025.