سياسة الخصوصية

PREAMBLE

The protection of your personal data is a priority for the Chabé Group. As a provider of premium transportation services operating internationally, Chabé is committed to processing your personal data with the utmost care, in strict compliance with the General Data Protection Regulation (GDPR – EU Regulation 2016/679) and the French Data Protection Act of January 6, 1978, as amended.

The purpose of this Personal Data and Cookies Management Policy is to inform you transparently about the nature of the data collected when you browse the website www.chabe.com, the purposes of processing, the conditions under which the data is retained, and your rights regarding such data.

This policy applies to all users of the website www.chabe.com, regardless of their geographical location.

1. IDENTITY OF THE DATA CONTROLLER

The controller of your personal data is:

CHABÉ – SAS with a share capital of €186,921
RCS Nanterre 314 613 720
VAT number FR35314613720
Registered office: 91-99 Avenue Jules Quentin, 92000 Nanterre, France
Phone: +33 1 41 20 95 10

Data Protection Officer (DPO)
For any questions relating to the management of your personal data, you may contact the Chabé Group’s Data Protection Officer:

• By post: SAS Chabé – For the attention of the DPO – 91-99 Avenue Jules Quentin – 92000 Nanterre, France
• By email: dpo@chabe.com

2. PROCESSING OF YOUR PERSONAL DATA

As data controller, Chabé undertakes to ensure that the collection and processing of your data are carried out in a clear, lawful, and transparent manner, in accordance with the GDPR and applicable regulations.

2.1 Our Commitments

Chabé ensures compliance with the following fundamental principles:

• Data minimization: only data strictly necessary for the intended purposes are collected.
• Accuracy: reasonable measures are taken to ensure that your data are kept up to date and corrected if necessary.
• Security: appropriate technical and organizational measures are implemented to protect your information.

2.2 Data Processed and Purposes

As part of our activities, we process categories of data for specific purposes:

• Management of requests and customer relationship: We process your identification and contact data to respond to your requests and ensure follow-up. This processing is based on Chabé’s legitimate interest in providing high-quality service (Art. 6.1.f GDPR).
• Information and communication: Subject to your consent (Art. 6.1.a GDPR), we use your contact details to send you communications relating to the Group’s news and services. You may withdraw your consent at any time.

2.3 Data Retention

Your personal data are retained only for the duration necessary for the purposes for which they were collected, in compliance with statutory limitation periods.

As a general rule, data relating to prospecting and customer relationships are retained for a maximum period of three (3) years from the last active contact or the end of the contractual relationship, after which they are deleted or archived in accordance with legal obligations.

2.4 Cookies and Browsing Data

Data collected: IP address, cookie identifiers, pages visited, browsing duration, browser type, operating system, browser language, traffic source.

Purpose: To ensure the proper technical functioning of the website, measure audience, and analyze browsing behavior in order to improve user experience and content.

Legal basis: User consent for non-essential cookies (Art. 6.1.a GDPR); Chabé’s legitimate interest for strictly necessary cookies (Art. 6.1.f GDPR).

Retention period: Varies depending on the type of cookie (see section 4 below).

3. FUNDAMENTAL PRINCIPLES APPLIED BY CHABÉ

In managing your personal data, Chabé undertakes to comply with the principles set out in Article 5 of the GDPR:

• Lawfulness, fairness and transparency: your data are collected on a valid legal basis and you are clearly informed of processing conditions.
• Purpose limitation: your data are collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes.
• Data minimization: only data strictly necessary for the intended purposes are collected.
• Accuracy: Chabé ensures your data are kept up to date and that inaccurate data are rectified or deleted without delay.
• Storage limitation: your data are not retained beyond what is necessary.
• Integrity and confidentiality: your data are processed securely to prevent unauthorized access, loss, or accidental destruction.

4. COOKIE MANAGEMENT POLICY

4.1 What is a Cookie?

A cookie is a small text file placed on your device (computer, tablet, smartphone) when you visit a website. It enables the website to store information about your browsing and improve your user experience during future visits.

4.2 Cookies Used on www.chabe.com

Strictly Necessary Cookies
These cookies are essential for the proper functioning of the website and cannot be disabled. They do not collect personal data for marketing purposes and are placed without prior consent.

Analytics Cookies
These cookies allow us to measure website traffic and analyze browsing behavior to improve our content and services. They are only placed with your consent.

Functional Cookies
These cookies enhance website functionality and personalization. They are only placed with your consent.

4.3 Managing Your Cookie Preferences

Upon your first visit to www.chabe.com, a cookie banner is displayed allowing you to accept or refuse different categories of cookies, except strictly necessary ones.

You can modify your preferences at any time via the cookie management tool available at the bottom of each page or through your browser settings:

• Google Chrome: Settings > Privacy and security > Cookies
• Mozilla Firefox: Options > Privacy & Security > Cookies
• Safari: Preferences > Privacy > Cookies
• Microsoft Edge: Settings > Privacy, search, and services > Cookies

Refusing certain cookies may affect your browsing experience and limit some website functionalities.

5. PROCESSORS AND DATA RECIPIENTS

As part of its activities, Chabé may engage third-party service providers acting as data processors within the meaning of the GDPR. These processors only access personal data to the extent strictly necessary for the performance of their tasks and are bound by contractual obligations of confidentiality and security (Art. 28 GDPR).

Main categories of processors:

• Website hosting provider: Infomaniak Network SA (Switzerland) – servers hosted in Europe.
• Analytics tool: Matomo (self-hosted) – anonymized data, hosted in Europe.
• Form protection: Google LLC (reCAPTCHA).
• Embedded multimedia content: Google LLC / YouTube.

Chabé does not sell, rent, or transfer personal data to third parties for commercial purposes.

6. DATA TRANSFERS OUTSIDE THE EUROPEAN UNION

Certain tools used on www.chabe.com, notably YouTube, are operated by companies whose servers may be located outside the EU, particularly in the United States.

Matomo analytics is hosted in Europe and does not involve data transfers outside the EU.

Transfers relating to YouTube and Google reCAPTCHA are governed by appropriate safeguards in accordance with Chapter V of the GDPR, including Standard Contractual Clauses and Google’s participation in the EU-US Data Privacy Framework.

Chabé ensures that all third-party providers offer sufficient guarantees regarding data protection.

7. DATA SECURITY

Chabé implements appropriate technical and organizational measures to ensure the security, integrity, and confidentiality of your personal data, including:

• Encryption of data in transit via HTTPS (TLS);
• Restricted access to authorized personnel only;
• Regular backup procedures;
• Selection of a secure hosting provider (Infomaniak Network SA).

In the event of a data breach likely to result in a risk to your rights and freedoms, Chabé will notify the CNIL within 72 hours and inform you where required.

8. YOUR RIGHTS

In accordance with the GDPR and applicable law, you have the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to object (Art. 21 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to withdraw consent at any time

How to exercise your rights

• By post: SAS Chabé – For the attention of the DPO – 91-99 Avenue Jules Quentin – 92000 Nanterre, France
• By email: dpo@chabe.com

Your request must include your name and may require proof of identity. Chabé will respond within one month, extendable by two months in complex cases.

Right to lodge a complaint

If you believe your rights are not respected, you may lodge a complaint with the competent supervisory authority. Chabé designates the Commission Nationale de l’Informatique et des Libertés as its lead authority:

CNIL
3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07
www.cnil.fr

9. UPDATES TO THIS POLICY

This Personal Data and Cookies Management Policy may be updated at any time, particularly to reflect regulatory developments or changes in Chabé’s data processing practices.

Any substantial modification will be notified via a visible notice on www.chabe.com.

Last update: April 2026 – V1.2