1.    WHO ARE WE?

The e-vadea.fr website (the “Site”) belongs to and is operated by SPIE CityNetworks (the “Company”).
Please refer to the Legal Notices page for information about the Company, including the identity and contact details of the persons in charge of the Site.
The Company is responsible for the processing of personal data collected on the Website.
The Company is the independent European leader in multi-technical services in the energy and communications fields.
In this privacy policy, “we”, “us” or “our” refer to the Company. “You” and “your” refer to users of the Site.
In this privacy policy (the “Privacy Policy”), “Personal Data” is information about you, which may be used to personally identify you (directly or indirectly).


This Privacy Policy:
•    Describes how we collect, use and otherwise manage the Personal Data you provide to us, made available or collected from you when you use our Site.
•    Explains the circumstances in which we transfer it to third parties; and
•    Explains the rights you have in relation to such Personal Data.
You should read our Privacy Policy in the same way as any other legal notices or conditions available on other pages of our Site.

3.1.    Personal Data We Collect

Types of Personal Data we may collect about you, depending on how you use our Site:
-    When creating your customer space:
o    Email address

-    When you fill in information within your customer area:
o    Your first and last name;
o    Your date of birth;
o    Your postal address including the following information: street number, street name, postal code, city, country;
o    Your email address;
o    Your mobile phone number;
o    Your home phone number (optional);
o    Your bank details.

-    When you place an order on the Site:
o    Your bank details (credit card or bank account details);

-    When making a contact request:
o    Your email address;
o    Any Personal Data disclosed.

-    When you browse the Site:
o    The type of browser used;
o    The number of pages viewed;
o    The exact browsing path that a visitor takes on the site;
o    Your IP address.

3.2.    On what legal bases and for what purposes do we use the Personal Data we collect?

In accordance with the applicable regulations on the protection of Personal Data, we only collect Personal Data when we can process it on a lawful basis.
The Personal Data is collected either:
(i)    on the basis of your consent,
(ii)    in our legitimate interest,
(iii)    in order to perform a contract with you or pre-contractual measures taken at your request,
(iv)    in order to fulfil our legal obligations.
We collect Personal Data with your consent for the following purposes:
•    Manage your requests and questions following a contact request: We use your Personal Data to provide you with the information you request;
•    Use a certain number of cookies. For more information about cookies, you can consult the Cookie Policy.
When we collect Personal Data with your consent, you can withdraw it at any time by contacting us via: rgpd.citynetworks@spie.com.

(i)    We collect Personal Data based on our legitimate interest for the following purposes:
•    To defend our interests in the event of litigation or legal action;
•    To compile statistics and better understand your preferences and interests;
•    To manage the Site's cyber-security;
•    To prevent fraudulent actions to ensure the security of our assets and contents.

(ii)    We collect Personal Data on the basis of the performance of a contract with you or pre-contractual measures taken at your request for the following purposes:
•    Creating your customer space then managing it;
•    Delivering badges to you for our terminals;
•    Allowing you to access our offers;
•    Allowing you to have access to your usage.

(iii)    We may also need to retain your Personal Data where we are required to do so by law or in order to enforce our rights under the law.


Certain features of our Site require that we cooperate with third parties and provide them with your Personal Data. We have identified these third parties and have taken the necessary steps to ensure that your Personal Data is properly protected in connection with this disclosure. Further information on how we process your Personal Data on our Site in conjunction with third parties is set out below:
•    Our service providers, for example: hosting, security and maintenance providers of the Site;
•    Our subcontractors;
•    Our accountants, auditors, lawyers or similar advisers where we ask them to provide us with professional advice;
•    Any other third party if we are required to disclose or share your Personal Data in order to comply with a legal obligation;
•    Any other third party for the purpose of acting in accordance with the decisions of a court, tribunal, administrative authority or governmental body, for example, to comply with a search warrant or a court order;
•    Investors and any other relevant third parties in the event of an actual or potential sale or transaction related to the Company.


The recipients of the Personal Data are entirely located within the European Union.


We keep your Personal Data for as long as necessary to fulfil the purpose or purposes for which it was collected. Nevertheless, we may find ourselves obliged to keep certain Personal Data for a longer period, taking into account various factors such as:
•    The legal obligation, in accordance with applicable law, to keep data for a specified period of time;
•    The statute of limitations and foreclosure under applicable law;
•    (Potential) disputes; and
•    Guidelines issued by the competent data protection authorities.
As long as we process your Personal Data, we will ensure that it is processed in accordance with this Privacy Policy. We will securely delete your data once we no longer need it.


Our Site is hosted on servers in the EEA. We use appropriate technical and organisational measures to ensure protection of your Personal Data and guard it against unauthorised access. Storage of data on secure computers in a certified and locked data centre is encrypted where possible. We conduct regular reviews of our security policies and procedures to ensure our systems are secure and protected. However, insofar as the transmission of data via the Internet is not completely secure, we cannot guarantee the security of your data transmitted to our Site.


We acknowledge that the information you provide to us may be confidential. We do not sell, rent, distribute or market your Personal Data to third parties, but we may share your Personal Data with our service providers for the purposes set out in this Privacy Policy. We will respect and protect the privacy of your data in accordance with our Privacy Policy and applicable law.


In accordance with the General Data Protection Regulation (“GDPR”) and the French Data Protection Act, you have a number of rights.
Please contact us if you wish to exercise any of your rights.
-    Right of access to data (right of access), Article 15 of the GDPR
You have the right to obtain a copy of your Personal Data (if we process it) and other information (similar to that provided in this Privacy Policy) about how we use it.
In this way, you are informed and you can check that we are using your Personal Data in accordance with applicable data protection legislation.
We may refuse to provide you with certain data where, to do so, we need to disclose Personal Data about another person or that infringes the rights of that other person.
-    Right of rectification, Article 16 of the GDPR
You may ask us to take reasonable steps to rectify your Personal Data if it is inaccurate or incomplete.
-    Right to erasure, Article 17 of the GDPR
You have the right to have your Personal Data erased. However, the right to erasure (or the “right to be forgotten”) is not absolute and is subject to special conditions. We may retain your Personal Data to the extent permitted by applicable law and regulation, in particular where processing remains necessary for compliance with a legal obligation to which we are subject or for the establishment, exercise or defence of legal claims.
-    Right to restriction of processing, Article 18 of the GDPR
In certain circumstances, you have the right to restrict the processing of your Personal Data. If you have the right to restrict processing, we will only be able to process your Personal Data - with the exception of storage - in the future with your consent or for the purpose of establishing, exercising or defending a legal right or protecting a person or a material public interest.
-    Right to object, Article 21 of the GDPR
You have the right to object to certain types of processing for reasons relating to your particular situation at any time insofar as we or third parties have legitimate grounds for the processing. We may continue to process your Personal Data if we are able to demonstrate that there are “overriding legitimate grounds for processing that override your interests and rights and freedoms” or if such processing is necessary for the establishment, exercise or defence of legal claims.
-    Right to portability, Article 20 of the GDPR
You have the right, in certain circumstances, to receive Personal Data about you and which you have provided to us in a structured, commonly used and machine-readable format and to transmit it to another processor.
-    Right to give instructions on his/her data, Article 85 of the French Data Protection Act
You may provide guidance on the use of your Personal Data after your death.


You also have the right to lodge a complaint with the Commission nationale de l'informatique et des libertés (Commission nationale de l'informatique et des libertés, 3 Place de Fontenoy - TSA 80715 - 75334 Paris CEDEX 07), you can find more information at www.cnil.fr.
If you have any questions about the processing of your Personal Data, you can contact by email at rgpd.citynetworks@spie.com.


We may make minor changes to this Privacy Policy. After making the corresponding changes, we will post the updated Privacy Policy on our Site. If we make any material changes, we will take additional steps to notify you.