Privacy policy

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Last update: April 20, 2025

At IT CyberWall, we attach great importance to the confidentiality and protection of our users’ personal data, regardless of their location or country of residence.

Our privacy policy is designed to comply with European regulations (in particular the RGPD), but also to respect local requirements applicable in other jurisdictions, including Africa, North America and other regulated areas. Where specific legislation prohibits or frames the transfer of data abroad, we take care to comply strictly with it.

This policy aims to provide you with clear and transparent information on :

♦ The data we collect

♦ How we use them

♦ Your rights as a user

♦ Measures in place to protect your privacy

NB: For the purposes of this document, the term “regional pole” (also known as a “hub”) refers to a legal entity of the Pioneer Humani group responsible for coordinating, supporting and supervising the activities of its subsidiaries located on the same continent or geographical territory. These hubs may, in compliance with local and European data protection legislation, access information strictly necessary for the provision of services, regulatory compliance, or support or communication actions, as part of their regional steering mission.

1. Identity of the data controller

The CyberWall IT site is published by Dédicace Software, which represents the Pioneer Humani group in Europe and is responsible for the promotion, sale and supply of CyberWall IT services in this area. Outside Europe, these activities are carried out directly by Pioneer Humani via its regional hubs and their respective subsidiaries.

If you have any questions about data protection, please contact our Data Protection Officer (DPO):

📧 [email protected]

2. Collected data

Pioneer Humani may collect the following types of data and transmit them to the group entities (hub or subsidiary) in charge of the data concerned geographically:

Identification data: surname, first name, e-mail, telephone number, postal address (for order management purposes).

Technical data: IP address, browser type, preferred language (for internal statistical purposes, your language preference is recorded via a cookie).

Data relating to your orders: purchase history, billing information and means of payment.

Messages: content of requests via our contact form.

Usage data: pages visited, time spent on the site (via our statistics server equipped with the Matomo solution).

3. Collection methods

Data is collected via :

Contact form

♦ The ordering process via this online store

Functional and audience measurement cookies (in particular language cookies)

♦ S ubscriptions to information about our products and services

4. Purposes of processing

Your data is collected for the following purposes:

♦ Processing and tracking orders placed on our online store

♦ Responses to contact requests

♦ Sending information about our products and services (with your consent)

♦ Improve your user experience (language, preferences)

Site traffic statistics (via our Matomo server)

5. Legal basis for processing

In accordance with the General Data Protection Regulation (GDPR), the processing of your data is based on:

Your consent (e.g. subscription to information about our products and services)

Fulfillment of a contract (ordering services)

♦ O ur legitimate interest (service improvement, traffic analysis).

♦ Legal obligations (billing and other)

6. Cookies

We use cookies to :

♦ Save navigation language

♦ Ensure the smooth running of the site, particularly the online store section

♦ Measure audience (via our statistics server, without transferring data to third parties).

You can manage your cookie preferences at any time using the consent management tool (to be integrated if necessary).

7. Recipients of data

Your personal data is processed by IT CyberWall and may, depending on your location, be accessible to authorized entities of the Pioneer Humani group, in particular the regional subsidiary concerned, its regional division, as well as the parent company.

This access is strictly limited to the needs associated with the provision of services, compliance with legal or regulatory obligations, and, where applicable, commercial canvassing in accordance with current data protection legislation.

No data is transferred to commercial third parties. Statistics are hosted on our own servers via Matomo.

8. Shelf life

Customer data: kept for 3 years after the last interaction or 10 years (depending on the regulations in force in the countries concerned) for accounting data.

Contact data: 1 year after last contact.

Cookies: 13 months maximum.

Anonymized statistical data: up to 37 months.

9. Your rights

In accordance with the RGPD, you have the following rights:

♦ Right of access

♦ Right of rectification

♦ Right to erasure

♦ Right to limit processing

♦ Right to object

♦ Right to portability

To exercise your rights, please contact us at

📧 [email protected]

You can also lodge a complaint with the CNIL in France (www.cnil.fr).

10. Data security

We implement all the technical and organizational measures necessary to guarantee the security of your data (SSL encryption, secure servers, access management, etc.).

11. International transfer of data and localization of processing

IT CyberWall is committed to complying with all applicable regulations on personal data protection and international transfers, in accordance with the General Data Protection Regulation (GDPR ) for European customers, as well as applicable local legislation in other territories.

For our customers located in the European Union, personal data is exclusively hosted and processed on servers located within the European Economic Area (EEA). No data is transferred outside the EU unless:

⇒ This is necessary for the execution of a service explicitly requested by the user;

⇒ Or that it meets a justified legal or contractual obligation.

For our customers based outside the European Union, particularly in Africa, Asia or South America, data is hosted as locally as possible, i.e. :

⇒ Or in the customer’s country when the available infrastructure complies with safety standards and local legislation;

⇒ Either in a third country recognized as having an adequate level of protection or in which appropriate legal safeguards (standard contractual clauses, BCR, etc.) are in place.

In all cases, IT CyberWall ensures that any cross-border transfer strictly complies with the legal frameworks in force, and implements appropriate technical and organizational measures to guarantee the security, confidentiality and integrity of the data processed.

Example: Data collected from customers located on African territory is not transferred to Europe or any other jurisdiction without prior verification of compliance with local laws and adequate legal supervision.

13. Regulations by region

Users based in Morocco

In accordance with law 09-08 relating to the protection of personal data, IT CyberWall undertakes not to transfer the personal data of Moroccan users outside the national territory without the authorization of the CNDP. Services, technical and business data are hosted locally or on infrastructures located in Morocco or in countries recognized as suitable by the CNDP.

Users located in other African countries

We comply with applicable local regulations on data sovereignty. Wherever possible, we host our African customers’ data and services on local or regional infrastructures, and we avoid any transfer of sensitive data outside the continent without consent or justified contractual necessity.

Users based in Brazil

In accordance with the LGPD, Brazilian user data is only transferred abroad if the destination country (such as the European Union) guarantees an adequate level of protection, or on the basis of explicit consent. IT CyberWall hosts the services and sensitive data of its Brazilian customers locally, unless otherwise contractually agreed.

Users based in Mexico

In accordance with the LFPDPPP, IT CyberWall informs Mexican users that certain data required to process orders (e.g. billing data) may be processed in the European Union. No sensitive data is transferred without explicit consent or legal obligation.

Users located in Asia

We comply with local regulations, such as the Indian Data Protection Act (DPDPA 2023) or equivalent. IT CyberWall takes care to host Asian customers’ services and data on regional or local infrastructures. No international transfers are made without a legal basis or informed consent.

China-based users

In accordance with the PIPL, no personal data collected in China will be transferred abroad without prior assessment of data security and, if necessary, authorization from the competent authorities. Chinese services and data are hosted exclusively on servers located in China.

14. Changes to the policy

This policy may be updated at any time. The current version is the one published on this site.