Política de proteção de dados pessoais

Your privacy is important to us, and we take it very seriously. We respect your privacy and are committed to protecting the personal data we collect about you. This personal data protection policy (hereinafter the "Personal Data Protection Policy") describes the information that Zenchef (hereinafter "Zenchef") and, where applicable, the other entities in the group to which Zenchef belongs (hereinafter the "Group Companies") collect about you. This collection may be carried out by or through, in whole or in part:

the zenchef.com website, including the blog.zenchef.com subdomain (hereinafter the "site"),
one of Zenchef's social networking pages,
as part of your relationship with Zenchef.

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This policy also describes how Zenchef and, where applicable, the Group Companies process your personal data (see information on how we collect, process and use your personal data).

This data protection policy also specifies the rights you have over your personal data in accordance with the applicable legal and regulatory provisions.

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If you have any questions, comments or concerns regarding this policy, you may of course direct them to us (i.e. Zenchef and/or the Group Companies) using the contact details set out below in the paragraph entitled "What are your rights and how to exercise them".

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The personal data processing operations presented and described in this Personal Data Protection Policy concern those carried out by Zenchef and/or by the Group Companies as data controller(s), or possibly as joint data controller(s), for its/their own account or jointly with some of its/their customers or with Zenchef Group partners, where appropriate.

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Customers are restaurants, or the entities to which they are attached, that have subscribed to Zenchef services (hereinafter the "Customer(s)").

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To find out more about the broad outlines of the division of roles, obligations and responsibilities in case of joint controllership, you can contact Zenchef data protection officer at the address referred to in paragraph 6.

The processing of personal data by other entities in their capacity as data controllers is not covered by this Personal Data Protection Policy. To find out more about these processing operations, please contact these entities.

For example, concerning the processing of your personal data by Customers, acting as data controllers, who have subscribed to Zenchef services and with whom you are in contact or with whom you have made a reservation, we invite you to contact them to find out more about such processing of your personal data.

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1. Definitions

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In addition to terms defined elsewhere in this policy, the following terms, whether used in the singular or plural in this Personal Data Protection Policy, shall have the following meanings:

"recipient": refers to the natural or legal person, public authority, department or any other body that receives personal data, whether or not it is a third party.

"personal data": means any information relating to an identified or identifiable natural person (see "data subject"); an "identifiable natural person" is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.

"data controller": refers to the natural or legal person, public authority, department or other body that determines the purposes and means of processing. When the controller determines the purposes and means of processing jointly with others, it is referred to as a "joint controller".

"processor": refers to the natural or legal person, public authority, department or other body that processes personal data on behalf of the controller.

"processing": means any operation or set of operations which may or may not be performed using automated processes and applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, communication by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

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2. What is our role in processing personal data?

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2.1 Zenchef is a French société par actions simplifiée (simplified joint-stock company) with share capital of €1,203.32, registered in the Paris Trade and Companies Register under no. 528 389 794, with its registered office at the following address: 63 avenue de Villiers 75017 Paris (France), intracommunity VAT number FR50528389794, SIRET No. 528 389 794 00041, Tel.: +33 (0)9 77 41 00, email: privacy@zenchef.com.

To find out more about Zenchef, click here.

The Group Companies are:

Resengo BV, a Belgian limited liability company with its registered office at: Borsbeeksebrug 1, BE-2600 Berchem (Belgium), registration number: 0479.650.944, intracommunity VAT number: BE 0479.650.944, Tel.: +32 3 547 02 10, email: info@resengo.com
Tablebooker, a Belgian limited liability company with its registered office at: LOZENBERG 11, 1932 ZAVENTEM (Belgium), registration number: 0849.393.861, intracommunity VAT number: BE 0849.393.861, Tel.: + 32 2 702 10 70, email: info@tablebooker.be
Formitable BV, a Dutch limited liability company with its registered office at: Elandsstraat 44, 1016 SG Amsterdam (Netherlands), registered with the Chamber of Commerce under number 67619665, intracommunity VAT number: NL857095821B01, Tel.: +31 20 238 4171, email: support@formitable.com

The Zenchef services offered are aimed at catering professionals and consist of the implementation of a software solution designed and developed by Zenchef, allowing Customers to manage their relationship with their customers and prospects, and more generally contacts, and to benefit from services useful to their business (such as a tool for taking, managing and monitoring reservations, paying at the table, collecting opinions, sending communications / solicitations, etc.). This platform provided to Customers is called ZenchefOS. Zenchef also offers restaurants website design services.

The Customer chooses the services to which it subscribes from Zenchef.

Zenchef also publishes a mobile application called Zenchef, which can be downloaded from a mobile phone and which lists Zenchef Customers. This application includes features enabling users to view the details of Customer restaurants of the Zenchef Group, to make reservations at one of the restaurants listed on the application, to create an online account, etc. Concerning the processing of personal data carried out for and/or by the listed restaurants (i.e. the Customers) as (possibly joint) data controllers, please refer to the personal data protection policy accessible on the said application (the characteristics of the processing carried out via this mobile application are not presented in this Persona Data Protection Policy).

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2.2 Zenchef publishes the website accessible to the public at the following url address: zenchef.com (including its sub-domains blog.zenchef.com and go.zenchef.com) (i.e. the site).

The purpose of this site is to provide any Internet user who uses or visits it with information about Zenchef's activity, the Zenchef services offered, as well as news and Customer testimonials.

It also offers features and/or information enabling users to contact Zenchef (see request for contact/information/demo/assistance, unsolicited application, etc.), to download guides intended for restaurant owners, to view information and news relating to the restaurant business and to apply for or respond to job offers or internships with Zenchef and/or Group Companies.

Zenchef also administers pages presenting its business and enabling it to publish content on social networks and interact with Internet users via these networks (see LinkedIn, Facebook, Instagram and Twitter (X)).

The processing of your personal data, whether you are a potential or current customer, prospect, contact, web surfer/user, job applicant, supplier, service provider or partner (also referred to as "you" or the "data subject(s)"), may be implemented by Zenchef (or by Group Companies where applicable) for the purposes set out below in paragraph 4.

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3. How is your personal data collected?

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3.1 Your personal data is collected by Zenchef and, where applicable, by Group Companies, directly from you or indirectly from third parties.

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3.1.1. Your personal data is collected or processed in whole or in part:

when you browse the site (for example, as a result of sharing or redirecting plug-ins or social network features that are linked to / integrated into the site or to which the site may be linked), when you interact with the site, and when you enter information in data collection forms that may appear on the site,
more generally in the context of requests that you may make to Zenchef by any means at your convenience, your relationship and your exchanges with Zenchef, your use of the services provided by Zenchef, as well as when you share content on the site by means of sharing "buttons" on social networks that may be offered on the site, or when you browse one of the pages administered by Zenchef on social networks.

Your personal data is therefore collected by Zenchef from you in the aforementioned cases.

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3.1.2. In addition, your personal data may be collected or processed in connection with job or internship applications that you may send to Group Companies by any means at your convenience, or in connection with your relationship and dealings with Group Companies.

In such cases, your personal data will be collected from you by the Group Companies concerned.

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3.1.3. Your personal data may also be collected through third parties.

In particular, your personal data is collected or processed in the context of requests that you may send to Customers by any means at your convenience, your relationship and your exchanges with said Customers (e.g. when you make a reservation with a restaurant which is a Customer using Zenchef services).

In such cases, your personal data is collected from you by the Customers that are concerned.

In addition, the personal data that we collect and process concerning you may be compiled or enriched by us, in particular for the purposes of carrying out commercial, communication, canvassing, prospecting or marketing operations, by means of other sources of information (so-called "public" information, social networks, websites of third parties/partners, professional directories, blogs, press articles, use of file rental/supply operations by third parties/partners, use of specialised databases offered by third parties, etc.).

In addition, your personal data may be transmitted to Zenchef and/or Group Companies by other members of staff/contacts within your company or via third parties in certain situations.

In the case of data relating to contacts with Zenchef prospects (i.e. restaurants or the entities to which they are linked that have not yet subscribed to Zenchef services), such data may have been transmitted to Zenchef and/or the Group Companies concerned by Zenchef Customers as part of sponsorship operations or by our partners.

Furthermore, more specifically with regard to personal data processed in the context of recruitment operations of the Zenchef Group, Zenchef and/or the Group Company concerned may use the information you provide (e.g. form filled in for this purpose or more generally information mentioned in your CV) which may, under certain conditions, be included in a file of candidates (CV archive).

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In this context, Zenchef and any Group Companies may also contact third parties (e.g. recruitment agencies, previous employers, internship supervisors or customers with whom you have worked on previous assignments) or use other sources of information (in particular, professional social networks, recruitment agencies or specialised recruitment websites) to gather information about you in order to examine your application or profile.

In addition, even if you do not apply for a job, Zenchef and, where applicable, the Group Company concerned, may collect personal data from third parties (e.g. recruitment agencies or "headhunters") or use other sources of information (in particular, professional social networks or specialised recruitment sites), in particular as part of their monitoring operations and their active search for professional profiles that may correspond to their job offers, in order to collect information about you with a view to offering you the opportunity to apply for one of their job vacancies.

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3.2 You are also informed that, as a matter of principle:

if the processing of your personal data is necessary to comply with the legal or regulatory obligations of the data controller, the collection of such data is compulsory;

if the processing of your personal data is subject to your consent, the communication of said data is completely optional (it being specified that not communicating such data could however have the consequence of preventing, at least in certain cases, the implementation of the processing concerned);

if the processing of your personal data is necessary for the performance of a contract or for pre-contractual measures taken at your request, the communication of said data is necessary for the pursuit of this purpose and the data controller could, if said data is not communicated, be prevented from performing its aforementioned contractual obligations or pre-contractual measures;

if the processing of your personal data is based on the pursuit of the legitimate interests of the data controller or of a third party, the communication of the said data is necessary for the pursuit of this purpose, and not communicating your data could prevent or hinder the implementation of the processing concerned. For example, if you fail to provide the information required to respond to a request from you (request for information, etc.), your request related to this collection of personal data may not be processed or its processing may be delayed.

Special case: in the event that any forms used to collect personal data (for example, forms integrated into the site or in Zenchef pages on social networks, or any other forms in any format that may be provided to you to collect information about you) require you to enter personal data that is mandatory for the associated processing to take place, the fields concerned will in principle be marked with an asterisk and you will be informed of the possible consequences of failing to provide this information. Where there is no asterisk, the information requested is optional.

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3.3 Except in special situations, or as otherwise specified in this policy, we do not collect "sensitive" or "special" personal data, i.e. data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, or genetic or biometric data for the purpose of uniquely identifying a natural person, or data concerning health or data concerning a natural person's sex life or sexual orientation. In this respect, you are informed that you are requested not to provide such "sensitive" or “special” data in your dealings with Zenchef and/or the Group Companies (or even with Customers, where applicable).

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3.4 Personal data of minors or protected adults: in general, use of the site and Zenchef's dedicated pages on social networks is reserved for adults with legal capacity, and Zenchef can in no way be held responsible for the use of Zenchef's site or pages on social networks by minors or incapable persons, and therefore for the consequences that may result therefrom, particularly in terms of the processing of their personal data.

However, in certain specific cases, Zenchef and the Group Companies, where applicable, may process the personal data of minors of at least fifteen years of age when they contact us to apply for a job or internship.

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4. What data is collected, for what purposes, on what basis and for how long?

Your personal data is processed for the following purposes:

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4.1 Management and follow-up of requests for information and exchanges with users, initiated via or by means of the site or Zenchef pages on social networks or by any other means, and more generally of relations with contacts in the broadest sense

- Purpose of processing: Zenchef is required to process your personal data in order to handle, manage and follow up any request (e.g. for contact, information, demo, assistance, download of a guide for restaurant owners, etc.) sent by you, by any means and in particular via the site or via interactions on Zenchef's social networking pages (including in particular, the management, processing, follow-up and possible moderation of your messages or comments) and the answers to be given to them, the management and monitoring of the features offered on or via the site, and more generally for the purposes of managing its relations with its contacts in the broadest sense, including the execution and preparation of surveys, if necessary.

- Data controller: Zenchef.

- Data processed: identity (title, surname, first name), user name or pseudonym/alias, contact details (in particular postal address, telephone number or e-mail address), country, request for contact, information, demo or assistance and correspondence exchanged, information concerning the way in which the person making the contact request came to know about Zenchef (through a partner, during an event, etc.), company and job title, where applicable.

- Legal basis for processing: the processing of your personal data in this context is necessary to pursue Zenchef's legitimate interests in responding to your requests and, more generally, in managing and monitoring its relations with its contacts.

- Data retention period: storage of personal data in an active database for as long as is necessary to provide you with a response to your request or to manage our relationship with you. At the end of the active database retention period, personal data will be stored in an archive for 5 years for administrative and/or evidential purposes, subject to any other retention periods that may apply if your personal data is processed for other purposes in accordance with the terms and conditions set out below in this paragraph 4.

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4.2 Relationship management with existing and potential Customers

- Purpose of processing: Zenchef processes the personal data of its current or potential Customers' contacts in order to manage relations with them, to ensure the management and follow-up of its pre-contractual, contractual and post-contractual relations with its current or potential Customers in the broadest sense, including the search for new Customers, the management and follow-up of the conclusion and execution of contracts, their onboarding, the services provided, the features associated with ZenchefOS, requests for assistance or technical support, payments and transactions, associated invoicing/accounting, the customer/prospect/contact relationship in the broadest sense, and in particular for the management and monitoring of customer accounts, and any complaints.

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- Data controller: Zenchef.

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- Data processed: identity (title, first name, surname), contact details (e-mail address, postal address, telephone number, etc.), language, data relating to professional life, economic and financial information, details of transactions / services provided / contracts, information relating to sponsorship where applicable (sponsorship link and benefit granted for the “sponsoring” Customer and for the "sponsored" prospect), data relating to these transactions / services provided / contracts, password (encrypted) for access to ZenchefOS, data relating to connections to ZenchefOS (see access, actions and interactions), data relating to the monitoring of transactions / services provided / contracts, and more generally to relations between the Zenchef Group and its Customers, data relating to complaints.

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- Legal basis for processing: the processing of your personal data is in principle necessary for the pursuit of Zenchef's legitimate interests in ensuring the proper management of relations with its current or potential Customers, and more generally contacts with said Customers in the broadest sense, in particular in the context of the search for new Customers, the monitoring of the proper performance of contracts entered into with Customers or with a view to the organisation and proper provision of services to Customers.

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- Data retention period:

for current Customers (or contacts linked to a current Customer): storage of your personal data in an active database for the duration of our contractual or commercial relationship;
for potential Customers (or contacts in connection with a potential customer): storage of your personal data in an active database for the duration of our pre-contractual relationship;

followed, at the end of the storage period in the active database, by storage in the form of archives for 5 years for administrative and/or evidential purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the terms and conditions set out below in this paragraph 4.

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4.3 Management of reservations and click-and-collect orders

- Purpose of processing: Zenchef is required to process personal data relating to persons who have made a reservation request or a click-and-collect order with a Customer when reservation or order requests are made via Zenchef services. The purpose of this processing is to take, manage and track reservation requests and/or click-and-collect orders. Reports, indicators and associated statistics are also provided to the Customer as part of Zenchef services (fill rate, change in the number of reservations/orders, no-show rate, etc.).

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- Data controller(s): Zenchef is responsible (possibly jointly) for such processing as the controller, together with the Customer with whom the reservations and/or orders were made.

Note: When reservations or orders are made with a Customer without Zenchef having visibility of it (e.g. reservation or order made directly with the Customer by telephone or via a reservation module other than the Zenchef module), then the Customer is the sole controller for such processing (see processing not covered by this Personal Data Protection Policy - you should contact the latter to find out more about such processing of your personal data).

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- Data processed: identification data (surname/first name), contact details (telephone number, email address), country/language, reservation number, date and time of requested reservation, room chosen for reservation and/or table reserved if applicable, reason for reservation if applicable (birthday, business event, family event, etc.), number of covers for the reservation request, date and time of reservation or order, reservation status (confirmed, cancelled, on waiting list, etc.), source of reservation (guest, reservation by email, website/reservation module from which the reservation was made, etc.), status to determine whether or not a guest has been invited to the restaurant), status to determine whether or not a customer has shown up for their reservation ("no-show" / "arrived" or "cancelled") and associated time stamp (date and time), information relating to the order placed via click-and-collect (products / items ordered and associated prices, date and time of pick-up, etc.), gift code, reservation reason, comments on the reservation/order request, payment data (particularly in the case of prepayment requested by the Customer) or data required to make a card pre-authorisation where applicable, meal duration, reservation notifications, history of any conversations / telephone calls in the absence of reservations / orders and alerts in the event of a "no-show" risk (see risk of a person not showing up for their reservation), which is automatic, objective and based on the history of reservations made by the data subject (if the person has not shown up for a reservation in the previous 12 months, or in the event of simultaneous reservations in at least two Customer restaurants), it being specified that this alert does not prevent the data subject from making a reservation request, and does not lead to automatic cancellation of the reservation (the Customer concerned receiving this alert may decide to ignore the alert, or to deploy additional measures to try to limit this risk (e.g. request for reconfirmation of the reservation by email/SMS, request for prepayment, or making a card pre-authorisation)).

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- Legal basis for processing: such processing of your personal data is necessary to pursue the legitimate interests of Zenchef and/or the Customer concerned with a view to responding to reservation/order requests, and to ensure the proper management of reservations and orders, and more generally of relations with the Customer's customers.

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4.4 Management of payments made using the pay-at-table module provided by Zenchef

- Purpose of processing: Zenchef processes personal data relating to people who have paid a bill to a Customer using the pay-at-table module provided by Zenchef. The purpose of this processing is to manage and monitor pay-at-table services via this module, and in particular the payment of the bill, when the personal data concerned has been collected by means of the pay-at-table module provided by Zenchef. Reports, indicators and associated statistics are also provided to the Customer as part of the Zenchef services (number of payments made using the pay-at-table module provided by Zenchef, proportion of payments made using this module, monthly revenue generated by the use of this module, etc.).

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- Data controller(s): Zenchef is responsible (possibly jointly) for such processing as the controller, together with the Customer to whom payment has been made using the pay-at-table module provided by Zenchef.

Note: When bill payments are made to a Customer by a means other than the pay-at-table module provided by Zenchef (e.g. payment in cash or by credit/debit card at the restaurant cash desk or by means of a tool provided by a third party), then the Customer is the sole controller for such processing (see processing not covered by this Personal Data Protection Policy - you should contact the latter to find out more about such processing of your personal data).

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- Data processed: identification data, bill information, items paid for and price paid (and distribution among guests if applicable), tip amount, payment method, payment data (see payment card information: number, expiry date, cryptogram, name of cardholder), payment receipt and contact information provided to obtain a note after payment if applicable.

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- Legal basis for processing: such processing of your personal data is necessary for the pursuit of the legitimate interests of Zenchef and/or the Group Company concerned, as well as for the pursuit of the legitimate interests of the Customer concerned with respect to the payment of bills and orders, and more generally for the proper performance of the Customer's customer relations and the catering services provided by the latter.

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- Data retention period: storage in an active database for three years from the date of collection of the personal data or the end of the relationship with you, or from the last contact you made with the Zenchef Group and/or a Customer, followed by retention in the form of archives for 5 years for administrative and/or evidential purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the terms and conditions set out below in this paragraph 4. Payment details are not stored by Zenchef or the Customer. The determination and application of their retention periods are the responsibility of the payment service providers used for this service. Zenchef and/or the Customer have no control over these retention periods.

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4.5 Online review management

- Purpose of processing: Following a reservation or an order placed with a Customer, you may be asked to leave your review following such an experience. One of Zenchef's services, called "Reviews", enables Zenchef Customers to collect reviews from their own customers and publish them on various media. In this context, Zenchef may be required to process personal data relating to persons whose reviews are collected via this Reviews service and published on the Zenchef mobile application. Reports, indicators and associated statistics are also provided to the Customer as part of Zenchef services (overall rating since the beginning of the year, evolution of reviews, average rating, etc.).

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- Data controller(s): Zenchef is responsible (possibly jointly with the Customer) for the processing of reviews collected by means of the Reviews service and their publication on the Zenchef mobile application.

Note: When reviews are collected by a Customer by a means other than the Reviews service or when reviews are published on a medium other than the Zenchef mobile application, then the Customer is solely responsible for such processing. In addition, the Customer is solely responsible for the processing of personal data implemented in the context of the management and follow-up of the reviews of the Customer's end customers in the broadest sense, including by means of the Reviews service, including in particular the responses to be provided and their dissemination on any medium under the Customer's control (for example, on its website) (see processing not covered by this Personal Data Protection Policy - you should contact the latter to find out more about such processing of your personal data).

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- Data processed: identification data (at least surname), telephone number, country/language, online review / rating and associated comment.

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- Legal basis for processing: such processing of your personal data is necessary to pursue the legitimate interests of Zenchef and/or the Customer concerned with respect to collecting the reviews of the Customer's customers and disseminating them on the Zenchef mobile application.

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4.6 Management of relations with current and potential Zenchef Group partners (including service providers and suppliers)

- Purpose of processing: Zenchef and, where applicable, the Group Companies may process personal data relating to their current or potential partners and/or contacts with these partners (e.g.: members of the partner's staff, the partner's service provider/consultant, etc.). The purpose of this processing is to seek out new partners, manage, follow up and respond to requests for partnerships, quotes or service proposals, as well as to manage partners and/or manage Zenchef's and, where applicable, Group Companies' relations with them, including in particular the management and follow-up of the execution of contracts, orders/services entrusted, deliveries, invoices, payments and transactions, associated accounting, and in particular the management and follow-up of partner accounts, partner relations in the broadest sense and any complaints.

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- Data controller(s): Zenchef and the Group Company with which you are in contact are responsible (possibly jointly) for such processing.

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- Data processed: identity (title, surname, first name), contact details (e-mail address, postal address, telephone number, etc.), company and job title, information relating to your education (studies, diplomas, etc.), your experience and career path, your skills/professional references, and any information that may be contained in your CV, if applicable, information on partnership requests, quotes and service proposals, details of orders/services/contracts, data relating to payments and payment methods, data relating to transactions, data relating to the monitoring of contracts and the relationship, data relating to invoices, data relating to complaints.

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- Legal basis for processing: the processing of your personal data is, in principle, necessary in order to pursue the legitimate interests of Zenchef and/or the Group Company concerned in ensuring the proper management of relations with their current or potential partners (and, more generally, contacts with said partners in the broadest sense of the term), in particular as part of the search for new partners, the monitoring of the proper performance of contracts signed with partners or with a view to the organisation and proper performance of the assignments or services entrusted to them.

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- Data retention period: storage in active database for the duration of the pre-contractual (for potential partners), contractual or commercial (for current partners) relationship, then storage in the form of archives for 5 years for administrative and/or evidential purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the terms and conditions set out below in this paragraph 4.

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4.7 Internal and external communications operations

- Purpose of processing: Zenchef may process personal data relating to potential or current Customers, prospects, contacts, web surfers/users, suppliers, service providers or partners, with a view to carrying out communication operations, including in particular the presentation of the Zenchef Group as well as its activity and/or services (testimonials, distribution of presentation brochures, promotion and communication relating to events, news information, etc.) internally (e.g. intranet) and/or externally (e.g. on the site and/or on espace-63.zensites.zenchef.com and/or any other website published by Zenchef and/or on Zenchef social networking pages), and generally on all communication media under Zenchef's control.

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- Data controller: Zenchef.

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- Processed data: identity (title, surname, first name), photograph / video / voice, status (e.g.: staff member of a Customer or prospect, contact, web surfer / user, supplier, service provider or partner, and details of this status if applicable), professional information if applicable (position held / job / profession / function / department / activity / company, etc.), feedback and testimonials.

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- Legal basis for processing: such processing is based on your consent (which will be obtained by means of a dedicated document submitted to you). As a result, you have the option of not consenting or, if you do consent, of withdrawing your consent at any time, without having to provide any reason or explanation.

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- Data retention period: storage in an active database for the period specified in the authorisation granted.

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4.8 Production and preparation of studies, analyses, reports and statistics

- Purpose of processing: Zenchef may process personal data relating to contacts of the Zenchef Group (Customers, prospects, web surfers/users, partners, service providers, etc.), with a view to carrying out and preparing studies, analyses, reports and statistics, in particular sales statistics.

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- Data controller: Zenchef.

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- Data processed: identity (title, surname, first name), user name or pseudonym/alias, job title and company where applicable, possibly data relating to professional life, contact details (telephone number, e-mail address or postal address), economic and financial information where applicable, details and data relating to the monitoring of current transactions/services/contracts/litigations, etc., and more generally data relating to our relations with the data subjects.

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- Legal basis for processing: such processing is in principle necessary for the pursuit of Zenchef's legitimate interests in order to ensure their development, or to assess the level of performance of the services provided, as well as to improve and supervise Zenchef's services.

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4.9 Management and monitoring of the accounting and financial situation of Zenchef or Group Companies, and more generally of the Zenchef Group

- Purpose of processing: Zenchef and, where applicable, Group Companies may process the personal data of their contacts (e.g. contacts of their partners or, as far as Zenchef is concerned, of current or potential Customers) for the purposes of managing and monitoring accounting operations relating to contracts entered into and their financial and budgetary situation (including in particular general and analytical accounting, the representation and monitoring of fluctuations in their assets, or the recording of their financial and budgetary situation, etc.).

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- Data controller(s): Zenchef and the Group Company to which you are connected and/or with which you are in contact, each insofar as it is concerned, are responsible (possibly jointly) for such processing.

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- Data processed: identity (title, surname, first name), contact details (postal address, telephone number, e-mail address, etc.), data relating to payments and payment methods, data relating to transactions, data relating to the monitoring of contracts and relations with contacts and data relating to invoices, accounting, financial, budgetary and tax information.

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- Legal basis for processing: in principle, such processing is necessary in order to comply with the legal or regulatory obligations incumbent on Zenchef or the Group Company concerned (financial, tax and accounting documents in particular). Furthermore, the sub-purposes of this processing linked to the monitoring of accounting and financial and budgetary situation are necessary to pursue the legitimate interests of Zenchef and/or the Group Company concerned in the context of the proper management of their accounting and financial situation.

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- Data retention period: retention in an active database for the duration of the current accounting or tax year, followed by retention in the form of archives for up to 10 years (except in the case of data retained solely to take account of the tax statute of limitations, which are therefore kept in archives for a limited period of 6 years).

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4.10 Event organisation, management and follow-up

- Purpose of processing: Zenchef may need to process your personal data in order to manage and monitor the events (conferences, webinars, live events, etc.) it offers (organisation of events, management, processing and monitoring of registrations, responses to requests for information, etc.).

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- Data controllers: Zenchef.

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- Data processed: identity (title, surname, first name), user name or pseudonym/alias, contact details, job title and company, information on event registrations and participation.

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- Legal basis for processing: in general, the processing of your personal data in this case is necessary for the organisation and management of events, and is therefore based on the execution of pre-contractual measures taken at your request or of a contract to which you are a party (see event registration). When participation in the event does not require prior registration, the processing of your personal data is based on the legitimate interests pursued by Zenchef to ensure the organisation and smooth running of its events and participation in said events in the broadest sense.

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- Data retention period: storage in an active database for the time required to organise and monitor the event, followed by storage in the form of archives for 5 years for administrative and/or evidential purposes, subject to other retention periods that may apply if your personal data is processed for other purposes under the terms and conditions set out below in this paragraph 4.

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4.11 Prospecting/solicitation by post or telephone

- Purpose of processing: Zenchef and, where applicable, the Group Companies may process the personal data of their contacts (e.g. contacts of their partners or, as far as Zenchef is concerned, of its current or potential Customers) for the purposes of carrying out commercial, communication, solicitation, prospecting or marketing operations (including technical operations involving segmentation, targeting, personalisation of communications, etc.) by post or telephone, in particular with a view to sending them certain information by these means: offers for products and services or information on services likely to interest them, information on their news and/or activities, other information or prospecting documents, or studies, surveys, promotions or satisfaction surveys. If you are a contact of a current or potential Customer, your data may also be transmitted by Zenchef to partners in order for them to carry out their own canvassing operations by post or telephone.

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- Data processed: identity (title, first name, surname), contact details (postal address, telephone number), job title and company where applicable, responses to studies / surveys / polls, profile / segment.

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- Legal basis for processing: such processing is implemented on the basis of the pursuit of the legitimate interests of Zenchef and/or the Group Company(ies) concerned to make themselves known, to ensure their development, in particular commercial development, and/or to carry out prospecting and solicitation operations in the broadest sense, it being specified that the recipient of such prospecting always has the right to object to it at any time without having to provide any reason or explanation. The same applies to the transmission of such data to partners for canvassing purposes by post and/or telephone.

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- Data retention period: in principle, data will be kept in an active database for three years from the date of collection of the personal data or from the end of our relationship, or from the last contact you made with Zenchef Group (for example, for a Customer or partner, from the end of a contract or from the last contact made by the Customer or partner and, for a prospect (see potential Customer), from the last contact made by this prospect (online request, e-mail or postal mail, telephone call, etc.)). In the case of data processed as part of satisfaction surveys, the data is kept in an active database for the time required to achieve the survey's objective. In any case, after the data retention period in the active database, it is archived for 6 years for administrative and/or evidential purposes.

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4.12 Prospecting/solicitation by e-mail

- Purpose of processing: Zenchef and, where applicable, the Group Companies may process the personal data of their contacts (e.g. contacts of their partners or, as far as Zenchef is concerned, of its current or potential Customers, or contacts of said Customers (e.g. people who have made a reservation with the Customer)) for the purposes of carrying out commercial, communication, solicitation, prospecting or marketing operations (including technical operations involving segmentation, targeting, personalisation of communications, etc.) by e-mail, in particular with a view to sending them certain information for this purpose by this means (i.e. e-mail, SMS, MMS, private online messages): product and service offers or information on services likely to be of interest to them, information/communications (including in particular their distribution, reminders, management of returns, etc.) on the Zenchef Group news and/or activities (e.g.: newsletter), other information or prospecting documents, gift codes, or even studies, polls, promotions or satisfaction surveys.

Commercial, communication, solicitation, canvassing or marketing operations promoting the services or image of the Zenchef Group, as well as of the Customer or of Zenchef Group partners, may also be carried out.

If you are a contact for an existing or potential Customer, your data may also be passed on to partners for their own e-mail prospecting operations.

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- Data controllers: Zenchef and the Group Company to which you are connected and/or with which you are in contact, each insofar as it is concerned, are responsible (possibly jointly) for such processing when the operations concerned promote the products or services or image of the Zenchef Group only.

When such operations are carried out for the attention of customers, prospects or contacts of a Customer and promote both the products or services or the image of the Zenchef Group and the Customer, Zenchef and the Customer concerned act as joint controllers for such processing.
When such operations are carried out for the attention of Zenchef's contacts, in particular its Customers, and promote both the products or services or the image of Zenchef Group and a partner of the Zenchef Group, Zenchef and the partner concerned are jointly responsible for such processing.

Note: Where such operations solely promote the Customer's or the partner’s products or services or image, the Customer or the partner is solely responsible for such processing (see processing not covered by this Personal Data Protection Policy

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- Please contact the Customer or the partner for further information on such processing of your personal data).

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- Data processed: identity (title, first name, surname), contact details (email address, telephone number), benefits granted (gift code), job title and company where applicable, responses to studies / surveys / polls, profile / segment.

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- Legal basis for processing:

such operations are not subject to the prior consent of the data subjects when the messages are addressed to professionals, sent to a professional e-mail address and are related to the profession of the recipient, in which case such processing is implemented on the basis of the pursuit of the legitimate interests of Zenchef and/or the Group Companies to make themselves known, to ensure their development, in particular commercial development, and/or to carry out canvassing and solicitation operations in the broadest sense, it being specified that the recipient of such canvassing always has the right to object to it at any time without having to provide any reason or explanation. The same applies to the transmission of such data to partners for canvassing purposes by e-mail;
in other cases, in particular when you subscribe to the newsletter on the site, such processing is based on your consent, which means that you have the possibility of not consenting to it or, if you do consent, of subsequently withdrawing your consent at any time, and without having to provide any reason or explanation. Your prior consent is also required for the communication of your personal data to partners in order for them to carry out their own canvassing operations by e-mail (it being specified that, failing this, your personal data will not be communicated).

- Data retention period: storage in an active database for three years from the date of collection of the personal data or from the end of our relationship and/or your relationship with the Customer concerned, as the case may be, or from your last contact with the Zenchef Group and/or with the Customer concerned, as the case may be (for example, for a Customer's customer, from the date of the last reservation or the last contact from the said customer, for a Customer or partner, from the end of a contract or the last contact from the Customer or partner, and for a prospect (see potential Customer), from the last contact from the latter (online request, e-mail or postal mail, telephone call, etc.)). In the case of data processed as part of satisfaction surveys, the data is kept in an active database for the time required to achieve the survey's objective. In any case, after the data retention period in the active database, it is archived for 6 years for administrative and/or evidential purposes.

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4.13 Use of cookies or other similar technologies to record your preferences, manage and monitor the proper operation and security of the site, monitor and measure navigation, traffic and performance of the site, including the performance and preparation of tests, studies, analyses, reports and statistics, or the evaluation and analysis of the way in which you use and interact with our site, adapting the site with a view to improving site performance and the user experience, providing certain services or features on the site, and displaying advertising, possibly targeted advertising (excluding social networks or features linked to social networks)

- Purpose of processing: in the context of your use of the site and, more generally, Zenchef's digital media (excluding social networks or features linked to social networks), Zenchef processes personal data concerning you, in particular for the purposes of recording your preferences, including the performance and preparation of studies, analysis, reports and statistics, for managing and monitoring the proper operation and in particular the security of the site, improving the user experience, providing certain services or certain features on the site, and monitoring and measuring the site traffic and performance. Your personal data may also be collected and processed in order to display advertising, possibly targeted advertising (or behavioural or programmatic advertising) to you on the site or on third-party websites, based on your profile, your browsing, your location (see geo-targeted advertising) and your interactions with the websites you visit. This personal data is collected by means of cookies or similar technologies.

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- Processed data: session, connection and Internet browsing data, in particular including information about your browser or terminal and its configuration (e.g. device fingerprinting, unique device identifier, display resolution, operating system, IP address, Internet browser, terminal type, etc.), history and more generally traffic and browsing information on the site, information relating to the traceability of actions on and interactions with the site, and on the number of visitors, the origin of users and the pages visited, "identifier" type information linked to your terminal, your hardware or your operating system, or "scoring" type information (e.g.: bot score to ensure that the user is not a robot), information relating to your browsing preferences and use of the site or third-party websites, location data (IP address and geographical area, for example), information relating to the network, your language, or personal data (age, gender, interests, demographic data, family/marital status, professional activity/status, etc.) that is not nominative (i.e. specific to the Internet user's identifier).

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- Data controller: Zenchef.

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- Legal basis for processing: when the sole purpose of processing your data is to enable or facilitate communication by electronic means, or is strictly necessary for the provision of an online communication service at your express request, i.e. in general if such processing is strictly necessary for the purposes of enabling you to browse the site and benefit from the offered features, it is based on Zenchef's legitimate interest in facilitating your browsing of the site. In other cases, such processing is subject to your prior consent to the use of cookies and other similar technologies for the aforementioned purposes, with the result that you have the option of not consenting to such processing or, if you do consent, of subsequently withdrawing your consent at any time, and without having to provide any reason or explanation.

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To find out more about the cookies, trackers and other similar technologies used by Zenchef and its partners on the site, how to adjust their settings and how long they last, please refer to the Cookie policy of Zenchef.

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4.14 Use of cookies or other similar technologies for the purposes of monitoring and measuring the browsing, traffic and performance of the site (in connection with features linked to social networks) and Zenchef pages on social networks, including the performance and preparation of tests, studies, analyses, reports and statistics, or the evaluation and analysis of the way in which you use and interact with the site (in connection with features linked to social networks) and said pages on social networks, for providing and monitoring interactive features with social networks, adapting the site and Zenchef's pages on social networks in order to improve the performance of the site and Zenchef's pages on social networks and the user experience, and displaying advertising, possibly targeted advertising (social networks and features linked to social networks)

- Purpose of processing: for the purposes of providing interactivity features between the site and social networks, and monitoring, understanding and studying the use of the site (in connection with features linked to social networks) and Zenchef's pages on social networks and interactions between the site and social networks, Zenchef may offer you links or "buttons" on the site to its pages on social networks, integrate / link to the site or link the site to features linked to social networks, configure the said pages on social networks in the capacity of an administrator or offer you the use on these networks of tools created / offered by these social networks. In this case, Zenchef processes your personal data in particular for the purposes of monitoring and measuring the browsing, traffic and performance of the site (in connection with the features linked to social networks) and Zenchef's pages on social networks, including the performance and preparation of tests, studies (e.g. positioning), analyses, reports and statistics, or the evaluation and analysis of the way in which you use and interact with the site (in connection with features linked to social networks) and the said pages on social networks, the provision and monitoring of features for interactivity with social networks (for example, "button" for sharing or accessing pages on social networks, etc.), adapting the site (in connection with features linked to social networks) and Zenchef pages on social networks with a view to improving the performance of the site (in connection with features linked to social networks) and said pages and the user experience. Your personal data may also be collected and processed in order to display advertising, possibly targeted advertising (or behavioural or programmatic advertising) to you on the site, on third-party websites or on social networks, according to your profile, your browsing, your location (see geo-targeted advertising) and your interactions on social networks and also with the site or with other websites you visit. This personal data is collected by means of cookies or similar technologies.

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Please note: the use of these cookies may enable the social networks concerned to track users' browsing on the zenchef.com website, whether or not they are users of these third-party social networks (i.e. whether or not they have created an account on these sites).

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- Data controller: when Zenchef's configuration of a social network tool has an impact on the nature of the personal data processed or on the characteristics of this processing, and more specifically when it can be considered that Zenchef contributes to jointly determining the purposes and means of the processing of personal data, Zenchef may be considered as a joint controller for the processing of your personal data with the social network concerned. In this case, the social network, which primarily determines the purpose and means of processing, as well as the nature and methods of depositing cookies, has primary responsibility for the processing and you are advised to consult the privacy policies and "cookie" policies of these third parties for detailed information on their practices for collecting and processing your personal data. The social networks concerned are LinkedIn, Facebook, Instagram and Twitter (X) (see below).

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- Data processed: session, connection and Internet browsing data, including in particular information about your browser or terminal and its configuration (e.g. device fingerprinting, unique device identifier, display resolution, operating system, IP address, Internet browser, terminal type, etc.), history and more generally traffic and browsing information on the site and on our pages on social networks, information relating to the traceability of actions on and interactions with the site or with Zenchef pages on social networks or between the site and social networks, and on the number of visitors, the origin of users and the pages visited, "identifier" type information linked to your terminal, your hardware, social networks or your operating system, or "scoring" type information (e.g.: bot score aimed at ensuring that the user is not a robot), information relating to your browsing preferences and use of the site, Zenchef pages on social networks, or even third-party websites, location data (IP address and geographical area, for example), information relating to the network, your language, or personal data (age, gender, interests, demographic data, family/marital situation, professional activity/status, etc.) that are not nominative (i.e. specific to the Internet user's identifier).

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- Legal basis for processing: such processing is subject to your prior consent to the use of cookies and other similar technologies for the aforementioned purposes, which means that you have the option of not consenting to such use or, if you do consent, of subsequently withdrawing your consent at any time and without having to provide any reason or explanation.

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- Maximum lifetime of cookies and retention period of personal data collected by this means: storage in an active database for the lifetime of cookies and other similar trackers by means of which personal data is collected, up to a maximum of six months. With regard to the retention of personal data by LinkedIn, Instagram, Facebook and Twitter (X), refer to their privacy policy and cookie policy (see below).

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- To find out more about the cookies, trackers and other similar technologies used by Zenchef and its partners on the site, how to adjust their settings and how long they last, please refer to the Cookie policy of Zenchef.

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- Find out more about cookies, trackers and similar technologies used by social networks:

regarding Facebook (Meta) and Instagram: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour Dublin 2, Ireland. For more information on how Meta Platforms Ireland Limited processes your personal data, please refer to the Meta Platforms Ireland Limited data use policy, as well as the Cookie Policies of Facebook and Instagram ;
for Twitter (X): Twitter International Unlimited Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Ireland. For more information on how Twitter processes your personal data, please refer to the Privacy Policy and the Cookie Policy of Twitter;
for LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. For more information on how LinkedIn processes your personal data, please refer to the Privacy Policy and the Cookie Policy of LinkedIn.

4.15 Managing applications and the recruitment process

- Purpose of processing: Zenchef and, where applicable, Group Companies may process your personal data for the purposes of managing and monitoring applications in response to job or internship offers or those sent to us on an unsolicited basis, and operations relating to the Zenchef Group recruitment process, including in particular the monitoring and active search for professional profiles corresponding to the positions to be filled, the receipt and review of applications, the evaluation and selection of candidates and professional profiles, the creation of a file of candidates (or CV archive), the use of methods and techniques to assist recruitment (in particular psycho-technical or psychological tests, handwriting analysis or case studies/professional roleplaying), the summoning of candidates and the holding of recruitment interviews, as well as the resulting decision (rejection of the application or recruitment of the candidate).

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- Data controller(s): Zenchef and the Group Company concerned by the application, each insofar as it is concerned, are (possibly jointly) responsible for such processing.

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- Data processed: identity (title, first name, surname), contact details (e-mail address, telephone number, postal address, etc.), language(s) spoken, data relating to your professional life, information relating to your education (studies, diplomas, etc.), your experience and career path, your professional skills/references and the job you hold, economic and financial information, and any information contained in your CV (including your interests, where applicable), and more generally in your application (including cover letter, portfolio of creations/content where applicable, etc.), answers to psycho-technical or psychological tests, handwriting analysis or case studies/professional roleplaying, technical information linked to the connection in the case of videoconference interviews (identity, date and time of interview start or duration).

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- Legal basis for processing: such processing is necessary for the pursuit of the legitimate interests of Zenchef and/or the Group Company concerned, depending on the entity to which you apply, with a view to the search for and recruitment of new employees. However, once the vacancy has been filled, your data may be stored in our candidate database (or CV archive) in order to offer you other positions that may be of interest to you at a later date, subject to your prior consent.

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- Data retention period: your personal data will be retained for the time required to process your application and may, subject to your prior consent, be retained until the end of a two-year period following receipt of your application, for example in order to enable Zenchef or the relevant Group Company, depending on the entity to which you have applied, to contact you again during this period should a position become available that matches your profile. At the end of this period, your personal data will be stored in the form of archives for 6 years for administrative and/or evidential purposes.

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4.16 Handling requests to exercise the rights of data subjects

- Purpose of processing: in order to enable Zenchef and, where applicable, the Group Companies, and even their Customers where applicable, to comply with their various legal and regulatory obligations in terms of the protection of personal data (e.g.: responding to data subjects’ requests to exercise their rights, taking into account the consequences resulting therefrom, in particular managing objections to canvassing, etc.), Zenchef and the Group Companies may be required to process your personal data in connection with this purpose.

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- Data controller(s): Zenchef and the Group Company to which you are linked and/or with which you are in contact and/or which intervenes within the context of your relations with the Zenchef Group and/or contact, each insofar as it is concerned, are responsible (possibly jointly) for such processing.

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- Data processed: identity (title, first name, surname), contact details (e-mail address, telephone number, postal address, etc.) and more generally all data processed concerning the applicant, content of the request, exchanges and response, additional information or a copy of an identity document, but only when the situation requires it (e.g. in the event of reasonable doubts as to the applicant's identity).

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- Legal basis for processing: such processing is in principle necessary in order to comply with the aforementioned legal and regulatory obligations incumbent on Zenchef and/or the Group Companies, where applicable, in their capacity as (possibly joint) data controllers.

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- Data retention period: storage in an active database until the data controller(s) respond(s) to the request, then storage in the form of archives for a maximum of 6 years from the time the data controller(s) respond(s) to the request (depending on the type of request), it being specified, however, that when a copy of an identity document is collected in this context, it is:

immediately deleted if you have provided it yourself, but the request does not require the transmission of such an identity document;
deleted as soon as the identity of the person making the request has been verified, where the situation requires such verification, or kept in archive form for 6 years for evidential purposes in certain exceptional cases where the data controller(s) identify a strong risk of litigation.

*In the event that you object to receiving canvassing, your identity and/or contact details may be kept by the data controller(s) in an active database for 3 years in order to take account of your request (see keeping of a canvassing objection list).

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4.17 Pre-litigation and litigation management and follow-up

- Purpose of processing: your personal data is processed by Zenchef and, where applicable, by Group Companies for the purpose of managing and monitoring pre-litigation and litigation (in particular commercial litigation / litigation with Customers, with partners / service providers / suppliers, with contacts in the broadest sense, etc.), including in particular the preparation, exercise and follow-up of litigation and the enforcement of decisions rendered, as well as the management and follow-up of actions aimed at establishing, exercising or defending a legal right (including, where applicable, the enforcement of decisions rendered).

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- Data processed: identity (title, first name, surname), marital status, economic and financial information, history/information relating to exchanges and relations with Zenchef and/or one or more Group Companies, and more generally any information if this is necessary in view of the subject matter of the dispute, facts giving rise to the proceedings, information / documents / exhibits gathered to establish or refute facts likely to be reproached, characteristics and details of the pre-litigation / litigation / proceedings, decision, information necessary for the enforcement of the decision, etc. including, where applicable, data relating to convictions (particularly criminal convictions) or offences or security measures, or so-called "special" data as defined above.

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- Legal basis for processing: such processing of your personal data is based on the legitimate interests pursued by Zenchef and/or by the Group Company concerned with a view to safeguarding/enforcing their interests and legal rights, in particular in the performance of relations with its Customers (current or potential), partners (current or potential), contacts, candidates, etc. In addition, in the context of this processing, so-called "special" personal data may be processed for the aforementioned purposes if strictly necessary for these purposes and for the establishment, exercise or defence of a legal right. Similarly, data relating to offences, convictions or security measures may be processed for the purposes of enabling Zenchef and/or the Group Company concerned to prepare and, where applicable, to exercise and monitor legal proceedings as victim(s), defendant(s), or on behalf of a victim or defendant, and to enforce the decision rendered.

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- Data retention period: as mentioned above, data processed for the various purposes described above is kept in the form of archives for the statutory limitation periods, in particular for evidential purposes in the event of litigation. In the event of pre-litigation initiated before the expiry of the above periods and which would require the retention of personal data in particular with a view to establishing, exercising or defending the rights of Zenchef and/or the Group Company concerned, such data will be retained until the amicable settlement of the dispute (including its enforcement, where applicable), or, failing this, will be deleted as soon as the corresponding legal action becomes time-barred. In the event of litigation/proceedings, in particular legal proceedings, initiated before the end of the above periods and which would require the retention of personal data in particular with a view to establishing, exercising or defending the rights of Zenchef and/or the Group Company concerned, such data will be retained for the duration of the said proceedings and until the ordinary and extraordinary remedies are no longer possible against the decision rendered. Zenchef and/or the Group Company concerned may keep all decisions until they have been fully implemented, or even as permanent archives.

Note: with regard to all the data retention periods in active databases referred to in paragraph 4 above, you are hereby informed that these are the periods applied “in principle” by the data controller(s), unless you exercise your right of erasure, objection or you withdraw your consent, in the situations and in accordance with the details referred to in paragraph 6 below. In this latter case, once such rights have been exercised, your data will only be kept in the form of archives for the period referred to in 4.16 above.

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5. Who will receive your personal data? How do we share your data?

5.1 As a matter of principle, only authorised persons within the Zenchef Group may access your personal data when such access is necessary for the performance of their duties and/or assignments, namely authorised staff (including employees, trainees, temporary staff, etc.) of Zenchef and/or the Group Companies, in particular staff in charge of marketing, communication, public relations/public affairs, sales management, recruitment and human resources, customer and prospective customer relations, administration, finance and legal affairs, development, IT, projects, etc.

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5.2 Recipients outside the Zenchef Group may also receive communication of your personal data, namely:

the Customers with whom you interact/exchange (e.g. Customer with whom you have made a reservation or placed an order, Customer with whom you have paid your bill via the pay-at-table module provided by Zenchef, etc.);
the departments or entities responsible for auditing Zenchef and/or the Group Companies and/or the Customers, where applicable (statutory auditors, departments or entities responsible for internal or external audit procedures, bodies authorised to carry out audits, etc.);
advisors of Zenchef and/or the Group Companies and/or the Customers, where applicable (legal, financial, accounting, etc.);
partners of Zenchef and/or the Group Companies and/or Customers, where applicable, including in particular their current or potential service providers and suppliers;
publishers of social networks, publishers of third-party websites or publishers of cookies used on the site, or even third-party companies involved, for example, in canvassing operations, communications, etc., or in the management of our marketing, or for the operation of the site in the broadest sense (e.g.: availability and proper functioning of the offered features, performance, security, etc.). In this respect, it is also specified for the record that if you post content disclosing your personal data on the Internet, and in particular on the site or on Zenchef social network pages, this content may of course be accessible to any Internet user. In addition, if you leave your review online via the Reviews service, you are informed that your data, and in particular the rating left by you, may be distributed and more generally used on publicly accessible digital media, and in particular on the Zenchef mobile application. Furthermore, if you have consented to us using your personal data for internal and/or external communication purposes, your data may be accessed/viewed by the audiences for whom these communications are intended, depending on the uses to which you have consented;

technical or other service providers involved in activities or assignments for which access to personal data is necessary and/or justified. This category of recipients may also include any publisher of an application, computer program or tool used in the course of our business, or any IT or maintenance service provider of the applications, computer programs and/or tools used by Zenchef and/or by Group Companies and/or by Customers, as the case may be, and in which your personal data may be processed;
social security and tax bodies authorised to receive personal data in certain cases;
organisations, judicial and legal officers, in particular in the context of their debt collection activities;
if applicable, the organisation in charge of managing the "Do Not Disturb" list;
judicial officers and, where applicable, the courts or competent administrative or judicial authorities, to enable the sale or transfer of all or part of the activities or assets of Zenchef and/or Group Companies and/or Customers, where applicable, or as part of the management and monitoring of pre-litigation and/or litigation;
the insurers of Zenchef and/or the Group Companies and/or the Customers, where applicable.

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5.3 The data controller(s) may also be required to disclose your personal data in the event of legitimate requests from public or authorised authorities, on the basis of legal or regulatory provisions applicable to them. Your personal data may therefore be communicated to any authority empowered to know it, in particular in the event of a requisition from the judicial, police or administrative authorities.

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5.4 Please note that the above-mentioned recipients are not necessarily recipients of all your personal data, but only that necessary for the purpose for which the data is communicated.

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6. What are your rights and how can you exercise them?

6.1 In accordance with the terms and conditions and within the limits defined by the legal and regulatory provisions on the protection of personal data, you have the following rights with regard to your data:

Right of access: you may obtain confirmation as to whether or not your personal data is being processed by the data controller(s), where such data is being processed, access to said personal data, and certain information relating to the processing of your personal data and the characteristics of such processing;

Right of rectification: you can request the rectification of your personal data that you consider incomplete or inaccurate;

Right to erasure: you may, in certain circumstances provided for by the applicable provisions, request the erasure of your personal data (except, for example, if it is necessary for the performance of your contractual relationship with the data controller(s), or if it is necessary for the data controller(s) to comply with its/their legal or regulatory obligations or to establish or exercise its/their rights);

Right to restriction of processing: you may request a restriction on the processing of your personal data, i.e. in certain cases, you may request that your personal data be marked in order to restrict future processing;

Right to data portability: you have the right, in certain circumstances and subject to certain conditions laid down by the applicable provisions, to request to receive your personal data that you have provided to us or, where technically possible, to have it transferred to a third party, in a machine-readable form (it being specified that this right to data portability applies only to processing based on the consent of the data subjects or on the performance of contractual relations, and provided that the data processing is carried out using automated processes);

Right to withdraw your consent: you may withdraw your consent if the processing is carried out on the basis of your consent, without the withdrawal of such consent affecting the lawfulness of the processing based on consent carried out prior to the withdrawal thereof;

Right to set up instructions for the retention, deletion or communication of your personal data after your death. In this respect, in the event of your death which is brought to the attention of the data controller(s), please be aware that your personal data will be deleted (unless it is required to be retained for a specific period of time for reasons relating to our legal and regulatory obligations and/or the mandatory statutory limitation and/or retention periods referred to above in paragraph 4 in the details of the characteristics of the processing operations), after having been communicated, where applicable, to a third party designated by you.

Moreover, in certain cases and under certain conditions provided for by the applicable provisions, you have the right to object, which enables you to object to the processing of your personal data on grounds relating to your particular situation, it being specified that in the case of canvassing operations, including profiling operations linked to such canvassing, you have an absolute right of objection, which may be exercised at any time without having to provide any grounds or justification.

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6.2 With regard to the processing of your personal data carried out by Zenchef and/or by the
Group Companies as data controller(s) (jointly or otherwise), and also with regard to the
processing carried out by Zenchef as joint data controller(s) with Customers or with Zenchef Group
partners, as described in this Personal Data Protection Policy, these rights may be exercised with
Zenchef's Data Protection Officer, whose contact details are given below.
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If such a request is received, it will be answered as soon as possible, and in any event within a maximum of one month from receipt of the request. If necessary, this deadline may be extended by two months, depending on the complexity and number of requests received, in which case the requesting person will be informed.
In the event of reasonable doubt as to the identity of the data subject submitting such a request for the exercise of the aforementioned rights, he or she may be asked to provide additional information necessary to confirm his or her identity and may be asked to provide a photocopy of an identity document bearing his or her signature for this purpose, where the situation so requires. In such a case, the aforementioned response times will be suspended pending receipt of the additional information needed to identify the data subject.
The request may be made by the data subject or by a person specially appointed for this purpose by the data subject, provided that this appointed person can prove his or her identity and the identity of the principal, as well as the duration and precise purpose of the mandate. The mandate must also specify whether the appointed person may receive the reply.
You are also informed that:

Zenchef has appointed a data protection officer and indicated this to the competent supervisory authority in France, the Commission Nationale de l'Informatique et des Libertés ("Cnil"). The contact details of the data protection officer appointed by Zenchef are as follows: privacy@zenchef.com - Zenchef, 63 avenue de Villiers, 75017 Paris (France);
Resengo has appointed a data protection officer and indicated this to the competent supervisory authority in Belgium, i.e. the Data Protection Authority. The contact details of the Data Protection Officer appointed by Resengo are as follows: privacy@resengo.com - Borsbeeksebrug 1, BE-2600 Berchem (Belgium).

6.3 With regard to the processing of your personal data carried out by Customers or by Zenchef Groupe partners in their capacity as data processors, and not jointly with Zenchef, we remind you that they are not covered by this Personal Data Protection Policy. It is up to you to contact the entity concerned directly to exercise your rights with regard to such processing.

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6.4 Furthermore and for the record, Zenchef may in certain cases be considered jointly responsible for the processing of your personal data with the social networks in which Zenchef has dedicated pages or with which Zenchef offers you interactions (see details of purposes in paragraph 4 above). Depending on the social network concerned, the joint controller may be:

Regarding Facebook (Meta) and Instagram: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour Dublin 2, Ireland. For more information on how Meta Platforms Ireland Limited processes your personal data, please refer to the Meta Platforms Ireland Limited data use policy, as well as the Cookie Policies of Facebook and Instagram;
for Twitter (X): Twitter International Unlimited Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Ireland. For more information on how Twitter processes your personal data, please refer to the Privacy Policy and the Cookie Policy of Twitter;
for LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. For more information on how LinkedIn processes your personal data, please refer to the Privacy Policy and the Cookie Policy of LinkedIn, where applicable, in order to configure the cookies used on the pages of this social network.

In these cases, to exercise your aforementioned rights, you may also use your account settings on the aforementioned social networks and/or contact:

in the case of Facebook and Instagram: the Data Protection Officer of Meta Platforms Ireland Limited by email, in particular using the dedicated contact form;
in the case of Twitter (X): the Data Protection Officer of Twitter by e-mail, in particular using the dedicated contact form;
in the case of LinkedIn: the Data Protection Officer of LinkedIn by e-mail, in particular using the dedicated contact form.

6.5 Finally, you have the right to lodge a complaint with the competent supervisory authority if you deem that your personal data is not being processed in accordance with the legal and regulatory provisions on the protection of personal data:

in France, this is the Commission Nationale de l'Informatique et des Libertés ("Cnil"): 3 place de Fontenoy - TSA 80715 – 75334 Paris cedex 07 (France); Tel.: +33 (0)1 53 73 22 22) - https://www.cnil.fr/en/contact-cnil;
in Belgium, this is the Data Protection Authority: rue de la Presse 35 - Drukpersstraat 35 - 1000 Brussels - Tel.: +32 (0)2 274 48 00 - contact@apd-gba.be;
in the Netherlands, this is the Autoriteit Persoonsgegevens: Hoge Nieuwstraat 8 - P.O. Box 93374 - 2509 AJ Den Haag/The Hague - Tel. +31 (0)70 888 8500.

If you are located in the European Union, in a country which is not mentioned above, you may of course lodge such a complaint with the supervisory authority of the country concerned, it being specified that the list of European supervisory authorities is accessible at the following address: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
To understand your rights, you can also refer to the explanations provided by the Cnil here: https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles or, if you are located in another member country of the European Union, with the competent supervisory authority for the protection of personal data.
6.6 You are also informed that, in accordance with articles L.223-1 et seq. of the French Consumer Code, you may, if you are a consumer, object at any time to being contacted by telephone, by registering free of charge on the site “www.bloctel.gouv.fr”.

7. How is your personal data secured?

7.1 The Zenchef Group implements appropriate organisational and technical security measures, in particular with regard to the categories of personal data processed, the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks, which vary in probability and severity, to the rights and freedoms of individuals, in order to protect your personal data against any malicious intrusion, loss, alteration or disclosure to unauthorised third parties, and more generally to preserve the security and confidentiality of said personal data and guarantee a level of security appropriate to the risk.
Because of the difficulties inherent in doing business on the Internet and the risks resulting from the transmission of data by electronic means, which you are aware of, Zenchef Group cannot be held to a performance obligation.
In the event of difficulties arising, the Zenchef Group will make its best efforts to contain the risks and will take all appropriate measures, in accordance with its legal and regulatory obligations (corrective action, informing a supervisory authority if necessary and, where applicable, the data subjects, etc.).

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7.2. During the development, design, selection and use of our services offered on the site which are based on the processing of personal data, the Zenchef Group takes into account the right to the protection of personal data by default and by design (see the principles of "Privacy by design and by default").

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7.3 Access to your personal data is restricted to our employees or partners, and more generally to the recipients referred to above, who are authorised and who need to know such data in order to carry out their duties and/or activities.

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7.4 In the event of subcontracting all or part of the processing of personal data, the Zenchef Group contractually requires its data processors to guarantee the security and confidentiality of the personal data to which they may have access (appropriate technical and organisational data protection measures).

8. Is your personal data transferred outside the European Union?

8.1 Your personal data is preferably processed in the European Union.

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8.2. For the above purposes, some of your personal data may however be transferred to third parties established in countries outside the European Union (e.g. processors involved in the above-mentioned processing operations).
Some of these entities are considered to ensure a sufficient level of protection for personal data because they are established in a country whose regulations on the protection of personal data have been recognised as ensuring an adequate level of protection for said data (see European Commission adequacy decisions https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) or because they have undertaken to comply with a data protection framework known as the "Data Privacy Framework" (the list of entities concerned is available here: https://www.dataprivacyframework.gov/s/participant-search, it should be noted however that this data protection framework only concerns US entities).
Furthermore, if the country of the entity concerned or the entity itself does not offer an adequate level of protection of said data, we ensure that appropriate security and confidentiality measures are taken to guarantee the continued protection of your data.
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In such cases, you are informed that transfers of your personal data to other entities outside the European Union are subject to the signing of contractual clauses with the recipients of said data, in accordance with the recommendations of the European Commission, to ensure that appropriate safeguards are taken to protect such data.
You are also informed that transfers of personal data outside the European Union are lawful if the transfer is necessary for the performance of a contract between the data subject and the data controller, or for the implementation of pre-contractual measures taken at the request of the data subject, if the transfer is necessary for entering into or for the performance of a contract entered into in the interests of the data subject between the data controller and another natural or legal person, or if the data subject has given his or her explicit consent to the planned transfer, after having been informed of the risks that this transfer could entail for him or her due to the absence of an adequacy decision and appropriate safeguards.
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A copy of the reference documents referred to in this paragraph may be obtained (free of any commercial information considered sensitive or confidential or covered by business secrecy), from the contact mentioned in the above paragraph "What are your rights and how to exercise them?".

9. What links do the site and social networking pages have to third-party sites?

9.1 Zenchef's digital media (in particular the site or Zenchef's pages on social networks) may provide or include links to third-party websites, including social networking sites. Zenchef has no control over the activity of these sites and the policies they apply to protect your personal data and your rights. We recommend that you examine the safeguards offered by these sites before interacting with them. In this respect, your attention is drawn to the fact that the personal data protection policy of these sites may differ from this Personal Data Protection Policy and that it is your responsibility to familiarise yourself with them.

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9.2 If you post content disclosing your personal data on the Internet, and in particular on social networks, including Zenchef's social network pages, this content may be accessible to any Internet user and collected or used by third parties for purposes for which Zenchef is not responsible. In any event, Zenchef shall not be held liable in the event that the processing of personal data implemented via one of these third-party sites contravenes applicable legal and regulatory provisions.

10. Can this Personal Data Protection Policy be modified?

10.1 This Personal Data Protection Policy may be modified at any time, with effect from the date of publication of the corresponding update.

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10.2 In the event of a change, the new Personal Data Protection Policy will be posted on the site in the dedicated section. In addition, all personal data collection forms that may appear on the site provide a link to this Personal Data Protection Policy.

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10.3 We therefore invite you to consult it regularly.

Date of last update: 29.05.2024

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