Privacy Policy
1. Overview
The following information provides a simple overview of what happens to your personal data when you visit our website www.e-roe.com or contact us. Personal data is any data by which you can be personally identified.
Who is responsible for data collection on this website? Data processing on this website is carried out by the website operator. Their contact details can be found in the "Data Controller" section below.
How do we collect your data? Your data is collected partly when you provide it to us — for example via our contact form. Other data is collected automatically when you visit the site, including technical data (browser, operating system, time of access).
What do we use your data for? Some data is collected to ensure the proper functioning of the website. Other data may be used to analyse site traffic or, with your consent, for commercial and advertising purposes.
What rights do you have? You have the right at any time to receive free information about the origin, recipient and purpose of your stored personal data, as well as the right to request its rectification or deletion. For any questions, you may contact us at any time at the address given below.
2. Data Controller
E-ROE SAS 189 Route de Sorlin 38110 La Chapelle-de-la-Tour France
SIREN: 929 898 245 RCS: Vienne
Email: contact@e-roe.com Website: www.e-roe.com
3. Hosting — Odoo Cloud
This website is built and hosted via Odoo Website, a service of Odoo S.A., Chaussée de Namur 40, 1367 Grand-Rosière, Belgium.
As publisher of the Odoo Online (SaaS) solution, Odoo S.A. acts as a data processor within the meaning of Art. 28 GDPR: E-ROE remains the sole data controller for all data collected on this website, and Odoo S.A. processes such data exclusively according to our instructions. A Data Processing Agreement (DPA) is included in the Odoo Enterprise subscription terms.
Personal data collected on this website is hosted on servers located within the European Union (OVH and/or Google Cloud infrastructure, European region). Backup copies are replicated across multiple geographically distinct datacentres, always in compliance with GDPR requirements.
Odoo Cloud is used to ensure the secure, fast and reliable operation of our website, with 256-bit SSL encryption of all communications and automatic daily backups (Art. 6(1)(f) GDPR).
For more information: www.odoo.com/privacy
4. Online Shop — Shopify
Our online shop is powered by Shopify, published by Shopify International Ltd., 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32, Ireland.
Shopify processes our customers' personal data (name, postal address, email address, payment information, order history) for the purposes of executing sales contracts and managing orders. Processing is based on Art. 6(1)(b) GDPR (performance of a contract).
Depending on account settings, data may be transferred to Shopify Inc. servers in Canada or the United States. Canada is recognised as a safe third country under GDPR. For transfers to the United States, Shopify relies on the European Commission's Standard Contractual Clauses. We have concluded a Data Processing Agreement (DPA) with Shopify in accordance with Art. 28 GDPR.
For more information: www.shopify.com/legal/privacy
5. General Information and Rights
Retention period
Your personal data will be retained until the purpose of the processing no longer applies. If you submit a legitimate deletion request or withdraw your consent to processing, your data will be deleted, unless we have other legally valid grounds for retaining it (e.g. tax or commercial retention obligations).
Note on data transfers outside the EU
Certain tools integrated into our website may involve the transfer of data to third countries, in particular the United States. We ensure in all cases that appropriate safeguards are in place — in particular the European Commission's Standard Contractual Clauses — before any such transfer.
Withdrawal of consent
You may withdraw any consent previously given to the processing of your data at any time. The lawfulness of processing carried out prior to the withdrawal is not affected.
Right to object (Art. 21 GDPR)
WHERE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT, AT ANY TIME AND ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA. WE WILL THEN NO LONGER PROCESS YOUR DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS (ART. 21(1) GDPR).
WHERE YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME. AFTER YOUR OBJECTION, YOUR DATA WILL NO LONGER BE USED FOR SUCH PURPOSES (ART. 21(2) GDPR).
Right to lodge a complaint with a supervisory authority
In the event of a GDPR violation, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. In France, the competent authority is the Commission Nationale de l'Informatique et des Libertés (CNIL) — www.cnil.fr.
Access, rectification, erasure and portability
You have the right at any time to obtain free information about your stored personal data, its origin, recipients and the purpose of its processing, as well as the right to rectification, erasure and data portability. Please contact us at any time at contact@e-roe.com.
Right to restriction of processing
You have the right to request restriction of the processing of your personal data in the following cases: if you contest the accuracy of the data; if the processing is unlawful and you prefer restriction to erasure; if we no longer need the data but you require it for the establishment, exercise or defence of legal claims; if you have lodged an objection and the balancing of interests is pending.
6. Data Collection on This Website
Cookies
Our website uses cookies that are technically necessary for the proper functioning of the site, stored on the basis of Art. 6(1)(f) GDPR. Third-party services likely to set tracking cookies (social networks, analytics tools, advertising, video players) are automatically blocked until you have given your explicit consent via our cookie management banner. You may change your preferences or withdraw your consent at any time via the same tool.
You may also configure your browser to be notified when cookies are set, to allow cookies only on a case-by-case basis, or to activate automatic deletion of cookies when the browser is closed.
Server log files
Odoo Cloud automatically collects information in server log files: browser type and version, operating system, referring URL, IP address, time of request. These data are not merged with other data sources and are collected on the basis of Art. 6(1)(f) GDPR.
Contact form
If you send us a request via the contact form, your data (name, email address, message) will be stored in order to process your request and to answer any follow-up questions. We do not pass on this data without your consent.
Processing is based on Art. 6(1)(b) GDPR (pre-contractual measures) or on our legitimate interest in efficiently handling incoming requests (Art. 6(1)(f) GDPR). Data is retained until your request has been fully processed, then deleted, subject to any legal retention obligations.
Requests by email or telephone
If you contact us by email or telephone, your request and the associated personal data (name, enquiry) will be stored for processing purposes. Processing is based on Art. 6(1)(b) or 6(1)(f) GDPR as applicable. Data is retained until the purpose of the processing no longer applies.
7. Social Media
We integrate functions from the social networks listed below into our website. These functions are not activated and no connection to third-party servers is established until you have given your consent via our cookie management banner, in accordance with Art. 6(1)(a) GDPR. You may withdraw your consent at any time.
Please note that data transfers to third countries, in particular the United States, cannot be excluded for some of these services. These providers rely on the European Commission's Standard Contractual Clauses to govern such transfers.
Provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. When the function is active, LinkedIn is informed of your visit via your IP address. If you are logged into your LinkedIn account, your visit may be associated with your profile.
For more information: www.linkedin.com/legal/privacy-policy
Facebook / Meta
Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. When the function is active, Meta receives information that you have visited our website. If you are logged into your account, this visit may be associated with your profile. Meta may use this data for advertising purposes in accordance with its privacy policy.
For more information: www.facebook.com/privacy/policy
Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. Instagram is a platform belonging to the Meta group. When the function is active, a connection to Instagram's servers is established. If you are logged into your Instagram account, your visit may be associated with your profile.
For more information: privacycenter.instagram.com/policy
YouTube
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When a YouTube video embedded on our site is played, a connection to YouTube's servers is established. YouTube can then identify the page from which you started the video and associate this information with your Google account if you are logged in.
For more information: policies.google.com/privacy
TikTok
Provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin D02 T380, Ireland. When the function is active, usage data is transmitted to TikTok. If you are logged into your TikTok account, your visit may be associated with your profile.
For more information: www.tiktok.com/legal/privacy-policy-eea
8. Video Hosting
YouTube
We embed videos hosted on YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) to showcase our vehicles and activities. When you play an embedded video, a connection to YouTube's servers is established. YouTube can then identify the page from which the video was started and, if you are logged into your Google account, associate this action with your profile.
We use YouTube's privacy-enhanced mode (youtube-nocookie.com) wherever possible, which limits data collection until you activate playback.
Processing is based on your consent (Art. 6(1)(a) GDPR). Videos are only loaded after you have given your consent via our cookie management banner.
For more information: policies.google.com/privacy
Vimeo
We also embed videos hosted on Vimeo, a service of Vimeo, LLC, 555 West 18th Street, New York, NY 10011, United States.
When you access a page on our website containing a Vimeo video and play it, a connection to Vimeo's servers is established. Vimeo then receives information that you have visited our page, along with technical data (IP address, browser, operating system). If you are logged into your Vimeo account, Vimeo may associate your interaction with your profile.
Vimeo may use Google Analytics to analyse usage of its player. For more information on this practice, please refer to Google's privacy policy: policies.google.com/privacy. You may opt out of Google Analytics tracking at: tools.google.com/dlpage/gaoptout.
Processing is based on your consent (Art. 6(1)(a) GDPR). Vimeo videos are only loaded after you have given your consent via our cookie management banner.
Data transfers to the United States cannot be excluded. Vimeo relies on the European Commission's Standard Contractual Clauses to govern such transfers.
For more information: vimeo.com/privacy
9. Analytics
Plausible Analytics
We use Plausible Analytics to analyse traffic on our website. Plausible is a privacy-friendly audience analytics tool published by Plausible Insights OÜ, Västriku tn 2, 50403 Tartu, Estonia (EU).
Plausible sets no cookies on your device and collects no personal data by which you could be identified. The data collected (pages visited, traffic sources, device type, country) are entirely anonymous and aggregated, and are hosted within the European Union.
This processing is based on our legitimate interest in obtaining anonymous usage statistics to improve our website (Art. 6(1)(f) GDPR). No prior consent is required for this tool, in accordance with CNIL guidance on exempt audience measurement tools.
For more information: plausible.io/privacy
Google Analytics
We use Google Analytics to conduct deeper analysis of visitor behaviour on our website. Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
During your visit, the following data is recorded in particular: pages visited, on-site behaviour (clicks, scrolling, time spent), approximate location (country and city), truncated IP address, technical information (browser, device, screen resolution) and the source of your visit. This data is transmitted to Google's servers and may be stored in the United States. Google relies on the European Commission's Standard Contractual Clauses to govern this transfer.
This processing takes place exclusively on the basis of your consent (Art. 6(1)(a) GDPR). Google Analytics is only activated after your explicit consent via our cookie management banner. You may withdraw your consent at any time via the same tool.
For more information: policies.google.com/privacy
10. Online Advertising
Google Ads — Remarketing and Conversion Tracking
We use Google Ads, an advertising service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, to promote our products and measure the effectiveness of our advertising campaigns.
Conversion tracking — Google Ads allows us to measure whether a visitor who clicked on one of our ads subsequently took an action on our website (contact request, product page visit). The data collected is aggregated and does not allow us to identify visitors individually.
Remarketing — This function enables personalised ads for E-ROE vehicles to be displayed to visitors of our website when they browse other sites in the Google network or use Google Search. For this purpose, Google places a remarketing cookie during your visit. The data collected (cookie ID, pages visited, interactions) may be combined by Google with other data to create pseudonymous profiles for advertising purposes.
These processing activities take place exclusively on the basis of your consent (Art. 6(1)(a) GDPR). Google Ads is only activated after your explicit consent via our cookie management banner. You may withdraw your consent at any time via the same tool, or disable personalised advertising directly in your Google settings: adssettings.google.com.
Data transfers to the United States cannot be excluded. Google relies on the European Commission's Standard Contractual Clauses.
For more information: policies.google.com/privacy
Facebook Ads — Meta Pixel and Conversion Tracking
We use Facebook Ads and the Meta Pixel from Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, to run targeted advertising on Facebook and Instagram and to measure its effectiveness.
The Meta Pixel is a snippet of code integrated into our website that enables Meta to detect certain actions taken by visitors (page view, form submission). This information allows us to assess the return on investment of our advertising campaigns and to optimise future ads.
Remarketing — The Meta Pixel also enables us to build custom audiences from visitors to our website, in order to show them targeted ads on Facebook or Instagram at a later stage, or to exclude existing customers from certain campaigns.
Data collected via the Pixel is anonymous to us. It is however stored and processed by Meta, which may link it to the relevant user profile and use it for its own advertising purposes.
These processing activities take place exclusively on the basis of your consent (Art. 6(1)(a) GDPR). The Meta Pixel is only activated after your explicit consent via our cookie management banner. You may withdraw your consent at any time, or manage your preferences directly in your Meta settings.
Data transfers to the United States cannot be excluded. Meta relies on the EU Standard Contractual Clauses.
For more information: www.facebook.com/privacy/policy
11. Newsletter
If you wish to receive our newsletter, we collect your email address and the information necessary to verify your consent. We use this data exclusively to send information about our products and activities, and do not pass it on to third parties.
Processing takes place exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You may withdraw your consent at any time via the unsubscribe link in each newsletter. Your data will be deleted upon unsubscription.
Sending tool — Odoo
Our newsletter is managed and sent via Odoo (Odoo S.A., Chaussée de Namur 40, 1367 Grand-Rosière, Belgium — EU). Odoo processes your contact data on our behalf under a Data Processing Agreement in accordance with Art. 28 GDPR. Data remains hosted within the European Union.
For more information: www.odoo.com/privacy
12. CRM — Odoo
For the management of our customer and prospect relationships, we use Odoo (Odoo S.A., Chaussée de Namur 40, 1367 Grand-Rosière, Belgium).
Odoo processes data such as name, email address, company and interaction history for the purposes of commercial management and request tracking. Processing is based on Art. 6(1)(f) GDPR (legitimate interest in efficient customer relationship management) or Art. 6(1)(b) GDPR (pre-contractual measures) depending on the context. We have concluded a Data Processing Agreement with Odoo in accordance with Art. 28 GDPR.
For more information: www.odoo.com/privacy
13. Summary of Your Rights
Right of access (Art. 15 GDPR) — Obtain confirmation that your data is being processed and receive a copy.
Right to rectification (Art. 16 GDPR) — Have inaccurate or incomplete data corrected.
Right to erasure (Art. 17 GDPR) — Request deletion of your data ("right to be forgotten"), subject to legal retention obligations.
Right to restriction of processing (Art. 18 GDPR) — Request temporary suspension of processing in the cases provided for.
Right to data portability (Art. 20 GDPR) — Receive your data in a structured, machine-readable format.
Right to object (Art. 21 GDPR) — Object to processing, in particular for direct marketing or targeted advertising purposes.
Right to withdraw consent — Withdraw your consent at any time without affecting the lawfulness of prior processing.
To exercise any of these rights: contact@e-roe.com To lodge a complaint with the supervisory authority: CNIL — www.cnil.fr
14. Changes to This Policy
E-ROE reserves the right to update this policy at any time. The version in force is the one published on www.e-roe.com with the date of the last update.
E-ROE SAS — 189 Route de Sorlin, 38110 La Chapelle-de-la-Tour — contact@e-roe.com — www.e-roe.com