Legal mentions and cookies


Customer: any professional or capable individual within the meaning of articles 1145 and following of the Civil Code, or legal entity, who visits the Site that is the subject of these general conditions.

Services:  provision of the Site to Clients:

Contents: All the elements constituting the information on the Site, in particular texts – images – videos – photos.

Customer information: Hereinafter referred to as “Information (s)” which corresponds to all personal data that may be held by for the purposes of analysis and statistics for the management of your account, customer relationship management.

User: Internet user connecting, using the aforementioned site.

Personal information: “Information that allows, in any form whatsoever, directly or indirectly, the identification of the natural persons to which it applies” (Article 4 of Law No. 78-17 of January 6, 1978).

The terms “personal data” (or Personal Data), “person concerned”, “subcontractor” and “sensitive data” have the meaning defined by the General Data Protection Regulations (RGPD: n° 2016-679).

Website :

1. Presentation of the website.

By virtue of article 6 of law no. 2004-575 of 21 June 2004 on confidence in the digital economy, users of the website are informed of the identity of the various parties involved in its creation and monitoring:

Owner: Spiecapag paid up capital of 14 400 000€ VAT number: FR 47 399 237 494  – 165 boulevard de Valmy 92700 colombes
Publication manager: Spiecapag –
The publication manager is a legal entity.
Developments & interventions: Whodunit
Data Protection

2. General conditions of use of the site and services offered.

The Site constitutes a work of the mind protected by the provisions of the Intellectual Property Code and the applicable International Regulations. The Customer may not in any way reuse, transfer or exploit for his own account all or part of the elements or works on the Site.

The use of the site implies full and complete acceptance of the general conditions of use described below. These conditions of use may be modified or supplemented at any time, Users of the website are therefore invited to consult them on a regular basis.

This website is normally accessible to Users at all times. However, an interruption for technical maintenance may be decided by, which will make every effort to inform Users in advance of the dates and times of the intervention, as far as possible and depending on the urgency of the intervention. The Website is regularly updated by the contributors appointed within Spiecapag. Similarly, the legal notices may be modified at any time: they are nevertheless binding on the user, who is invited to refer to them as often as possible in order to read them.

3. Description of the services provided.

The purpose of the website is to provide information concerning all of the company’s activities. Spiecapag strives to provide information on the website that is as accurate as possible. However, it cannot be held responsible for omissions, inaccuracies and shortcomings in updating, whether caused by itself or by the third party partners who provide it with this information.

All the information indicated on the website is given as an indication, and is subject to change. Furthermore, the information on the website is not exhaustive. It is given subject to correction, completion or updating having been made since it was put online.

4. Contractual limitations on technical data.

The Site uses JavaScript technology. The Website may not be held liable for any material damage related to the use of the Website. In addition, the user of the site undertakes to access the site using recent, virus-free equipment and with a latest-generation browser that has been updated. The website is hosted by a service provider on the territory of the European Union in accordance with the provisions of the General Regulation on Data Protection (RGPD: n° 2016-679).

The objective is to provide benefits and services that ensure the best rate of accessibility. The host ensures the continuity of its service 24 hours a day, every day of the year. It nevertheless reserves the right to interrupt the hosting service for the shortest possible time, in particular for maintenance, improvement of its infrastructures, infrastructure failure or if the Services and Benefits generate traffic deemed abnormal.

Spiecapag and the host cannot be held liable in the event of malfunctioning of the Internet network, telephone lines or computer and telephony equipment related in particular to network congestion preventing access to the server.

5. Intellectual property and counterfeits.

Spiecapag is the owner of the intellectual property rights and holds the usage rights to all elements accessible on the Website, in particular texts, images, graphics, logos, videos, icons and sounds. Any reproduction, representation, modification, publication, adaptation of all or part of the elements of the Website, regardless of the means or process used, is prohibited without prior written authorisation from Spiecapag.

Any unauthorised use of the Site or any of the elements it contains will be considered as constituting an infringement and will be prosecuted in accordance with the provisions of articles L.335-2 and following of the Intellectual Property Code.

6. Limitations of liability.

Spiecapag acts as the publisher of the Site. It is responsible for the quality and truthfulness of the Content that it publishes.

Spiecapag may not be held liable for any direct or indirect damage caused to the User’s equipment when accessing the website, and resulting either from the use of equipment that does not meet the specifications indicated in point 4, or from the occurrence of a bug or incompatibility.

Spiecapag cannot also be held liable for indirect damage (such as loss of business or loss of opportunity) resulting from the use of the https://spiecapag.comwebsite. Interactive areas (possibility to ask questions in the contact area) are available to Users. Spiecapag reserves the right to delete, without prior notice, any content posted in this space that contravenes the legislation applicable in France, in particular the provisions relating to data protection. Where applicable, Spiecapag also reserves the right to hold the user liable under civil and/or criminal law, in particular in the event of a racist, insulting, defamatory or pornographic message, regardless of the medium used (text, photograph, etc.).

7. Management of personal data.

The Customer is informed of the regulations concerning marketing communication, the law of 21 June 2014 for confidence in the Digital Economy, the Data Protection Act of 6 August 2004 and the General Regulations on Data Protection (RGPD: No. 2016-679).

7.1 Persons responsible for the collection of personal data

For Personal Data collected in the context of the creation of the User’s personal account and his navigation on the Site, the person responsible for processing Personal Data is: Spiecapag. Spiecapag is represented by Benoît Lecinq, its Chairman.

As the person responsible for processing the data it collects, Spiecapag undertakes to comply with the legal provisions in force. In particular, it is its responsibility to establish the purposes of its data processing, to provide its prospects and clients, on the basis of the collection of their consent, with full information on the processing of their personal data and to maintain a register of processing that is consistent with reality. Whenever Spiecapag processes Personal Data, Spiecapag shall take all reasonable steps to ensure the accuracy and relevance of the Personal Data in relation to the purposes for which it processes them.

7.2 Purpose of collected data

Spiecapag may process all or part of the Personal Data:

  • to enable browsing on the Site and the management and traceability of the Services ordered by the User: connection and Site use data, etc.
  • to prevent and fight against computer fraud (spamming, hacking, etc.): computer equipment used for browsing, IP address, password (hash), etc.
  • to improve navigation on the Site: connection and usage data
  • to conduct optional satisfaction surveys on email address
  • to carry out communication campaigns (sms, mail): telephone number, email address does not market personal data, which is therefore only used out of necessity or for statistical and analytical purposes.

7.3 Right of access, rectification and opposition

In accordance with the European regulations in force, Users of the website have the following rights:

  • right of access (article 15 RGPD) and rectification (article 16 RGPD), updating, completeness of Users’ data right to block or erase Users’ personal data (article 17 RGPD), when they are inaccurate, incomplete, ambiguous, outdated, or whose collection, use, communication or storage is prohibited;
  • right to withdraw consent at any time (article 13-2c GDMP);
  • right to limit the processing of Users’ data (Article 18 GDMP);
  • right to object to the processing of Users’ data (Article 21 DPMR);
  • right to the portability of the data provided by Users, when these data are subject to automated processing based on their consent or on a contract (Article 20 GDMP);
  • right to define the fate of Users’ data after their death and to choose to whom should communicate (or not) their data to a Third Party that they have previously designated.

As soon as becomes aware of the death of a User and in the absence of prior instructions from him, undertakes to destroy his data, unless its conservation proves necessary to meet a legal obligation.

If the User wishes to find out how Spiecapag uses his Personal Data, to ask for it to be rectified or to oppose its processing, the User may contact Entrepose Group in writing at the following address:

Spiecapag – DPO, Hugues Toussaint
165 boulevard de Valmy 92700 colombes, France.

In this case, the User must indicate the Personal Data that he/she would like Spiecapag to rectify, update, complete or delete, by identifying himself/herself precisely with a copy of an identity document (identity card or passport).

Requests for the deletion of Personal Data shall be subject to the obligations imposed on Spiecapag by law, in particular with regard to the conservation or archiving of documents. Finally, Users of may file a complaint with the control authorities, and in particular with the CNIL (

You can also request the recovery or deletion of your personal data via the following form :

7.4 Non-communication of personal data

Spiecapag shall refrain from processing, hosting or transferring Personal Data on its Customers to a country outside the European Union or recognised as “unsuitable” by the European Commission without prior notice to the Customer. However, Spiecapag remains free to choose its technical and commercial subcontractors provided that they offer sufficient guarantees with regard to the requirements of the General Data Protection Regulation (RGPD: n° 2016-679).

Spiecapag undertakes to take all necessary precautions to preserve the security of Information and in particular that it is not communicated to unauthorised persons. However, if an incident affecting the integrity or confidentiality of the Customer’s Information is brought to the attention of Spiecapag, the latter shall inform the Customer as soon as possible and inform him/her of the corrective measures taken. Furthermore, Spiecapag does not collect any “sensitive data”.

The User’s Personal Data may be processed by Spiecapag subcontractors (service providers), exclusively in order to achieve the purposes of this policy.

Within the limits of their respective attributions and for the purposes mentioned above, the main persons likely to have access to the data of Spiecapag Users are mainly Spiecapag’s sales representatives.

8. Incident notification

No matter how hard you try, no method of transmission over the Internet and no method of electronic storage is completely secure. Therefore, we cannot guarantee absolute security. If we become aware of a security breach, we will notify the Users concerned so that they can take appropriate action. Our incident notification procedures take into account our legal obligations, whether at national or European level. We are committed to keeping our Customers fully informed of all matters relating to the security of their accounts and to providing them with all the information necessary to help them comply with their legal obligations.

No personal information of the User of the website is published without the User’s knowledge, exchanged, transferred, assigned or sold on any medium whatsoever to third parties. Only in the event of the transfer of Spiecapag and its rights would it be possible to transmit the said information to the potential purchaser, who would in turn be bound by the same obligation to keep and modify the data with regard to the User of the website.


To ensure the security and confidentiality of Personal Data and Personal Health Data, Spiecapag uses networks protected by standard devices such as firewalls, pseudonymization, encryption and passwords.

When processing Personal Data, the Spiecapag takes all reasonable steps to protect it from loss, misuse, unauthorized access, disclosure, alteration or destruction.

9. Hypertext links “cookies” and internet tags

The website contains a number of hyperlinks to other sites, set up with the authorisation of Spiecapag. However, Spiecapag is not in a position to verify the content of the sites visited in this way, declines all responsibility for this fact and assumes no consequences.

Unless you decide to disable cookies, you agree that the site may use them. You may deactivate these cookies at any time, free of charge, using the deactivation options offered to you and recalled below, bearing in mind that this may reduce or prevent access to all or part of the Services offered by the site.


A “cookie” is a small information file sent to the User’s browser and stored on the User’s terminal (e.g. computer, smartphone), (hereinafter “Cookies”). This file includes information such as the User’s domain name, the User’s Internet service provider, the User’s operating system, and the date and time of access. Cookies can in no way damage the User’s terminal.

Spiecapag is likely to process the User’s information concerning their visit to the Site, such as the pages consulted and searches carried out. This information enables Spiecapag to improve the content of the Site and the User’s navigation.

As Cookies facilitate navigation and/or the provision of services offered by the Site, the User can configure his browser to allow him to decide whether or not to accept them so that Cookies are recorded in the terminal or, on the contrary, that they are rejected, either systematically or according to their issuer. The User may also configure his browser software so that he is offered the possibility of accepting or rejecting Cookies from time to time, before a Cookie is likely to be stored on his terminal. Spiecapag informs the User that, in this case, it is possible that not all the functionalities of his browser software will be available.

If the User refuses to accept the registration of Cookies in his or her terminal or browser, or if the User deletes those registered, the User is informed that his or her browsing and experience on the Site may be limited. This could also be the case when or one of its service providers cannot recognise, for technical compatibility purposes, the type of browser used by the terminal, the language and display settings or the country from which the terminal appears to be connected to the Internet.

Where applicable, Spiecapag declines all responsibility for the consequences related to the degraded functioning of the Site and any services possibly offered by, , resulting (i) from the User’s refusal to accept Cookies (ii) from the impossibility for to record or consult the Cookies necessary for their functioning due to the User’s choice. The configuration of each browser is different for the management of Cookies and the User’s choices. It is described in the browser’s help menu, which will show how the User can change his wishes regarding Cookies.

At any time, the User may choose to express and modify his or her wishes regarding Cookies. Spiecapag may also use the services of external service providers to assist it in collecting and processing the information described in this section.

Finally, by clicking on the icons dedicated to the social networks Youtube and Linkedin on the Site of or in its mobile application, and if the User has accepted the deposit of cookies by continuing his navigation on the Website or the mobile application of, Linkedin and Youtube may also deposit cookies on your terminals (computer, tablet, mobile phone).

These types of cookies are only placed on your terminals if you agree to them by continuing to browse the Website or the mobile application of At any time, the User may nevertheless revoke his/her consent for to deposit this type of cookies.

  • Cookie Name: PHPSESSID
    Purpose: Cookie generated by applications based on the PHP language. It is a general purpose identifier used to manage user session variables.
    Expiration: End of session
  • Cookie Name: wordpress_logged_in
    Purpose: The cookie indicates when the user has logged in (WordPress).
    Expiration: End of session
  • Cookie Name: wordpress_test_cookie
    Purpose: Cookie used on sites built with WordPress. Tests if the browser has cookies enabled
    Expiration: End of session
  • Cookie Name: icl_current_admin_language icl_current_language
    Purpose: These cookies are used to store the value of the language in which the user wishes to consult the website.
    Expiration: 1 day

Article 9.2. INTERNET TAGS may occasionally use Internet tags (also known as “tags”, or action tags, single-pixel GIFs, transparent GIFs, invisible GIFs, and one-to-one GIFs) and deploy them through a web analytics partner that may be located (and thus store the corresponding information, including the User’s IP address) in a foreign country.

These tags are placed both in online advertisements allowing Internet users to access the Site, and on the various pages of the Site.

This technology allows Spiecapag to evaluate visitors’ responses to the Site and the effectiveness of its actions (for example, the number of times a page is opened and the information consulted), as well as the User’s use of the Site.

The external service provider may collect information about visitors to the Site and other websites using these tags, compile reports on Site activity for, and provide other services related to the use of the Site and the Internet.

10. Applicable law and jurisdiction.

Any dispute relating to the use of the website is subject to French law. Except in cases where the law does not allow it, exclusive jurisdiction is given to the competent courts of Nanterre.