At Newable, respecting your privacy and protecting your personal data is our top priority. This Privacy Policy (hereinafter the “Policy”) is intended to inform you about how your personal data is processed when using the website www.newable.energy (the “Site”), in accordance with Regulation (EU) 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”), and with French Law No. 78-17 of January 6, 1978 on information technology, files and freedoms, as amended and currently in force (together, the “Applicable Regulations”).

1. Who is the data controller?

When you browse our Site, or more generally in the context of managing our contractual relationship with you, the data controller is Newable SAS, registered with the Bordeaux Trade and Companies Register under number 984 815 498, with its registered office at 87 Quai des Queyries, 33100 Bordeaux (“We,” “Us,” “Our”).

2. What data do we collect?

Personal data is any information that identifies an individual directly or indirectly by cross-referencing with other data.

We collect personal data from the following categories:

• Identification data: first name, last name, email address, postal address, phone number;

• Professional data: company name, CV, position/function, LinkedIn profile;

• Data relating to your orders or service requests;

• Login data: connection logs, encrypted passwords;

• Any information you choose to provide via our contact form or communications.

Mandatory data is indicated at the time of collection.

3. Purposes and processing of your personal data

• Client management and contract follow-up

  • Legal basis: Contract performance

  • Retention period: For the entire duration of the contractual relationship. Archived for evidentiary purposes: 5 years (excluding banking data).

• Commercial prospecting

  • Legal basis: Legitimate interest in developing our business

  • Retention period: 3 years after the last contact.

• Sending newsletters and promotional communications

  • Legal basis: Legitimate interest

  • Retention period: 3 years after the last contact.

• Telephone marketing

  • Legal basis: Legitimate interest

  • Retention period: 3 years after the last contact.

• Responding to requests for information, contact, or demonstrations

  • Legal basis: Pre-contractual measures

  • Retention period: 3 years after the last contact.

• Administrative and legal archiving

  • Legal basis: Legal compliance

  • Retention period:

    • Invoices: 10 years

    • Transactional data: 5 years

    • Contractual data: 5 years

• Exercise of data subject rights

  • Legal basis: Legal compliance

  • Retention period: Proof of identity kept only for the duration of verification.

4. Recipients of your data

Your personal data may be accessed by:

• Newable staff;

• Our subcontractors: hosting, newsletters, email services, billing;

• Any authority legally authorized to access it (judicial, police, administrative).

5. Data transfers outside the European Union

Your data is stored on servers located within the European Union.

In certain cases (third-party tools, service providers), your data may be transferred outside the EU:

• To countries recognized as adequate by the European Commission;

• With appropriate safeguards (standard contractual clauses, binding corporate rules, certification mechanisms).

You may request the list of tools and safeguards used from our Data Privacy Officer.

6. Your rights over your data

You have the following rights:

• Right to information (Articles 13 and 14 GDPR)

• Right of access (Art. 15 GDPR)

• Right to rectification (Art. 16 GDPR)

• Right to restriction of processing (Art. 18 GDPR)

• Right to erasure (Art. 17 GDPR)

• Right to define post-mortem instructions on retention and communication

• Right to withdraw consent (Art. 7 GDPR)

• Right to data portability (Art. 20 GDPR)

• Right to object (Art. 21 GDPR)

To exercise these rights: sebastien@newable.energy.

If you believe your rights have not been respected, you may lodge a complaint with the CNIL (3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07).

7. Changes

We may update this Policy to remain compliant with legal or technical developments. Changes will take effect on the date of publication. We encourage you to consult this page regularly.

Effective date: September 2025