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Conditions Générales d’Utilisation (CGU)2019-06-03T09:35:52+00:00

Terms of Service (TOS)


As part of its activity, SMART GLOBAL PRIVACY SOLUTIONS, a company incorporated under the laws of Monaco, registered under the number 17S07390, whose registered head office is located at 1 rue du Gabian 98000 Monaco, processes personal data in the database of its solution. 

Smart Global Privacy Solutions provides a platform for managing and monitoring data protection compliance regulations to clients around the world, hereinafter referred to as client. This solution is made available to SMART GLOBAL PRIVACY SOLUTIONS clients in the form of a subscription in the legitimate interest of the client who wishes to have a solution of compliance with the regulations. SMART GLOBAL PRIVACY SOLUTIONS clients are therefore exclusively composed of public or private organisations concerned by these regulations who wish to have an online management tool or solution. 

The purpose of these general conditions of use is to define the terms and conditions of use of the services available on the Smart Global Privacy website.

These will be the only applicable terms and conditionsprevailing over any previously mentioned. 

The lack of opposition to a particular action will never be construed as a waiver of a rightThe use of the Smart Global Privacy service implies the express and unconditional acceptance of the general conditions of use that can be consulted online. 

We invite you to read the terms and conditions carefully before using this site or sending us personal information. 

The Services are very varied: it may be that additional or special conditions apply to certain Services. These additional conditions will be made available to you with the Services concerned. If you choose to use these Services, you agree that these additional conditions are also part of your contractual engagement with us.

The present G.C.U. of the SMART GLOBAL PRIVACY platform is directly from the Privacy Policy, viewable at any time via the link:

A. Access to the service

Access is possible to the Smart Global Privacy platform service (hereinafter the “Service”) subject to compliance by the User with the General Terms and Conditions of Use indicated below (hereinafter referred to as “GCU”). It is recommended to read the GCU at each visit to this website as they may be modified at any time, without notice. 

B. Acceptance of the General Conditions of Use

The use of the Service, whether by free or paid access to the platform (Smart Global Privacy Platform) requires registration and entails the User’s commitment to comply with the GCU. Unless otherwise indicated, when the User has paid for access to the Service, the General Conditions of Sale and Subscription to which he has subscribed prevail over the GCU, even in the event of contradiction. 

Use of the Service implies the User accepts the General Conditions of Sale and Subscription and Special Conditions, 

In the use of this Service, the User may be directed : 

  • to use the Service of a third-party partner of Smart Global Privacy (hereinafter « Partner Services »). Smart Global Privacy represents these Partner Services on the Service’s websiteBy its use, the User accepts the GCU. 
  • to access third-party websites protected by intellectual property rights. 

Use of the Service, whether by free or paid accessrequires registration and is designed to meet reasonable and normal usage. 

C. Use of our Service 


Smart Global Privacy undertakes to implement all means to provide the User with reliable and fast access to the Service. The User declares to have accepted the costs as well as the limits specific to any connection to the Internet network. 

The User, informed of the minimum specifications communicated by Smart Global Privacy, takes responsibility for accessing the Service in good technical conditions (hardware, software, telecommunications) – and for safeguarding and protecting against possible intrusions. 

The information contained on the Smart Global Privacy website is accessible 24 hours a day, 7 days a week, subject to interruption necessary for the proper functioning of the service. This interruption does not give rise to any compensation. A support service, limited to the use of the Service used by subscribed Users (paid access), is available to the User during the business hours set by Smart Global Privacy. 


The data and information available on the site are the property of Smart Global Privacy and can not in any way be the subject of any total or partial extraction of data nor of any transfer to another medium, Internet or not. 

Consequently, the data and information may only be subject to on-screen display and printing on paper or electronic media, for the exclusive benefit of the User and for their own needs, as well as transmission by fax or email, to a recipient linked to the User by the same usage restrictions. The use of any automated system or software to extract data from this website for commercial purposes is prohibited. 

Smart Global Privacy reserves the right to take any action or claim necessary to enforce this prohibition, including in the context of legal proceedings, without prior notice. 

You must comply with the regulation applicable to the services you use. 

Do not use our Service improperly. For example, do not attempt to interfere with or access the Service using any method other than the interface and instructions that we make available to you. You must only use the Service in compliance with applicable laws, including applicable laws and regulations regarding the control of exports and re-exports. We may suspend or terminate the provision of the Service if you fail to comply with any applicable terms or regulations, or if we investigate a suspicion of misuse. 

The use of our Service does not give you any intellectual property rights over our Service or the content you access. You may not use any content obtained through our Service without the permission of the owner of such content, unless permitted by law. These GCU do not give you the right to use any brand or logo from our Service. 

You may not delete, obscure or modify the legal notices displayed in or with our Service. 

We may have to review the content to make sure it complies with the law or our GCU. We reserve the right to remove or refuse to post any content that we reasonably believe is against the law or our policies. The fact that we reserve this right does not necessarily mean that we verify the content. Therefore, please, do not assume that we are reviewing the content. 

As part of your use of the Service and the performance of our contractual commitment, we may send you messages related to the operation or administration of the Service and other information. You can choose to stop receiving some of these messages.

D. Your account provided by SMART GLOBAL PRIVACY

An account is required to use the Service. Your account is assigned by an administrator. The administrator can access your account or deactivate it. 

To protect your account, keep your password confidential. You are responsible for the activity performed on your account. Make sure you do not reuse the same password in other applications. If you discover that your password or account has been used in an unauthorised manner, you must notify Smart Global Privacy immediately. 

Global Privacy reserves the right to cancel any registered User: 

  • in the event of non-compliance by the User with one of the clauses of theseGCU, or in the event of excessive use of the service considered likely to be the result of an illegal use.
    • if requested by the user. 

E. Termination

Smart Global Privacy may terminate the Service at any time 

In the case of breach of the obligations established in this section, Smart Global Privacy reserves the right to terminate the account of the registered User, to prevent its re-registration and to take the appropriate measures and / or resources in order to stop any violation of rights and obtain compensation for damages suffered. 

The User may terminate the use of the Site at any time by unsubscribing in the area provided for this purpose OR by sending an e-mail to the following address: OR By postal mail: Smart Global Privacy, Customer Service 1 rue du Gabian 98000 MONACO 

The request for cancellation by the User will be taken into account by Smart Global Privacy as soon as possible. 

In case of non-compliance with these GCU by the User, Smart Global Privacy reserves the right to terminate access to the Service without notice. 

F. Protection of privacy and copyright  

Smart Global Privacy’s Privacy Policy explains how personal information is processed and how your privacy is protected when you use the Service. By using the Service, you agree that Smart Global Privacy may use this data in accordance with its Privacy Policy. 

We will respond to notifications of alleged copyright infringement and disable the accounts of users who have repeatedly violated these rights, in accordance with the procedure established by the applicable legislation. 

G. Your content and services

Some of our Services allow you to import, submit, store, send or receive content. You maintain all your intellectual property rights over this content.  

The rights granted in this data collection are limited to: 

– The execution of the service for which you have signed a commercial contract with Smart Global Privacy as User – Client or User-partner  

– GCU-approved administration and management of your user registration.  

– The timely payment of invoices for “client(?) or provider(?)” services 

– The exploitation, promotion or improvement of our Services, or the development of new Services. 

This authorisation remains for the entire legal term of protection of your content, even if you stop using the Service. 

Ensure you have the right to transfer the content that you submit to our Service. 

H. Privacy Policy applicable from May 25, 2018

Our data protection policy is available to view at any time on our website

I. Cookies Policy

When you first login to the Smart Global Privacy website, you are informed that information about your browsing could be stored in files called “cookies”. 

Our policy of use of cookies allows you to better understand the provisions that we implement, in terms of navigation, on our site. It informs you, for example, about all the cookies on our website, their purpose (part I.) and gives you the procedure to follow to set up preferences (part II.) 

  • 1. General information about cookies on the Smart Global Privacy website

Smart Global Privacy Solutions, as the publisher of this website, can place a cookie on your terminal’s hard drive (computer, tablet, mobile device, etc.) in order to guarantee optimal navigation.  

“Cookies” are small text files of limited size that recognise your computer, tablet or mobile to customise the services we offer. 

The information collected through cookies does not allow you to be identified by nameIt is used solely to improve the interactivity and performance of our website and to offer content tailored to your interests. 

This information is not disclosed to third parties, except when Smart Global Privacy Solutions has obtained your consent in advance or when the law requires the sending of such information, by order of a court or any administrative or judicial authority.  

To better inform you about the information that cookies identify, you will find below a table listing the different types of cookies that may be used on the website of Smart Global Privacy, their names, purposes and their retention period.  

  • 2. Configure your cookie preferences

You can accept or refuse the deposit of cookies at any time.
When you first log in to the Smart Global Privacy website, a banner briefly outlining information about cookies and similar technologies will appear on your screen. 

This banner informs you that by continuing your navigation on the website of Smart Global Privacy Solutions (by loading a new page or by clicking on various elements of the site for example), you accept the deposit of cookies on your terminal. You are also deemed to have consented to the deposit of cookies by clicking on the “X” icon to the right of the banner on your screen. 

Depending on the type of cookie involved, collecting your consent to deposit and read cookies on your device may be imperative. 

Cookies consent exemption 

In accordance with the recommendations of the control authorities of the European Unionsome cookies are exempt from obtaining prior consentThey are exempt in those cases where they are strictly necessary for the proper functioning of the website or when they have the ultimate objective of enabling or facilitating electronic communication. These include cookies for session ID, authentication, load balancing session cookies as well as cookies for customising your interface. These cookies are fully subject to this policy insofar as they are issued and managed by Smart Global Privacy. 

Cookies requiring the prior collection of your consent  

This requirement applies to third-party cookies that are described as “persistent” because they remain on your device until they are deleted or expire. 

Because these cookies are issued by third parties, their use and deposit are subject to their own privacy policies, which you will find below. This cookie family includes audience measurement cookies (including Google Analytics), advertising cookies (which Smart Global Privacy Solutions does not use) and social sharing cookies (including YouTube, Twitter and LinkedIn).  

Audience measurement cookies provide statistics on the frequency of use and the use of various elements of the website (such as the content / pages you visited). This data contributes to improving the ergonomics of the Smart Global Privacy Solutions website. An audience measurement tool is used on this website. 

The social network sharing cookies are issued and managed by the social network publisher 

Subject to your consent, these cookies allow you to easily share part of the content published on the Smart Global Privacy Solutions site, especially through a “button” to share applications according to the corresponding social network.  

There are four types of social media exchange cookies available on the Smart Global Privacy Solutions website: 

 Facebook: of which you can consult the policy regarding cookies by clicking on the following link

 LinkedIn: you will find the cookie policy by clicking on the following link

 Twitter: here you will find the options dedicated to the control or the restriction of the use of the cookies as well as the policy of use of the cookies

 YouTube, you will find help to delete cookies from the Google Chrome browser by clicking on the following link

and also the complete cookie policy from the following link:

Configuration of cookies 

Most Internet browsers are configured by default to allow cookies. Your browser allows you to modify these standard configurations so that all cookies are rejected systematically or so that only part of the cookies is accepted or refused according to the issuer.  

PLEASE NOTE: The rejection of the deposit of cookies on your terminal could alter your experience as a user and your access to certain services of the website. In this case, Smart Global Privacy Solutions is not responsible for the consequences related to the degradation of navigation conditions that may arise due to your choice to reject, delete or block the cookies necessary for the proper functioning of the website. These consequences could not constitute damage and there can be no claim for any compensation for this fact. Your browser also allows you to delete existing cookies on your device or notify you in the event that new cookies are deposited on your device. This configuration does not affect your browsing, but you lose all the benefit of the cookie. 

Take note below of the many tools available to set cookies on your device. 

Settings in your internet browser  

Each Internet browser has its own cookie management settings. To know how to change your cookie preferences, below are the links you need to access the browser menu provided for this purpose: 

Chrome :

Firefox :

Internet Explorer :

Opera :

Safari :

For more information on the tools for controlling cookies, you can consult the ICO website :

Configuration of the cookies management tool 

The deactivation of cookies can also be made directly through the online tool configured on the Smart Global Privacy Solutions website. Interactively, it allows you to manage your cookies through a banner available on the bottom right of the displayed page (“Service Management” button) and it lists all active cookies.  

To deactivate a cookie, simply click on the cross next to the proposed service. If all cookies are disabled, the banner dedicated to collecting the user’s consent will reappear when the page is updated. 

For any questions or additional requests for information about the current cookie policy, please contact us through our contact form. 

J. Conditions and legal information

1.Identity of the Data Processing Controller 

The Controller of Data Processing is Smart Global Privacy,  represented by its acting manager, Mr. Benoît Guignard, based at 1 rue du Gabian 98000 MONACO. phone : +377,

Response time : Smart Global Privacy Solutions undertakes to respond to your request for access, rectification or objection or any other additional request for information within a reasonable period of time, that may not exceed the period of 1 month, counted from the date of receipt of your request.

Information – ClaimsAny clarification related to the application of these general terms and conditions or any request for information or complaints related to the operation of the Smart Global Privacy service should be addressed to:

By e-mail :

By post : Smart Global Privacy, Service Client, 1 rue du Gabian 98000 MONACO

2.Making a complaint to the competent authority

If you believe that Smart Global Privacy Solutions does not comply with its obligations with respect to your personal information, you have the right to file a complaint or request with the competent authority: The Control and Nominative Information Committee -12 Avenue de Fontvieille – 98000 MONACO – ++ 377 97 70 22 44 

Limited Liability Company, with a capital of 15,000 euros, registered under number 17S07390 in the Directory of Commerce and Industry since 30th April 2014 and under number 17S07390 to the NIS Directory. With respect to the processing of personal data, Smart Global Privacy Solutions has made a simplified declaration before “The Commission of Contrôle et des Informations Nominatives” with the numbers No. 2017.05065 and No. 2017.05093. Smart Global Privacy Solutions has a licence to exercise the princely government issued by the Minister of State on 22nd February 2017. The registered office is located at 1 rue du Gabian 98000 MÓNACO – Principality of Monaco Address E-mail: communication @ smart- The director of the publication is Mr. Benoît Guignard. 


Any user of the Smart Global Privacy Solutions website expressly agrees: 

not to use the Smart Global Privacy Solutions website to spread and promote computer viruses, Trojan horses or any other similar programme, to damage computer systems or to disrupt the general good functioning of sites.  

to assume any direct or indirect material or bodily harm caused and to resolve any dispute that may occur.  

to relieve Smart Global Privacy Solutions of any responsibility in this regard. 


The personal data collected and processed by Smart Global Privacy Solutions is that which the Service User of Smart Global Privacy Solutions voluntarily transmits including via registration or contact forms. 

The User of Smart Global Privacy Solutions undertakes to provide accurate and up-to-date information and to promptly notify any changes to this information by e-mail to , in order for all the corresponding modifications to be made. 

The nominative files have been the subject of a simplified declaration to the CCIN No. 2017.05065 and No. 2017.05093 in accordance with the law relating to data and privacy.  

In accordance with the aforementioned law, the user who has completed an online registration form has the right to information, to objectionand to access and rectification of dataThese rights can be exercised by sending a letter to the address of the head office indicated in the heading, indicating surname, first name, date and place of birth, postal address and email. 


Smart Global Privacy Solutions reserves the right to modify this legal notice. Given the possible extensions and improvements to the functioning of the site, Smart Global Privacy Solutions reserves the right to unilaterally modify the present legal notices at any time, without prior notice. 

In particular, the visitor must consult and accept the legal notice of the website. Each use of the same implies the acceptance of the latest version of these legal notices. 

In the event of a significant change in these legal notices, the new legal notices will become effective the day after their publication on the website of Smart Global Privacy. 


The Service includes all available data, as defined by Smart Global Privacy Solutions.

All background documents to which Smart Global Privacy Solutions grants access within the framework of the Service, directly or under licence of a third party, are protected by copyright and by the law of databases, in accordance with the Code of intellectual property. 

The User is prohibited from using the Service for purposes other than those expressly stipulated in the contract signed with Smart Global Privacyfrom publishing, distributing or selling, in any way, the content accessed and from infringing, directly, indirectly or through third parties, agents or collaborators the rights of Smart Global Privacy Solutions. 

The provision of the Service implies the acceptance of a non-exclusive and non-transferable licence for use by third parties, formulated through direct validation on screen when connecting to the Service. 

Any form of subscription to the Service does not imply any transfer of rights related to the property or any type for the benefit of the User. 

The User is also prohibited from interfering in any way with the rights of reproduction, representation and any other internal right by Smart Global Privacy Solutions, including through the application of articles L.342-1 and following of the Property Code. 

The User can not, under any circumstance, reproduce or represent in its entirety the data contained in the background documents. It also refrains from making any reproduction, extraction or qualitative or quantitatively substantial reuse of the contents of the database, as well as from the repeated or systematic extraction or reuse of the parts qualitatively or quantitatively substantial of the content of the database.  


Any other use not provided for in the Intellectual Property Code is subject to the prior written consent of Smart Global Privacy Solutions. 

The obligations set forth in this document are applicable for the full term of the intellectual property rights of Smart Global Privacy Solutions and for any country, even after the end of the contract. 

The content of the website can not be modified, copied, distributed, framed or reproduced without the agreement of Smart Global Privacy. 

Smart Global Privacy Solutions is a registered trademark of Smart Global Privacy Solutions SARL. Copyright © 2017-2087 Smart Global Privacy Solutions USPTO Patent pending # 62592565 


The User is solely responsible for: 

the veracity, legality and lawfulness of the information that he voluntarily provides on the platform.

-the consultation, the selection, the use and the interpretation of the documentation provided by Smart Global Privacy Solutions, as well as the acts and advice that it deduces.

-the negotiations and contracts concluded through the Smart Global Marketplace with other Users. 

Smart Global Privacy Solutions will never be responsible for the consequences of the use of search results by the User or the consequences of the obligations arising from the contracts that are likely to pass with other Users through the Smart Global Privacy Marketplace.  

Consequently, Smart Global Privacy Solutions will not be civilly liable, due to an express or implied obligation, to the User or third parties for any direct or indirect damage resulting from the use of the information, and in particular as a result of inaccurate or incomplete information, price error, commission error or delay. 

Under no circumstances will Smart Global Privacy Solutions be liable for any damage, whatever its nature, including loss of exploitation, loss of data or any other financial loss resulting from the use or inability to use the Service mentioned in this document. 

In any case, the User expressly acknowledges that Smart Global Privacy will not be held responsible, whether in the event of direct or indirect damage or harm, such as commercial prejudice or loss of a client, because of an inaccuracy, omission, delayed uploadingincomplete data contained in the site 

In addition, no assistance provided by Smart Global Privacy Solutions in the use of the Service can create any additional guarantee against these conditions.  

The User is solely responsible for access to the Service and any use made of it before modification or cancellation of the means of access, remains the responsibility of the latter. 


It is expressly stipulated that these legal notices are governed by the Monegasque law. Any dispute that arises during the execution of this contract will be submitted to the competent courts of Monaco. 

Copyright © 2019 Smart Global Privacy Solutions SARLAll rights reserved 

Date of last modification: 10/01/2019
Seen by the Data Protection Officer : Odile DUSSART