1. Purpose of this policy

This cookie and tracker management policy (hereinafter the "Cookie Policy") is intended to inform users of the website https://www.hoxbook.com (the "Site") and the application platform https://www.app.hoxbook.com (the "Platform") about how HOXBOOK SAS uses cookies and similar technologies when they browse.

It supplements Hoxbook's Terms of Use and Privacy Policy, which should be consulted for more information on the processing of personal data.

2. Who is responsible for Cookies?

The publisher of the Site and the Platform is:

  • HOXBOOK SAS,

  • a simplified joint-stock company,

  • registered with the Paris Trade and Companies Register under number [to be completed],

  • with its registered office located at [address to be completed].

In connection with the use of Cookies on the Site and the Platform, Hoxbook acts as the data controller for data relating to reading and writing operations on users' devices, within the meaning of Article 82 of the French Data Protection Act.

If you have any questions about Cookies, you can contact us at:

  • Email: admin@hoxbook.com

  • Postal address: HOXBOOK SAS, [address to be completed]

3. What is a cookie?

A cookie (or "tracker") is a small text file that may be stored on your device (computer, smartphone, tablet) when you visit a website or use an application. For its period of validity, it allows the device concerned to be recognized and certain information relating to your browsing or preferences to be stored.

The terms "cookies" or "trackers" also cover other technologies with similar purposes (for example: local storage, technical identifiers, etc.), provided they involve a read or write operation on your device.

4. What types of Cookies do we use and for what purposes?

The Cookies used on the Site and the Platform can be divided into two main categories:

4.1 Cookies strictly necessary for the operation of the Services

These Cookies are essential for the technical operation of the Site and the Platform and for providing the services you request. They make it possible in particular to:

  • authenticate you and keep your session active on the Platform;

  • manage your basic preferences (for example, display language);

  • secure access to accounts and prevent fraudulent or abusive use;

  • ensure pages display properly and detect possible technical errors.

These Cookies are exempt from the consent requirement, insofar as they are strictly necessary for the provision of an online communication service explicitly requested by the user or have the sole purpose of enabling or facilitating electronic communication.

Deleting or blocking them may cause significant malfunction of the Site or the Platform.

4.2 Audience measurement and statistics Cookies (if applicable)

Subject to your consent, Hoxbook may use audience measurement Cookies that allow, in an aggregated manner, to:

  • measure traffic and usage of the Site and the Platform (pages viewed, browsing paths, time spent, technical errors);

  • produce anonymized statistics to improve the quality and usability of the Services.

Where these Cookies do not meet the criteria for consent exemption (for example, if the data is not strictly anonymized or if it is intended for third parties), they are only placed after we have obtained your explicit consent via the banner or the Cookie management module.

4.3 No advertising Cookies

As Hoxbook Services are intended exclusively for business customers, Hoxbook does not currently use Cookies for the purpose of advertising targeting of end consumers.

5. Legal basis for Cookies

In accordance with Article 82 of the French Data Protection Act, the reading and writing of Cookies on your device are based on the following legal grounds:

  • Legitimate interest: for Cookies strictly necessary for the technical operation of the Site and the Platform, for security, and for providing a service you have expressly requested (authentication, session maintenance, security, etc.);

  • Consent: for audience measurement Cookies or other Cookies that are not strictly necessary, when they are implemented. Consent must be freely given, specific, informed and unambiguous, and you may withdraw it at any time as easily as you gave it.

6. Obtaining your consent

When you first visit the Site and periodically thereafter, a banner or Cookie management module is displayed to inform you of:

  • the existence of Cookies and their main purposes;

  • the option to accept or refuse the placement of Cookies that are not strictly necessary;

  • the option to set your choices by purpose.

Through this banner or module, you have several options:

  • "Accept all": you consent to the placement of all Cookies subject to consent;

  • "رفض all": no Cookie that is not strictly necessary will be placed on your device;

  • "Customize" / "Settings": you choose, purpose by purpose, which Cookies you accept or refuse.

No Cookie subject to consent will be placed until you have given a positive choice of acceptance (for example, by clicking "Accept all" or by enabling a specific purpose in the settings module).

Hoxbook keeps a record of the choices expressed (acceptance or refusal) for a limited period of time, so that you are not prompted on every visit, within the limits of the guidance issued by the supervisory authorities.

7. How can Cookies be managed and deleted?
7.1 Management via the banner or settings module

At any time, you can change your mind and modify your Cookie preferences by clicking the "Cookie settings" link (or equivalent wording) available at the bottom of the Site page, where this feature is offered.

This module allows you to:

  • view the categories of Cookies used;

  • withdraw your consent for certain purposes;

  • accept Cookies you previously refused.

7.2 Browser settings

Most browsers also allow Cookies to be configured through their settings. For example:

  • accept or reject all Cookies;

  • accept only certain types of Cookies;

  • delete all Cookies already placed.

The settings process is specific to each browser. It is described in its help menu.

Warning: blocking certain Cookies, especially technical Cookies, may affect the operation of the Site or the Platform and your user experience.

8. Retention period for Cookies and related information

Cookies are stored on your device for a period not exceeding what is necessary in view of the purposes for which they are used and, in any event, within the limits recommended by the applicable regulations and supervisory authorities (in particular the CNIL).

In general:

  • strictly necessary Cookies are retained for the period strictly required for the operation of the Services (for example, the duration of the session or the technically necessary period);

  • Cookies subject to consent are retained for a period not exceeding the validity period of the consent, then deleted or renewed as applicable.

Logging data and technical metadata associated with Cookies used for security, traceability and audience measurement are retained for a period reasonably necessary for these purposes, then deleted or, where possible, anonymized, in accordance with the Terms and Conditions and the GDPR appendix entered into with professional Clients.

9. Link with the Privacy Policy

The use of Cookies may result in the processing of personal data (for example: IP address, login credentials, browsing data).

For more information on:

  • the processing of personal data carried out by Hoxbook;

  • the legal bases for such processing;

  • the rights you have (access, rectification, objection, erasure, etc.);

  • and how to exercise them,

please refer to Hoxbook's Privacy Policy, available on the Site and the Platform.

10. Changes to this Cookie Policy

This Cookie Policy may be updated, in particular to take into account:

  • possible legislative or regulatory changes;

  • recommendations from supervisory authorities (CNIL, European Data Protection Board, etc.);

  • changes in the Cookies used or the purposes pursued.

Any new version of the Cookie Policy will take effect as soon as it is published online. We encourage you to review it regularly.