Privacy Policy

The SARAWAK COMPANY attaches the greatest importance to the protection of the data of the users of its websites.
This Privacy and Cookie Policy (hereinafter referred to as the “Policy”) sets out the principles and guidelines for the protection of the user’s personal data and is intended to inform the user about:

  • The personal data that SARAWAK COMPANY collects and the reasons for such collection,
  • The way in which this data is used,
  • The rights of the user with regard to his personal data.

All operations on this data are carried out in compliance with the regulations in force and in particular with the law n°78-17 “Informatique et Libertés” of January 6, 1978 modified and with the Regulation n°2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free circulation of such data.

To this end, SARAWAK COMPANY has appointed a data protection officer who is the privileged contact for any question relating to the protection of personal data.

The user of the site acknowledges having read and accepted this policy at the same time as he/she accepted the general conditions of use of the site. If he/she disagrees with these terms, he/she is free not to use the site and not to provide any personal data.


“Personal data”: any information relating to a natural person who is identified or can be identified, directly or indirectly, by reference to an identification number or to one or more elements that are specific to him.

“Processing of personal data” means any operation or set of operations which is performed upon data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Data subject”: any natural person whose personal data are collected and processed.

“Controller”: the natural or legal person, public authority, department or other body which, alone or jointly with others, collects and processes personal data.

“Recipient”: the natural or legal person, public authority, department or other body that receives personal data, whether or not it is a third party.

“Authorized third party”: the natural or legal person, public authority, service or organization, under the direct authority of the controller or processor, authorized to process personal data.

“User”: any person visiting the website.


The SARAWAK COMPANY carries out an activity within the meaning of the law n° 2004-575 of June 21, 2004 for confidence in the digital economy.
The purpose of this policy is to inform the persons concerned of the manner in which their personal data is collected and processed by the SARAWAK COMPANY.


Personal data is collected by SARAWAK COMPANY, whose registered office is located at 160B rue de Paris, 92100 Boulogne-Billancourt, SIRET number 91780869300019, represented by Mr. Guy MAINDIAUX in his capacity as President.


Within the framework of the exploitation of its Internet site the SARAWAK COMPANY collects data concerning its users. This data is processed in accordance with the purposes set out at the time of collection, some information being compulsory and others optional, indicated by an asterisk (*) in the collection forms

– Management of applications;

– Management of partnership requests;

– Management of information requests;

– Statistics of frequentation;

– Collection of information for targeted advertising.

The collection of data is based on the user’s consent by filling in the collection form or by writing directly to SARAWAK COMPANY, or on the legitimate interest of SARAWAK COMPANY to organize the management of its missions.

Processed data

When data is collected, the user is informed whether certain data must be filled in or whether it is optional. The data identified by an asterisk in the forms are mandatory. Otherwise, access to and use of the services by the user will be impossible.

In addition, SARAWAK COMPANY may collect personal data for other purposes, taking care to obtain the prior consent of the persons concerned.

In particular, the SARAWAK COMPANY may collect the following data

– Identity: name, first names, postal address, telephone number (fixed or mobile), e-mail address;

– Contact data: messages sent to the site via the contact forms;

– Traffic statistics: IP address, cookies, pages consulted, date and time of consultation (see details concerning cookies below).

Recipients of the data collected

The personal data collected on this site are exclusively reserved for the SARAWAK COMPANY.

In the event that SARAWAK COMPANY calls upon subcontractors, the latter will be chosen in particular for their sufficient guarantees as to the implementation of appropriate technical and organizational measures, particularly in terms of reliability and security measures.

d) Data transferred abroad

No transfers are made outside the European Union.

However, SARAWAK reserves the right to transfer users’ personal data in order to comply with its legal obligations, and in particular if it is obliged to do so by judicial requisition.

e) Retention periods

The SARAWAK COMPANY keeps personal data in a secure environment for the time necessary to achieve the purposes for which they have been collected or for the minimum period of time required by the applicable legislation, particularly in civil and commercial matters.

– Management of requests via the contact form: 1 year from receipt of the requests

– Audience measurements: 13 months maximum

– Management of prospect data: 3 years from the last contact


In accordance with Regulation (EU) 2016/679 on the protection of personal data, the user has the following rights over his or her data: right of access, right of rectification, right to erasure (right to be forgotten), right of opposition, right to limit processing, right to portability. He or she may also have additional national rights (e.g., to define directives on the retention, erasure and communication of his or her personal data after his or her death).
For reasons related to his particular situation, the user may also object to the processing of his data.

To exercise his rights, the user may contact our Data Protection Officer (DPO) by mail with proof of identity: SOCIÉTÉ SARAWAK – Bruno SONNETTE, 160 B, Rue de Paris, 92100 Boulogne-Billancourt.

Subject to a breach of the above provisions, the user has the right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL) or with the data protection supervisory authority of his place of residence.


The user is informed that, when connecting to the site and using the services, cookies or other technologies are used, subject to the choice expressed by the latter, this choice can be changed at any time.

A cookie allows its issuer, during its period of validity, to recognize the terminal concerned (computer, tablet, smartphone, etc.) each time this terminal accesses digital content containing cookies from the same issuer. A cookie records information relating to navigation on the site (the pages consulted, the date and time of consultation, etc.) which will be readable during the user’s subsequent visits.

These cookies facilitate navigation and improve the user-friendliness of the site.

The user may oppose the recording of cookies by configuring the settings of his or her browser, as indicated below. In this case, access to certain services and sections of the site may be altered or even impossible.

Several types of cookies are likely to be used by the site:

a) Navigation cookies:

Browsing cookies make it possible to improve the performance of services in order to provide the user with a better use of the site. These cookies do not require the user’s prior information and consent to be deposited on his or her terminal.

More specifically, these browsing cookies allow us to

  • To adapt the presentation of the site to the display preferences of the terminal (language used, display resolution, operating system used, etc.) of the user;
  • To memorize information relating to the form that the user has filled in or to information that the user has chosen on the site;
  • To implement security measures, for example when the user is asked to log in again to a content or service after a certain period of time has elapsed.

b) Audience measurement cookies:

The audience measurement cookies help to establish statistics and volumes of frequentation and use of the various elements composing the site (sections and contents visited, navigation paths), allowing the editor to improve the interest and ergonomics of the services.

c) Matomo and privacy

This site uses a web analysis service provided by Matomo Analytics, which respects privacy by design. All data collected is stored only in your MySQL database, no other company (or Matomo team member) can access this information, and logs or report data will never be sent to other servers by Matomo. The software source code is open-source, so hundreds of people have reviewed it to ensure that it is secure and keeps your data private.

  1. Advertising and behavioral analysis cookies

Behavioral analysis cookies make it possible to identify what information on the site is of most interest to the user and to help improve his or her navigation. These cookies also make it possible to determine in real time which advertisement to display based on the user’s recent navigation on the site in order to limit the number of times the user has seen an advertisement and to measure the effectiveness of an advertising campaign.

Advertising content is likely to contain cookies issued by third parties: either the advertiser at the origin of the advertising content in question, or a company outside the advertiser (communication consulting agency, audience measurement company, targeted advertising provider, etc.) or advertising agency that has associated a cookie with the advertising content of an advertiser.

Subject to his consent and through analysis of his browsing, the user may also be offered electronic prospecting offering personalized advertising.
The user may, at any time, request to no longer receive advertisements or prospecting tailored to the user’s browsing information, by contacting SARAWAK directly and free of charge, or by means of the unsubscribe link included in any prospecting sent by e-mail. If the user chooses to refuse behavioral advertising, this does not mean that he or she will no longer receive advertising on the Internet. It only means that the advertising that will be displayed on the site will no longer match the user’s interests or browser preferences.

In the event that SARAWAK CORPORATION intends to obtain information from a third party about the user’s browsing habits, which it could associate with the data provided by the user, it will first seek the user’s explicit consent before proceeding with such association and sending him targeted advertising or prospecting. The explicit agreement consists in checking a box proposed on the services to which he is registered.

Cookies subject to consent

The deposit of certain cookies is subject to the prior consent of the user. This consent can also be withdrawn by clicking here.

The user can also oppose the recording of cookies by configuring the settings of his browser (see below).

Rejecting cookies

The user can configure his navigation software so that cookies are recorded or rejected in his terminal, either systematically or according to their issuer. The user can also configure his browser software so that the acceptance or rejection of cookies is proposed from time to time, before a cookie is likely to be recorded in his terminal.

The configuration is described in the help menu of each browser:

Internet Explorer:

  1. Click on the Tools button, then on Internet Options.
    2. On the General tab, under Browsing History, click on Settings.
    3. Click on the View Files button.
    4. Click the “Name” column heading to sort all files alphabetically, and then scroll through the list until you see files that begin with the prefix “Cookie”.
    5. Select the cookies you want to delete.
    6. Click OK twice.


  1. Click on the Tools button and then click on Options.
    2. Choose Privacy and select Show Cookies.
    3. Check the cookies you want to delete and click Delete Now.
    Google Chrome 4, Google Chrome 8 and higher:
    1. Choose on the Tool menu, then Option.
    2. Click the Advanced Options tab.
    3. Locate the Content Settings section.
    4. Check the box to prevent all sites from storing data.

Safari :

  1. Select the Safari menu, then Preferences in the Edit menu.
    2. Click on the Security tab, then select the desired privacy level.
    Netscape Navigator 9.0:
    1. Select the Tools menu, then Option.
    2. Click on the Privacy tab.
    3. Uncheck Accept cookies from sites.


  1. Select Menu, then Settings.
    2. Click on the Preferences tab.
    3. Select Advanced, then Cookies.
    4. Check Never accept cookies again.
    5. Check Delete new cookies when quitting Opera and click OK.

In this case, the user is informed that access to certain services and sections of the site could be altered or even impossible.

The length of time that cookies are stored varies according to their type. The SARAWAK COMPANY uses mainly cookies which are self-destructing after the end of the connection. These are called session or navigation cookies. A log file is also used to record all accesses to web pages or the downloading of various files available on the site, for a period of 6 months. Finally, the information concerning the consent relating to the cookies is preserved for a maximum duration of 13 months. Cookies are used for internal purposes and are not accessible to third parties.


Taking into account the evolution of technologies, the costs of implementation, the nature of the data to be protected as well as the risks for the rights and freedoms of the persons, the SARAWAK COMPANY implements all the appropriate technical and organizational measures in order to guarantee the confidentiality of the personal data collected and treated and a level of security adapted to the risk.


The present policy by SARAWAK COMPANY is likely to evolve if legal or regulatory texts require it. Consequently, the user is invited to refer to it during his visits.

For any information on the protection of personal data, the user can also consult the site of the National Commission for Information Technology and Civil Liberties (CNIL) or the Data Protection Control Authority of his place of residence.


SARAWAK in Europe