myPrimobox Privacy Policy

Septeo HR Solutions attaches great importance to protecting the personal data of myPrimobox users. myPrimobox is the personal digital safe provided to employees whose employer has chosen to go paperless for its HR documents.

This policy explains how your data is collected, used and protected when you use your myPrimobox space (www.myprimobox.com) and its applications.

1. Who is responsible for your data?

The processing of your data in myPrimobox falls under two separate frameworks:

Documents uploaded by your employer (payslips, contracts, certificates, etc.): your employer is the data controller. Septeo HR Solutions acts as a data processor, on its behalf and according to its instructions, under the contract between them.
Management of your personal space (account creation and security, documents you upload yourself, support, retention of your safe after you leave the company): Septeo HR Solutions is the data controller.

Septeo HR Solutions, 42 chemin de la Bruyère, 69570 Dardilly, France.

2. The data we process

Identification data: last name, first name, email address, phone number, date of birth [to be confirmed], employee ID number, employer name.
Login and security data: login credentials, encrypted password, authentication codes, IP address, connection logs, device type.
HR documents sent by your employer: these may contain salary data, your social security number, your bank details or information about your absences.
Personal documents you choose to upload to your safe.
Support data: content of your exchanges with our support team.

Septeo HR Solutions does not access the content of your documents, except at your express request during a support intervention or where required by law.

3. Why we process it (purposes and legal bases)

Distribution and provision of your employer’s HR documents: contract between your employer and Septeo HR Solutions, legal obligation of the employer (articles L.3243-2 and D.3243-7 of the French Labour Code).
Creation, management and security of your account: performance of the terms of use.
Retention of your safe, including after you leave the company: legal obligation and performance of the terms of use.
Storage of your personal documents: performance of the terms of use.
User support: performance of the terms of use, legitimate interest.
Service security and fraud prevention: legitimate interest.
Website audience measurement: consent.

4. Recipients

Your data is only accessible to:

authorised Septeo HR Solutions staff (support, technical teams), strictly within the scope of their duties;
your employer, for the documents it has uploaded itself and the information needed to distribute them (your employer never has access to your personal documents or to the content of your safe);
our technical subcontractors, in particular our hosting provider OVH (France);
administrative or judicial authorities, upon a written and justified request provided for by law.

Your data is never sold or used for advertising purposes.

5. Retention periods

Payslips and paperless HR documents: kept for 50 years or until you reach the age of 75, in accordance with article D.3243-8 of the French Labour Code. Your space remains accessible throughout this period, including if you leave your employer.
Personal documents: kept as long as your account is active, until you delete them.
Account closure: you may request the closure of your space at any time. It is your responsibility to retrieve your documents beforehand. [to be confirmed: effective deletion period]
Support data: 3 years from the last exchange.
Connection logs: 1 year.
Audience measurement cookies: 13 months maximum.

6. Data location

Your data is hosted on servers located in France. No transfer outside the European Union takes place. Should this change, you would be informed in advance and appropriate safeguards would be put in place in accordance with the GDPR.

7. Security

myPrimobox is designed to store sensitive documents. Septeo HR Solutions implements, in particular:

encryption of data in transit and at rest [to be confirmed];
strong authentication [to be confirmed: two-factor authentication];
access restricted to authorised persons only, bound by confidentiality obligations;
traceability of access and operations;
regular backups and security audits;
guarantees of document integrity and durability in line with French Labour Code requirements.

8. Your rights

In accordance with the GDPR and the French Data Protection Act, you have the right to access, rectify, erase, restrict, port and object to the processing of your data, as well as the right to set instructions regarding what happens to your data after your death.

Some of these rights may be limited by the legal obligations to retain payslips. For documents uploaded by your employer, you may also contact your employer directly.

To exercise your rights:

by email: dpo@septeo.com
by post: Septeo HR Solutions, DPO, 42 chemin de la Bruyère, 69570 Dardilly, France

Proof of identity may be requested. If you believe your rights have not been respected, you may lodge a complaint with the CNIL, the French data protection authority (www.cnil.fr).

9. Cookies

myPrimobox uses cookies that are strictly necessary for the service to work (session, security, language preferences), which do not require your consent.

Any audience measurement cookies are only placed with your agreement, collected through the banner displayed on your first visit. You can change your choices at any time via the “Cookie settings” link at the bottom of the page.

10. Data Protection Officer

Septeo HR Solutions has appointed a Data Protection Officer, who can be reached at dpo@septeo.com.

11. Changes to this policy

This policy may change in line with legal developments or changes to the service. The current version is always available on the website. Last updated: 16 October 2026.

myPrimobox Privacy Policy