Privacy Policy

Information on your rights and how we protect your personal data

1. Our commitments to protecting your personal data

JULIABAM-STM B.V., acting as data controller, explains how we collect, use, and process your personal data to deliver our services on a daily basis while respecting your rights.

We are committed to protecting your privacy by ensuring the confidentiality, integrity, availability, and security of the personal data you share with us across all our communication channels.

To that end, we implement measures designed to:

• provide clear and transparent information about how your personal data is collected and processed;

• implement appropriate technical and organizational safeguards against unauthorized access, disclosure, loss, alteration, or misuse;

• retain personal data only for as long as necessary for the stated purposes;

• allow you, whenever applicable, to access and update personal data through your user account areas on our websites.

We apply appropriate technical and organizational measures to ensure our processing activities comply with applicable personal data protection laws.

1.1 When do we collect your personal data?

We may collect personal data when you:

• contact us via a contact form;

• subscribe to a loyalty program (if applicable);

• create an account on our websites or mobile applications;

• browse our websites (which may use cookies);

• purchase products or services online or on-site (if applicable);

• subscribe to our newsletter;

• call our customer service team;

• interact with us on social media;

• participate in promotional activities or contests;

• exercise your rights regarding your personal data.

1.2 What personal data do we collect?

We collect information you provide in the context of our commercial relationship, including, for example:

• when you create a customer account or join a loyalty program;

• when we manage bookings/orders and related services;

• when you contact our customer service team or interact with our web pages;

• when you participate in a contest or promotion.

Fields that are strictly necessary to provide a service are usually marked with an asterisk. They may include: first name, last name, postal address, email address, phone number, and (where applicable) loyalty card numbers.

We may also collect information related to your transactions and service usage, such as the amount and nature of purchases/bookings, order details, invoices, and your journey through our online services.

In accordance with applicable regulations, we do not collect special category data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data used for unique identification, health data, or data concerning sex life or sexual orientation.

These categories of sensitive data are not collected or processed by JULIABAM-STM B.V.

2. How do we use your personal data?

We process personal data transparently and securely. Your personal data is collected for the purposes described below.

2.1 Managing our obligations towards customers

Website browsing

We process certain data to enable you to browse our websites (e.g., jumbocar-sxm.com). Legal basis: your consent (where required, especially for non-essential cookies).

Processing bookings/orders

We process your data to manage bookings/orders and deliver the requested services. This includes managing the customer relationship, confirming bookings, issuing invoices, and providing relevant service-related information and offers. Legal basis: performance of a contract.

Payment collection and fraud prevention

We process data to secure payments, prevent fraud, and manage unpaid amounts (where applicable). Legal basis: performance of a contract and/or legitimate interest in protecting our business (depending on the activity).

Advertising operations and marketing activities

We may process data to manage marketing operations (including prospecting, statistical analysis, promotional operations, contests, and updating prospect lists). Legal basis: your consent (where required).

Communication with you

We use your data to contact you regarding bookings/orders, invoices, and customer service requests. Legal basis: performance of a contract.

Improving your customer experience

We may analyze data to improve our services and, unless you object, to offer relevant services or display advertising aligned with your interests. Legal basis: your consent (where required) and/or legitimate interest (depending on the context).

Targeted partner advertising (profiling)

With the support of specialized service providers, we may analyze data for marketing purposes (profiling). Your data may be:

• converted into pseudonymized profiles used to deliver interest-based online advertising campaigns (display);

• used directly by us or shared with providers to deliver marketing by mail or phone via human agents (not automated calling systems), and/or by email. Legal basis: your consent (unless an exception applies, such as marketing for similar services where permitted under legitimate interest and local law).

You can disable targeted advertising via:

• your account settings (when available);

• mobile settings (Limit Ad Tracking on iOS or equivalent settings on Android).

Legal or regulatory requirements

We may be required to disclose personal data in response to lawful requests from public authorities (e.g., national security, fraud prevention, law enforcement).

Supplier file management (if applicable)

Data may be shared with internal purchasing/admin/accounting teams, auditors, contracted partners, public bodies (when legally required), legal officers for debt recovery, or financial institutions managing relevant accounts.

Recruitment

Applicant data is used by staff responsible for recruitment (HR and relevant hiring managers).

Other cases

In any other situation, you will be informed of the intended processing.

2.2 Who can access your personal data?

We ensure that only authorized individuals within JULIABAM-STM B.V. access your data when needed to deliver services.

Our service providers (including payment, hosting, IT, analytics, and advertising partners) may receive strictly necessary data to perform the services we entrust to them (e.g., online payments, service delivery, targeted campaigns).

2.3 Where is your personal data stored?

Personal data is stored in compliance with applicable EU and local data protection laws.

Where a service provider processes data outside the European Union, we apply appropriate safeguards, including the standard contractual clauses recommended by the European Commission (or equivalent legal mechanisms).

Data retention periods

We retain personal data for durations aligned with legal obligations and regulatory recommendations. Examples:

At the end of these periods, data may be archived as necessary to comply with statutory limitation periods and legal defense requirements.

3. Cookie Policy (summary)

Personal data protection is governed by the GDPR and applicable national legislation. As data controller, we explain how cookies are used on [www.jumbocar-sxm.com] and how you can manage your preferences.

3.1 What is a cookie?

A cookie (or tracker) is placed, stored, and/or read by your browser when you visit a website, use an app, or interact with digital content.

We distinguish three main categories:

• Essential cookies (technical): required for the service; consent is not required.

• Analytics/performance cookies: measure audience and performance; consent is generally required unless an exemption applies.

• Advertising/targeting cookies: personalize advertising; consent is required.

3.2 Which cookies may be placed?

Cookie names, purposes, and retention are described in your cookie settings interface and/or the detailed cookie list on the website (e.g., via TarteAuCitron).

3.3 When are cookies placed?

Cookies may be placed when you browse our websites or use our applications. Some may be placed by us as publisher, or by third parties acting as processors on our behalf or for their own purposes.

3.4 How can you manage cookies?

You can manage cookies:

• via the cookie settings tool available at any time: [INSERT COOKIE SETTINGS URL]

• or via your browser settings (links provided for guidance; availability may change).

Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=fr Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies Mozilla Firefox: https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences Opera: http://help.opera.com/Windows/10.20/fr/cookies.html

We cannot guarantee that these URLs will remain available over time, nor the accuracy or quality of the information they contain. For mobile applications, emails, and social networks, we invite you to refer to your account settings, which vary depending on platforms and providers, but allow you to manage the data collected about you.

Until you have given your consent, no cookies are placed or read on your device (except for session cookies, which do not require prior consent). Refusing to give your consent does not prevent access to our Website.

4. How to exercise your rights

You have the following rights:

• Right of access (confirmation and access to your data)

• Right to rectification (correct inaccurate data)

• Right to erasure (subject to legal exceptions)

• Right to data portability (for data you provided, processed automatically, based on consent or contract)

• Right to object (including direct marketing and certain profiling)

• Right to restriction of processing (in specific situations)

• Right to withdraw consent at any time (when processing is based on consent)

• Right to post-mortem instructions (where applicable)

You also have the right to lodge a complaint with the competent supervisory authority. If you are in France, this is the CNIL.

Contact to exercise your rights

Email: dpo.@gbh.fr
Postal address: JULIABAM-STM B.V., Airport Road #122 – Simpson Bay – Sint Maarten - specifying “JULIABAM-STM B.V.- For the attention of the DPO Subject line (recommended): “Privacy Request – Data Subject Rights”

We may request proof of identity where there is reasonable doubt about the requester’s identity. We respond as soon as possible and in any case within one month of receiving your request (subject to permitted extensions).

5. Data security measures

5.1 Security and confidentiality

Protecting your personal data is a priority. JULIABAM-STM B.V. implements organizational and technical security measures adapted to the sensitivity of data, to protect against malicious intrusion, loss, alteration, or unauthorized disclosure.

We apply privacy-by-design principles and, where appropriate, use pseudonymization and/or anonymization.

Access to personal data is limited to staff and providers who need it for their duties. All authorized persons are bound by confidentiality obligations and may face disciplinary measures if they fail to comply.

We encourage you to take precautions to prevent unauthorized access to your devices, including using strong passwords and logging out after use on shared devices.

5.2 Data Protection Officer / Privacy contact

Our privacy contact is available to answer questions:

• By email: dpo.@gbh.fr

• By mail: JULIABAM-STM B.V., Airport Road #122 – Simpson Bay – Sint Maarten - specifying “JULIABAM-STM B.V.- For the attention of the DPO

6. Glossary (key definitions)

• Anonymization: processing that irreversibly prevents identification.

• Collection: gathering personal data (e.g., via forms).

• Consent: a freely given, specific, informed, unambiguous indication of wishes.

• Personal data: any information relating to an identified or identifiable natural person.

• Restriction of processing: marking stored data to limit future processing.

• Data minimization: limiting collection/use to what is necessary.

• Profiling: automated processing to evaluate personal aspects (preferences, interests, behavior, location, etc.).

• Pseudonymization: replacing identifiers so data cannot be attributed to a person without additional information.

• Controller: entity that determines purposes and means of processing.

• Processor: entity processing data on behalf of the controller.

• Third party: anyone other than you and JULIABAM-STM B.V.

• Processing: any operation performed on personal data.