Privacy policy

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The purpose of the data protection policy is to detail the data processing of Customers who use Elaya's Services.

Please note that this Data Protection Policy is an integral part of the General Terms and Conditions of Sale (GTCS). All terms not defined herein are defined in the GSC.

Use of the Site and the placing of an Order imply acceptance of the terms of this Data Protection Policy.

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^{What is personal data?}

Personal data ("Personal Data") is information that can directly or indirectly identify a natural person. This may include a surname, first name, e-mail address, telephone number or address.

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^{Who collects your personal data?}

The Site and Services are offered by Elaya. In this context, in its capacity as data controller, the Company is likely to collect the personal data of Customers.

The Company attaches great importance to respect for privacy and takes all necessary measures to ensure the confidentiality and security of customers' personal data.

Also, the purpose of this Data Protection Policy is to help Customers understand how the Company processes their personal data in accordance with the principles set out by the General Data Protection Regulation ("GDPR") that came into force on May 25, 2018.

To this end, the Company invites Customers to familiarize themselves with the present Data Protection Policy in order to be informed of how their personal data is processed and of their rights.

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^{What data is collected and for how long?}

When Customers browse the Site and/or place Orders, the Company may collect certain personal data from Customers, in particular: first name, surname, postal address, e-mail address, telephone number.

Customers' personal data is kept only for as long as is necessary to achieve the purpose for which the Company holds the data, to meet customers' needs or to fulfil its legal obligations.

To establish the retention period for personal data, the Company applies the following criteria:

• in the case of orders for services, personal data is kept for the duration of the contractual relationship and for a period of three years after collection or the last contact with the customer, for commercial prospecting purposes,
• if the Customer makes a request to the Company, personal data will be kept for the time necessary to process the request,
• if cookies are placed on the customer's computer, personal data is stored for the duration of a session for session identification cookies and for any period defined in accordance with applicable regulations.

The Company may retain certain data in order to meet its legal or regulatory obligations, to enable it to exercise its rights and/or for statistical or historical purposes.

At the end of the above-mentioned periods, personal data will be deleted or made anonymous.

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^{Who are the recipients of personal data?}

Customer personal data is collected and processed by Elaya. Data may also be communicated to the Company's subcontractors who act in the name of and on behalf of the Company, in particular the Site host, payment service providers and advertising technology.

The Company may communicate customers' personal data in order to cooperate with administrative and judicial authorities.

Lastly, the Company may communicate customers' personal data to third-party service providers for the purposes of statistical studies of Site usage and Site optimization. In this case, the customer's personal data will be anonymized.

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^{Why does the Company use cookies?}

In accordance with CNIL deliberation no. 2013-378 of December 5, 2013, the Company informs Customers that cookies record certain information that is stored in the memory of their hard disk. This information is used to generate Site audience statistics and to offer services according to the information they have already selected during their previous visits.

A warning message, in the form of a banner, asks each person visiting the Site, beforehand, if they wish to accept cookies. These cookies do not contain any confidential information about Site customers.

Customers visiting the home page or any other page of the Site directly from a search engine will be informed :

• the precise purpose of the cookies used,
• the possibility of objecting to these cookies and changing the settings by clicking on a link in the banner,
• and that continued browsing implies consent to the deposit of cookies on the user's terminal. To guarantee the free, informed and unequivocal consent of the user visiting the Site, the banner will not disappear until the user continues browsing.

Unless the Customer has given his prior consent, cookies will not be deposited or read:

1. If any person who visits the site (home page or directly on another page of the Site from a search engine for example) does not continue his navigation: a simple absence of action can not be assimilated to a manifestation of will,
2. If they click on the link in the banner allowing them to configure their cookies and, if necessary, refuse the deposit of cookies.

_{How can I manage the cookies on my computer?} 

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Just click on the link below.

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For more information on how cookies work, the User may refer to the CNIL website.

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^{Why does the Company collect IP addresses?}

Every computer connected to the Internet has an IP address. Whenever a User browses the Site, the Company collects the User's IP address in order to analyze the traffic on the Site and to monitor the User's activity on the Site in order to ensure that the User does not engage in acts that may infringe the General Terms and Conditions of Sale and General Terms and Conditions of Use appearing on the Site.

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^{How does the Company ensure the security of personal data?}

The Company ensures that customers' personal data is adequately and appropriately secured, and has taken the necessary precautions to preserve the security and confidentiality of data, and in particular to prevent it from being distorted, damaged or communicated to unauthorized persons. To this end, the Company includes computer protection measures such as antivirus software, firewalls and access authorization controls.

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^{What are customers' obligations?}

Customers acknowledge that the personal data disclosed by them is valid, adequate and up to date. Customers are solely responsible for their personal data.

Customers undertake not to infringe the privacy or personal data protection rights of any third party.

In order to improve the relevance of its services, the Company records statistical and non-personal information relating to the use of the Service (frequency of use, quantity and type of data entered).

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^{What are Customers' rights?}

In accordance with the provisions of the Data Protection Act dated January 6, 1978 as amended and the RGPD, Customers are informed that they have, in particular, a right of access, rectification, deletion, limitation of data processing, data portability, as well as a right to object to the processing of their personal data.

• The right of access: the Company undertakes to provide the user, upon request, with a copy of the personal data concerning him/her.
• The right of rectification: The user has the right to ask the Company to rectify personal data that has been communicated to him/her because it is incorrect.
• The right to object: Users may object to their personal data being processed by the Company.
• The right to be forgotten: The user may obtain from the Company, under certain conditions, the deletion as soon as possible of certain personal data concerning him or her. This right to oblivion may not be obtained in certain cases, notably for reasons of public interest, for archival purposes or to comply with legal obligations governing the processing of personal data by the Company.
• The right to limit processing: The User may obtain that the Company limits the processing of his/her personal data and those in particular when the User objects to such processing, disputes the accuracy of the data or when he/she believes that the use is unlawful.
• The right to data portability: Under certain conditions, users may request to receive all their personal data so that they can be transferred to another data controller without the Company being able to object.

Customers may exercise their rights with the Company, subject to proof of identity, either directly on the Site under the heading "Contact", or by post to the following address:

Elaya

54-56 Avenue Hoche

75008 PARIS

contact@elayapartners.com

The Company will respect the instructions given by any user concerning the conservation, deletion and communication of his or her personal data after his or her death. In the absence of such instructions, the Company will comply with requests from heirs as exhaustively set out in the applicable provisions of the French Data Protection Act (Loi Informatique et Libertés).

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^{How are Customers informed of changes to this Privacy Policy?}

The Company may modify this Data Protection Policy at any time. The Company will inform Customers by any means of any changes made to this Policy.

The Company invites Customers to regularly read the Privacy Policy in order to keep themselves fully informed of its provisions.

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