This document therefore explains to users (“Data Subjects”) the methods adopted to manage processing operations, and also constitutes a confidentiality notice, submitted in accordance with the legislation regulating the protection of personal data.
1. THE DATA CONTROLLER
The Data Controller is the Zallomber Groupe company, tax code and VAT identification number. The data controller establishes the purposes for which the data is processed and the methods adopted.
2. DATA PROCESSING OBJECTIVES AND LEGAL BASIS
2.1. DATA GATHERING
2.2 OBJECTIFS ET BASE JURIDIQUE
Personal data is collected and processed by Zallomber Groupe for purposes strictly related to the use of the site, the services it offers (which may also include marketing activities) and the purchase of products. More specifically, your personal data may be processed for the following purposes:
- provide services relating to registration and access to reserved areas or to specific services (when registering the site, we collect the email address, personal data and / or shipping information and password with online registration forms)
Upon express request, send our newsletter by e-mail;
- for purposes necessary in order to provide full information and assistance regarding services and / or purchasing products on the Site (in order to provide support services, we collect your personal data through our Customer Service in the section« Contactez-nous »);
- for purposes necessary in order to provide full information and assistance regarding services and / or purchasing products on the Site (in order to provide support services, we collect your personal data through our Customer Service in the section
- in order to provide information regarding navigation problems, browser compatibility or downloading of web pages from the Site (collection and processing of data in response to a request for technical assistance);
- to prevent or discover fraudulent activity or improper use harmful to the Site;
- so that Zallomber Groupe can exercise its rights (such as the right to defend itself in legal actions);
- to allow you to save the products you like most in your virtual basket;
- have obtained explicit and specific consent for marketing, analysis and profiling activities, such as:
- commercial information and / or promotions by paper mail (or flyer) and by telephone or electronic communications such as emails, text messages and other automated systems available for this purpose, aimed at promoting new products and improving the services offered;
- market studies and surveys on the quality of services and customer satisfaction, also through specialized companies, with the aim of improving the products and services offered;
- profiling aimed at analyzing the needs, tastes, choices and habits of consumers, also by means of electronic processing, in order to provide information on products or services which reflect the preferences and interests of users;
- analyzes of aggregated data relating to user behavior or to the analysis of user behavior on the site.
The processing of your data for marketing and profiling purposes requires your clear and specific consent; nevertheless, we must inform you that the Data Controller may process your personal data for other purposes, even if you do not give your consent, in certain circumstances provided for by law (for example, whenever necessary to comply with a legal obligation) or whenever necessary to fulfill contractual obligations to users (for example, if the user has purchased products on the Site) or when you have requested to benefit from specific services via our website.
All personal data provided is therefore processed exclusively for purposes related to the activities carried out by Zallomber Groupe on the following legal bases:
- consent (necessary for marketing, profiling and / or transfer of your data to third parties or to personalize a user profile on the website);
- the execution of a contract to which the user is a party (for example to send information related to the services by e-mail and / or text messages and / or any other means of communication, for the purpose, for example, of confirm an order or notify that changes have been made to our services, and receive payments or transfer payments when a product is returned) or pre-contractual measures taken at the request of the user;
- the fulfillment of the legal obligations by which the data controller is bound;
- the legitimate interests of the data controller (as indicated below).
Your personal data is processed mainly in electronic format and, in some cases, on paper.
Marketing, advertising and promotion activities and the provision of information on products and services, as well as statistical analyzes aimed at establishing the degree of satisfaction of customers with the services offered, are carried out through channels. traditional (paper mail,), as well as automated digital channels (such as e-mails, SMS, browsers and social networks).
The purposes of processing your personal data may, in any case, be the subject of a specific mention in the confidentiality notice that the data controller submits to the user on the page on which the attribution personal data is requested.
The data controller may deem it necessary to process personal data of third parties transferred directly by its users, for example in the case where the user shares the reduction code with friends, or if a product purchased must be sent to a third party, or if the subject paying the purchase price for the product is not the object to whom the product is to be sent.
In all these cases, be sure to obtain the consent of the person to whom the data refers before transmitting them to Zallomber Groupe. and that you have informed the data subject of the processing, knowing that you will be held solely and exclusively responsible for the transfer of information and data relating to third parties, even if they are not expressly requested, and for abusive or illicit use Datas . In any case, Zallomber Groupe. will, to the extent required by law, fulfill its obligation to inform the specified user and, if applicable, will ask for their express consent when saving the relevant personal data in their files.
2.3 LEGITIMATE INTERESTS OF THE DATA CONTROLLER AND / OR THIRD PARTIES
Zallomber Groupe may process your personal data for marketing purposes, after obtaining your express consent, using the contact details provided when registering on the Site. However, in the legitimate interest of the Data Controller, if the advertisement relates to products similar to those already purchased, you can receive it at your email address without your express consent, provided that you do not refuse your use . question when you provided your email address or on subsequent occasions. Likewise, we may process your data without your consent in order to provide the services you have voluntarily requested (for example, to assess the optimization of the effectiveness of our advertising campaigns, to set up, exercise or defend the rights of the Data Controller), or when processing is necessary to prevent fraud on the Site or to guarantee security and proper functioning).
3. NATURE OF DATA AND CONSEQUENCES OF REFUSAL TO RESPOND
The attribution of personal data to Zallomber Groupe (in particular personal data, e-mail address, postal address and telephone number) is necessary to conclude the contract for the purchase of products on the Site.
However, some of this data may be of fundamental importance when providing other services provided on the Site at your request or when carrying out legal or regulatory obligations. Refusal to provide the data necessary for these purposes may make it impossible to perform the contract for the purchase of products on the Site or to provide other available services – such as assistance services – or to fulfill legal obligations or regulatory in an appropriate manner.
The transfer to the data controller of additional data, different from that conferred as a mandatory requirement, for the performance of its legal or contractual obligations, or to provide specific services on request, is, however, optional and will not influence not the use of the website and the services it offers, or the purchase of products.
Depending on the case and whenever necessary, you will be duly informed, in each case, whether the allocation of your personal data to the data controller is compulsory or optional. We will indicate whether the transfer of your data is compulsory or optional with a notice (« please fill in this field ») or by means of a specific character (*) indicating that the information is mandatory or simply data necessary to provide services and allow the purchase of products on the site. We remind you that the impossibility of providing personal data when it is optional will not subject our users to any obligation or disadvantage whatsoever.
4. DATA TRANSFER OUTSIDE THE EU
Your personal data will not be transferred abroad to countries that are not members of the European Union and are not able to guarantee that the interests of individuals are adequately protected. If it proves necessary to do so to provide the requested services (for example, with certain treatments that can be delegated to suppliers who do not operate in the European Union) or to conclude a contract for the purchase of products, we assure you that the transfer of data to countries not members of the European Union and unable to guarantee adequate protection standards will be subject to the conclusion by Zallomber Group of specific contracts containing appropriate protection clauses and guarantees for the safeguarding of personal data provided (for example standard contractual clauses approved by the European Commission) or other conditions required by French and European legislation in force.
5. DATA SUBJECT RIGHTS
Users have the right, at any time, to obtain confirmation of the existence or not of personal data concerning them and to receive it in an intelligible form. Data subjects are entitled to an indication:
- the content and origin of personal data;
- the purposes for which the data are processed and the methods adopted;
- the method applied in the event that the data is processed using electronic tools;
- details identifying the data controller and the data processors;
- the storage period envisaged for the specific categories of data processed;
- subjects or categories of subjects to whom personal data may be transferred or to whose attention it may be made, when they act as data processors or data controllers.
Data subjects are also entitled to:
- have data updated, rectified or, if it is in his interest, supplemented;
- so that the data processed (for example in violation of the law) is deleted, made anonymous or its distribution is restricted, including any information which does not need to be kept in relation to the purposes for which the data were collected or processed;
- data portability to another data controller;
- object to the processing (for example for sending advertising or direct marketing material or for carrying out market research or for commercial communication purposes);
- oppose any automated decision-making process (including profiling);
- revoke any consent given, when this is envisaged (it should be noted that the revocation of consent will not prejudice the legitimacy of the processing on the basis of the consent granted before its revocation);
- receive confirmation that the operations referred to in the preceding paragraphs have been brought to the attention, even with regard to their content, of the persons to whom the data have been transferred or disseminated, except in cases where this obligation proves impossible or necessitates means which are obviously disproportionate to the right to be protected.
The right to object to the processing of personal data for marketing purposes may be exercised in connection with so-called automated (e.g. e-mail, SMS, WhatsApp or other social media, etc.) contact methods and traditional (mail) paper and Telephone); this right may be exercised in whole or in part (for example only for communications sent by paper mail or by telephone, or by opposing only the transmission of promotional communications using automated tools such as email, test message). Your own initiative thanks to the specific services made available to the user (for example by deactivating the corresponding box in the bulletin).
In order to exercise the above rights, users may write to the processor responsible for responding to users exercising their rights, by sending an email to firstname.lastname@example.org, indicating “Confidentiality” as a reference.
6. SUBJECTS TO WHICH PERSONAL DATA MAY BE TRANSFERRED
To receive a complete list of processors processing your data, you can contact our customer service by sending an email to email@example.com.
Your personal data will not be transferred, communicated or transmitted to third parties for purposes not authorized by law or without your express consent. In addition to the companies that act as Data Processors, personal data is also made available to third parties (autonomous data controllers) who process the data autonomously, only for the purpose of executing contracts for the purchase of products on the Site. related to the provision of the services requested by the user (for example, in purchase transactions, the bank providing remote electronic payment services, using a credit / debit card).
These third parties, with whom we work in close contact and who may be the recipients of the user’s personal data, include, for example:
- social media platform partners, who may offer connection services (such as connecting to profile information) from their social media platforms to our website;
- service providers related to the delivery of purchased products or the processing of payments;
- IT service or solution providers backing up internal customer service or marketing (for example, service « Live chat »).
Your data will not be released. However, this does not affect the transfer or dissemination of data required by law, by the police, the judicial authorities, information and security organizations or other public bodies for defense or security purposes of State. crimes.
7. DATA STORAGE PERIOD
Your personal data is processed for the time strictly necessary to achieve the objectives listed above. The following criteria are adopted to establish the storage period:
- specific legislative provisions regulating the activities carried out by Zallomber Groupe
- the period for which the user subscribes to the newsletter (for marketing purposes), until the subscription is revoked;
- tax legislation with regard to the processing of administrative and accounting data (10 years); more specifically, the storage period provided for by applicable tax and accounting legislation is applied to financial data (for example, payments, refunds, etc.).
With regard to data collected for commercial purposes, information relating to identifiable users is kept for 12 months (from the date of obtaining this information) for the transmission of targeted commercial communications (profiling) and 24 months to for direct marketing purposes. The data covered by profiling can therefore be stored for this purpose only for a period not exceeding twelve months from the date of registration, with the exception of the real transformation of the data into anonymous form, not allowing the identification of the persons concerned. , even indirectly or by connection to other databases (profiling operations will be carried out using the data strictly necessary to achieve the objectives set). Personal data of a user « enregistré » will rather be stored for:
– 12 months from the closing of the account
– 10 years after the last visit to our site (for example, access to a personal space, purchase by a logged-in user, etc.), if the user does not close the account.
Finally, the Customer’s personal data may also be kept for the period authorized by French law protecting the legitimate interests of the Data Controller company.
8. PROCESSING BASED ON AUTOMATED DECISIONS AND PROFILING
For more information on the processing of personal data based on automated decision-making and profiling, you can consult our Cookies policy.
In any case, if you have subscribed to one of our services (for example in the section « registered users “Of the site) via authentication methods on social networks (Facebook) or on Google, Zallomber Groupe can access personal data. , first name, last name, email, etc.) found in the social media account or in the user’s profile, in accordance with the operating conditions applicable to the platform in question. We may also collect your personal data when you interact with third-party social media features, such as ” I love ».
In addition to the situations described above relating to the profiling of user behavior on the site and the analysis of consumer tastes and habits, Zallomber Groupe does not adopt other automated processing methods that may have a decision-making effect on the field user’s legal information.
9. TREATMENT FOR ADDITIONAL PURPOSES
The data controller may, once you have been specifically informed, process your data for purposes other than those indicated above, provided that they are compatible with the initial objective stated when collecting data. data. If an additional objective is incompatible with the initial objective, your consent must be given and you will be informed in advance so that you can update or modify your preferences (following the instructions given), confirming or refusing your consent to the use of your personal data.
Your consent will not be necessary if the additional processing carried out by the data controller is based on other grounds of legitimacy, such as compliance with a legal obligation on the part of the data controller or the execution contractual obligations.
This Site and the services it offers are not intended for persons under the age of 18 and the Data Controller does not intentionally collect personal information relating to minors. In the event that information relating to minors is involuntarily recorded, the data controller will quickly delete it, at the request of the users.
11. APPLICABLE LAW AND CONTACTS