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Privacy Policy

This privacy policy aims to help you understand how your personal data is collected, processed, and stored by Sophie d’Agon through the Site.

Sophie d’Agon understands that protecting data and privacy is a crucial matter for all users visiting the Site.

In accordance with GDPR regulations, Sophie d’Agon is committed to respecting your privacy and protecting your personal data, meaning any information that can directly or indirectly identify you as an individual.

The purpose of this privacy policy is to outline Sophie d’Agon’s commitments in this regard.

DEFINITION

When using our Site, we may ask you to provide personal data concerning you.

The term “personal data” refers to all information that can identify an individual, including your name, surname, username, photograph, postal address and email address, job title, phone numbers, date of birth, data related to your transactions on the Site, details of your purchases, credit card numbers, SIRET number, VAT number, IP address, as well as any other information you choose to share about yourself.

OBJECT

This charter (hereinafter the “Charter”) aims to inform you about the methods we use to collect your personal data, while strictly respecting your rights.

We hereby inform you that, in collecting and managing your personal data, we comply with French Law no. 78-17 of 6 January 1978 relating to information technology, files, and freedoms, in its current version (hereinafter: “Loi Informatique et Libertés”), as well as Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data (hereinafter: the “GDPR”).

IDENTITY OF THE DATA CONTROLLER

The controller responsible for collecting your personal data is SOPAXED, registered with the Paris Trade and Companies Register under number 830 886 131, with headquarters at 62 rue de Saintonge – 75003 Paris (hereinafter: “We”).

COLLECTION OF PERSONAL DATA

The legal basis for collecting your personal data is:

  • This collection is necessary to perform the contract when you use our services on our Site;
  • Legitimate interest when you voluntarily provide us with personal data during your visit to our Site, so that we can better respond to your requests for information about our services.

Your personal data is collected to fulfill one or more of the following purposes:

  • Manage your access to and use of certain services available on the Site,
  • Carry out operations related to Client management concerning contracts, invoices, and Client relationship follow-up,
  • Build a user, client, and prospect database,
  • Send newsletters, solicitations, and promotional messages. If you do not wish to receive these, you can opt out at the time we collect your data,
  • Develop commercial and usage statistics for our services,
  • Organize contests, lotteries, and all promotional operations excluding online gambling or games of chance subject to the approval of the Online Gaming Regulatory Authority,
  • Manage product, service, or content reviews,
  • Handle unpaid amounts and potential disputes regarding the use of our products and services,
  • Personalize responses to your information requests,
  • Comply with our legal and regulatory obligations. We inform you, at the time of collecting your personal data, whether certain data is mandatory or optional (indicated by asterisks on the Site).
Why do we collect your personal data? Which categories of personal data do we collect for this purpose? What is the legal basis allowing us to collect your personal data for this purpose?
We collect your personal data to identify you when using our site and to send you messages regarding proper site administration (e.g., registration confirmation, site or terms of use changes, etc.).

  Identification data
  Connection data
This processing is legally based on fulfilling the contract between us when you accept our general terms upon creating your account.
We collect your personal data to deliver your order.   Identification data This processing is legally based on fulfilling the contract between us when you accept our general terms upon creating your account.
We collect your personal data to improve and optimize our site, for example by studying your behavior during your visit and making changes in terms of ergonomics and user experience. Usage and consumption data
Connection data
This processing is legally based on our legitimate interest in providing and improving the user experience for our site’s visitors and members.
We collect your personal data to understand your preferences and offer you commercial proposals that correspond to services/products similar to those already ordered. Usage and consumption data
Identification data
This processing is legally based on our legitimate interest in providing and improving the user experience for our site’s visitors and members.

We inform you, at the time of collecting your personal data, whether certain data is mandatory or optional.

RECIPIENTS OF PERSONAL DATA

Recipients of your personal data include:

  • Our company staff;
  • Monitoring services (lawyer, accountant, etc.);
  • Our subcontractors (communication service providers, productivity software providers, data hosting providers, payment service providers, billing providers, analytics and audience measurement providers, customer relationship management providers);
  • Public bodies, solely to fulfill our legal obligations, judicial officers, court officials, and organizations responsible for debt collection may also receive your personal data.

DURATION OF PERSONAL DATA RETENTION

Regarding data related to client and prospect management:

Your personal data will not be kept longer than strictly necessary for managing our commercial relationship with you.

However, data proving a right or contract that must be retained for compliance with a legal obligation will be kept for the duration provided by the applicable law.

Regarding potential prospecting operations directed at clients, their data may be retained for a period of three (3) years from the end of the commercial relationship.

Personal data relating to a prospect, not a client, may be retained for three (3) years from the date it was collected or the last contact from the prospect.

After this three-year period, we may contact you again to find out if you wish to continue receiving commercial solicitations.

In the event of an exercise of the right of access or rectification, data relating to identity documents may be retained for the period provided in Article 9 of the French Code of Criminal Procedure, i.e., one (1) year. If the right of opposition is exercised, these data may be archived for the limitation period provided in Article 8 of the French Code of Criminal Procedure, i.e., three (3) years.

Financial transactions for purchases and fees on the Site are handled by a payment service provider ensuring the proper functioning and security of these transactions.

In providing these services, the payment service provider may receive your personal data relating to your credit card numbers, which it collects and stores on our behalf. We do not have access to this data.

To allow you to make regular purchases or pay related fees on the Site, your credit card data is stored for the duration of your registration on the Site and, at minimum, until you make your last transaction.

The visual cryptogram (CVV2) on your credit card is not stored.

If you refuse to have your credit card data stored as specified above, we will not retain that data beyond the time needed to complete the transaction.

In any case, data concerning it may be kept in intermediate archives for proof in case of any dispute regarding the transaction, for the period stipulated by Article L 133-24 of the French Monetary and Financial Code, i.e., thirteen (13) months from the debit date. This period may be extended to fifteen (15) months to account for the possibility of using deferred debit payment cards.

Regarding managing the list of people who oppose receiving prospecting:

Information used to record your right to object is retained for at least three (3) years from the exercise of that right.

Regarding audience measurement statistics:

Information stored on users’ devices or any other element used to identify users and allowing their traceability or site visits is not kept longer than thirteen (13) months.

SECURITY

We take all necessary precautions, as well as appropriate organizational and technical measures, to safeguard the security, integrity, and confidentiality of your personal data and to prevent it from being altered, damaged, or accessed by unauthorized third parties. We also use secure payment systems in line with industry standards and applicable regulations.

HOSTING

We inform you that your data is held and stored, throughout its retention period, on servers owned by Google Cloud, located in the European Union.

TRANSFER OUTSIDE THE EUROPEAN UNION

Your data may be transferred outside the European Union as part of the tools we use and our relationships with our subcontractors.

This transfer is secured by one of the following methods:

  • Either the data is transferred to a country deemed to offer an adequate level of protection by a decision of the European Commission;
  • Or we have signed a specific contract with our subcontractors regulating data transfers outside the European Union, based on the Standard Contractual Clauses (SCCs) approved by the European Commission.

ACCESS, RECTIFICATION, LIMITATION, AND ERASURE OF YOUR PERSONAL DATA

In accordance with European regulations on personal data protection, you have the following rights:

  • The right of access, allowing you to know at any time whether your personal data is being processed by our services and, if so, to access your personal data and information required by law about how we process it.
  • The right to rectification, allowing you to request the correction, as soon as possible, of any inaccuracies in the personal data about you.
  • The right to erasure, allowing you to request as soon as possible that your personal data be erased, provided this request meets the conditions required by the applicable law.
  • The right to restrict the processing of your personal data, provided this request meets the conditions required by the applicable law.
  • The right to data portability, allowing you to receive your personal data in a structured, commonly used, and machine-readable format, or to request the transfer of your personal data to another controller, provided this request meets the conditions required by the applicable law.
  • The right to object to the processing of your personal data for reasons related to your particular situation, provided this objection meets the conditions required by the applicable law.
  • The right to withdraw your specific consent given at any time for the collection of your personal data, especially when your personal data is processed for commercial prospecting purposes.
  • The right to define instructions regarding the storage, deletion, and communication of your personal data after your death.

You have the right to obtain the restriction of the processing of your personal data, in the cases defined in Article 18 of the GDPR:

  • During the verification period we undertake when you dispute the accuracy of your personal data,
  • If the processing of your data is unlawful, and you prefer to limit its processing rather than erase your data,
  • If we no longer need your personal data, but you want us to keep it to exercise your rights,
  • During the verification period of legitimate grounds, if you objected to the processing of your personal data.

We remind individuals whose data is collected based on our legitimate interest that they may object to the processing of their data at any time. However, we may continue processing if there are compelling legitimate grounds that override your rights and freedoms or if the processing is necessary to establish, exercise, or defend our legal claims.

You can unsubscribe from our promotional emails via the link provided in those emails. Even if you choose not to receive promotional messages from us, you will still receive our administrative messages.

PORTABILITY OF YOUR PERSONAL DATA

You have the right to data portability for the personal data you have provided to us, meaning data that you actively and knowingly provided in the course of accessing and using the services, as well as data generated by your activity in using the services.

Please note that this right does not apply to data collected and processed under any legal basis other than your consent or the performance of the contract binding us.

This right can be exercised free of charge, at any time, including when closing your account on the Site, in order to retrieve and keep your personal data.

In this context, we will send your personal data by any means deemed appropriate, in an open standard format commonly used and machine-readable, in accordance with industry best practices.

LODGING A COMPLAINT WITH A SUPERVISORY AUTHORITY

You are also informed that you have the right to lodge a complaint with a competent supervisory authority (the Commission Nationale Informatique et Libertés in France), in the EU member state where you have your habitual residence, place of work, or where you believe your rights have been violated, if you consider that the processing of your personal data under this charter constitutes a breach of applicable regulations.

This remedy may be exercised without prejudice to any other administrative or judicial remedy. Indeed, you also have the right to an effective administrative or judicial remedy if you consider that the processing of your personal data under this charter constitutes a violation of applicable regulations.

CHANGES

We reserve the right, at our sole discretion, to modify this Charter at any time, in whole or in part.

These changes take effect upon publication of the new charter.