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Privacy Policy

 

1 - Preamble

 

1.1 This Privacy Policy is an integral part of the T&Cs (as defined below) and the definitions used in the T&Cs are reused in this Privacy Policy.

 

1.2 The purpose of the present Privacy Policy is to inform the Persons Concerned about the way their Personal Data is collected from the Site, how this data is processed by Aluspirit and finally the rights they benefit from with regard to this processing as defined hereafter.
 
 

2 - Definitions

 

The following terms, whether used in the singular or plural in this Privacy Policy, shall have the following definition:

 

Intermediate Archiving :

refers to the movement of Personal Data which still have an administrative interest for Aluspirit (such as in the event of litigation and/or legal obligation) into a separate database, separated logically or physically and to which, in any case, access is restricted. This archive is an intermediate step before the Personal Data concerned is deleted or made anonymous.

 

Privacy policy :

 

 

 

 

refers to the present policy of confidentiality and protection of Personal Data of the Persons Concerned implemented by Aluspirit, which is an integral part of the T&Cs.

GC :

 

refers indiscriminately to the Terms and Conditions accessible by clicking here and Terms of service accessible by clicking here.

Personal data :

refers to the personal data of the Person Concerned, within the meaning of the Personal Data Regulations, collected and processed by Aluspirit in the context of the use of the Site.

Specific Rights :

refers to the rights granted by the Personal Data Regulation to Data Subjects regarding the processing of their Personal Data.

Person Concerned :

designates the natural person (Client, Users as defined in the T&Cs) whose Personal Data is processed by Aluspirit.

Personal Data Regulations :

refers to Law n°78-17 of 6 January 1978 relating to information technology, files and liberties, in application of the General Regulations for Data Protection.

 

Aluspirit :

designates the company referred to in the legal notices accessible by clicking here.

 

Site :

 

means the website accessible at the URL: https://aluvy-design.com/ on which this Privacy Policy is hosted.

 

Terminal(s) :

 

means the hardware equipment (computer, tablet, smartphone, telephone, etc.) used by the Person Concerned to consult or view the Site and/or any other digital medium published by a third party.

3 - The legal basis of the processing

 

3.1 In accordance with the Personal Data Regulation, the processing operations designated in this Privacy Policy are supported by a specific legal basis.

 

3.2 The Data Subject has consented to the processing of his or her Personal Data for one or more specific purposes.

 

The Site has required the express consent of the Concerned Person in order to carry out a specific processing operation explained at the time of obtaining consent.

 

3.3 The processing is necessary for the performance of a contract to which the Concerned Person is a party or for the performance of pre-contractual measures taken at the request of the Concerned Person.

 

3.3.1 In order to use the Site and benefit from its Services, the Concerned Person has accepted at least the T&Cs. These documents formalise a contractual relationship between the Concerned Person and Aluspirit, serving in particular as the legal basis for the collection and processing of the Personal Data of the Concerned Person by Aluspirit.

3.3.2 These Personal Data are necessary for the performance of a certain number of processing operations related to the execution of the contractual relationship between the Concerned Person and Aluspirit, the purposes of which are detailed in paragraph 4 - The purposes of the processing operations.

 

3.4 Processing is necessary to comply with a legal obligation to which Aluspirit is subject.

 

The processing of Personal Data may also be necessary to comply with a legal obligation to which Aluspirit is subject, in particular the retention for accounting and tax purposes.

 

3.5 Processing is necessary for the purposes of the legitimate interests pursued by Aluspirit or by a third party, unless such interests prevail over the interests or fundamental rights and freedoms of the Person Concerned which require the protection of Personal Data, particularly when the Person Concerned is a child.

 

3.5.1 Aluspirit may have a legitimate interest justifying the processing of the Personal Data of the Person Concerned, such as, for example, the processing of Data strictly necessary for fraud prevention purposes.

3.5.2 In this hypothesis, Aluspirit ensures that the processing in question is indeed necessary for the fulfilment of its legitimate interest and assesses the consequences of this processing on the Concerned Person, notably by taking into account the nature of the Data processed, and the way in which it is processed.

3.5.3 Aluspirit ensures that it does not disregard the interest or the fundamental rights and freedoms that allow the Person Concerned to oppose, at any time, all or part of the processing described in this Privacy Policy, as well as to implement his/her Specific Rights, under the conditions of paragraph 9 - Specific Rights.

 

  1. Purposes of the treatments

 

 The Personal Data of the Person Concerned is necessary to enable him/her to access, use and improve the Site, and to enable Aluspirit to :

 

      1. Create and manage the Account;
      2. Carry out operations relating to its commercial relationship with the Person Concerned, i.e. concerning invoices, accounting, follow-up of the "customer relationship" with the Client, such as carrying out satisfaction surveys, managing complaints, use of the Site, etc. ;
      3. Selecting Customers to carry out studies, surveys and product tests, as well as loyalty, prospecting and promotional actions;
      4. Personalise its communication with Customers, in particular by means of information e-mails and newsletters, according to its preferences and its use of the Site;
      5. Carry out operations relating to prospecting, i.e. the management of technical prospecting operations (which includes in particular technical operations such as standardisation, enrichment and deduplication);

      6. Carrying out commercial solicitation operations;

      7. The elaboration of commercial statistics; analyses and marketing tools (including classification, scoring, etc.);
      8. The organisation of competitions, lotteries or any promotional operation with the exception of online gambling and games of chance subject to the approval of the Online Gaming Regulatory Authority;
      9. The management of requests for the exercise of Specific Rights under the conditions of paragraph 9 - Specific Rights;
      10. The management of unpaid invoices and litigation;
      11. The management of comments from Concerned Persons on the Site and/or on the web pages published by Aluspirit such as social network pages;
      12. The fight against fraud.

 

5 - Storage of Personal Data

5.1 The Site is hosted by the company whose contact details are available by clicking here.

 

5.2 All precautions have been taken to store the Personal Data of the Persons Concerned in a secure environment and to prevent them from being distorted, damaged or accessed by unauthorised third parties. The information transmitted by the Concerned Person will never be transmitted to third parties for commercial purposes nor sold or exchanged.

 

6 - Collection of Personal Data on the Site

6.1 Aluspirit collects the following Personal Data when creating an Account, and then when the Account is progressively completed, which the Concerned Person enters or communicates during his or her browsing and which is kept for a period of three (3) years, on an active basis, starting from the last connection of the Concerned Person to the Site:

  • Identification data: surname, first name, postal address, e-mail address, telephone number;

  • Data relating to means of payment: credit card number, expiry date of the credit card;

  • Invoicing data; 

  • Identifier used on the Site,

  • Where applicable, the reason(s) for exclusion (all the elements that make it possible to demonstrate the actions that are less than one month old and that justify the exclusion),
  • Connection data (date, time, IP address, pages consulted) of the Person Concerned when browsing the Site

The above Personal Data is also kept in Intermediate Storage for an additional period of two (2) years in accordance with the common limitation period.

  • Invoices

  • Amount of transactions carried out and the date and time of such transactions

The above Personal Data is also kept in Intermediate Archiving for an additional period of seven (7) years, in accordance with Aluspirit's tax and accounting obligations.

 

6.2 Only the Personal Data designated on the Site as mandatory are indispensable to benefit from an Account.

 

7 - Recipients or categories of recipients

 

Recipient of Personal Data

Nature of data transferred

Purpose of the planned transfer

Level of protection offered by the country or exception provided by the Personal Data Regulations

Shopify

 

Login data to the Site, Identification data

Hosting of the Site

 

https://www.shopify.fr/legal/confidentialite

 

Payplug

Payment method data, invoicing data

Payment

Treatment within the European Union

Oney

Payment method data Invoicing data

Payment

Treatment within the European Union

Transport company

Identification data

Product Delivery

Treatment within the European Union

Customer Service

 

Identification data

Enable customer relationship management

Treatment within the European Union

 

8 - Security of Internet transactions

8.1 In accordance with the T&Cs, the Site uses Payplug or Oney technology to secure the Customers' banking transactions.

 

8.2 Thus, during payment on the Site, the Client's bank details are transmitted in encrypted form to Payplug or Oney without Aluspirit being able to read them.

 

8.3 Aluspirit collects neither the Client's full credit card number nor its cryptogram.

 

8.4 In order to exercise his rights, such as those identified in paragraph 9 - Specific Rights, relating to his credit card details, the Person Concerned is invited to contact Payplug or Oney directly, as the case may be.

 

9 - Specific Rights

 

9.1 In accordance with the Personal Data Regulation, the Data Subject may, at any time, benefit from the following Specific Rights from/to :
    • access,
    • correction,
    • erasure,
    • limitation of a treatment,
    • portability,
    • opposition,
    • post-mortem instructions,

 

9.2 Access rights

9.2.1 The Concerned Person has the possibility to obtain from Aluspirit confirmation as to whether or not his or her Personal Data is or is not being processed and, when it is, access to said Personal Data as well as the following information:

 

  • the purposes of the processing ;
  • the categories of Personal Data;
  • the recipients or categories of recipients to whom the Personal Data have been or will be communicated;
  • when possible, the intended period of retention of the Personal Data or, where this is not possible, the criteria used to determine this period; 
  • the existence of the right to ask Aluspirit to correct or delete Personal Data, or to limit or oppose the processing of Personal Data;
  • the right to lodge a complaint with the CNIL ;
  • when the Personal Data is not collected from the Person Concerned, any information available as to its source;
  • the existence of automated decision making, including profiling, and, at least in such cases, useful information concerning the underlying logic, as well as the importance and the expected consequences of this processing for the Data Subject
 
9.2.2 When Personal Data is transferred to a third country or to an international organisation, the Data Subject has the right to be informed of the appropriate safeguards with respect to such transfer.

 

9.2.3 Aluspirit provides a copy of the Personal Data being processed.

 

9.2.4 Aluspirit may require the payment of reasonable fees based on administrative costs for any additional copy requested by the Person Concerned.

9.2.5 When the Concerned Person submits his request by electronic means, the information shall be provided in a commonly used electronic form, unless he requests otherwise.

9.2.6 The right of the Concerned Person to obtain a copy of his or her Personal Data shall not prejudice the rights and freedoms of others.

 

9.3 Rights of rectification

 

The Person Concerned has the possibility of obtaining from Aluspirit, as soon as possible, the rectification of Personal Data concerning him/her that is inaccurate. He or she also has the possibility of obtaining the completion of incomplete Personal Data, including by providing an additional declaration.

 

9.4 Deletion rights

 

9.4.1 The Concerned Person has the possibility to obtain from Aluspirit the deletion, as soon as possible, of Personal Data concerning him/her when one of the following reasons applies :
 
    • The Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed by Aluspirit;
    • The Data Subject has withdrawn his or her consent to the processing of this Personal Data and there is no other legal basis for the processing;
    • The Concerned Person exercises his/her right to object under the conditions set out below and there is no compelling legitimate reason for the processing;
    • The Personal Data have been processed unlawfully;
    • The Personal Data must be erased to comply with a legal obligation;
    • The Personal Data has been collected from a child.

 

9.5 Limitation rights

 

9.5.1 The Concerned Person has the possibility to obtain from Aluspirit the limitation of the processing of his Personal Data when one of the following reasons applies :

    • Aluspirit verifies the accuracy of the Personal Data following a challenge by the Concerned Person to the accuracy of the Personal Data,
    • The processing is unlawful and the Data Subject opposes the deletion of the Personal Data and demands instead the limitation of their use;
    • Aluspirit no longer needs the Personal Data for the purposes of processing, but they are still necessary for the Person Concerned to establish, exercise or defend his rights in court;
    • The Concerned Person has objected to the processing under the conditions set out below and Aluspirit verifies whether the legitimate reasons pursued prevail over the alleged reasons.

 

 

9.6 Right to Data Portability

 

9.6.1 The Concerned Person has the possibility of receiving from Aluspirit Personal Data concerning him/her, in a structured, commonly used and machine-readable format when :

 

  • The processing of Personal Data is based on consent, or on a contract and,

  • The treatment is carried out using automated processes.
9.6.2 When the Data Subject exercises his or her right to portability, he or she has the right to obtain that the Personal Data be transmitted directly by Aluspirit to another data controller that he or she will designate when this is technically possible.

 

9.6.3 The right to the portability of the Personal Data of the Person Concerned must not infringe upon the rights and freedoms of others.

 

9.7 Right of opposition

 

The Person Concerned may oppose at any time, for reasons relating to his or her particular situation, the processing of Personal Data concerning him or her based on Aluspirit's legitimate interest. Aluspirit will then no longer process the Personal Data, unless it can demonstrate that there are compelling and legitimate reasons for the processing which prevail over the interests and rights and freedoms of the Person Concerned, or may keep them for the establishment, exercise or defence of legal rights.

 

9.8 Post-mortem guidelines

 

9.8.1 The Person Concerned has the possibility of communicating to Aluspirit directives relating to the conservation, erasure and sharing of his Personal Data after his death, which directives may also be registered with a "certified digital trust third party". These directives, or a kind of "digital will", may designate a person responsible for their execution; failing this, the heirs of the Person Concerned will be designated.

 

9.8.2 In the absence of any directives, the heirs of the Person Concerned may contact Aluspirit in order to

    • access Personal Data processing allowing "the organisation and settlement of the deceased's estate";
    • receive communication of "digital assets" or "data similar to family memories, transmissible to the heirs";
    • to have the account of the Person Concerned closed on the Site and to oppose the further processing of his/her Personal Data.

9.8.3 In any case, the Concerned Person has the possibility of indicating to Aluspirit, at any time, that he or she does not wish, in the event of death, that his or her Personal Data be communicated to a third party.

 

10 - Exercise of Specific Rights

 

10.1 These rights may be exercised at any time with Aluspirit :

 

    • By e-mail at the following address: vosdonnees@aluvy-design.com
    • By post to the following address Aluspirit, 231 Chemin du Ténement, 38260 Porte-des-Bonnevaux (France).
10.2 In order to assert its rights according to the conditions referred to above, and in the event that Aluspirit has doubts about the author of the request, Aluspirit may ask the latter to prove its identity by mentioning its surname, first name, e-mail address and to accompany its request with a copy of a valid identity document.

 

10.3 A reply shall be sent to the Person Concerned within a maximum period of one (1) month following the date of receipt of the request.

 

10.4 If necessary, this period may be extended by two (2) months by Aluspirit, which will notify the Person Concerned, taking into account the complexity and/or number of requests.

 

10.5 In the event of a request by the Person Concerned to delete his/her Personal Data and/or in the event of the exercise of his/her right to request the deletion of his/her Personal Data, Aluspirit may however retain such Personal Data in the form of Intermediate Archiving, for the duration necessary to meet its legal obligations, or for evidentiary purposes during the applicable prescription period.

 

10.6 The Person Concerned may also bring a claim before the competent control authority (the CNIL).

 

11 - Password security

 

11.1 Aluspirit takes all useful precautions to ensure the secure storage of the Concerned Person's password.
 

11.2 However, the security of this password also depends on its design.

 
11.3 The Concerned Person is therefore reminded that his password, in order to be valid, must be composed of at least 8 characters, at least 3 of the following 4 types: upper case, lower case, numbers, special characters, etc.
 

11.4 Mnemonics can be used to create complex passwords, such as :

 
    • Keeping only the first letters of words in a sentence; for example, the sentence "A Password is remembered! For example, the phrase "A Password is remembered!" corresponds to the password 1mdp@sr!
    • By putting a capital letter if the word is a name (ex: word)
    • By keeping punctuation marks (e.g. !)
    • By expressing numbers using numbers from 0 to 9 (ex: One ->1)
 
12 - Cookies placed on the Concerned Person's Terminal following his or her browsing on the Site.
 
 

12.1 Cookies are used on the Site.

 
 
12.2 A cookie is a piece of information deposited on the Terminal that is used by the Person Concerned to access the Site.
 
 
12.3 Cookies relate to the browsing of the Concerned Person on the Site and make it possible to determine the pages that the Concerned Person has consulted, their date and time of consultation.
 
 
12.4 At no time do these cookies allow Aluspirit to personally identify the Person Concerned.
 
 

12.5 The storage period of these cookies in the Concerned Person's Terminal does not exceed thirteen (13) months.

 
 
12.6 More specifically, the Personal Data collected from cookies issued by Aluspirit or third parties allow :
 
    • To establish statistics and volumes of visits to and use of the Site, making it possible to improve the interest and ergonomics of the services;
    • To adapt the presentation of the Site to the display preferences of the Concerned Person's Terminal (language used, display resolution, operating system used, etc.) ;
    • To store information relating to a form completed by the Concerned Person on the Site (registration or access to the Account);
    • To implement security measures, for example when the Concerned Person is asked to log back on to the Site after a certain period of time;

 

12.7 Thanks to cookies, Aluspirit collects and processes all or part of the following Personal Data for the purposes determined above:

 

  • Information related to the Terminal of the Person Concerned and/or of the Person Concerned:

    • His type of Terminal (Smartphone, tablet, computer, etc.);
    • The operating system of his or her Terminal (Mac Os, iOS, Android, Windows, BlackBerry, etc.);
    • The categories and plug-in versions of his or her Terminal;
    • Your Internet service provider (Orange, SFR, Bouygues, Free, etc.);
    • The browser used (Safari, Chrome, Internet Explorer, etc.);
    • The advertising identifier linked to the operating system of the Terminal;
    • The IP address of your Terminal;
    • The geolocation data of your Terminal;
    • Its language preferences.

  • Information on its browsing and behaviour on the Site:

    • Statistics on the consultation of the different pages of the Site;
    • The complete URL path to, via and from the Site;
  • Information concerning the Person Concerned (age or age group, gender, declared and/or presumed socio-professional category, presumed centres of interest, etc.) linked to his/her activity on the Internet and communicated by third parties (advertisers, advertising agencies, etc.).


13 - Aluspirit Cookies

 

Cookie categories

Purpose

Shelf life

Session cookie

used to maintain the operation of the Site

duration of the session

Cookie of session identifiers

strictly necessarily to the operation of the Site and the identification of the Client

duration of the session

Cookie preferred

collects information about the choices and preferences of the Concerned Person and allows the language or other local settings to be saved in order to personalise the User's experience on the Site.

duration of the session

Cookie to validate the order (Shopify cookies: cart_currency, cart_sig, secure_customer_sig, storefront_digest)

used in order to maintain the Products pre-selected for purchase, and to validate the Order

duration of the session

Social network cookie (Facebook)

used in order to allow the User to connect via his account created on a social network.

duration of 13 months

14- Opposition to cookies

 

14.1 The Person Concerned is informed, during his/her first visit, that he/she has the option of opposing the recording of cookies which are accessory to the operation of the Site, in particular by configuring his/her Internet browser or by exercising his/her choices on this page (see below).

 
 
14.2 When the Concerned Person browses the Site, information may be recorded or read in his Terminal, subject to his choices.
 
 
14.3 The Concerned Person will find more help on the dedicated pages of his browser (hereafter the most common browsers):

 

14.4 The Concerned Person may also set his browser to send a code indicating to websites that he does not wish to be tracked ("Do No Track" option):

 

Version effective as of: 18 January 2021