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Privacy policy

Traphic privacy policy

Last updated on 20/10/2020

In accordance with our philosophy, the protection of your personal data is essential to us and we wish to inform you through this privacy policy ("Privacy Policy") of how we collect and process your personal data and how you can control this use and exercise your rights.

1. Glossary

In the Privacy Policy, unless otherwise specified, the following expressions and words respectively have the meanings indicated below:

Intermediate Archiving: refers to the isolation by a logical separation (management of access rights and authorizations limited to a specific service) and / or physical of Personal Data which is still of administrative interest to Traphic.

Customer: refers to the natural person who ordered a Product from Traphic.

CNIL : refers to the Commission Nationale de l’Informatique et des Libertés (which could be translated as the National Commission for Informatics and Freedoms)

Personal Data : refers to any information relating directly or indirectly to a natural person. Some Personal Data may be Sensitive Data

Sensitive Data : refers to any Personal Data which reveals either the racial or ethnic origin of the natural person, his political opinions, his religious or philosophical convictions, his trade union membership, his state of health, his sexual orientation or elements of his sexual life.

Service provider : refers to all the service providers with which Traphic has contractual relations.

Regulation : refers to Law n ° 78-17 of January 6, 1978 relating to computers, files and freedoms, as amended, Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 relating to the protection of natural persons with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46 / EC (hereinafter "GDPR") as well as any applicable data protection regulations Personal.

Social networks : refers to the social network pages dedicated to Traphic, in particular on Facebook, Youtube and Instagram.

Controller : means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing; when the purposes and means of such processing are determined by European Union law or the law of a Member State, the controller may be designated or the specific criteria for its designation may be laid down by European Union law or the law of a Member State.

Site : refers to the website published by Traphic which url address is https://www.traphic.fr.

Subcontractor : means the natural or legal person, public authority, service or other body that processes Personal Data on behalf of the Controller.

Terminal : means the hardware equipment (computer, tablet, smartphone, telephone) that you use to consult or watch the Site.

Processing or Treatment of Personal Data : means the collection, recording, organization, structuring, storage, adaptation, or modification, retrieval, consultation, use or any other form of making available, alignment or interconnection, limitation, erasure and destruction.

User : refers to the person browsing the Site and/or the Social Networks but who has never created a customer account and has never ordered a Product.

These definitions are capitalized and are to be understood in the singular as well as in the plural.

2. What is the scope of the privacy policy ?

The Privacy Policy applies to the Site and Social Networks.

This Privacy Policy is addressed to :

- Customers ;

- Users.

Consequently, accessing and browsing the Site and the Social Networks and ordering Products from Traphic assumes that you have accepted all the terms of the Privacy Policy, and therefore the collection and use of your Personal Data.

3. Who are the actors of the protection of Personal Data within Traphic ?

The person in charge of processing Personal Data is Traphic, SASU simplified joint stock company with a single shareholder, with a capital of 9,000 euros, whose registered office is located at 85, rue d'Hauteville - 75010 Paris, for the Treatments it implements on the Personal Data of Clients, Prospects and Users collected.

You can contact Traphic by writing to the postal address 85 rue d'Hauteville - 75010 Paris - FRANCE or by sending an email at hello@traphic.fr.

4. What is the nature of the Personal Data processed by Traphic ?

Traphic takes into account the principles of data minimization, data protection from the design stage and default data protection. Consequently, relevant, adequate information is collected and limited to what is necessary for the purposes for which it is processed, and in particular necessary for the supply of the Products ordered.

This Personal Data is collected when you order a Product or when you do contact Traphic.

When you fill in input fields on a form, the mandatory nature of an answer is indicated by the use of an asterisk (*) at the end of the question. Failure to answer a question marked with an asterisk will prevent your request from being processed.

When you choose to voluntarily send your Personal Data to Traphic, without being asked to do so, you expressly consent to the collection of the Personal Data and you agree to assume full responsibility for the Personal Data transmitted.

4.1 The data relating to the order of a Product

Traphic collects and processes gender, first name, last name, email, password, phone number and mailing address.

The Customer information collected and processed does not contain any Sensitive Data.

4.2 The Customer's payment information and bank details

Traphic does not process any payment information or bank details of the Customer.

5. What are the purposes of Treatment and the legal bases?

Traphic collects and processes Personal Data only if one of the following conditions is met:

- Traphic has obtained your prior consent;

- The Processing is necessary for the performance of a contract or pre-contractual measures;

- Processing is necessary to comply with Traphic's legal or regulatory obligations; or

- The Treatment is necessary for the purposes of the legitimate interests pursued by Traphic and does not unduly affect your interests or fundamental rights and freedoms.

5.1 On the basis of a contract or pre-contractual measures :

On the basis of a contract or pre-contractual measures, Traphic carries out the following processing operations:

- Management of orders and deliveries ;

- Management of incidents and complaints;

- Invoicing;

- The follow-up of the relationship with the Customers.

5.2 On the basis of Traphic's legitimate interest :

On the basis of the legitimate interest, Traphic performs the following processing operations:

- The preparation, the exercise and the follow-up of the appeals and litigations;

- The execution of the rendered decision.

5.3 On the basis of the consent of the Prospects/Clients :

On the basis of the consent of the Customers, Traphic performs the following Treatments:

- The sending of newsletters to Customers.

In this context, you may withdraw your consent at any time, without such withdrawal may affect the legality of the Treatments performed by Traphic before such withdrawal.

5.4 On the basis of compliance with legal and regulatory obligations :

Traphic may also use your Personal Data to meet its legal and regulatory requirements, in particular concerning :

- Responding to security, anti-fraud or law enforcement requirements;

- Maintaining accounting records.

6. How long is the Personal Data retained ?

Traphic retains your Personal Data for the time necessary to fulfill its purposes, subject to the legal possibilities of archiving, obligations to retain certain Personal Data and/or anonymization.

6.1 Personal data relating to the management of the customer account and the order of a Product

Traphic retains your Personal Data for the time necessary to fulfill its purposes, subject to the legal possibilities of archiving, obligations to retain certain Personal Data and/or anonymization.

Customer Personal Information relating to the order and delivery of a Product is retained for a period of three (3) years from the date of the order for such Product.

At the end of this period of three (3) years, the Personal Data relating to the management of a customer account and the order of a Product are subject to Intermediate Archiving for the duration of legal or regulatory requirements.

At the end of the legal or regulatory prescription period, Traphic undertakes to erase the Personal Data from its databases or to make them anonymous.

In addition, Personal Data collected through the use of Cookies are only kept for a period of thirteen (13) months from the date of collection of such Personal Data.

7. Who are the recipients of your Personal Data?

Traphic never transmits your Personal Data to third parties likely to use them for their own purposes and in particular for commercial and/or direct advertising purposes.

7.1 Customer's Personal Data

Traphic may share your Personal Data, only to the extent necessary, with :

- Its employees authorized to process your Personal Data;

- Its suppliers, service providers and subcontractors, for the performance of tasks related to the purposes described above;

- Public authorities: Traphic may be required to disclose your Personal Data in response to a specific request from a competent administrative or judicial authority, as well as more generally in all situations where the law, regulation or an administrative or judicial decision so requires.

In addition, in the event of a reorganization, merger, sale, joint venture or other transfer or assignment of all or part of our business, Traphic may disclose or transfer your Personal Data to the successor in title.

8.How is the storage of your Personal Data ensured?

Your Personal Data is stored either in Traphic's databases or in those of suppliers, service providers and subcontractors.

9. How is the security of Personal Data ensured?

Traphic is committed, in the course of its business and in accordance with the Regulations, to ensuring the protection, confidentiality and security of Personal Data.

Traphic takes the necessary precautions, taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the Processing as well as the likelihood of each risk, in order to preserve the security and confidentiality of the Personal Data that you communicate to Traphic and in particular to prevent it from being distorted, damaged or communicated to third parties (unless you agree otherwise).

Accordingly, Traphic implements all technical, logical, physical and organizational measures to ensure a level of security appropriate to the risk and to prevent any loss, alteration, disclosure of Personal Data or access to unauthorized third parties.

However, given the intrinsic characteristics of the Internet, any transmission of information via the Internet is not completely secure. The Personal Data transmitted to Traphic are subject to measures that cannot prevent all risks of misappropriation and/or piracy. The transmission of your Personal Data therefore occurs at your own risk.

In case of violation of Personal Data and in accordance with the Regulation, Traphic undertakes to notify the CNIL.

10. How is the protection of Personal Data on Social Networks ensured?

Traphic is present on Social Networks, including Facebook, YouTube and Instagram.

Traphic would like to remind you that Treatments are implemented by the Social Network when you access or use this Social Network, which requires that you consult and accept the privacy policy of each of the Social Networks you use.

Depending on the Social Network you are using, you will be able to access many features such as following Traphic's news, commenting or sharing content published by Traphic on your personal page within the Social Network, etc.

For these purposes, Traphic will process some of your Personal Data, including your name, surname and any information made public on your personal page.

11. How is children's privacy protected?

Traphic Products are not intended for children and are not targeted to children under fifteen (15) years of age. If you are under fifteen (15) years of age, you may not order Products and you may not send Traphic any information about yourself.

12. Does Traphic use cookies?

Cookies, which are small computer files stored on the hard drive of your Terminal that record certain information in order to facilitate your browsing experience, are deposited on your Terminal when you browse the Site.

Traphic uses the following Cookies:

- Functional Cookies: These cookies are required for the basic functionality of the site and are therefore always active. This includes cookies that allow you to be recognized when you visit our Site during the same session or, if you wish, from one session to another. They allow us to establish your shopping cart and the payment procedure but also to ensure the security of exchanges and compliance with regulations.

- Performance cookies: These cookies allow us to improve the functionalities of our Site by tracking their use. In some cases, these cookies allow us to improve the speed with which we process your request, and to retain the preferences you have selected. Refusing these cookies may result in less relevant recommendations and slower site performance.

- Social Network and Advertising Cookies: Social network cookies provide the ability to connect to your social networks and share content from our Site on social networks. Advertising cookies (from third parties) collect information to better tailor advertisements to your interests, both on and off our Site. In some cases, these cookies require the processing of personal data. Refusing these cookies may result in the display of advertisements that are not tailored to you, or may prevent you from effectively connecting to Facebook, Twitter, or other social networks and/or prevent you from being able to share content on social networks.

13. How can you manage/delete these cookies?

Any settings that you may undertake will be likely to modify your browsing on the Internet and your conditions of access to certain services requiring the use of Cookies.

You do not expose yourself to any risk by accepting the use of this system. Cookies do not damage your Terminal.

The registration of a Cookie in a Terminal is essentially subject to your consent. You can express and modify your choices at any time and free of charge in the navigation software of your Terminal.

If you have accepted the registration of Cookies in your browser software, the Cookies embedded in the pages and content that you have consulted may be stored temporarily - without exceeding thirteen (13) months - in a dedicated space on your Terminal. They will be readable there only by their sender.

If you do not want Cookies to be placed on your Terminal, you can easily limit or delete them by setting your browser or mobile device. However, you will no longer be able to benefit from a certain number of functionalities that are nevertheless necessary to navigate in certain areas of our Site.

Where applicable, we decline all responsibility for the consequences related to the degraded functioning of our Services resulting from the impossibility for us to record or consult the Cookies necessary for their functioning and which you would have refused or deleted.

14. Does Traphic transfer Personal Data outside the European Union?

For the purposes mentioned above, Personal Data may be transferred to a country located within the European Union. However, no transfer of data to a country that has not been the subject of an adequacy decision by the European Commission is carried out by Traphic.

15. What are your Rights?

Traphic informs you that you benefit, under the terms and conditions set forth in the Regulation :

- A right to information: You have the right to receive clear, transparent and easily understandable information about how we use your information and your rights.

- A right of access: You have the right to access the Personal Information about you that Traphic holds and processes.

- A right of rectification: you have the right to ask Traphic to rectify the information concerning you in the event of errors or inaccuracies.

- A right of opposition: when the Processing is based on the legitimate interests of Traphic, you have the right to oppose, for legitimate reasons, a Processing of Personal Data. Please note that this right to object does not apply if our legitimate interests in continuing the Processing take precedence over yours.

- A right to limit processing: the right to ask Traphic not to keep some of your Personal Data for future processing when :

o You dispute the accuracy of your Personal Data;

o You consider and can establish that the Processing of the Personal Data is unlawful and you object to the deletion of the Personal Data and instead require the limitation of the Processing;

o Traphic no longer needs your Personal Data, but that they are still necessary for the establishment, exercise or defense of your rights in court ;

o You object to the Processing based on Traphic's legitimate interest, during the verification of whether the legitimate reasons pursued by Traphic prevail over those of the data subject.

- A right to erasure: subject to the exceptions provided by the Regulation, the right to obtain from Traphic the erasure of your Personal Data, when one of the following reasons applies:

o Your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed;

o You wish to withdraw the consent on which the Processing of your Personal Data was based and there is no other basis for such Processing;

o You object to the Processing and there are no compelling legitimate reasons for the Processing or you object to the sending of commercial solicitations;

o You consider and can establish that your Personal Data have been processed unlawfully;

o Your Personal Data must be erased pursuant to a legal obligation.

- A right to the portability of your data: when the Processing is based on your consent or a contract, you have the right to receive from Traphic Personal Data about you in a structured, commonly used format and to transmit such Personal Data to another data controller without Traphic interfering with it.

Where technically possible, you may request that Traphic transfer your Personal Data directly to another data controller.

- A right to withdraw consent: Where the Treatment is based on your consent, you have the right to withdraw your consent, at any time, without Traphic being able to object.

- A right to decide the fate of your Personal Data after your death: Finally, you have the right to organize the fate of your Personal Data post-mortem by adopting general or specific guidelines. Traphic is committed to respecting these guidelines. In the absence of such directives, Traphic recognizes the heirs' right to exercise certain rights, in particular the right of access, if necessary for the settlement of the deceased's estate; and the right to object to the closure of the deceased's user accounts and to object to the Processing of their data.

You can exercise your rights by sending an email to Traphic at the following address: hello@traphic.fr , accompanied by a copy of your ID.

If, despite Traphic's efforts to preserve the confidentiality of your Personal Data, you believe that you are a victim of a violation of the Regulations, you may submit a complaint to the national data protection authority: Commission Nationale de l'Informatique et des Libertés (CNIL), 3, place de Fontenoy - TSA 80715 -75334 Paris CEDEX 07 (01 53 73 22 22 - www.cnil.fr). You also have the right to seek compensation from the competent courts if you consider that we have not respected your rights.

16. How can I be notified of a change in our privacy policy?

Traphic reserves the right to change its Privacy Policy. Any changes to the Privacy Policy will be posted on the Site. We invite you to regularly consult the Privacy Policy. Any order placed after the date of modification presumes your full acceptance of the new Privacy Policy as modified.