Privacy policies

Preamble

These Privacy Policies form an integral part of the general terms and conditions (as defined below), and the definitions used in the latter are reused in these Privacy Policies.

The purpose of these Privacy Policies is to inform Data Subjects about how their Personal Data is collected from the Site, how it is processed by Dolazar and finally the Specific Rights (as defined below) that Data Subjects have with regard to these processing operations as defined below.

Definitions

The following terms, whether used in the singular or plural in these Privacy Policies, shall have the following definitions:

  • Intermediate Archiving: This refers to the transfer of Personal Data that still has administrative value for Dolazar (such as in the event of litigation and/or a legal obligation) to a separate database, logically or physically separated and whose access is restricted in any case. This archive is an intermediate step before the deletion of the Personal Data concerned or its anonymization;
  • Privacy policies: refers to this privacy and personal data protection policy implemented by Dolazar, which forms an integral part of the General Terms and Conditions;
  • General Terms and Conditions refers indiscriminately to: General Terms of Use, General Terms of Service and General Terms of Sale
  • Personal Data: refers to the personal data of the Data Subject, as defined in the Personal Data Regulations, collected and processed by Dolazar in connection with the use of the Site;
  • Specific Rights: refer to the rights granted by the Personal Data Regulations to Data Subjects regarding the processing of their Personal Data and detailed in Article IX;
  • Person Concerned: refers to the natural person (Internet user, Client, Subscriber) whose Personal Data is processed by Dolazar;
  • Regulations on Personal Data: refers to Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms, in application of the General Data Protection Regulation;
  • Dolazar: refers to the company Ecomeo OÜ, whose registered office is located at Lõõtsa tn 2a, 11415 Tallinn, Estonia, registered under number 16563515.
  • Terminal(s): refers to the hardware (computer, tablet, smartphone, telephone, etc.) used by the Data Subject to consult or view the Site and/or any other digital media published by a third party.

The legal basis for processing

In accordance with the Personal Data Regulations, the processing operations described in these Privacy Policies are supported by a specific legal basis.

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

The Site may have requested the express consent of the Data Subject in order to carry out a specific processing explained during this collection of consent.

The processing is necessary for the performance of a contract to which the Data Subject is a party or in order to take steps at the request of the Data Subject prior to entering into a contract.

In order to use the Site and benefit from its services, the Data Subject has accepted at a minimum the General Terms of Use and, where applicable, the General Terms of Sale and/or General Terms of Service. These documents formalize a contractual relationship between the Data Subject and Dolazar, serving in particular as the legal basis for the collection and processing of the Data Subject's Personal Data by Dolazar.

This Data is necessary for the performance of a number of processing operations related to the execution of the contractual relationship between the Data Subject and Dolazar, the purposes of which are detailed in the paragraph "Purposes of processing".

The processing is necessary for compliance with a legal obligation to which it is subject.

The processing of Personal Data may also be necessary to comply with a legal obligation to which Dolazar is subject, for example, the retention of access logs to the Site, in accordance with Decree No. 2011-219 of 25 February 2011 relating to the retention and communication of data enabling the identification of any person who has contributed to the creation of online content.

The processing is necessary for the purposes of the legitimate interests pursued by Dolazar or by a third party, unless the interests or fundamental rights and freedoms of the Data Subject which require protection of personal data override those interests, in particular where the Data Subject is a child.

Dolazar may have a legitimate interest justifying the processing of the Personal Data of the Data Subject, such as the processing of Data strictly necessary for the purposes of fraud prevention.

In this scenario, Dolazar ensures that the processing in question is indeed necessary for the achievement of its legitimate interest and assesses the consequences of this processing on the Data Subject, in particular taking into account the nature of the Data processed, and the way in which it is processed.

Dolazar ensures that it does not disregard the interest or fundamental rights and freedoms by allowing the Data Subject, at any time, to object to all or part of the processing described in these Privacy Policies, as well as to implement their Specific Rights, under the conditions of the paragraph "Specific Rights".

The purposes of the processing

The Personal Data of the Data Subject is necessary to enable them to access, use and improve the Site, and to enable Dolazar to:

  • To carry out operations relating to its commercial relationship with the Person Concerned, i.e. concerning invoices, accounting, monitoring of the "customer relationship" with a Client or Subscriber, such as carrying out satisfaction surveys, managing complaints, use of the Site and more generally of services, etc.;
  • Selecting Customers or Subscribers to conduct studies, surveys and product tests, as well as loyalty, prospecting and promotional activities;
  • To personalize its communication for Clients or a Subscriber, in particular through informational emails, based on their observed preferences and their use of the Site;
  • Carry out prospecting operations, i.e. the management of technical prospecting operations (which notably includes technical operations such as normalization, enrichment and deduplication);
  • Carrying out commercial solicitation operations;
  • The development of sales statistics; analyses and marketing tools (including classification, scoring, etc.)
  • The organization of competitions, lotteries or any promotional operation, excluding online gambling and games of chance subject to the approval of the Online Gaming Regulatory Authority;
  • The management of requests to exercise Specific Rights under the conditions of the paragraph "Specific Rights";
  • Managing unpaid invoices and litigation;
  • Managing comments from Data Subjects on the Site and/or on internet pages published by Dolazar such as social network pages;
  • The fight against fraud.

Storage of Personal Data

The Site is hosted by the company whose contact details are available in the General Terms and Conditions of Use, accessible from the footer of the site.

Every precaution has been taken to store the Personal Data of the Data Subjects in a secure environment and to prevent it from being altered, damaged, or accessed by unauthorized third parties. Information provided by the Data Subject will never be transmitted to third parties for commercial purposes, nor sold or exchanged, without their express prior consent.

The collection of Personal Data on the Site

Dolazar collects, where applicable during the creation of an Account and then as it is completed, the following Personal Data that the Client and the Subscriber enters and communicates during their browsing and which is kept for a period of three (3) years, in an active database, from the last connection of the Person Concerned to the Site:

  • Sex,
  • Date of birth,
  • Email address,
  • Identifier used on the Site,
  • Payment ID,
  • Delivery address,
  • Billing address,
  • Phone number,

Connection data (date, time, IP address, pages viewed) of the Person Concerned during their browsing on the Site and, in particular, those related to the use of Specific Services by the Subscriber.

The data entered by the Subscriber on the Site when using the Specific Services.

If applicable, the reason(s) for exclusion (all the elements that demonstrate the actions which date from less than one month ago and which justify the exclusion).

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

  • Invoices,
  • Amount of transactions carried out, as well as the date and time of these transactions,

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

Only the Personal Data designated on the Site as mandatory is essential to benefit from an Account.

Recipients or categories of recipients, if any.

Dolazar may disclose to third parties certain Personal Data necessary for the processing of Orders under the General Terms and Conditions of Sale or Subscription under the General Terms and Conditions of Service, in particular to ensure:

  • the shipment of the Products;
  • the fight against fraud,
  • after-sales service, etc.

Security of online transactions

In accordance with the General Terms and Conditions, the Site uses the technology of various PSP (Payment Service Provider) companies to secure the banking transactions of Customers and Subscribers.

Thus, when paying on the Site, the bank details of the Person Concerned are transmitted in encrypted form to the company that processes the payment, without Dolazar being able to have access to them.

Dolazar does not collect the full number of the Client's or Subscription's bank card, nor its cryptogram.

To exercise their rights, such as those identified in the "Specific Rights" section, relating to their bank card details, the Data Subject is invited to contact the company that processed the payment directly. For PSP's contact details, please contact Dolazar at contact@dolazar.com.

Specific Rights

In accordance with the Personal Data Regulations, the Data Subject may, at any time, exercise the following Specific Rights:

  • access,
  • correction,
  • erasure,
  • limitation of a treatment,
  • portability,
  • opposition,
  • post-mortem directives.

Access rights

The Data Subject has the right to obtain from Dolazar confirmation as to whether or not Personal Data concerning him or her are being processed, and, where that is the case, access to the Personal Data and 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;
  • where possible, the envisaged period for which Personal Data will be retained or, where this is not possible, the criteria used to determine this period;
  • the existence of the right to request from Dolazar the rectification or erasure of Personal Data, or a limitation of the processing of his Personal Data, or the right to object to this processing;
  • the right to lodge a complaint with the CNIL;
  • when Personal Data is not collected from the Data Subject, any available information as to its source;
  • the existence of automated decision-making, including profiling, and, at least in such cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the Data Subject.

When Personal Data is transferred to a third country or international organisation, the Data Subject has the right to be informed of the appropriate safeguards relating to that transfer.

Dolazar provides a copy of the Personal Data being processed.

Dolazar may require payment of reasonable fees based on administrative costs for any additional copies requested by the Data Subject.

When the Data Subject submits their request electronically, the information shall be provided in a commonly used electronic form, unless they request otherwise.

The right of the Data Subject to obtain a copy of their Personal Data must not infringe on the rights and freedoms of others.

Right of rectification

The Data Subject has the right to obtain from Dolazar, without undue delay, the rectification of inaccurate Personal Data concerning him or her. He or she also has the right to have incomplete Personal Data completed, including by providing a supplementary statement.

Rights to erasure

The Data Subject has the right to obtain from Dolazar the erasure, without undue delay, of Personal Data concerning him or her when one of the following grounds applies:

  • Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed by Dolazar;
  • The Data Subject has withdrawn their consent for the processing of this Personal Data and there is no other legal basis for the processing;
  • The Data Subject exercises their right to object under the conditions recalled below and there is no overriding legitimate ground for the processing;
  • Personal Data has been processed unlawfully;
  • Personal Data must be erased to comply with a legal obligation;
  • The Personal Data was collected from a child.

Rights to limitation

The Data Subject has the right to obtain from Dolazar the restriction of the processing of their Personal Data when one of the following grounds applies:

  • Dolazar verifies the accuracy of Personal Data following a dispute by the Data Subject regarding the accuracy of the Personal Data;
  • The processing is unlawful and the Data Subject objects to the erasure of Personal Data and demands instead the restriction of its use;
  • Dolazar no longer needs the Personal Data for the purposes of processing, but this data is still required by the Data Subject for the establishment, exercise or defence of legal claims;
  • The Data Subject objected to the processing under the conditions recalled below and Dolazar verifies whether the legitimate grounds pursued prevail over the grounds alleged.

Right to Data Portability

The Data Subject has the option to receive from Dolazar their Personal Data 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 processing is carried out using automated processes.

When the Data Subject exercises their right to data portability, they have the right to have the Personal Data transmitted directly by Dolazar to another data controller they designate where technically feasible.

The right to data portability of the Personal Data of the Data Subject must not infringe on the rights and freedoms of others.

Right to object

The Data Subject may object at any time, on grounds relating to their particular situation, to the processing of Personal Data concerning them based on Dolazar's legitimate interest. Dolazar will then cease processing the Personal Data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject, or may retain the data for the establishment, exercise or defence of legal claims.

Similarly, we remind you that, in the event that the Person Concerned has provided a telephone number, they have the right to register on a list to opt out of telephone marketing.

Post-mortem directives

The Data Subject has the option of providing Dolazar with instructions regarding the retention, deletion, and disclosure of their Personal Data after their death. These instructions may also be registered with a certified digital trusted third party. These instructions, or a kind of "digital will," may designate a person responsible for their execution; otherwise, the Data Subject's heirs will be designated.

In the absence of any instructions, the heirs of the Person Concerned may contact Dolazar in order to:

  • access to the processing of Personal Data enabling "the organisation and settlement of the deceased's estate";
  • to receive communication of "digital assets" or "data resembling family memories, transmissible to heirs";
  • to have the account of the Person Concerned closed on the Site and to object to the continued processing of their Personal Data.

In any event, the Person Concerned has the possibility to indicate to Dolazar, at any time, that he/she does not wish, in the event of death, for his/her Personal Data to be communicated to a third party.

Exercising Specific User Rights

These rights can be exercised at any time with Dolazar:

  • By email to the following address: contact@dolazar.com
  • By post to the following address: Ecomeo OÜ, Lõõtsa tn 2a, 11415 Tallinn, Estonia.

In order to assert its rights under the conditions referred to above and in the event that Dolazar has doubts about the author of the request, Dolazar may ask the latter to prove his identity by mentioning his surname, first name, email address and to accompany his request with a copy of a valid identity document.

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

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

In the event of a request from the Data Subject to the deletion of their Personal Data and/or in the event of the exercise of their right to request the erasure of their Personal Data, Dolazar may nevertheless retain them in the form of Intermediate Archiving, for the period necessary to satisfy its legal obligations, or for evidentiary purposes during the applicable limitation period.

The Data Subject may also lodge a complaint with the competent supervisory authority (the CNIL).

The security of your password

Dolazar takes all necessary precautions to ensure the secure storage of the Data Subject's password.

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

Furthermore, the Person Concerned is reminded that their password, to be valid, must be at least 8 characters long and include at least 3 of the following 4 types: uppercase letters, lowercase letters, numbers, and special characters.

Mnemonic devices can be used to create complex passwords, such as:

  • Keep only the first letters of the words in a sentence; for example, the sentence "A password is memorable!" corresponds to the password 1mdp@sr!
  • Capitalize the first letter if the word is a noun (e.g., word).
  • While retaining punctuation marks (e.g., !)
  • By expressing numbers using the digits from 0 to 9 (e.g., One -> 1)

Cookies placed on the Data Subject's Terminal following their browsing of the Site

Cookies are used on the Site.

A cookie is a piece of information stored on the Terminal which is used by the Person Concerned to access the Site.

Cookies are used to track the Data Subject's navigation on the Site and allow us to determine the pages they have visited, and the date and time of their visit.

At no time do these cookies allow Dolazar to personally identify the Person Concerned.

The storage period for these cookies in the Data Subject's Terminal does not exceed thirteen (13) months.

More specifically, the Personal Data collected from cookies issued by Dolazar or third parties allows:

  • To establish statistics and volumes of traffic and use of the Site in order to improve the interest and ergonomics of the services;
  • To adapt the presentation of the Site to the display preferences of the Terminal of the Person Concerned (language used, display resolution, operating system used, etc.);
  • To remember information relating to a form completed by the Person Concerned on the Site (registration or access to your account);
  • to implement security measures, for example when the Data Subject is asked to log back into the Site after a certain period of time;

Through the use of cookies, Dolazar collects and processes, for the purposes specified above, all or part of the following Data:

  • Information related to the Data Subject's Terminal and/or the Data Subject:
  • Its type of terminal (smartphone, tablet, computer, etc.);
  • Its operating system (Mac OS, iOS, Android, Windows, BlackBerry etc.);
  • The categories and versions of its Terminal plug-ins,
  • His/her Internet service provider (Orange, SFR, Bouygues, Free, etc.);
  • The browser he uses (Safari, Chrome, Internet Explorer, etc.);
  • His advertising identifier linked to the operating system of his terminal;
  • The IP address of his terminal;
  • His language preferences.
  • Information about his browsing and behavior on the Site:
  • Statistics on the viewing of the different pages of the Site;
  • The complete URL path to, through and from the Site;
  • Information concerning the Person Concerned (age or age range, sex, declared and/or presumed socio-professional category, presumed interests, etc.) related to their activity on the Internet and communicated by third parties (advertisers, advertising agencies, etc.).

Opting out of cookies

The Data Subject is informed, on their first visit, that they have the option to object to the recording of cookies which are ancillary to the operation of the Site, in particular by configuring their Internet browser to do so or by exercising their choices on this page (see below).

When the Data Subject browses the Site, information may be recorded, or read, on their Terminal, subject to their choices.

To exercise their rights, such as those identified in the "Specific Rights" section, relating to their bank card details, the Data Subject is invited to contact the company that processed the payment directly. For PSP's contact details, please contact Dolazar at contact@dolazar.com.

The person concerned will find more help on the dedicated pages of their browser (the most common browsers are listed below):

The Data Subject can also configure their browser to send a code to websites indicating that they do not wish to be tracked (the "Do Not Track" option):