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    Privacy Policy

    Preamble

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

    These Privacy Policies are intended to inform Data Subjects about how their Personal Data is collected from the Site, how it is processed by Dolazar, and the Specific Rights (as defined below) which Data Subjects have with regard to such processing 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: refers to the transfer of Personal Data that still holds administrative interest for Dolazar (for example in the event of litigation and/or a legal obligation) to a separate database, logically or physically separated and in any event with restricted access. This archive is an intermediate step before the deletion or anonymisation of the relevant Personal Data;
    • Privacy Policies: refers to this privacy and personal data protection policy for Data Subjects implemented by Dolazar, which forms an integral part of the General Terms;
    • General Terms refers indistinctly to the: General Terms of Use, General Terms of Service and General Terms of Sale;
    • Personal Data: refers to the personal data of the Data Subject, within the meaning of Personal Data Regulations, collected and processed by Dolazar in the context of the use of the Site;
    • Specific Rights: refers to the rights granted by Personal Data Regulations to Data Subjects regarding the processing of their Personal Data, as detailed in Article IX;
    • Data Subject: refers to the natural person (User, Customer, Subscriber) whose Personal Data is processed by Dolazar;
    • Personal Data Regulations: refers to Law No. 78-17 of 6 January 1978 relating to data processing, files and freedoms, in application of the General Data Protection Regulation;
    • Dolazar: refers to the company Ecomeo OÜ, whose registered office is at Lõõtsa tn 2a, 11415 Tallinn, Estonia, registered under number 16563515.
    • Terminal(s): refers to the hardware equipment (computer, tablet, smartphone, telephone, etc.) used by the Data Subject to access or view the Site and/or any other digital medium published by a third party.

    Legal bases for processing

    In accordance with Personal Data Regulations, the processing described in these Privacy Policies is 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 required the express consent of the Data Subject to carry out specific processing explained when this consent was collected.

    The processing is necessary for the performance of a contract to which the Data Subject is a party or for the implementation of pre-contractual measures taken at their request.

    In order to use the Site and benefit from its services, the Data Subject has at minimum accepted the General Terms of Use and, where applicable, the General Terms of Sale and/or General Terms of Service. These documents formalise 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 Dolazar is subject.

    The processing of Personal Data may also be necessary for compliance with a legal obligation to which Dolazar is subject, for example, the retention of Site access logs, in accordance with Decree No. 2011-219 of 25 February 2011 relating to the retention and communication of data enabling 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 prevail, in particular when the Data Subject is a child.

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

    In such a case, Dolazar ensures that the processing in question is necessary for the pursuit of its legitimate interest and assesses the consequences of this processing for 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 interests or fundamental rights and freedoms by enabling the Data Subject, at any time, to object to all or part of the processing described in these Privacy Policies, as well as to exercise their Specific Rights, under the conditions set out in the paragraph "Specific Rights".

    Purposes of processing

    The Data Subject's Personal Data is necessary to allow them to access the Site, use it and improve it, and to enable Dolazar to:

    • Carry out operations relating to its commercial relationship with the Data Subject, i.e. regarding invoices, accounting, monitoring the "customer relationship" with a Customer or Subscriber, such as conducting satisfaction surveys, handling complaints, Site use and more generally services, etc.;
    • Select Customers or Subscribers to carry out studies, surveys and product tests, as well as loyalty, prospecting and promotional activities;
    • Personalise its communications for Customers or a Subscriber, in particular through information emails, based on observed preferences and Site usage;
    • Carry out operations relating to prospecting, i.e. the management of technical prospecting operations (which notably includes technical operations such as standardisation, enrichment and deduplication);
    • The carrying out of commercial solicitation operations;
    • The development of commercial statistics; analyses and marketing tools (including classification, scoring, etc.);
    • The organisation of competitions, prize draws or any promotional operation, excluding online games of chance and games of skill subject to approval by the Online Gaming Regulatory Authority;
    • The management of requests to exercise Specific Rights under the conditions set out in the paragraph "Specific Rights";
    • The management of unpaid debts and disputes;
    • The management of Data Subjects' comments on the Site and/or on web pages published by Dolazar such as social media 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 of Use, accessible from the website footer.

    All necessary precautions have been taken to store Data Subjects' Personal Data in a secure environment and to prevent it from being distorted, damaged, or accessed by unauthorised third parties. The information transmitted by the Data Subject will never be passed to third parties for commercial purposes or sold or exchanged, except with their prior express consent.

    Collection of Personal Data on the Site

    Dolazar collects, where applicable when an Account is created and then completed progressively, the following Personal Data that the Customer and Subscriber enter and communicate during their browsing, which is retained for a period of three (3) years in active storage from the last connection of the Data Subject to the Site:

    • Gender,
    • Date of birth,
    • Email address,
    • Username used on the Site,
    • Payment identifier,
    • Delivery address,
    • Billing address,
    • Telephone number,

    The connection data (date, time, IP address, pages viewed) of the Data Subject when browsing the Site and, in particular, those related to the Subscriber's use of the Specific Services.

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

    Where applicable, the reason(s) for exclusion (all elements enabling demonstration of the conduct, less than one month old, justifying exclusion).

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

    • Invoices,
    • Transaction amounts as well as the date and time of such transactions,

    The Personal Data above is also retained 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 as mandatory on the Site is essential in order to benefit from an Account.

    Recipients or categories of recipient if applicable

    Dolazar may communicate to third parties certain Personal Data that is necessary for the fulfilment of Orders under the General Terms of Sale or the Subscription under the General Terms of Service, in order to ensure in particular:

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

    Security of transactions on the Internet

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

    Thus, when making a payment on the Site, the Data Subject's bank details are transmitted in encrypted form to the company handling the payment, without Dolazar being able to access them.

    Dolazar does not collect the full bank card number of the Customer or Subscriber, nor their security code.

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

    Specific Rights

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

    • access,
    • rectification,
    • erasure,
    • restriction of processing,
    • portability,
    • objection,
    • post-mortem directives.

    Right of access

    The Data Subject has the ability to obtain from Dolazar confirmation of whether or not Personal Data relating to them is being processed, and where it is, access to such 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 disclosed;
    • where possible, the envisaged retention period for the Personal Data, or where this is not possible, the criteria used to determine that period;
    • the existence of the right to request from Dolazar rectification or erasure of Personal Data, or restriction of processing of the Data Subject's Personal Data, or to object to such processing;
    • the right to lodge a complaint with the CNIL;
    • where 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 those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the Data Subject.

    Where 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 relating to such transfer.

    Dolazar provides a copy of the Personal Data undergoing processing.

    Dolazar may require the payment of a reasonable fee based on administrative costs for any additional copy requested by the Data Subject.

    Where the Data Subject submits their request electronically, the information is provided in a commonly used electronic form, unless the Data Subject requests otherwise.

    The Data Subject's right to obtain a copy of their Personal Data must not adversely affect the rights and freedoms of others.

    Right of rectification

    The Data Subject has the ability to obtain from Dolazar, without undue delay, the rectification of inaccurate Personal Data relating to them. They also have the ability to obtain the completion of incomplete Personal Data, including by providing a supplementary statement.

    Right of erasure

    The Data Subject has the ability to obtain from Dolazar the erasure, without undue delay, of Personal Data relating to them where one of the following grounds applies:

    • the Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed by Dolazar;
    • the Data Subject has withdrawn consent on which the processing is based and there is no other legal ground for the processing;
    • the Data Subject exercises their right to object under the conditions referred to below and there is no overriding legitimate ground for the processing;
    • the Personal Data has been unlawfully processed;
    • the Personal Data must be erased for compliance with a legal obligation;
    • the Personal Data has been collected in relation to a child.

    Right to restriction

    The Data Subject has the ability to obtain from Dolazar restriction of processing of their Personal Data where one of the following applies:

    • Dolazar is verifying the accuracy of Personal Data following the Data Subject's contestation of the accuracy of the Personal Data;
    • The processing is unlawful and the Data Subject opposes the erasure of the Personal Data and requests the restriction of its use instead;
    • Dolazar no longer needs the Personal Data for the purposes of the processing but they are still needed by the Data Subject for the establishment, exercise or defence of legal claims;
    • The Data Subject has objected to processing under the conditions referred to below and Dolazar is verifying whether the legitimate grounds pursued override those put forward by the Data Subject.

    Right to data portability

    The Data Subject has the ability to receive from Dolazar the Personal Data relating to them, in a structured, commonly used and machine-readable format where:

    • The processing of Personal Data is based on consent, or on a contract. And,
    • The processing is carried out by automated means.

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

    The Data Subject's right to personal data portability must not adversely affect 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 processing of Personal Data relating to them which is based on the legitimate interest of Dolazar. The latter will then no longer process the Personal Data unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject, or can retain them for the establishment, exercise or defence of legal claims.

    Similarly, we remind you that, where the Data Subject has provided a telephone number, they have the right to register on a telephone marketing opt-out list.

    Post-mortem directives

    The Data Subject has the ability to communicate to Dolazar directives relating to the retention, erasure and communication of their Personal Data after their death, which directives may also be recorded with a "certified digital trusted third party". These directives, or a form of "digital will", may designate a person responsible for their execution; failing this, the Data Subject's heirs will be designated.

    In the absence of any directives, the Data Subject's heirs may contact Dolazar in order to:

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

    In any event, the Data Subject has the ability to indicate to Dolazar, at any time, that they do not wish, in the event of their death, for their Personal Data to be communicated to a third party.

    Exercise of Users' Specific Rights

    These rights may be exercised at any time with Dolazar:

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

    For the purpose of exercising their rights under the conditions referred to above, and in the event that Dolazar has doubts about the identity of the requester, Dolazar may ask them to prove their identity by providing their surname, first name, email address and accompanying their request with a copy of a valid proof of identity.

    A response will be sent to the Data Subject within a maximum of one (1) month from the date of receipt of the request.

    If necessary, this period may be extended by a further two (2) months by Dolazar, who will alert the Data Subject accordingly, taking into account the complexity and/or number of requests.

    In the event of a Data Subject's request for deletion of their Personal Data and/or in the event of their exercising their right to request the erasure of their Personal Data, Dolazar may however retain them in the form of Intermediate Archiving for the period necessary to fulfil 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).

    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 how it is designed.

    Accordingly, the Data Subject is reminded that their password, to be valid, must consist of at least 8 characters, including at least 3 of the following 4 types: uppercase letters, lowercase letters, numbers, special characters.

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

    • Using only the first letters of the words in a sentence; for example, the phrase "One Password is worth keeping!" corresponds to the password 1Piwk!
    • Capitalising if the word is a noun (e.g.: Word)
    • Keeping punctuation marks (e.g.: !)
    • Expressing numbers using the digits 0 to 9 (e.g.: One →1)

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

    Cookies are used on the Site.

    A cookie is information placed on the Terminal that the Data Subject uses to access the Site.

    Cookies relate to the Data Subject's browsing on the Site and allow the pages they have visited, their date and time of consultation to be determined.

    At no time do these cookies allow Dolazar to personally identify the Data Subject.

    The retention period of these cookies on 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 enables:

    • Establishment of statistics and volumes of traffic and use of the Site enabling improvement of the interest and ergonomics of the services;
    • Adaptation of the Site's presentation to the display preferences of the Data Subject's Terminal (language used, display resolution, operating system used, etc.);
    • Storage of information relating to a form completed by the Data Subject on the Site (registration or access to your account);
    • Implementation of security measures, for example when the Data Subject is asked to log back into the Site after a certain period of time;

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

    • Information relating to the Data Subject's Terminal and/or the Data Subject:
    • Their type of Terminal (Smartphone, tablet, computer, etc.);
    • Their Terminal's operating system (Mac OS, iOS, Android, Windows, BlackBerry etc.);
    • The categories and versions of plug-ins of their Terminal;
    • Their Internet service provider (Orange, SFR, Bouygues, Free, etc.);
    • The browser they use (Safari, Chrome, Internet Explorer, etc.);
    • Their advertising identifier linked to their Terminal's operating system;
    • The IP address of their Terminal;
    • Their language preferences.
    • Information about their navigation and behaviour on the Site:
    • Statistics on the viewing of the various pages of the Site;
    • The complete URL path to, through and from the Site;
    • Information about the Data Subject (age or age group, gender, declared and/or presumed socio-professional category, presumed areas of interest, etc.) linked to their Internet activity and communicated by third parties (advertisers, advertising networks, etc.).

    Objection to cookies

    The Data Subject is informed, upon their first visit, that they have the ability to object to the registration of cookies which are incidental 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).

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

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

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

    • Internet Explorer: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
    • Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
    • Safari: https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=fr_FR
    • Firefox: http://support.mozilla.org/fr/kb/Activer%20et%20désactiver%20les%20cookies
    • Opera: http://help.opera.com/Windows/10.20/fr/cookies.html

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

    • Internet Explorer™: http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11
    • Safari™: http://support.apple.com/kb/PH11952
    • Chrome™: https://support.google.com/chrome/answer/114836
    • Firefox™: https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister
    • Opera™: http://help.opera.com/Windows/12.10/fr/notrack.html
     
     

    Dolazar

    📍 Lõõtsa tn 2a, 11415 Tallinn, Estonia

    📞
    +33 2 59 57 00 58

    📧
    contact@dolazar.com

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