privacy policy

The legally binding document is written in french language, please visit: https://www.edskomo.com/pages/copy-of-privacy-policy

 

This privacy policy describes how the website publisher www.edskomo.com ("the Site") undertakes to protect the confidentiality and security of your personal data collected in the context of the activity of the Site.
It undertakes to process the said data in compliance with the applicable regulations such as the law of 20 June 2018 relating to data processing, files and freedoms and the General Regulation on the Protection of Personal Data.

1. Definitions

Personal Data: Any information relating to a natural person who may be identified, directly or indirectly.

Processing of Personal Data: Any operation or set of operations performed on personal data or sets of personal data (hereinafter "Personal Data"), regardless of the process used, whether automated or not, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or making available, alignment or combination, restriction, deletion or destruction

Cookie: A cookie is a small text file that a website stores on the user's computer or mobile device when the user visits the website. It allows the site to remember the user's actions and preferences (such as login, language, font size and other display preferences, or temporary storage of orders placed in the customer's shopping cart) over a period of time, so that the user does not have to re-enter them each time he or she returns to the site or navigates from page to page.

2. Person in charge of the processing

The person in charge of processing Personal Data is the editor of the website, Mr. Edgar Skomorowski, domiciled at 4 rue Popincourt, 75011 Paris, France, a sole proprietor registered under the number 812 914 943.

3. Personal data collected

Within the framework of the Site's activity, the Site's editor (hereinafter "the Editor") may be required to collect Personal Data transmitted :

- directly by the user: title, surname, first name, postal address, country of residence, date of birth, e-mail, user name/password, telephone number, bank details, etc. ;

- or indirectly: data related to the connection (type of connection used, IP address, cell phone operator, time zone...), to the navigation (browser version, statistics of the consulted pages, rate of activity or inactivity...), to the use of the services provided by the Site, to the interactions with the possible proposed advertisements, to the transactions and to the invoicing (history of the orders...), to the opening of the emails sent by the Editor by means of cookies, log files, web beacons, tags or pixels for example.

The Editor collects Personal Data when the User creates a customer account on the Site, when the User browses the Site, when the User connects to his customer account, when the User uses the Site, when the User completes the sections concerning his personal profile on the customer account, when the User sends documents to the Editor, when the User subscribes to the newsletter, via the contact forms on the Site, when the User publishes comments on the website or when the User contacts the customer support.

By providing the Publisher with this information and Personal Data, the User expressly agrees that this Personal Data may be collected, recorded, used and be subject to computer processing, under the conditions defined below. The processing is subject to the European Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (hereinafter the "RGPD") as well as to the law of 6 January 1978 known as the "Informatique et liberté" law as amended by the law of 20 June 2018.

The platform on which the Site is hosted, Shopify, uses limited automated decision-making, in particular to prevent fraud.

Services that include elements of automated decision-making include:

- A temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a number of hours not to exceed If there are 10 failed payment attempts in a row in the last 6 hours, the IP address will be blocked for approximately 6 hours.

- Temporary blacklist of credit cards associated with the blacklisted IP addresses. This blacklist persists for a number of days that cannot exceed. This usually lasts for about 24 hours.

4. Purposes of the collection of Personal Data

The collection of Personal Data is carried out for the needs of operation of the Site and access to the services of the Site (hereinafter the "Services") and in particular for :

- the administration of users' accounts,

- the provision of the Services and their improvement, in particular the optimization of the display of the Site,

- customer relations and personalization of the Services, in particular for product recommendations,

- the management of orders and billing and delivery operations,

- satisfaction surveys,

- the sending of promotional offers,

- the realization of statistics of analysis,

- commercial prospecting, i.e. to allow the sending of information, in particular commercial information from the Editor, such as newsletters, new offers, or news,

- the personalization of online advertisements,

- the fight against fraud,

- the security of the Site.

5. Recipients of the Data

This Data is subject to automated processing and is recorded in the information system and database of the Publisher. The information required in the forms marked with an asterisk is necessary to create a customer account and place an order on the Site.

The Personal Data are mainly intended to be used by the Publisher.

It may be transmitted to service providers (subcontractors) used by the Publisher to provide the Services for the purposes mentioned above, in particular the processing of orders, the shipment of products, the sending of postal or electronic mail, marketing services, the processing of credit card payments, customer service or the accessibility of the Site. These subcontractors have access to the personal information needed to perform their services and are not permitted to use it for any other purpose. In addition, they are required to process such information in accordance with this policy and in compliance with French personal data laws.

Personal Data may also be shared with the Shopify host and partners or third parties for the purpose of advertising targeting, electronic, telephone or postal marketing campaigns with the user's consent.

You can learn more about how Shopify uses your personal information by reviewing its privacy policy available at https://www.shopify.com/legal/privacy.

In the event of illegal activities or fraud, suspicions of illegal activities or fraud, for the purposes of investigations or judicial requisitions, Personal Data may be transmitted, upon request, to the judicial or control authorities: police, gendarmerie, magistrate, tax or social services, etc.


6. Rights

In accordance with the legislation and regulations in force, each user has the following rights:

1. Right of inquiry: the user has the right to know whether his or her Personal Data are being processed, and in particular what data are collected, where they come from, why and by whom they are processed.
2. Right of access: the user has the right to access the Personal Data collected from or about him/her. This includes the right to request and obtain a copy of their collected Personal Data.
3. Right of rectification: the user has the right to request rectification of inaccurate, incomplete, ambiguous or outdated Personal Data.
4. Right of deletion: the user may request that his Personal Data be deleted from our files, in the cases provided for by the legislation and regulations and subject to the legal obligations of conservation by the Publisher (accounting, taxation, etc.).
5. Right to limit processing: the user may request the limitation of the processing of his/her Personal Data in the cases provided for by the laws and regulations.
6. Right to portability: the user has the right to obtain his/her Personal Data in a machine-readable format or, if possible, in the form of direct transfer from one controller to another.
7. Right to withdraw consent: the user has the right to withdraw any consent given for the processing of his Personal Data.
8. Right to digital inheritance: the user has the right to define directives (general or specific) concerning the fate of his Personal Data after his death.
9. Right to object to processing: the user has the right to object, at any time, for reasons related to his/her particular situation, to the processing of his/her Personal Data that has as its legal basis the legitimate interest of the Publisher. In particular, the user has the right to object at any time to the use of his/her Personal Data for commercial prospecting purposes.

In order to exercise these rights, the user must send a request, accompanied by proof of identity, to the Publisher by e-mail to edgar@edskomo.com or by post to the address mentioned herein.

In the event of a dispute, the user may file a complaint with the Commission Nationale de l'Informatique et des Libertés (www.cnil.fr), the supervisory authority in charge of compliance with obligations regarding the protection of personal data.

7. Security

The Publisher takes all necessary measures to ensure the security of the Personal Data it collects. The Personal Data collected is hosted by specialized subcontractors (web hosts, emailing). The servers are subject to restricted access by means of a strong identifier and password, through an encrypted connection of the ssl / https type. The servers are hosted in data centers of the authorized provider, highly secured, and administered by the

said provider.

During the confirmation of an order, the Editor reveals only the last five digits of the user's credit card. The entire number is simply transmitted to the GIE carte bancaire (Groupement d'Intérêt Économique carte bancaire) during the processing of the order.

8. Duration of data retention

In order to comply with its legal obligations or to have the elements necessary to assert its rights, the Publisher will archive the Personal Data under the conditions provided for by the applicable regulations.

The legality of the processing carried out by the Publisher results from :

- either the contract concluded with the user for the purpose of providing the Services ;
- the express consent of the user, which may be withdrawn at any time; or
- the legitimate interest of the Publisher (commercial interest, justified, balanced and not infringing the privacy of the user);
- or by law.

The length of time Personal Data is retained varies depending on the purpose for which it was collected.

Most of the Personal Data are kept for a period of 3 years from the last activity of the user on the Site, then archived with restricted access, for an additional period of time, for specific reasons and authorized by law (payment, warranty, disputes ...).

They are then deleted.

Purposes of the processing	Legal basis	Retention period in operational base	Archiving
To provide, improve and customize the Services or perform statistical analysis (Personal Data related to account creation and use, navigation and use of the Services)	Contract / Legitimate interest	3 years from the last activity	5 years
Prospection commerciale électronique, téléphonique*** ou par voie postale par l’Éditeur	Legitimate interest*	3 years from the last activity
Electronic commercial prospecting by third parties	Consent**	3 years from the last activity
Advertising targeting for the benefit of the Publisher	Legitimate interest*	3 years
Targeted advertising for the benefit of third parties	Consent**	13 months from the deposit of the cookies	25 months from the deposit of the cookies
Retention of credit card data during a one-time payment	Law (L133-24 of the Monetary and Financial Code) / Contract	13 months from the date of debit
Storage of credit card data to facilitate future purchases	Consent**	For the duration of the consent
Fraud Prevention	Legitimate interest*	3 years from the incident	2 years

*user may object at any time
**which can be withdrawn at any time
***The user may object to telephone canvassing by contacting the Publisher and/or by registering on the Bloctel list on the website www.bloctel.gouv.fr

9. Transfer of data outside the EU

The Publisher may transfer some of the Personal Data outside the European Union. Transfers of Personal Data outside the European Union will only be made to countries whose level of security for Personal Data is recognized by the European Union or by standard contractual provisions.

In particular, certain Personal Data may be transmitted to the Shopify platform on which the Site is hosted, in Canada and the United States, for storage and fraud prevention purposes.

For more information on how data transfers comply with the GDPR, you can read Shopify's GDPR white paper: https://help.shopify.com/en/manual/your-account/privacy/GDPR .

10. Information in the Event of Personal Data Theft

If, despite all the protections implemented by the Publisher and its subcontractors, some of the Personal Data should suffer a security breach, the Publisher undertakes to inform the users within the applicable legal deadlines. This legal obligation to inform shall not be construed as an admission of liability or negligence on the part of the Publisher or its subcontractors.

11. Cookies

The Site and its partners use cookies to store and access Personal Data such as navigational data for the purposes of providing services, customizing content, advertising and analyzing Site traffic.

Different types of cookies may be used on the Site, in particular to facilitate the user's navigation on the Site (to identify himself, to access his account, to manage his order basket, to memorize his consultations) and to personalize the offers that the Editor proposes to him and the advertisements that the user visualizes on the Site or outside:

Analytical or statistical cookies

Cookies that make it possible to know the use and performance of the Site, to establish statistics, volumes of visits and use of the various elements of the Site (content visited, path) and to improve the interest and ergonomics of the services offered on the Site (the pages or headings most often consulted, etc.). These cookies are also used to count the number of visitors to a page, as well as the total number of advertisements displayed by the Site.

Marketing Cookies

Cookies that collect information about the user's browsing behavior: for example, what products/services the user is interested in on the Site and on other websites, what marketing campaigns/activities the user participates in, or the user's device identifier and geographic location (provided by the IP address). This information may be combined with other information relating to the user's order history, any prior correspondence and user profile information, and other information provided by the user to the Site's advertising partners or collected directly by such partners. The Site's partners may use cookies to collect information when the user visits the Site. The Site also uses cookies to track the user's navigation to other sites in order to present advertisements on those sites.


Functional cookies (always on)

Cookies that allow the Site to function better. The Site uses these cookies to temporarily record information about the user's session (visit to the Site), for example, by remembering what the user entered in a form. Some of these functional cookies are essential. This means that these cookies are necessary for the proper functioning of the Site. The user cannot refuse or deactivate cookies that are deemed necessary.

The user must express his consent to the deposit of certain cookies, the information of which is communicated to him in the cookies information banner visible at the first connection to the Site.

The consent thus given is valid for a maximum period of thirteen (13) months from the first deposit in the user's terminal equipment.

Each user has the possibility of refusing the installation of cookies on his/her device. However, in case of refusal, the navigation and the experience of the user may be limited. Advertisements will continue to be displayed on the pages visited, without being personalized.

Acceptance of cookies to facilitate connection and navigation of the Site can be modified at any time by clicking on "Cookies Settings".

The user is informed that the Publisher's partners and any other third party may place cookies on the Site. Only the sender of a cookie can read or modify the information contained in it and the Publisher has no access to or control over cookies that third parties may use. The issuance and use of cookies by third parties is subject to the privacy policies of those third parties as a supplement to these Terms of Use. Accordingly, the user is encouraged to visit the websites of such third parties for more information about the cookies they store and how to manage them.

We use the following cookies to optimize your experience on our site and to provide our services.

12. Modification of the Privacy Policy

The Publisher reserves the right to change this Privacy Policy at any time, including as a result of changes in applicable laws and regulations.

13. Recourse

If you wish to make a complaint about your personal data, please contact us by e-mail or by post using the contact details provided in the preamble to this Privacy Policy.

If you are not satisfied with our response to your complaint, you have the right to file your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: https://www.cnil.fr/.

Last update: February 24, 2023