S.i.n.i.n.e.n Sarl privacy policy

1. Objective

This policy applies to any processing of personal data carried out by S.i.n.i.n.e.n. and aims to inform the user about how S.i.n.i.n.e.n. processes personal data (including details on the type of personal data collected and the purpose of the processing) and about the rights of the user in relation to his personal data.

2. Contact – How can I get in touch?

In case of questions regarding the Privacy Policy, the User may contact S.i.n.i.n.e.n. by the following means:

• The registered office is located at: 8 rue Jacquard, F-54500 Vandoeuvre
• The contact telephone number is: +33 (0)7.69.22.11.50

The user may establish direct and effective communication with S.i.n.i.n.e.n. in writing by sending a communication to the address indicated or by sending an email to the address: eboutiques-sininen@live.fr In addition, the information of the person responsible for the processing of your personal data is set out below:

• Name: S.i.n.i.n.e.n.
• Identity of the person responsible: S.i.n.i.n.e.n.
• Address: 8 rue Jacquard, F-54500 Vandoeuvre
• Email: eboutiques-sininen@live.fr

3. Identification of processing – How do we collect personal data?

In accordance with the regulations in force on the protection of personal data, in particular:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, the "GDPR").

S.i.n.i.n.e.n. collects the personal data in its possession when the user:

• (i). Completes mode-confort.com forms ("Site");
• (ii). Subscribe to the newsletter;
• (iii). Completes a survey or fills out an online form;
• (iv). Completes a printed form;
• (v). Sends an email or telephone call, which are then loaded into the corresponding forms;

4. Personal data collected – What personal data do we collect?

S.i.n.i.n.e.n. collects information when visiting their web page, and mainly by completing its registration forms.

The following data is collected: full name, e-mail, telephone number and address.

As a general rule, when personal data is required to use a service or access certain content, its provision will not be mandatory, except in cases where it is specifically stated that it is data required for the provision of the service. In this case, the user may freely choose not to register and/or contract the services.

The user declares and guarantees that all the data provided by him/her is true and accurate and undertakes to update it. Changes may be communicated to the Data Protection Officer or to the address indicated in paragraph 2 above.

Likewise, the user acknowledges that the data required by S.i.n.i.n.e.n. are necessary, adequate and not excessive to achieve the purposes expressed in paragraph 5 above, which would be impossible to achieve if such data are not provided.

Any false or inaccurate statements that result from the information and data provided, as well as the damage that such information may cause, will be the responsibility of the user.

5. Purpose – What is the purpose of the personal data we collect?

The personal data requested from the user will be used for the following purposes:

• To provide our Service and respond to your requests. We use your information to provide and maintain our Service, to process and respond to your requests, to communicate with you about your use of our Service or changes to our Service, to respond to your requests, and for other customer service and business administration purposes. For example, when you sign up for a newsletter, we may use your personal information to send you an email newsletter.
• Identification and authentication purposes. We may use your information for identification and authentication purposes. For example, when you enter your account login ID and password to access one of our registration or login portals, we use your login information to authenticate your identity.
• Customization. We use your information to tailor the content and information we may send or display to you, to offer location customization, personalized help and instructions, and to otherwise personalize your experience when using the Service. For example, if you allow us to collect geolocation data, we use this information to serve content around your specific location and identify locations/business listings around your location.
• For marketing and promotional purposes. We may use your information to send you news and newsletters, event updates, and to communicate with you about new features, offers, events, or products, or to otherwise contact you about information that we think may be of interest to you. We may also use your information to display advertisements to you on our site (including to sell advertising space on the Service) and on other unaffiliated websites and services.
• Research and reporting. We may use your information to administer surveys and questionnaires (online and offline) for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the educational products, services, and information we provide. Survey responses may be used to determine the effectiveness of our service, various types of communications, advertising campaigns, and/or promotional activities.
• Combine information. We (and our third-party business partners on our behalf) may merge, mix, or otherwise combine information, including your personal information, in furtherance of the purposes described above.
• Comply with legal obligations. We may use your information to comply with our legal obligations or to exercise or defend our rights or the rights of a third party, including to comply with requests from law enforcement or government authorities and to participate in compliance audits.
• To protect ourselves and others. We may use your information when we believe it is necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to the safety of any person, or to otherwise enforce this policy, our terms and conditions, and the integrity of the Service.
• Anonymized data. We may also de-identify or anonymize your data in such a way that you cannot reasonably be re-identified by us or any other party, and we may use such anonymized data for any purpose permitted by applicable law. To the extent that we anonymize data that was initially based on personal information, we will retain and use that data in an anonymized form and will not attempt to re-identify the data.

The data subject to processing will not be used for purposes other than those mentioned above and for which they were collected. Notwithstanding the above, it is specified that the data recorded may be used, in addition to the purposes for which they were expressly collected, for statistical, incident management or market research purposes. However, in the event of processing of personal data for purposes other than those initially specified when such data was collected, a compatibility analysis will be carried out by S.i.n.i.n.e.n. in accordance with the applicable regulations. Processing will only be permitted if the original purpose is compatible with the new purpose or permitted in accordance with an independent legal basis. In these cases, the user will be informed of changes in purpose or of the legal justification for the processing of their data. We remind the user that they may object to the sending of commercial communications (unsubscribe) and no longer receive emails from S.i.n.i.n.e.n., informing S.i.n.i.n.e.n. in a reliable manner, which will proceed with the interruption as soon as possible after receiving such communication. To this end, they may send an email to the address set out in Section 2, a postal letter to the address set out in Section 2 above, or directly follow the unsubscribe instructions detailed at the end of each email from S.i.n.i.n.e.n.

6. How do we use your information?

We will use the information we collect about you for the following purposes:

• Administrative Information
• Creating User Accounts
• Testimonials
• Collecting customer feedback
• Application of the T&Cs
• Sales order management
• Support
• Targeted advertising
• Dispute Resolution
• User account management
• Payment processing: Crédit Agricole

If we want to use your information for any other purpose, we will ask for your consent and will only use your information once you have given your consent and only for the purpose (or purposes) for which you have given your consent, unless we are required to do otherwise by law.

We will retain your personal information with us for an indefinite period of time after user accounts are no longer active or for as long as necessary to fulfill the purposes for which it was collected, as set out in this Privacy Policy.

7. Consent

By providing personal data to S.i.n.i.n.e.n., the user declares that he or she fully and unreservedly accepts their processing by S.i.n.i.n.e.n. The user hereby grants his free, express and informed consent to S.i.n.i.n.e.n. to use the data collected for the purposes indicated in section 5 above, as well as their incorporation into a database of S.i.n.i.n.e.n.

S.i.n.i.n.e.n. carries out the processing of the data of the legitimate user by: (i) the conclusion of a service contract with S.i.n.i.n.e.n. by the user, in accordance with the terms and conditions that are made available to the user at the end of the completion of the service request form (before a possible hiring) and that the user (after having read it), and if he agrees, can accept by ticking the box that has been included for this purpose; and (ii) the free, informed and unequivocal consent of the user, given after reviewing this Privacy Policy where S.i.n.i.n.e.n. informs the processing it will carry out with your data, and if you agree, by ticking the box that has been included for this purpose in the service request form. The processing of data that is not covered by any of the legal bases indicated above, will be carried out if S.i.n.i.n.e.n. deems it necessary to protect a legitimate interest and only if they do not infringe on the fundamental rights and freedoms of the user.

8. Expiration – How long do we keep them?

The data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes detailed in section 5 above. In particular, personal data will be kept for as long as the business relationship is in force (and to the extent that the user has not previously requested their deletion) and for the period during which obligations, compensation and/or liabilities may arise in the context of the business relationship or for the services provided. S.i.n.i.n.e.n. informs that it will keep the essential information to identify the origin of the data stored for the duration of the customer relationship with S.i.n.i.n.e.n. and/or the revocation of the user's consent in accordance with the information contained in section 5 of this Privacy Policy and/or the period required by applicable law.

9. Privacy / Assignment / International Transfer – Do we disclose data to third parties?

S.i.n.i.n.e.n. will keep the personal data collected private and confidential and will not use it for any purpose other than those established in section 5 above. S.i.n.i.n.e.n. requires the signing of confidentiality and personal data processing agreements by its employees and third parties who provide services that access the content of the databases (or include such obligations in the service agreements it signs with such providers as indicated in the following paragraph).

The user's personal data collected by S.i.n.i.n.e.n. will not be transferred, sold, exchanged, transmitted and/or communicated to third parties outside S.i.n.i.n.e.n. without the user's consent, unless there is a legal obligation and/or for the purpose of providing the services to the user. This does not include certain employees and service providers who allow S.i.n.i.n.e.n. to keep the website in operation, to comply with the purposes established in section 5 above and/or to provide services to the user, who have assumed the obligation to maintain the confidentiality of the data provided and undertake to comply with the applicable regulations on the protection of personal data, at the time of hiring. Contracts with service providers stipulate the purpose, scope, content, duration, nature and purpose of data processing, the type of personal data, the categories of data owners and the obligations and responsibilities of S.i.n.i.n.e.n. and the contractual third parties.

In particular: S.i.n.i.n.e.n. may share the personal information provided with S.i.n.i.n.e.n.'s controlling companies, subsidiaries, affiliates, related companies and/or intermediaries related to S.i.n.i.n.e.n.

S.i.n.i.n.e.n. may share certain personal information provided by the user internally within S.i.n.i.n.e.n., with certain departments, such as administration, marketing or IT.

• In some cases, S.i.n.i.n.e.n. transfers personal data on the basis of legitimate interest and the economic and technical benefits associated with the use of specialized providers. In this regard:
  • YouTube. The Site contains links to YouTube in connection with videos related to S.i.n.i.n.e.n.n.'s services. As stated in Section 13 above, by using these links, the user leaves the Site and is redirected to the YouTube page. The user can view YouTube's privacy policy and other legal aspects via the following link: https://policies.google.com/privacy
  • Facebook. S.i.n.i.n.e.n. has integrated Facebook components into the Site. In particular, S.i.n.i.n.e.n. uses the Facebook advertising platform. The company that operates the Facebook services is Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The user can consult the privacy policy and other legal aspects of the said company through the following link: https://en-en.facebook.com/about/privacy/.
  • Instagram. The Site contains links to Instagram. As stated in Section 13 above, by using these links, the user leaves the Site and is redirected to Instagram. The user can view Instagram's privacy policy and other legal aspects through the following link: https://help.instagram.com/155833707900388.

Social networks. S.i.n.i.n.e.n. also uses social networks, such as Facebook or Instagram, and has integrated functions of these networks into its services. The user may only use these social networks if he or she is registered and has accessed the corresponding social network with his or her user. These social networks have their own privacy policies and terms and conditions, over which S.i.n.i.n.e.n. has no interference or control.

Finally, you should be aware that S.i.n.i.n.e.n. may (and S.i.n.i.n.e.n. reserves the right to) disclose your information in the following circumstances:

• Business Transfer: If we or our subsidiaries are acquired, merged, or invested by another company, or if any of our assets are transferred or may be transferred to another company, whether in connection with bankruptcy or insolvency proceedings or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain information about you to outside lenders, auditors and advisors, including lawyers and consultants.
• Compliance with law: We may disclose your personal information to comply with the law, a judicial proceeding, a court order, or other legal process, such as in response to a court order or subpoena.
• Protection and Facilitation of Rights: We may disclose your personal information when we believe it is appropriate to investigate, prevent, or take action against illegal activities, suspected fraud, situations that may pose potential threats to the safety of any person, or human rights violations. our terms and conditions or this policy. This disclosure may also include using your personal information as evidence in litigation in which we are involved. In addition, we may disclose your personal information when necessary to assist you in exercising your rights under S.i.n.i.n.e.n.'s Terms and Conditions and this Privacy Policy.
• Public safety, national defence or public health reasons: In situations where there are well-founded reasons related to community safety, national defence or public health, your personal information may be disclosed.
• Aggregated, Anonymized, or Anonymized Information: We may disclose aggregated, anonymized, or de-identified information about you for any purpose permitted by applicable law.
• Consent: We may disclose your personal information with your consent.

10. Security – How do we keep data safe?

S.i.n.i.n.e.n. declares its intention to adopt the necessary technical and organisational measures to guarantee the security, integrity and confidentiality of the data in accordance with the provisions of the GDPR in order to prevent their alteration, loss, consultation or unauthorised processing.

S.i.n.i.n.e.n. does not guarantee absolute privacy in the use of the website, as it cannot be excluded that unauthorised third parties may become aware of it. The user acknowledges that the existing technical security means are not impenetrable and that even with the adoption of all reasonable security precautions, it is possible to suffer manipulation, destruction and/or loss of information. In the event of the detection of a security incident involving a significant risk to the data owner, this event will be communicated without delay to the competent supervisory authority, as well as to the corrective and palliative measures implemented and/or to be implemented.

S.i.n.i.n.e.n. is not responsible for the loss or deletion of data by users. Likewise, S.i.n.i.n.e.n. does not accept any responsibility for any damage caused by computer viruses.

Finally, the user must also take steps to protect their information. S.i.n.i.n.e.n. insists that you take every precaution to protect your personal information while on the Internet. At the very least, you are advised to change your password periodically, using a combination of letters and numbers, and to make sure that you are using a secure browser.

11. Rights of the data owner and procedures to respond to their exercise – What rights do I have as a data owner?

The user who owns the data may at any time exercise the rights of access, rectification, cancellation, opposition, limitation of processing, portability, confidentiality and deletion of their personal data, in accordance with the provisions of articles 15 et seq. of the GDPR, as the case may be. The exercise of these rights may be carried out by the user himself by email to eboutiques-sininen@live.fr, or by any of the means provided for by the applicable regulations mentioned above. S.i.n.i.n.e.n. may request the data necessary to validate the identification of the owner of the data.

The deletion of certain data will not be carried out when it could cause damage to the rights or legitimate interests of third parties, or when there is a legal obligation to keep the data.

If you are a resident of the UK or EEA and are subject to national or local legal exemptions, you have certain data protection rights in certain circumstances. Please contact us if you wish to exercise any of these rights.

• Withdraw consent at any time. Users have the right to withdraw their consent if they have previously given their consent to the processing of their personal data.
• Object to the processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their data. Users have the right to know whether the data is being processed by the Owner, to obtain information about certain aspects of the processing and to obtain a copy of the data being processed.
• Check and request rectification. Users have the right to verify the accuracy of their data and to request that it be updated or corrected.
• Restrict the processing of their data. Users have the right to restrict the processing of their data. In this case, the Owner will not process its Data for any purpose other than its storage.
• Have their personal data deleted or otherwise deleted. Users have the right to obtain the erasure of their data from the Owner.
• Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine-readable format and, if technically feasible, to have them transmitted to another controller without any hindrance.
• File a complaint. Users have the right to lodge a complaint with their competent data protection authority.

12. Training – Do we train?

S.i.n.i.n.e.n. staff whose functions are related to the processing of personal data are trained to ensure better protection of personal data and the rights of its holders.

13. Links to third parties – Does our Site contain links to other sites?

The Site may contain links to third-party sites, with or without advertising content, whose privacy policies are beyond S.i.n.i.n.e.n.'s control. The linked sites are not linked to S.i.n.i.n.e.n. and their existence does not in any way presuppose that there is any suggestion, invitation or recommendation for the visit of the destination places or any link or association between S.i.n.i.n.e.n. and these sites. S.i.n.i.n.e.n. is not responsible or liable for the content, use and activities of these linked sites, nor for any damages, whether actual or potential, material or moral, direct or indirect, suffered by users and derived from the information contained in these sites or from the relationship that users may establish with third parties whose services have been published on the site. Nevertheless, any comments on these linked sites will be useful for S.i.n.i.n.e.n. to improve the services and/or guarantee the integrity of the site. S.i.n.i.n.e.n. undertakes to do everything possible to prevent the existence of links on its site to sites with illegal content.

14. Children's Privacy

At S.i.n.i.n.e.n., we recognize the importance of protecting children's privacy. Our commitment to protecting the personal information of minors is unwavering. We may collect and process personal information from children under the age of 13, but only in compliance with all applicable laws and regulations, including obtaining parental or guardian consent, if required.

If you are a parent or guardian and believe that we have collected personal information about your child without appropriate consent, please contact us immediately and we will take prompt action to remedy the situation.

For California residents: We do not sell the personal information of California consumers 16 years of age or younger unless we have obtained prior parental permission. If your child is under the age of 13, we insist on obtaining consent from their parent or guardian for the collection and processing of their personal information. If your child is between the ages of 13 and 16, they may choose to allow the sale of their personal information. Our websites and services designed for children will incorporate age verification and ensure that necessary consents are obtained.

For EU residents: We do not collect or process personal information from anyone under the age of 16 in the EU without the explicit consent of a parent or guardian. Our websites and services directed to children will include age verification and will require appropriate consents.

15. Cookies – Do we use cookies?

When the user enters the website, S.i.n.i.n.e.n. may store information on his or her computer in the form of a "cookie" or similar file. The Site uses cookies to (i) track advertising, (ii) collect data about site traffic, and (iii) improve the user experience when using the Site.

The user should be aware that in order to browse the website, it is not necessary for the user to authorise the installation of cookies sent by the website. This may only be required for certain services. The user can delete cookies from their hard drive, prevent access to their computer either through their browser or by choosing the corresponding option when asked if they wish to use cookies for these purposes and in accordance with S.i.n.i.n.e.n.'s cookie policy.

Cookies are information files that the website or the provider of certain website services transfers to the hard drive of the user's computer via the browser program. Cookies by themselves cannot personally identify the user (although they may contain the user's IP address) but they do allow the user to recognize the user's browser and capture and store certain data (the user's operating system, the domain name of the website from which the site was linked, among others). S.i.n.i.n.e.n. reserves the right to contract the services of third parties to analyze and understand the users of the site, who may not use the information collected for any purpose other than to improve the services of S.i.n.i.n.e.n.

16. Consent

The use of the Site by the User implies full knowledge and approval of S.i.n.i.n.e.n.n.'s Privacy Policy and S.i.n.i.n.e.n.'s Terms and Conditions, if any. Likewise, the user accepts S.i.n.i.n.e.n.'s Privacy Policy and S.i.n.i.n.e.n.'s General Terms and Conditions by completing the request for services.

17. Changes – Is this the latest version?

This is the current version of S.i.n.i.n.e.n.'s Privacy Policy, updated on March 11, 2023.

S.i.n.i.n.e.n. may change this Privacy Policy at any time without notice. These changes will be operational from the time they are published on the website or when they are communicated to users by any means, whichever occurs first. The user must keep informed of the terms included herein by entering periodically.