Privacy policy

Preamble

Entry into force: 30 March 2023

INFINIWAVE LIMITED

77, LOWER CAMDEN STREET,

DUBLIN D02 XE80

Ireland

Registration number 737750 and VAT number 4162209VH

Access to the Site and its functionalities requires the collection and processing of Users' personal data. It was therefore necessary to establish a Personal Data Protection Policy in order to comply with the recommendations for the use and processing of personal data, as established by the applicable laws and regulations.

The Site's Data Protection Policy has been drawn up in accordance with the recommendations of the Data Protection Commission (DPC). Its purpose is to inform Users of the Site about how their personal data is processed and about the commitments and measures we have taken to ensure that the personal data of Users of the Site is respected.
It has been drawn up in accordance with the provisions of :

The Data Protection Act 2018;

The European Data Protection Regulation 2018;

The European Data Protection Regulation Transposition Act 2018.

The version currently published on the Site is the current version of this policy. The Seller reserves the right to modify it at any time in order to comply with current legal obligations. All changes to the Privacy Policy will be communicated to Users in order to obtain their consent to the new policy.

By visiting our Site, Users acknowledge that they have read, understood and accepted this data protection policy. Any questions relating to this policy may be sent to the following address: contact@perso1.com.

Article 1 - Definitions

1.1 Technical terms relating to the protection of personal data

On our Site, the terms below have the meaning attributed to them by the General Data Protection Regulation (Article 4):

Consent: from the data subject, any manifestation of free, specific, informed and unequivocal will by which the data subject accepts, by a declaration or by a clear positive act, that personal data concerning him or her may be "processed";

Controller: "the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing operation; where the purposes and means of such processing are determined by Union law or by the law of a Member State, the controller may be designated or specific criteria applicable to his designation may be laid down by Union law or by the law of a Member State";

Processor: "the natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller";

Processing: "any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction";

Personal data breach: "a breach of security resulting in the destruction, loss, unauthorised alteration, disclosure of or unauthorised access to personal data transmitted, stored or otherwise processed".

1.2 Other terms used in this document

"Customer" means, in accordance with the provisions of the introductory section of the Consumer Rights Act 2022, a person acting for purposes which are primarily or exclusively outside his trade, business, craft or profession ;

"Site": refers to the https://perso1.com/ site operated by the Seller and made available to the User;

"User": refers to any natural person using our Site and having access to its content.

ARTICLE 2 - What is personal data?

Personal data refers to any information that directly or indirectly identifies a natural person (surname, first name, e-mail address, telephone number, postal address, etc.).

Thus, the RGPD defines personal data as follows: "any information relating to an identified or identifiable natural person (hereinafter referred to as the "data subject"); an "identifiable natural person" is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity".

ARTICLE 3 - Data concerning minors

In accordance with the provisions of Article 8 of European Regulation 2016/679 and the Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data.

Users under the age of fifteen (15) are asked to obtain the consent of a legal representative - required by the Seller - before their personal data can be collected and before they can use the Site's services.

The Seller may not be held liable in the event of a user providing personal data concerning a minor under the age of fifteen (15).

ARTICLE 4 - Collection of personal data

We collect your consent.

When browsing the Site, Users must, on several occasions, provide some of their personal data (for the purposes indicated in article 5). By providing their data, Users consent to the collection and processing of the personal data provided by the Seller for the sole purpose of

purposes detailed in article 5 of the Policy. This consent, together with other reasons, serves as the legal basis for processing the data collected.

The Seller only collects and processes data that is strictly necessary for the purposes for which it is processed. We undertake to our Users not to process data for purposes other than those mentioned below. If we were to offer a new service on the Site, or any other feature of the Site, requiring the collection and processing of data, we undertake to obtain Users' consent once again before offering the new service in question.

Whenever the Site processes personal data, the Seller takes all reasonable steps to ensure the accuracy and relevance of the personal data in relation to the purposes for which it is processed.

ARTICLE 5 - Purpose of processing

We collect data from Users solely for the following purposes:

5.1 Creating an account (optional)

Customers may create an account on the Site. To do so, they must provide the following details: surname, first name, e-mail address.
Customer data is used for the following purposes:

- Confirm the creation of your account;
- Create your customer account ;
- Communicating with customers;
- After-sales support.

The legal basis is the performance of a contract, by virtue of the placing of an order, the latter accepting these provisions.

5.2 Placing an order

To place an order on the Site, customers must provide the following information: surname, first name, e-mail address and billing address.

User data and communication data are only used for the following purposes:

- Confirm the customer's order;
- Processing customer orders;
- Provide the services covered by the order;
- Provide after-sales service.

The Customer is also informed that, by placing an order, they will receive transactional communications from the Vendor (invoices, password changes, personality test results). They may unsubscribe at any time by using the functions provided for this purpose in the communication emails sent by the Vendor.

The legal basis is the performance of a contract, by virtue of the placing of an order, the latter accepting these provisions.

5.3 Payment for services

Payment for orders via the Site is made via our payment service provider STRIPE, the latter acting as the party responsible for processing the customer's payment data. The Seller does not have access to customer payment data.

5.4 Subscription

By placing an order on the Site, the customer automatically benefits from a subscription to the Seller's subscription service (see GTC). If the customer has not cancelled their subscription after 24 hours, it is automatically extended for a period of one month, renewable by tacit agreement.

The data used to conclude the subscription is the data provided by the customer when placing the order and is used for the following purposes:

- Provide subscription services ;
- Manage subscriptions (billing, termination, renewal) ;
- Provide after-sales service.

5.5 Contact form

A contact form is available on the Site. To respond to their request, Users must provide their surname, first name, e-mail address and telephone number.
User data and communication data are only used for the following purposes:

- Process the User's request;
- Respond to the User's request.
The legal basis is the User's consent.

5.6 Analysis

When browsing the Site, Users may be asked to enter their personal connection data (cookies, tracers).

Connection data and browsing information are only used for statistical studies (analysis of site traffic and user experience) and other purposes mentioned in the cookie policy.

The processing is necessary for the purposes of the legitimate interests pursued by the Seller, in particular to offer Users a smooth and improved browsing experience.

Connection data is also used to prevent and combat computer fraud.

The legal basis is the response to a legal obligation.

ARTICLE 6 - Data retention period

We do not exceed the legal data retention periods and User data is only retained for as long as is necessary for the purposes for which it was collected.

The retention periods are as follows:

- Data relating to the identity of the User who is not a customer (surname, first name): this is deleted or made anonymous three (3) years after the last contact with the User, unless the User has previously exercised a right (in application of the RGPD) leading to the deletion of his/her data;

- Non-customer communication data (e-mail address, telephone number, postal address): this is deleted or made anonymous three (3) years after the User's last contact, unless the User has previously exercised a right (in application of the RGPD) that led to the deletion of his/her data;

- Data relating to customers who have placed an order: this data is deleted five (5) years after the end of the commercial relationship with the customer, unless the latter has previously exercised a right (pursuant to the RGPD) leading to the deletion of his data;

- Connection data: in accordance with the cookies policy, this is kept for a maximum of 13 months (unless otherwise indicated in article 13).

In drawing up our data processing policy, we have established a reference grid for data retention periods, based on the recommendations of the Data Protection Commission.

In addition, the Seller may retain certain personal data in order to comply with its legal or regulatory obligations, to enable users to exercise their rights or for the following purposes

statistics. At the end of the retention period, personal data will be deleted or made anonymous.

ARTICLE 7 - Access to data

The data collected via the Site is intended exclusively for the following recipients.

7.1 Site hosting

The Site is hosted by Scaleway, 8 rue de la Ville l'Evêque, 75008 Paris.

The host has access to the data within the limits of its respective remits, for the purposes of hosting the Site. It has limited access to the User's data, as part of the performance of these services, and is contractually obliged to use it in accordance with the provisions of the regulations applicable to the protection of personal data.

For more information, see Scaleway's policy.

7.2 Third-party service providers

The Site and the Seller rely on certain third-party services to provide certain functionalities. These third parties have limited access to User data in the context of providing these services and are contractually obliged to use it in accordance with the provisions of the applicable regulations on the protection of personal data.

Payment for orders placed on the Site is handled by Stripe.

Users' statistical data (cookies) is used to improve the user experience and enhance the Site's functionalities. Users are invited to refer to the site's cookies policy.

7.3 Legal obligations

Data may also be transmitted by the Vendor to third parties and the competent authorities in order to meet legal, judicial, fiscal or regulatory obligations. The Vendor guarantees Users that no personal data will be transmitted to an unauthorised third party without the prior, voluntary, informed, explicit and written consent of the User.

The Seller is prohibited from processing, hosting or transferring information collected about its users to a country outside the European Union or recognised as "inappropriate" by the European Commission without first informing the owner of the data and obtaining its consent.

ARTICLE 8 - Data protection

The Seller has taken all useful and necessary precautions, taking into account the state of the art in the field, to protect your information in a secure environment in order to avoid any destruction, loss, alteration, distribution or unauthorised access. However hard we try, no method of transmission over the Internet and no method of electronic storage is completely secure. We cannot therefore guarantee absolute security. If we become aware of a breach of security, we will notify the users concerned so that they can take appropriate action. Our incident notification procedures take into account our legal obligations, whether national or European.

In the event that the integrity and confidentiality of your data is compromised, the data controller undertakes to comply with the procedures put in place under the Data Protection Act 2018 and the General Data Protection Regulation ("GDPR").

The Seller does not resell or outsource any User data.

ARTICLE 9 - Individual rights

In accordance with the legal provisions of the Data Protection Act 2018 and the General Data Protection Regulation, users of the Site have the following rights:

9.1 Right of access, rectification and deletion

Users may read, update, modify or request the deletion of data concerning them by sending an e-mail to the person responsible for processing personal data, specifying the purpose of the request to the following e-mail address: contact@perso1.com.

9.2 Right to portability

The User has the right to request the portability of his/her personal data, held by the Site or by the Seller, to another site, by making a request for the portability of his/her personal data to the data controller, by sending an e-mail to the address provided above.

9.3 Right to restrict and object to data processing

The User has the right to request the limitation of or to oppose the processing of his/her data by the Vendor, without the latter being able to refuse, unless it can be shown that there are legitimate and overriding reasons, likely to prevail over the interests and rights and freedoms of the User.

The User must make a request to the data controller to limit the processing of his/her personal data, by sending an e-mail to the address provided above.

9.4 Right not to be subject to a decision based exclusively on an automated process

In accordance with the provisions of Regulation 2016/679, the User has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him or her or significantly affects him or her in a similar way.

9.5 Right to determine the fate of data

Users are reminded that they can organise what the future of their data collection and processing should be if they die, in accordance with the Data Protection Act 2018.

ARTICLE 10 - Exercise of rights

10.1 How to exercise your rights

To exercise any of your rights, simply :

- Write a letter to the Seller at the address of its registered office;
- Or send an e-mail to contact@perso1.com.

Please give your full name and address and enclose proof of identity.

The data controller is Carlo Ela, contact@perso1.com.

Requests will be processed within one month, unless there is a compelling reason presented and justified by the Seller justifying an extension of the period.

10.2 Appeals to the Commission

of Data Protection

If the data controller refuses to respond to the User's request, and the User is not satisfied with this, the User is entitled to lodge a complaint (online or by post) with the Irish Data Protection Commission (DPC), the data protection supervisory authority of the Member State in which the Seller is located.

ARTICLE 11 - Data confidentiality

The Seller undertakes to take the technical and organisational measures necessary to guarantee a level of security appropriate to the risk of processing personal data. However, as the Internet is an open system, the Vendor cannot guarantee the absolute security of information transmitted on the Site. Users are invited to report any incident likely to harm their interests.

When data is collected and processed, the Seller undertakes to take appropriate measures to protect your information from unauthorised access, disclosure, modification or destruction. In addition, the Seller ensures that third party service providers also comply with these provisions.

ARTICLE 12 - Cookies

When the Site is consulted, cookies are placed on the User's computer, mobile phone or tablet.

12.1 Deactivating cookies

The User may deactivate cookies at any time. Deactivating cookies may result in the loss of certain Site functions. The User can ensure that his/her computer warns him/her each time a cookie is sent, or he/she can choose to deactivate all cookies. To do this, the User must change the settings on their browser. To find out how cookies are managed in their browser, they should consult the browser's help menu. However, it is possible that some of the Site's functions will not function correctly if cookies are deactivated in the User's browser.

12.2 Purpose of cookies

The cookies used on the Site enable the User's browser to be recognised each time the User connects, in order to provide a quality user experience and to monitor the performance of the Site. Cookies are also used to monitor Site traffic and improve its performance. Lastly, sharing cookies (social networks) are placed by the Seller.

12.3 Third-party cookies

The collection and processing of information relating to the use of these social networks are subject to the privacy policies of the third parties in question. The User may accept or refuse these cookies. We use Google Analytics to collect information on the use of the Site. Google Analytics cookies have a maximum lifetime of thirteen (13) months.

ARTICLE 13 - Conditions for amending the privacy policy

This data protection policy can be consulted at any time on the Site.

The data controller reserves the right to modify it to ensure compliance with current law. The User will be informed of any changes by the Vendor, by all reasonable means, as soon as possible and in good time before the new policy comes into force. In the event of disagreement with the new data protection policy, the User may delete his/her account. The User acknowledges that there is no recourse in the event of rejection of the new data protection policy.

This data protection policy has been drawn up in accordance with the recommendations of the General Data Protection Regulation. It will be effective from 30 March 2023.

ARTICLE 14 - Consent

By using the Site, Users consent to the collection and processing of their personal data by the Seller under the conditions and for the purposes described in this data protection policy.

The English-language version of this data protection policy is binding and takes precedence over the French-language version. It takes precedence over the French version.