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- About this policy
- What types of personal data do we collect and where do we get it from?
- What do we do with your personal data, and why?
- Who do we share your personal data with, and why?
- Where is your personal data transferred to?
- How do we keep your personal data secure?
- How long do we keep your personal data for?
- What are your privacy rights and how can you exercise them?
- About this policy
For the purposes of this policy, the controller will be S.E.V.H.A.N Suisse Sarl (the controller is also referred to in this policy as “S.E.V.H.A.N”, “we”, “our” and “us”).
This Privacy Policy describes how we collect, use, process and disclose your personal data when you access to or use our internet site Pristinemood.com (our « Site« )
In this policy, when we talk about personal data we mean any information that relates to an identifiable natural person – in this case, you.
You should read this policy, so you know what personal data we collect about you, what we do with it and how you can exercise your rights in connection with it. You should also read any other privacy policies that we give you, that might apply to our use of your personal data in specific circumstances from time to time. If you have any questions about this policy, please contact us at legal@pristinemood.com
- Our data protection responsibilities
S.E.V.H.A.N is a «controller » in relation to its use of your personal data. This is a legal term – it means that we make decisions about how and why we use your personal data and, because of this, we are responsible for making sure it is used in accordance with applicable data protection laws. We are required by law to give you the information in this policy.
- What types of personal data do we collect and where do we get it from?
The personal information we process about you broadly falls into four main categories: (i) Contact Information; (ii) Business-related information; (iii) Marketing Preferences; and (iv) Browsing Information.
We collect your personal information from various sources.
- Personal data provided by you and based on your consent
We may collect and use the following information that you provide to us:
- Identification information that you provide us when establishing our contractual relationship, or by filling in forms on our Site. You may provide us with your first name, last name, title, country of residence, company name, email address, and phone number, including all relevant data needed for our services
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete, although you do not have to respond to them.
- Your search queries on the Site.
- Personal data collected automatically from our Website and from third party (Cookie policy)
We may collect your personal data automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses and information collected through cookies.
A cookie is a small text file containing a string of alphanumeric characters that is sent to your browser and stored on your device, that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the Site. A cookie may also convey information to us about how you use our services on the Site (e.g., the pages you view, the links you click and other actions you take on the Site),and allow us or our business partners to track your usage of the Site over time.
We use cookies to improve functionality and speed up processing times. By saving a user’s settings, cookies can enhance the user’s experience and the performance of the Site.
We collect three different types of cookies on our Site.
- Required—Strictly necessary for the Site to function correctly.
- Functional—Used for analytics and performance.
- Advertising—Related to online behavioural advertising or collection of data for marketing purposes.
Most browsers give you the possibility not to accept cookies by activating the browser’s related preferences. If you use different devices to access our Web Site, you must make sure that each browser on each device is set to your cookie-related preferences. You can generally set your browser’s preferences to be informed cookies have been installed, to refuse certain cookies or to block them in their entirety.
However, if you choose to block cookies entirely, you might not be able to access certain parts of our Web Site for we may not use the cookies that are essential to its functioning.
This Site may link through to third party websites which may also use cookies over which We have no control. We recommend that you check the relevant third parties’ privacy policy for information about any cookies that may be used.
- Cookies Google Analytics
We use a tool called “Google Analytics” to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.
- What do we do with your personal data, and why?
We use your personal data for a number of different purposes. We must always have a “lawful basis” (i.e. a reason, prescribed by law) for processing your personal data. For some processing activities, we consider that more than one lawful basis may be relevant – depending on the circumstances.
We generally collect data about you: When you contact Us through the contact form available on our Web Site; When you register and enter in a contractual relationship with us When you browse our Site, your browsing data, such as clicking on products or destinations, your search engine, etc., help us expand your profile and suggest you adapted content (for more information on cookies, please read our cookie chart). When you contact us by requesting to be subscribed to our newsletter. |
- Who do we share your personal data with, and why?
Sometimes we share your personal data with third parties, including the following:
- courts, where we are asked to respond to a court order or other binding requests;
- regulatory and law enforcement authorities and agencies, in connection with any investigations or to respond to enquiries in relation to our compliance with applicable law or regulations; and
- professional advisors (such as but not limited to third-party law firms, lawyers and accountants).
These organisations will also use your personal data as a “controller” – they will have their own privacy policies which you should read, and they have their own responsibilities to comply with applicable data protection laws.
We may also ask third party service providers to carry out certain business functions for us. These include:
- IT support, cloud platform and data hosting providers who help us with the operation of our websites and other systems and applications;
- marketing service providers, including companies who send out surveys and marketing communications on our behalf; and
- survey providers who help collate feedback for us.
We will have in place an agreement with our service providers which will restrict how they are able to process your personal data and impose appropriate security standards on them.
- Where is your personal data transferred to?
Since S.E.V.H.A.N operates the Traveller Made® global network, we will sometimes need to transfer your personal data to recipients in jurisdictions other than your own. Some of these jurisdictions may not provide the same level of protection to your personal data as provided in your jurisdiction. If we transfer your personal data outside the EEA, we will only make that transfer if:
- that country ensures an adequate level of protection for your personal data;
- the recipient or recipient country is subject to an approved certification mechanism or code of conduct with binding and enforceable commitments which amount to appropriate safeguards for your personal data – this includes for example, the EU-US Privacy Shield which enables the secure transfer of personal data to the United States;
- we have put in place appropriate safeguards to protect your personal data, such as a contract with the person or entity receiving your personal data which incorporates specific provisions as directed by the European Commission;
- the transfer is permitted by applicable laws; or
- you explicitly consent to the transfer.
If you would like to see a copy of any relevant safeguards used by us to protect the transfer of your personal data, please contact us.
- How do we keep your personal data secure?
We will put in place appropriate security measures to protect your personal data from unlawful or unauthorised processing and accidental loss, destruction or damage.
However please note that, in relation to any personal data you submit to us online, we cannot guarantee the security of data sent to us in this way. Transmission of data over the internet is at your own risk. You are responsible for keeping any passwords you use to access our Site safe.
- How long do we keep your personal data for?
We will only retain your personal data for a limited period of time, and for no longer than is necessary for the purposes for which we are processing it for. This will depend on a number of factors, including:
- any laws or regulations that we are required to follow;
- whether we are in a legal or other type of dispute with each other or any third party;
- the type of information that we hold about you; and
- whether we are asked by you or a regulatory authority to keep your personal data for a valid reason.
- Once you have consented to receive our newsletter or market research messages, we store your personal data until you request to no longer receive marketing solicitation by clicking a link to unsubscribe or by sending an express request; and for a maximum of 3 years after the last contact we have from you.
- When you contact us through a contact form, we store your personal data for all the time necessary to process your request and for a period of 3 years after the last contact we have from you.
- What are your privacy rights and how can you exercise them?
Where our processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. If you do decide to withdraw your consent, we will stop processing your personal data for that purpose, unless there is another lawful basis we can rely on; in which case, we will let you know.
Where we are processing your personal data for direct marketing purposes, you have the right to object to that processing.
You have the right to (subject to certain limitations):
- access your personal data and to be provided with certain information in relation to it, such as the purpose for which it is processed, the persons to whom it is disclosed and the period for which it will be stored;
- require us to correct any inaccuracies in your personal data without undue delay;
- require us to erase your personal data;
- require us to restrict processing of your personal data;
- object to a decision that we make which is based solely on automated processing of your personal data.
Please contact us at legal@pristinemood.com if you would like to exercise any of your privacy rights.
We also encourage you to let us know if you have any concern about how we are processing your personal data so we can try to resolve your concerns. However, if you consider that we are in breach of our obligations under data protection laws, you are always entitled to submit a complaint with your data protection supervisory authority (www.cnil.fr).
Changes to this Privacy Policy
We may change this Privacy Policy. If the change is fundamental or may significantly affect you, we will provide you with the updated Privacy Policy in advance of the change actually taking effect. We will notify you by email or through a policy on the Site’s home page. We encourage you to review the content of this Privacy Policy regularly. The date the Privacy Policy was last revised is identified at the top of the page.