Adova Group collects, uses and shares various information users of our Products may provide via our website (the “Website”) which is accessible via the website https://treca.com
Concerned about preserving the confidentiality of your Personal Data and as part of our engagement towards transparency, we have prepared this document so you may know and understand the processing done with the data you communicate to us.
Adova Group undertakes to ensure the best level of protection and security for your personal data in accordance with applicable European and French regulations.
Thus, the Confidentiality Policy hereby formalised describes:
• the data we collect and the reasons for such collection;
• the way in which we use such data
• the way in which we use such data; • your rights concerning the use of your personal data
Please note that this Policy indicates our contractual obligations and particularly the general terms of use of this Website.
This Confidentiality Policy does not apply to mobile apps and websites owned by third parties, whether or not partners of our company, our Website may redirect to.
For any additional information on personal data protection, please refer to the French Data Protection Agency (CNIL) site: https://www.cnil.fr/
I. Data collected
In order to provide the best services to all users of our products, we may collect and process various data in the following ways:
(i) data collected directly from the user: When using our Website or our App, you are asked to give us information which identifies you (“Personal Data”). For guidance only, you provide us with Personal Data when buying one of our Products, when you complete a registration form for our services, when you participate in one of our games, contests, promotional offers, studies or surveys or even when you contact us by any means.
This information particularly includes the following data:
• your surname, given name, address, date and place of birth, sex, telephone number, email address;
• banking and financial information, especially your credit card number
• data connected to your location when you agree that we may collect and process such data;
(ii) data collected automatically: When you use our products and services, we collect various information systematically and automatically. This information mainly includes the following categories:
• data relating to the devices used when connecting or the means of consultation and use of our services: we may collect information on the devices you use with our services or the networks from which you access our services such as your IP address, connection data, browser type and version used, browser plug-in types and versions, operating systems and platforms, data concerning your browsing history;
In any case, we collect and process only the data strictly necessary for the purpose of such collection. Finally, when you request information from us, we will inform you of the mandatory or optional nature of the provision of such information and the consequences resulting from a failure to provide such information. Only the data fields marked with an asterisk need to be completed so that we can offer you a service such as processing an order, for example.
Children
Our Website is not designed for children under the age of 16 and we ask minors not to communicate any personal data to Adova Group. If we learn that we have collected Personal data on a minor under the age of 16, we take the necessary measures to delete such data as quickly as possible.
II. Duration of data conservation
In principle, the data collected are saved for no more than five (5) years after the final visit to the Website.
This period may be shorter if you close an account or request your Data be deleted.
Nonetheless, some data may be saved for longer than five (5) years as mentioned above in order to fulfil our accounting and fiscal obligations and, more generally, our legal obligations. This particularly refers to all transactions performed as well as any attached financial data.
III. Use of the data collected
The Data collected are used to:
(i) send you information on our services by any means of communication such as important security notices or any significant modifications to this Confidentiality policy as well as provide you with quality customer service;
(ii) collect your payments; when you order, we do not post or save the information from your payment card. The only information provided is that which allows us to process your order, respect the contract and prevent any attempted fraud against you or us;
(iii) allows you to customise our services, correct them and improve them to always offer you the best services; as well as your buying history which may allow us to better inform you when you visit our Site;
(iv) geolocation features; we collect location data only if you authorise us to do so and for the exclusive purpose of providing the Services based on the position you request (use of a store locator to locate points of sale). These data are saved on your terminal and are not saved or processed by us.
(v) allow you to create an account that may give you access to certain services subject to pre-registration, for example, when you create an Account, we ask you for your email address as well as your name to ensure the security of your Account;
(vi) allow you to connect to your Account using usernames and passwords used on a social media network; if you choose to proceed in such manner, you will be invited upon your first connection to grant the social network provider with your agreement so they may provide Tréca with certain information; particularly, your name, your email address, your profile photo, your publications, your comments and other information associated with your account on such social media network. All of this information will be transferred to Tréca by the social network provider due to the operation of social media connections. However, we only save and process your email address. If you do not wish to connect in such manner, you can simply log into your Account using your login details without using the username/password associated with your social media account;
(vii) Provide you with product assistance and customer service and track the quality and nature of this service; when you communicate with a customer service representative by email or phone, we collect Personal data such as your name, your mailing address, your phone number, your email address and your contact preferences as well as information on the Products you own such as the date of purchase. We can also create event logs which help us diagnose performance problems with a product or application and collect information on a problem associated with assistance or service. Under applicable law, we may also save and record your conversations with our customer service representatives as well as analyse any comments voluntarily provided via a customer survey all in a view to enhancing our customer service. With your agreement –which you may withdraw at any time-, our customer service representatives may connect to your Account if the problem resolution so requires.
IV. Disclosure of data collected
In order to provide you with the best service, we may share information concerning you, particularly your Personal Data, with third-party companies that process them on our behalf as per our instructions and in accordance with the laws in effect and this policy. Your Data will only be shared with partners who can ensure sufficient guarantees as concerns the implementation of appropriate technical and organisational measures that guarantee protection of your rights and your Data.
We may also share certain data, including your Personal Data, in virtue of a legal obligation to do so or if we believe in good faith that such is necessary to (i) respond to a complaint filed against Tréca, (ii) to comply with an enforceable court request, (iii) to perform any contract signed with our users (iv) in the event of any emergency putting public health or a person’s physical integrity at risk, (v) as part of an inquiry or investigation or (v) in order to guarantee the rights, assets and security of ADOVA Group, its employees and, more generally, any third party;
More generally, we may disclose all the information you have authorised us to communicate to third parties. We further reserve the right to disclose all or part of the Data collected as part of a transfer of ownership or restructuring of our company or its assets as long as the entity to which we transfer the Personal data exclusively processes your Personal data in accordance with this Confidentiality policy and pursuant to applicable law.
V. Data location
We save your Personal Data on our secured servers situated within the European Union. Nonetheless, it is possible for the data we collect when you use our services to be transferred to another country.
In such case, we make sure any such processing is done securely and in accordance with this Policy and that it complies with European Commission standard contractual clauses that can guarantee an adequate level of protection.
VI. Data security
We implement the appropriate security measures in accordance with the uses thereof to protect your data against any unauthorised access, modification, disclosure or destruction.
VII. Your rights
ADOVA Group has implemented Personal Data protection mechanisms adapted to ensure they are used in accordance with the purposes above and to ensure their accuracy and updating as well as the exercise of your rights.
Right of access: You have the right to access the Personal Data we hold through your account (accessible via the Website or App).
Right of rectification: You have the right to request the immediate rectification and updating of your Data.
Right to erasure (“right to be forgotten”): Unless there is a law otherwise, we will delete you Data in order to comply with our legal obligations; particularly when your Data are no longer needed or when you request such.
Right to the restriction of processing: You also have the right to restrict the processing of your Personal data if you believe your Data are not accurate or you object to the use thereof
Right to Data portability: You may ask us for a copy of the Data you have provided us with in a structured, commonly used and machine readable format whenever automatically processed. When technically possible, you may request that your Data be directly transferred to another data controller.
Right to object to processing: In certain circumstances and for reasons concerning your own individual situation, you may object to our processing of your Personal Data. When you make such request and it is compliant with applicable law, we will not process your Data anymore unless we can prove the legal basis and imperative nature of the personal data processing and that such basis prevails over your rights, interests and liberties. Likewise, we may process your Data if necessary to prove, exercise or defend our rights in court.
In order to comply with your request, we may (i) verify your identity and (ii) request you provide the type of information you request.
Please note that we may save certain information when the law requires us to or when we have a legitimate reason to do so notwithstanding the deletion thereof by you.
Right to file a complaint with a supervisory authority: If you believe ADOVA has not complied with this Confidentiality policy or that your rights guaranteed by applicable law are not adequately protected by ADOVA, you have the right to file a complaint with the supervisory authority. All things considered, we invite you to contact us directly at the following address: donneespersonnelles@adova-group.com
Finally, we will take all reasonable measures to notify each user to whom the personal data have been communicated of any rectification or erasure of personal data or any restriction of the processing carried out unless such communication proves impossible or requires disproportionate efforts
VIII. Cookies and similar technologies
Cookies are data files saved on a user’s terminal that may be used by the Website to send information to the User’s or Member’s browser, allowing that browser to send information to the site of origin (a session ID, choice of language, date, etc.). Cookies also make it possible to save status information when a browser accesses different pages of a website or when the browser later returns to the website, thereby enhancing the browsing experience.
Upon visiting the Website, the user is informed that their browsing information may be collected and saved in cookies files which may be automatically installed on their terminal.
When browsing the Website, you may find different types of cookies:
Publisher cookies
The main purposes of Publisher cookies are:
• to store variable and personalised data on a Website user;
• to memorise various data entered to optimise the services that are of interest to the User or Member and facilitate data entry on various forms.
Third-party cookies
• tracking cookies;
• audience cookies;
• technical and functional cookies.
The main purposes of third-party cookies:
• to distinguish Users, sessions and new visits;
• to establish anonymous statistics analysing traffic and browsing;
• to save the source of traffic or a campaign;
• to memorise the login and password in order to facilitate the connection for a Member already registered;
• to personalise potential commercial offers;
• to secure the connection for a User/Member on the Website, to memorise preferences of use and browser optimisation;
• to collect site display settings for easier browsing.
This list is not exhaustive and may evolve with the Website.
The User may reject the installation of cookies on their terminal by adjusting their browser settings following the procedure indicated by the browser.
In such case, the use of the Website and access to the Services may not be complete.
IX. Modification of the data processing and collection policy
We may occasionally modify this Confidentiality policy. In the event of a substantial modification, we will inform you and/or request your agreement as soon as possible and using reasonable means. We recommend you check our Policy in effect regularly to be informed of any modifications or updates.
X. Contact details and data controller
For any questions or queries related to this Policy and the way in which we use your Personal Data, please contact us at: donneespersonnelles@adova-group.com
You may also contact us by email at the following address:
ADOVA GROUP
To the attention of the Data Protection Officer
15 rue Traversière
75012 PARIS
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