This Privacy Policy is intended to help you understand how your personal data is collected, processed and stored by Shigeta via the Site.
Shigeta understands that data protection and privacy is an issue for all users visiting the Site.
Shigeta is committed, in accordance with the RGPD regulation, to respect your privacy and to protect your personal data, i.e. data that may identify you directly or indirectly as a person.
The purpose of this privacy policy is to inform you of Shigeta’s commitments in this regard.
DEFINITION
When you use our Site, we may ask you to provide us with personal information about yourself.
The term “personal data” refers to all data that can be used to identify an individual, which includes your name, surname, pseudonym, photograph, postal and e-mail address, job title, telephone numbers, date of birth, data relating to your transactions on the Site, details of your purchases, credit card numbers, SIRET, intra-community VAT number, IP address, as well as any other information that you choose to communicate to us about yourself.
SUBJECT
The purpose of this charter (hereinafter the “Charter”) is to inform you about the means we use to collect your personal data, in strict compliance with your rights.
In this regard, we inform you that we comply, in the collection and management of your personal data, with Law No. 78-17 of January 6, 1978 relating to data processing, in its current version (hereinafter: the “Data Protection Act”), as well as Regulation (EU) 2016/679 of April 27, 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” or the “GDPR”).
IDENTITY OF THE DATA COLLECTOR
The person responsible for collecting your personal data is the company Shigeta, registered in the Trade and Companies Register of Paris under the number 519 493 258, having its registered office at 116 rue du Bac – 75007 Paris (hereinafter referred to as “We”).
COLLECTION OF PERSONAL DATA
The legal basis for our collection of your personal data is as follows:
- This collection is necessary in order to execute the contract concluded when you use our services on our Site;
- the legitimate interest when you voluntarily provide us with personal data during your visit to our Site, the data being collected to enable us to better respond to your requests for information on our services.
Your personal data is collected to fulfill one or more of the following finalities:
- To manage your access to and use of certain services available on the Site,
- Carry out operations related to Customer management concerning contracts, invoices, follow-up of the relationship with Customers,
- Build a file of users, customers and prospects,
- To send newsletters and promotional messages. If you do not wish to receive such information, we give you the opportunity to express your refusal to do so at the time of collection of your data,
- To elaborate commercial and traffic statistics of our services,
- Organize contests and all promotional operations with the exception of online games of chance subject to the approval of the French Autorité de Régulation des Jeux en Ligne
- Manage people’s opinions on products, services or content,
- To manage any unpaid bills and disputes regarding the use of our products and services,
- Personalize responses to your information requests,
- To respect our legal and regulatory obligations. We inform you, when collecting your personal data, if certain data must be filled in or if they are optional (by asterisks visible on the Site).
| Why do we collect your personal data? | What categories of personal data do we collect for this purpose? | What is the legal basis for us to collect your personal data for such a purpose? |
| We collect your personal data in order to identify you when you use our site and to send you messages related to the proper administration of our site (e.g.: confirmation of registration, modification of the site or of the terms of use, etc.) |
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The legal basis for this processing is the execution of the contract binding us at the time of your acceptance of our general conditions at the time of the creation of your account |
| We collect your personal data in order to deliver your order. |
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The legal basis for this processing is the execution of the contract binding us at the time of your acceptance of our general conditions at the time of the creation of your account |
| We collect your personal data in order to improve and optimize our site, for example by studying your behavior during your visit and to draw conclusions in order to make changes in terms of ergonomics and user experience. |
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The legal basis for this processing is our legitimate interest in providing and improving the user experience of our site visitors and members. |
| We collect your personal data in order to understand your preferences and to provide you with commercial offers for services/products similar to those you have already ordered. |
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The legal basis for this processing is our legitimate interest in providing and improving the user experience of our site visitors and members. |
When collecting your personal data, we inform you whether certain data is mandatory or optional.
RECIPIENT OF PERSONAL DATA
Will have access to your personal data:
- The staff of our company ;
- The services in charge of the control (lawyer, accountant in particular) ;
- Our subcontractors (communication providers, productivity software providers, data hosting providers, payment service providers, billing providers, audience analysis and measurement providers, customer relationship management providers);
- The recipients of your personal data may also include public bodies, exclusively to meet our legal obligations, court officers, ministerial officers and bodies responsible for effecting the collection of debts.
RETENTION PERIOD OF PERSONAL DATA
Concerning data related to the management of customers and prospects :
Your personal data will not be kept beyond the time strictly necessary to manage our commercial relationship with you.
However, the data allowing to establish the proof of a right or a contract, having to be preserved under the respect of a legal obligation, will be it during the duration envisaged by the law in force.
With regard to any prospecting operations aimed at customers, their data may be kept for a period of three (3) years from the finding of the commercial relationship.
Personal data relating to a prospect, not a customer, may be kept for a period of three (3) years from the date of their collection or the last contact from the prospect.
At the end of this three (3) year period, we may contact you again to see if you wish to continue receiving commercial solicitations.
In the event of exercising the right of access or rectification, data relating to identity documents may be kept for the period provided for in Article 9 of the French Code of Criminal Procedure, i.e. one (1) year. In case of exercise of the right of opposition, such data may be archived for the period of limitation provided for in Article 8 of the French Code of Criminal Procedure, i.e. three (3) years.
The financial transactions relating to the payment of purchases and fees via the Site, are confined to a payment service provider who ensures the smooth running and security.
For the purposes of the Services, this payment service provider may be the recipient of your personal data relating to your credit card numbers, which it collects and stores on our behalf. We do not have access to this data.
To enable you to make regular purchases or to pay on the Site, your credit card data is kept for the time of your registration on the Site and at least until you make your last transaction.
The data relating to the visual cryptogram or CVV2, written on your bank card, are not stored.
If you do not want your personal data relating to your credit card numbers to be retained as described above, we will not retain such data beyond the time necessary to complete the transaction.
In any event, the data relating to these may be kept, for a finality of proof in the event of a possible dispute of the transaction, in intermediate archives, for the period provided for in Article L 133-24 of the French Monetary and financial Code, in this case thirteen (13) months following the date of debit. This period may be extended to fifteen (15) months afin order to take into account the possibility of using payment cards with credit.
Concerning the management of lists of opposition to receive prospecting:
The information that allows us to take into account your right to object is kept for a minimum of three (3) years from the time you exercise your right to object.
Concerning the statistics of audience measurement:
The information stored in the users’ terminal or any other element used to identify the users and allowing their traceability or frequentation will not be kept beyond thirteen (13) months.
SECURITY
We inform you that we take all useful precautions, organizational and technical measures appropriate to preserve the security, integrity and confidentiality of your personal data and, in particular, to prevent them from being distorted, damaged or accessed by unauthorized third parties. We also use secure payment systems that comply with the state of the art and applicable regulations.
ACCOMMODATION
We inform you that your data are kept and stored, for the duration of their retention, on the servers of the company OVH, located in the European Union.
TRANSFER OUTSIDE THE EUROPEAN UNION
Your data may be transferred outside the European Union as part of the tools we use and our relationship with our subcontractors.
This transfer is secured with the following tools:
- Either these data are transferred to a country that has been deemed to offrant an adequate level of protection by a decision of the European Commission ;
- Or we have entered into a specific contract with our processors to govern transfers of your data outside the European Union, based on the standard contractual clauses between a data controller and a processor approved by the European Commission.
ACCESS, RECTIFICATION, RESTRICTION AND DELETION OF YOUR PERSONAL DATA
In accordance with the European regulation on the protection of personal data, you have the following rights:
- A right of access allowing you at any time to know whether or not your personal data is being processed by our services and when it is, to have access to said personal data and to the information required by law concerning the way in which said data is processed,
- A right of rectification allowing you to request that any inaccuracies concerning your personal data be corrected as soon as possible,
- A right to erasure, allowing you to promptly request the deletion of your personal data, provided that such request for deletion meets the requirements of applicable law,
- A right to limit the processing of your personal data, provided that such request for limitation complies with the requirements of applicable law,
- A right to portability allowing you to receive your personal data in a structured, commonly used and machine-readable format, or to request that such personal data be transmitted to another data controller, provided that such request for portability complies with the requirements of applicable law,
- A right to object to the processing of your personal data for reasons relating to your particular situation, provided that such objection complies with the conditions required by the applicable law,
- The right to withdraw at any time the specific consent given to the collection of your personal data, in particular when the processing of your personal data is used for commercial prospecting purposes,
- The right to set up instructions for the retention, deletion and disclosure of your personal data after your death.
You have the right to obtain the limitation of the processing of your personal data, in the cases definis in Article 18 of the GDPR:
- During the period of checking that we implement, when you dispute the accuracy of your personal data,
- When the processing of such data is unlawful, and you wish to restrict such processing rather than delete your data,
- When we no longer need your personal data, but you wish to retain it to exercise your rights,
- During the period of checking of legitimate reasons, when you have objected to the processing of your personal data.
Persons whose data is collected on the basis of our legitimate interest are reminded that they may object to the processing of their data at any time. We may, however, continue to process data if there are legitimate reasons for the processing which override your rights and freedoms or if the processing is necessary to establish, exercise or defend our legal rights.
You may unsubscribe from our promotional emails via the link provided in the emails. Even if you choose to stop receiving promotional messages from us, you will continue to receive our administrative messages.
PORTABILITY OF YOUR PERSONAL DATA
You have a right to the portability of the personal data you have provided to us, understood as the data you have actively and consciously declared in the course of accessing and using the services, as well as the data generated by your activity in the course of using the services.
We remind you that this right does not apply to data collected and processed on a legal basis other than consent or the performance of the contract binding us.
This right can be exercised free of charge, at any time, and in particular when closing your account on the Site, in order to recover and store your personal data.
In this context, we will send you your personal data, by any means deemed useful, in a standard open format commonly used and readable by computer, according to the state of the art.
LODGING A CLAIM WITH A SUPERVISORY AUTHORITY
You are also informed that you have the right to lodge a complaint with a competent supervisory authority (the Commission Nationale Informatique et Libertés for France), in the Member State in which you usually reside, your place of work or the place where the violation of your rights would have been committed, if you consider that the processing of your personal data subject to this charter constitutes a violation of the applicable texts.
This remedy may be exercised without prejudice to any other remedy before an administrative or judicial court. In effet, you also have the right to an administrative or jurisdictional recourse if you consider that processing of your personal data subject to this charter constitutes a violation of the applicable texts.
MODIFICATIONS
We reserve the right, at our sole discretion, to modify this policy in whole or in part at any time.
These changes will be effective upon publication of the new policy.