Last updated on: February 16, 2021
Preamble
Our data protection policy has been established in accordance with the recommendations of the French Data Protection Authority (CNIL). Its purpose is to inform users of our website (www.lockall.fr) of the commitments and measures we have taken to ensure the protection of the personal data of visitors, users, and customers of Sodeval France.
It was established in accordance with the provisions of the French Data Protection Act of 6 January 1978, the European General Data Protection Regulation (GDPR) of 23 May 2018 and the Law transposing the European General Data Protection Regulation (GDPR) of 20 June 2018.
1. Definitions
On our website, the terms below have the meanings attributed to them under the GDPR (art. 4):
- Consent : "From the data subject, any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her."
- Personal data: “any information relating to an identified or identifiable natural person (hereinafter referred to as “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 the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
- Data controller: "The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for by Union or Member State law."
- Subcontractor : "The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller."
- Treatment : "any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated 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 security breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed."
2. The data collected
2.1 Consent
Our company collects and processes data strictly necessary for the purposes for which it is processed. We commit to our users not to process data for purposes other than those mentioned below.
If we were to offer a new service on our website, requiring the collection and processing of your data, we commit to collecting the consent of our users once again before offering them the new service in question.
Whenever our site processes personal data, it takes all reasonable steps to ensure the accuracy and relevance of the personal data with regard to the purposes for which it is processed.
2.2 Access to data
The data we collect on our site is for our exclusive use only. Our users' personal data is not shared with third parties and is only accessible to authorized employees of our company.
The data controller for your data at Lockall can be contacted at the following address: [email protected]
As the data controller for the data it collects, it undertakes to comply with the applicable legal provisions. In particular, it is responsible for providing prospects, customers, and users with complete information on the processing of their personal data and for maintaining an accurate and up-to-date record of processing activities.
2.3 The purpose of the processing
We collect our users' data only for the following processing purposes:
- Contact our customer service: On our website, several services are available to users to contact our company (a "Contact Us" module, a "Schedule an Appointment" module, a "Request a Free Callback" module, and a chat module). The data collected allows us to quickly get back in touch with our users to process their requests or orders, as appropriate.
- Creating a customer account: For all orders placed on our website, users must create a customer account. To create a customer account, we ask users to provide their email address and set a password. Users can request the deletion of their customer account by sending an email to the following address: [email protected]
- Order management: For every order placed on our website, we collect the following data: telephone number, address and delivery information, and the buyer's identity. Your payment information is collected by our payment partner, Stripe; its security is therefore Stripe's responsibility. The user is responsible for the accuracy of the information provided. Lockall cannot be held liable for any incorrect information provided when placing an order.
- Navigation on our site: Our company collects your browsing information solely for statistical analysis purposes. Please refer to our relevant cookie policy.
- Preventing and combating computer fraud (spamming, hacking, etc.): computer hardware used for browsing, IP address, password.
We do not exceed the legal data retention periods and your data is kept only for the time necessary to process the purposes for which it was collected.
2.4 Non-disclosure of personal data
Our website will not process, host, or transfer information collected about its customers and users to a country outside the European Union or recognized as "inadequate" by the European Commission without first informing the data owner. However, Lockall remains free to choose its technical and commercial subcontractors, provided they offer sufficient guarantees with regard to the requirements of the General Data Protection Regulation (GDPR: No. 2016-679).
The user's personal data may be processed by subsidiaries of our company and subcontractors (service providers), solely for the purposes described in this policy. Our company is committed to taking all necessary precautions to ensure the security of information and, in particular, to prevent its disclosure to unauthorized persons.
2.5 Data security and incident notification
Our site and our company have taken all necessary and appropriate precautions, in accordance with current best practices, to protect your information in a secure environment to prevent any destruction, loss, alteration, dissemination or unauthorized access.
Despite our best efforts, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, we cannot guarantee absolute security. If we become aware of a security breach, we will notify affected users so they can take appropriate action. Our incident notification procedures comply with our legal obligations, whether at the national or European level.
In the event that the integrity and confidentiality of your data are compromised, the data controller undertakes to comply with the procedures put in place under the French Data Protection Act of 6 January 1978 and the European General Data Protection Regulation (“GDPR”).
However, the user is responsible for the security of their own username and password for their customer account. Lockall cannot be held liable in the event of loss or theft of these credentials or unauthorized access to a user's account by a third party due to the theft of those credentials.
3. Rights of individuals
In accordance with the legal provisions of the French Data Protection Act of 6 January 1978 and the European General Data Protection Regulation (“GDPR”), users of our site have the following rights:
- Right of access (Article 15 GDPR) and rectification (Article 16 GDPR), updating, completion of user data;
- Right to block or erase personal user data (Article 17 of the GDPR), when it is inaccurate, incomplete, ambiguous, outdated, or when its collection, use, disclosure or storage is prohibited;
- Right to withdraw consent at any time (Article 13-2c GDPR);
- Right to restriction of processing of user data (Article 18 GDPR);
- Right to object to the processing of user data (Article 21 GDPR);
- Right to data portability for data that users have provided, when this data is subject to automated processing based on their consent or on a contract (Article 20 GDPR);
- Right to define the fate of user data after their death and to choose to whom Lockall should (or should not) disclose their data to a third party that they have previously designated.
Our website and our company cannot oppose users' requests to exercise their rights. These requests can be made at any time electronically to the following address: [email protected]Requests will be processed within ten (10) working days unless there is a compelling reason presented and justified by our company justifying an extension of the period.
3.1 Referral to the CNIL
If our company does not meet the user's request, the user has the right to contact the CNIL (National Commission for Information Technology and Freedoms, https://www.cnil.fr) in order to assert its rights.
3.2 Minimum age
In accordance with Article 8 of the GDPR, we do not collect, directly or indirectly, personal data from individuals under the age of sixteen (16). Users under the age of sixteen (16) are asked to obtain the consent of a legal guardian—required by Lockall—before their personal data can be collected. Sodeval France reserves the right to request proof of this consent from the legal guardian.
Our company cannot be held responsible for the provision by any user of personal data concerning a minor under sixteen (16) years of age.
4. Cookies
4.1 Definition of cookies
The user is informed that a cookie is a small file placed on the user's device (computer, tablet, or mobile device) by our website when they visit it. It does not contain any personal information, but allows us to link the user's device to their preferences for use and experience on our site (e.g., location, language, font size).
4.2 Consent regarding the use of cookies
For the use of "cookie" files involving the saving and analysis of personal data, the user's consent is always requested. This consent is valid for a period of thirteen (13) months, after which the user will be asked for renewed authorization.
4.3 Use of cookies
We use and collect cookies for the purposes of:
- To process statistics and information about traffic on our site and to optimize it as best as possible;
- To offer our users a smooth browsing experience by adapting the presentation of our site to the display preferences of the user's terminal;
- To remember information provided on the platform by the user (access to their account, contents of an order basket, etc.).
The cookies present on our site are as follows:
- _to Single view control function
- Hubspot Marketing management function
4.4 Opposition et configuration
All users of the website www.lockall.fr can refuse the recording of "cookies" by configuring their browser software in the following way(s):
- Open a private browsing window;
- Cookie configuration via the "Cookies" widget available on our website's homepage;
- Configuring your computer so that a message appears asking you to accept, customize, or reject cookies on each site or systematically;
- Or any other means available to the user.
Users can express and modify their cookie preferences at any time. Our company accepts no responsibility for any consequences related to the operation of the website and any services offered resulting from a user's refusal of cookies and/or the website's inability to save or access cookies necessary for its operation due to the user's choice.
4.5 Navigation software settings
The user can configure their browser software to set their preferences regarding the use of cookies:
The user is informed that by configuring their browser to refuse cookies, certain features of our site may not be accessible and our company or the hosting provider cannot be held responsible in this regard.
4.6 Social network settings
By clicking on the social media icons (Facebook, Twitter, YouTube, LinkedIn, and Instagram) on our website, and if the user has accepted the use of cookies by continuing to browse the site, these social networks may also place cookies on the user's device. The user can consult the data protection policies of these social networks to configure their cookie settings.
5. Changes to the privacy policy
The version currently published on our website is the current version of this policy. Lockall reserves the right to modify it at any time to comply with applicable legal obligations. It is therefore the responsibility of each user to regularly consult this policy to stay informed of any changes.
By browsing our site, the user acknowledges having read, understood and accepted this data protection policy.
