The purpose of this privacy policy is to inform users of the www.croma-designstudio.com website about how their personal data is collected, in accordance with current legislation, particularly Law n°78-17 of January 6, 1978 relating to information technology, files, and freedoms, amended by Law n°2004-801 of August 6, 2004, and by Law n°2018-493 of June 20, 2018 (“Loi Informatique et Liberté”), Regulation (EU) No. 2016/679 of the European Parliament and of the Council 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 (“GDPR”), as well as Directive 2002/58 of July 12, 2002 amended by Directive 2009/136/EC (“ePrivacy Directive”).

This policy also informs users of their rights concerning this data, as stipulated in the articles of the French Data Protection Act (Loi Informatique et Liberté) and the GDPR. Furthermore, it specifies the identity of the person responsible for processing the personal data collected and processed, as well as the recipients of this data. We attach great importance to respecting the privacy and protecting the personal data of our users.

ARTICLE 1: PRINCIPLES REGARDING THE COLLECTION AND PROCESSING OF PERSONAL DATA

In accordance with Article 5 of European Regulation 2016/679, personal data is:

• Processed lawfully, fairly, and transparently with regard to the data subject;
• Collected for specified, explicit, and legitimate purposes, and not further processed in a manner incompatible with those purposes;
• Adequate, relevant, and limited to what is necessary with regard to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date. All reasonable steps must be taken to ensure that personal data which are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which they are processed;
• Processed in such a way as to guarantee appropriate security of the data collected, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.

Processing is lawful only if, and insofar as, at least one of the following conditions is met:

• The data subject has consented to the processing of his or her personal data for one or more specific purposes;
• The processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request;
• The processing is necessary for compliance with a legal obligation to which the controller is subject;
• The processing is necessary to protect the vital interests of the data subject or of another natural person;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data prevail, in particular where the data subject is a child.

Similarly, Croma Design undertakes not to transfer any personal data outside the European Union without implementing appropriate safeguards in accordance with the regulations in force.

ARTICLE 2: PERSONAL DATA COLLECTED AND PROCESSED DURING WEBSITE NAVIGATION

Article 2.1: Collected data

The personal data collected within the framework of our activity are the following:

• Names and First names
• E-mail addresses
• Location
• IP address
• Payement Method

Article 2.2: Data collection mode

When you use our site, the following data is automatically collected:

• Location
• IP address
• Cookies
• Pages consulted
• Date and time of consultation

Article 2.3: Retention period

The Croma Design site undertakes to respect the principles of personal data retention, in accordance with the regulations in force. Thus, we will only keep your personal data for as long as is strictly necessary for the purposes for which it was collected.

As soon as the initially defined purpose or retention period expires, we undertake to anonymize or delete your personal data.

• 3 years for information relating to users following their last contact, end of newsletter subscription, or end of contract with Croma Design
• 5 years for subscriptions with Croma Design from the date of subscription
• No retention of bank details beyond a transaction period or following a single purchase unless you have consented to their preservation
• Variable duration for browsing and interaction data with the Croma Design site depending on the type of cookie selected

However, in certain cases, notably to meet legal obligations such as the investigation, recording, and prosecution of criminal offenses, or for accounting or tax reasons, your data may be archived beyond the periods stipulated. Archiving your personal data implies that they will be subject to access restrictions and will no longer be accessible online. It will be extracted and stored on a secure, independent medium. The maximum retention periods defined in our policy will apply unless you expressly request the deletion or cessation of processing of your personal data before the expiry of these periods, in accordance with our internal procedures and the regulations in force.

Article 2.4: Hosting of data

The www.croma-designstudio.com site is hosted by:

LWS

10 Rue de Penthièvre

75008 Paris

Article 2.5: Transmission of data to third parties

Data may be transmitted to our partners, listed below:

STRIPE FRANCE

10 Boulevard Haussmann

75009 Paris

Article 2.6: Cookie policy

The Croma Design Studio site’s cookie policy aims to guarantee a transparent user experience that respects privacy. Cookies are small text files stored on your device when you visit our site. They are used to enhance your browsing experience, collect anonymous data about your use of the site, and personalize content according to your preferences.

We use different types of cookies, including:

– Essential cookies: These cookies are necessary for the site to function and allow you to access certain features, such as logging in to your user account.

– Performance cookies: These cookies help us to understand how visitors interact with our site by collecting information about the pages visited, the time spent on the site, and any error messages. This enables us to optimize our site to offer a better user experience.

– Functionality cookies: These cookies enable the site to remember your choices and preferences (such as language or region) in order to offer a more personalized experience on your next visits.

– Targeting cookies: These cookies are used to track your browsing activity in order to offer you targeted advertising according to your interests. By using our site, you consent to the use of cookies in accordance with our policy. You can disable cookies in your browser settings, but please note that some site features may not function properly without them.

ARTICLE 3: DATA CONTROLLER AND DATA PROTECTION OFFICER

Personal data are collected by Croma Design, whose registration number is SIREN 899 252 118.

The data controller can be contacted as follows:

By post to the address: 18 rue de la federation, 93100 Montreuil, FRANCE;

By e-mail: hello@clovisromano.com

If, after having contacted us, you feel that your ‘Informatique et Libertés’ rights have not been respected, you can send a complaint to the CNIL.

ARTICLE 4: USER RIGHTS REGARDING THE COLLECTION AND PROCESSING OF DATA

Any user concerned by the processing of their personal data may avail themselves of the following rights, pursuant to European Regulation 2016/679 and the French Data Protection Act (Law 78-17 of January 6, 1978):

• Right of access, rectification, and right to erasure of data (laid down respectively in Articles 15, 16, and 17 of the GDPR);
• Right to data portability (Article 20 of the GDPR);
• Right to limitation (Article 18 of the GDPR) and opposition to data processing (Article 21 of the GDPR);
• Right not to be the subject of a decision based exclusively on an automated process;
• Right to determine the fate of data after death;
• Right to seize the competent supervisory authority (Article 77 of the GDPR).

To exercise your rights, please send a letter to Croma Design Studio, 18 rue de la federation, 93100 Montreuil, FRANCE or an e-mail to hello@clovisromano.com In order for the data controller to process your request, you may be required to provide certain information, such as your first and last names, e-mail address, and account, personal space or subscriber number. Consult the cnil.fr website for more information on your rights.

ARTICLE 5: CONDITIONS FOR MODIFICATION OF THE PRIVACY POLICY

The publisher of the Croma Design site reserves the right to modify the present Policy at any time in order to ensure its conformity with current law.

Any modifications will not affect purchases previously made on the site, which remain subject to the Policy in force at the time of purchase and as accepted by the user at the time of purchase validation. The user is invited to take cognizance of this Policy each time he/she uses our services, without it being necessary to formally inform him/her of it.

The present policy, edited on 01/06/2024, was updated on July 1st, 2024.