Privacy Policy for www.sutanpu.com website and Sutanpu mobile application

PRIVACY AND PERSONAL DATA PROTECTION POLICY

Following the entry into force, on May 25, 2018, of European Regulation No. 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, we define our personal data protection policy below. ​

 

These data correspond to any information allowing you to be identified directly or indirectly as a natural person.

This personal data protection policy (hereinafter the "Policy") aims to tell you what data we collect, for what reason and on what basis, and how we use and store it, as well as your rights regarding this data. data. We invite you to read this Policy carefully to know and understand our practices regarding the processing of your personal data that we implement.

Please note that this Policy may be modified or supplemented at any time by our services, in particular with a view to complying with any legislative, regulatory, jurisprudential or technological developments. You should therefore consult this Policy regularly in order to be aware of any changes. ​

 

This Policy is valid for both the Sutanpu mobile application (referred to as "Sutanpu Application" in the rest of the document) and for the www.sutanpu.com website.

I - Identity of the the person accountable for processing personal date

​The person accountable for processing personal data is Matthieu Polet, 15 rue de la Bourgeonnière, 44300 Nantes / Sutanpu / SIRET: 908 509 870 000 14 / Mail: hello@sutanpu.com

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II – Personal data subject to processing

 

The information we collect is used to improve the services we offer to you. This may be data:

  • relating to your identity: your surname, first name, postal and electronic address, telephone number (landline and/or mobile);

We also inform you that certain information is collected and stored automatically when you access our services:

  • When browsing our website and/or when creating an account on our website (IP addresses, connection data, types and versions of internet browsers used, types and versions of your browser plugins, systems and operating platforms, data concerning your navigation path on our site, cookies);

 

III – Processed operations on this data

 

We process your personal information in order to operate, provide and improve our services to you. Processing may have all or part of the following purposes:

  • Comply with our legal obligations​

In some cases, we have a legal obligation to collect and process your personal data.

  • Satisfy your rights

We may process your personal data to meet your requests to exercise your rights. We invite you to consult Part VI of this Policy to know your rights.

  • Share your information

We do not sell your personal data. We only share it with third-party partners in certain very specific situations. We thus share your personal data when required by law, or we transmit your personal data with third-party partners (established within the European Union or outside the European Union) who provide us with services such as hosting our websites and sending emails to customers.

 

On this subject, we invite you to consult Part V of our Policy.

  • Manage and improve our website and our mobile application

When you visit our website, we collect information, such as your IP address, location, visiting hours, etc., to learn about the habits of people using our site and improve their experience.

The Sutanpu mobile app requires keeping your email address as it is the ID that your digital stamps are associated with.

We also store photos that you can associate with the Sutanpu digital stamps you have collected.

IV – Retention duration of this data

 

Your personal data is kept for the time necessary to achieve the objective pursued when it was collected. For example :

- the email address provided when registering on the Sutanpu application is used to associate your Sutanpu collections with it.

- when you buy a product online, we keep the data related to your purchase, thus allowing us to execute the specific contract that you have accepted.

 

We also keep personal data for a period allowing us to process or respond to complaints or possible requests for information concerning the purchase.

 

The personal data which concerns you may also be kept longer under legal obligations, applicable legal limitation periods or recommendations of the CNIL (Examples: Tax documents = 6 years from their collection / accounting documents = 10 years from their collection)

We may retain your Personal Information (and the Personal Information of your Users) for as long as your User Account is active or as necessary to provide our Services to you. We may continue to retain your Personal Information after you deactivate your User Account and/or stop using our Services, as reasonably necessary to comply with our legal obligations, to resolve disputes concerning our Users or their Users, to prevent fraud and abuse, to enforce our agreements and/or to protect our legitimate interests.

V – Transfer of personal data

 

Your personal data may be transferred to other companies of our company located within the European Union. All of our companies are required to follow the privacy and personal data protection practices set forth herein.

 

Your personal data may also be transferred to other companies established within the European Union or outside the European Union on the basis of contracts incorporating the standard clauses drawn up by the CNIL, setting the requirements to be complied with in regarding the transfer of personal data. These companies provide us with services such as hosting our websites, telephone prospecting, order processing and sending e-mails to customers.

VI – Your rights

 

You have the following rights regarding your personal information, which you can exercise by writing to us at the following address: Matthieu Polet, 15 rue de la Bourgeonnière 44300 Nantes / Sutanpu / Mail: hello@sutanpu.com

 

To do this, we inform you that the CNIL offers a mail generator that will help you formulate your request: https://www.cnil.fr/fr/modeles/courrier

  • Right of access and communication of data

You have the right to know if and how we process your personal data and to obtain communication of it in an understandable format.

However, due to the obligation of security and confidentiality in the processing of personal data which is incumbent on us, you are informed that your request will be processed provided that you provide proof of your identity, in particular by producing a copy of one of your valid identity documents (either electronically or via a signed paper photocopy).

 

We inform you that we will be entitled, if necessary, to oppose manifestly abusive requests (by their number, their repetitive or systematic nature) as well as requests infringing the rights of third parties.

 

This request can be made by sending us a written request to the address mentioned above, using the letter template developed by the CNIL.

  • Right to rectification of data

You have the right to request the rectification, updating, blocking or deletion of personal data concerning you which may prove to be inaccurate, erroneous, incomplete or obsolete.

 

This request can be made by sending us a written request to the address mentioned above, using the letter template developed by the CNIL.

  • Right of opposition

The right to object allows you to object to your personal data being processed by us. You must justify this request for opposition by reasons relating to your particular situation, except with regard to commercial prospecting (including profiling insofar as it is linked to such commercial prospecting), for which you can oppose without motive.

 

Thus, if your opposition request does not concern commercial prospecting, we will be entitled to refuse your request on the grounds that:

  • you have given us your consent: you can however withdraw your consent;

  • there are legitimate and compelling reasons to process your data, in particular for the proper functioning of the Sutanpu application (for example: management of Sutanpu stamps that you have personally collected);

  • we are bound by a contract;

  • we are under a legal obligation to process your data;

  • the processing is necessary to safeguard your interests

 

This request can be made by sending us a written request to the address mentioned above, using the letter template developed by the CNIL.

  • Right to deletion

You have the right to ask us to erase your personal data without undue delay.

This request will no longer allow you to use the Sutanpu app or access the stamps you have collected. Sutanpu cannot be held responsible for this.

We inform you that in rare cases, we will not be able to satisfy your request, particularly in the context of compliance with a legal obligation (for example: the retention period for an invoice and therefore the data contained therein is 10 years ).

This request can be made by sending us a written request to the address mentioned above, using the letter template developed by the CNIL.

  • Right of limitation

You have the right to request the restriction of processing.

This request can be made by sending us a written request to the address mentioned above, using the letter template developed by the CNIL.

If this limitation no longer allows the Sutanpu app to associate you with the list of Sutanpu stamps you have collected, you will no longer be able to use the Sutanpu app or access the stamps you have collected. Sutanpu cannot be held responsible for this.

  • Right to portability

You have the right to the portability of your personal data, i.e. to receive the personal data that you have provided to us, in a structured, commonly used and machine-readable format, and to transmit them to another controller.

We inform you that this right can only be implemented if your data is processed automatically (paper files are therefore not concerned) and on the basis of your prior consent or the execution of a contract concluded with you.

To exercise this right, we invite you to contact us as follows: Matthieu Polet, 15 rue de la Bourgeonnière 44300 Nantes / Sutanpu / Mail: hello@sutanpu.com

  • Digital Will

You have the right to provide us with specific instructions relating to the fate of your personal data after your death and in particular with regard to their storage, deletion and communication in the context of the processing carried out by us.

These guidelines are provided to us by you as follows: Matthieu Polet, 15 rue de la Bourgeonnière 44300 Nantes / Sutanpu / Mail: hello@sutanpu.com

These guidelines may be changed at any time. In the absence of instructions or mention to the contrary, the heirs of a deceased person may exercise the rights of the deceased person.

  • Reply duration

We undertake to respond to your request for access, rectification or opposition or any other additional request for information within a reasonable period of time which may not exceed ONE (1) month from receipt of your request.

However, we may extend this period by two additional months depending on the complexity and the number of requests. You will then be informed of this extension of the response time, within one month of your request.

  • Right to contact the competent supervisory authority

In the event of difficulties, you have the right to lodge a complaint with the CNIL: https://www.cnil.fr/fr/plaintes

  • Withdrawal of consent

You also have the right to withdraw your consent, for the processing of personal data based on obtaining your consent. If, for example, you have given us your consent to send advertising messages electronically, you can unsubscribe from these mailings at any time by clicking on the unsubscribe link at the bottom of the advertising messages you have received.

You can also delete your user account at any time and without any reason directly online or by contacting our customer service.

 

VII – Cookies and other technologies

 

To enable us to analyze how you browse our website, we, with the possible help of third-party partners, collect certain information when you visit our site. This information includes the IP address, the geographical position of your device, the type of browser, the language of your browser, the date and time of your requests, the time of your visits, the pages consulted and the elements on which you clicked.

 

It is possible that we use cookies or other tracers when you consult our website or when reading certain e-mails that we send to you or when installing a mobile application, regardless of the type device you use (computer, tablet, smartphone, e-reader, etc.) in order to simplify efforts to collect and analyze such information.

We use this information to provide more appropriate and better content on our site, to measure the effectiveness of our advertisements, to identify and fix any problems.

We may also use one or more third party service providers to deliver online advertisements on our behalf. They may then use a pixel tag or other similar technology to collect information about your visits to the sites and use this information to send you targeted advertisements.

 

How to manage cookies?

If your browser is configured to refuse all cookies, you will not be able to take advantage of some of the services we offer.

 

To oppose the registration of cookies, you must configure your browser as follows:

  • Internet Explorer: In Internet Explorer, click on “Tools”, then on “Internet Options”. Under the General tab, under "Browsing history", click on "Settings". Finally, click on “show files”.

  • Firefox: go to the Tools tab of the browser then select the Options menu. In the window that appears, choose “Privacy” and click on “Show cookies”

  • Safari: in your browser, choose the “Edit” menu > “Preferences”. Click on “Security”. Click on “Show cookies”.

  • Google Chrome: click on the “Tools” menu icon. Select “Options”. Click on the “Advanced Options” tab and navigate to the “Privacy” section. Click on “Show cookies”.

 

VIII – Personal data of children​

Minors under the age of 15 must ask the holder of parental authority for authorization to register on the Sutanpu application.