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[\/et_pb_text][\/et_pb_column][\/et_pb_row][\/et_pb_section][et_pb_section fb_built=”1″ admin_label=”Politique” _builder_version=”4.21.2″ _module_preset=”default” background_enable_color=”off” custom_padding=”54px|0px|54px|0px|false|false” global_colors_info=”{}”][et_pb_row _builder_version=”4.21.2″ _module_preset=”default”][et_pb_column _builder_version=”4.21.2″ _module_preset=”default” type=”4_4″][et_pb_text _builder_version=”4.21.2″ _module_preset=”default” hover_enabled=”0″ sticky_enabled=”0″]<\/p>\n
Preamble<\/p>\n<\/div>\n<\/div>\n
Entry into force: March 30th, 2023<\/p>\n<\/div>\n<\/div>\n
INFINIWAVE LIMITED<\/strong><\/p>\n 77, LOWER CAMDEN STREET,<\/strong><\/p>\n DUBLIN D02 XE80<\/strong><\/p>\n Ireland<\/strong><\/p>\n Registration number 737750 and VAT. 4162209VH<\/strong><\/p>\n<\/div>\n<\/div>\n Access to the Site and its features requires the collection and processing of Users\u2019 personal data. It was therefor necessary to establish a personal Data Protection Policy to comply with the recommendations for use in the processing of personal data as established by the applicable law and regulation.<\/p>\n The Site\u2019s Data Protection Policy has been established in accordance with the recommendations of the Data Protection Commission (DPC). Its purpose is to inform Site Users of how their personal data is processed and of the commitments and measures we have taken to ensure that the personal data of Site Users is respected. The Data Protection Act 2018;<\/p>\n The European Regulation on Personal Data, 2018<\/p>\n The Law of transposition of the European Regulation on the Protection of Personal Data, 2018.<\/p>\n The version currently posted on the Site is the current version of this policy. The Seller reserves the right to modify it at any time in order to comply with the legal obligations in force. Any changes to the Privacy Policy will be will be communicated to Users in order to obtain their consent to the new policy.<\/p>\n By browsing our Site, the User acknowledges having read, understood and accepted this data protection policy. Any question relating to this policy can be sent to the following address:\u00a0<\/span>contact@test4u1.com<\/a>.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n Article 1 \u2013 Definitions<\/p>\n<\/div>\n<\/div>\n 1.1 Technical terms relating to the protection of personal data<\/span><\/strong><\/p>\n On our Site, the terms below have the meaning attributed to them with the meaning of GDPR (Article 4);<\/p>\n Consent:<\/strong>\u00a0<\/span>of the data subject, any free, specific, informed and unambiguous manifestation of will by which the data subject accepts, by a declaration or by a clear positive act, that personal data concerning him or her be the subject of a \u201ctreatment\u201d;<\/p>\n Controller:<\/strong>\u00a0<\/span>\u201cthe natural or legal person, public authority, service or other body alone or jointly with others, determines the purposes and means of processing; where the purposes and means of such processing are determined by Union law or the law of a Member State, the controller may be designated or the specific criteria applicable to his designation may be provided for by the law of the \u2018Union or by the law of a Member State\u2019\u201d;<\/p>\n Processor:<\/strong>\u00a0<\/span>\u201cthe natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller\u201d;<\/p>\n Processing:<\/strong>\u00a0<\/span>\u201cany operation or set of operations whether or not carried our using automated processes and applied to data or sets of personal data, such as the collection, recording, organisation, structuring, storage, adaption or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, erasure or destruction\u201d;<\/p>\n Personal Data Breach:<\/strong>\u00a0<\/span>\u201ca security breach resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of personal data transmitted, stored or otherwise processed, or unauthorised access to such data\u201d<\/p>\n 1.2 Other terms used herein<\/span><\/strong><\/p>\n \u201cCustomer\u201d:<\/strong>\u00a0<\/span>designated according to the provisions of the introductory article of the Customer Rights Act 2022, an individual acting for purposes that are wholly or mainly outside that individual\u2019s trade, business, craft or profession;<\/p>\n \u201cSite\u201d:<\/strong>\u00a0<\/span>means the Site\u00a0<\/span>https:\/\/test4u1.com\/<\/a>\u00a0<\/span>operated by the Seller and made available to the User;<\/p>\n \u201cUser\u201d:<\/strong>\u00a0<\/span>refers to any individual using our Site and having access to its content.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n ARTICLE 2 \u2013 What is personal data?<\/p>\n<\/div>\n<\/div>\n Personal data means any information that can directly or indirectly identify a natural person (surname, first name, email, telephone number, postal address, etc.).<\/p>\n As such, the GDPR defines personal data as: \u201cany information relating to an identified or identifiable natural person (hereinafter referred to as \u201cdata subject\u201d); an \u201cidentifiable natural person\u201d is deemed to be a natural person 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 specific elements specific to his physical, physiological, genetic, psychic, Economic, cultural or social identity\u201d.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n ARTICLE 3 \u2013 Data of minors<\/p>\n<\/div>\n<\/div>\n In accordance with the provisions of Article 8 of European Regulation 2016\/679 and the Data Protection Act, only minors aged 15 or over can consent to the processing of their personal data.<\/p>\n Users under the age of fifteen (15) are invited to seek the agreement of a legal representative \u2013 required by the Seller \u2013 so that their personal data can be collected and to be able to use the services of the Site.<\/p>\n The Seller\u2019s liability cannot be sought in the event of the provision by any user of personal data concerning a minor under the age of fifteen (15).<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n ARTICLE 4 \u2013 Collection of personal data<\/p>\n<\/div>\n<\/div>\n We collect your consent.<\/span><\/strong><\/p>\n By browsing the Site, the User must, on several occasions, provide some of their personal data (for the purposes indicated in Article 5). The Seller collects and processes the data strictly necessary for the purposes for which they are processed. We undertake with our Users not to process data for purposes other than those mentioned below. If we were to offer a new service on the Site, or any other functionality of the Site, requiring the collection and processing of data, we undertake to collect the consent of the Users once again before offering the new service in question<\/p>\n Whenever the Site processes personal data, the Seller takes all reasonable measures to ensure the accuracy and relevance of the personal data with regard to the purposes for which they are processed.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n ARTICLE 5 \u2013 Purpose of processing<\/p>\n<\/div>\n<\/div>\n We collect User data only for the following processing purposes:<\/span><\/p>\n 5.1 Account creation (optional)<\/span><\/strong><\/p>\n Customers can create an account on the Site. To do this, they must provide the following data: surname, first name, email address. \u2013 Validate the creation of his account; The legal basis is the execution of a Contract, due to the placing of an order, the latter accepting these provisions.<\/p>\n 5.2 Placing the order<\/span><\/strong><\/p>\n For the purpose of placing an order on the Site, Customers must provide the following information: surname, first name, email and billing address.<\/p>\n User data and communication data are used only for the purposes of:<\/p>\n \u2013 Validate the customer\u2019s order; The Customer is also informed that by placing an order, he will receive transactional communications from the Seller (invoices, change of password, results of personality tests). He can unsubscribe at any time by using the functionalities provided for this purpose in the communication emails sent by the Seller.<\/p>\n The legal basis is the Execution of a Contract due to the placing of an order, the latter accepting these provisions.<\/p>\n 5.3 Payment for services<\/span><\/strong><\/p>\n Payment for orders via the Site is made through our payment provider STRIPE, the latter acting as the controller of Customer payment data. The Seller does not have access to Customer payment data.<\/p>\n 5.4 Subscription<\/span><\/strong><\/p>\n By placing an order on the Site, the Customer automatically benefits from a Subscription to the Seller\u2019s Subscription (see the GCS). If the Customer has not terminated his subscription after 24 hours, it is automatically extended for a period of one month, renewable by tacit agreement.<\/p>\n The data used for the conclusion of the subscription are the data provided by the Customer at the time of placing the order and are used for the purposes of:<\/p>\n \u2013 Provide subscription services; 5.5 Contact form<\/span><\/strong><\/p>\n A contact form is available on the Site. To respond to his request, the User must provide his surname, first name, email and telephone number. \u2013 Process the User\u2019s request; 5.6 Analysis\u00a0<\/span><\/strong><\/p>\n By browsing the Site, the User may be required to enter their personal connection data (cookies, tracers).<\/p>\n Connection data and browsing information are used solely for the purposes of statistical studies (analysis of site traffic and user experience) and other purposes mentioned in the cookie policy.<\/p>\n The processing is necessary for the purposes of the legitimate interests pursued by the Seller, in particular to offer Users a smooth and improved browsing experience.<\/p>\n The connection data is also used to prevent and fight against any computer fraud.<\/p>\n The legal basis is the response to a legal obligation.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n ARTICLE 6 \u2013 Duration of data retention<\/p>\n<\/div>\n<\/div>\n We do not exceed the legal data retention periods and User data is only kept for the time necessary to process the purposes for which it was collected.<\/p>\n The retention periods are as follows:<\/p>\n \u2013 Data relating to the identity of the User not having the quality of customer (surname, first name): they are deleted or anonymized three (3) years after the last contact from the User unless the latter has previously exercised a right (in application of the GDPR) having led to the deletion of his data;<\/p>\n \u2013 Communication data of the User not having the status of customer (email, telephone number, postal address): they are deleted or anonymized three (3) years after the last contact from the User unless this the latter has previously exercised a right (in application of the GDPR) which has led to the deletion of his data;<\/p>\n \u2013 Data relating to Customers who have placed an order: they are deleted five (5) years after the end of the commercial relationship with the Customer, unless the latter has previously exercised a right (in application of the GDPR) which has led to the deletion of their data ;<\/p>\n \u2013 Connection data: they are kept, in application of the Cookies policy, for a maximum period of 13 months (except as indicated in article 13).<\/p>\n In establishing our data processing policy, we have established a reference grid for the duration of data retention, developed thanks to the recommendations of the Data Protection Commission.<\/p>\n In addition, the Seller may retain certain personal data in order to fulfil its legal or regulatory obligations, to allow users to exercise their rights, or for statistical purposes. At the end of the retention period of the personal data, these will be deleted or anonymized.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n ARTICLE 7 \u2013 ACCESS TO DATA<\/p>\n<\/div>\n<\/div>\n The data collected via the Site is intended exclusively for the following recipients.<\/span><\/p>\n 7.1 Hosting of the Site<\/span><\/strong><\/p>\n The Site is hosted by\u00a0<\/span>Scaleway<\/span><\/strong>\u00a0, 8 rue de la Ville l\u2019Ev\u00eaque, 75008 Paris\u00a0<\/span>https:\/\/www.scaleway.com\/<\/span><\/a><\/p>\n The host has access to the data within the limits of its respective attributions, for the hosting of the Site. It has limited access to User data, within the framework of the performance of these services and has a contractual obligation to use them in accordance with the provisions of the applicable regulations on the protection of personal data.<\/p>\n For more information, see\u00a0<\/span>Scalaway<\/span><\/a>\u00a0\u2018s policy .<\/span><\/p>\n <\/p>\n 7.2 Third party providers<\/span><\/strong><\/p>\n <\/p>\n The Site and the Seller rely on certain third-party services to provide certain functionalities. The latter have limited access to User data, as part of the performance of these services and have a contractual obligation to use them in accordance with the provisions of the applicable regulations on the protection of personal data.<\/p>\n <\/p>\n Payment management for orders on the Site is provided by Stripe<\/span>.<\/span><\/strong><\/p>\n <\/p>\n User statistics data (cookies) are used to improve the user experience and allow the improvement of the Site\u2019s functionalities.\u00a0The user is invited to refer to the cookies policy of the site.<\/span><\/p>\n <\/p>\n 7.3 Legal obligations<\/span><\/strong><\/p>\n <\/p>\n The data may also be transmitted by the Seller to third parties and competent authorities to meet legal, judicial, tax or regulatory obligations. The Seller guarantees Users that no transfer of personal The Seller is prohibited from processing, hosting or transferring the Information collected on its users to a country located outside the European Union or recognized as \u201cunsuitable\u201d by the European Commission without first informing the owner of the data and without having obtained his agreement.<\/p>\n <\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n ARTICLE 8 \u2013 Data protection<\/p>\n<\/div>\n<\/div>\n The Seller has taken all useful and necessary precautions, with regard to the state of the art in the matter, to protect your information in a secure environment in order to avoid any destruction, loss, alteration, dissemination or unauthorized access. No matter how hard you try, no method of transmission over the Internet, and no method of electronic storage, is completely secure. We cannot therefore guarantee absolute security. If we become aware of a security breach, we will notify affected users so that they can take appropriate action. Our incident notification procedures consider our legal obligations, whether at national or European level.<\/p>\n In the event that the integrity and confidentiality of your data are compromised, the controller undertakes to comply with the procedures put in place under the Data Protection Act 2018 and the European Data Protection Regulation(\u201cGDPR\u201d).<\/p>\n The Seller does not carry out any resale or outsourcing of User data.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n ARTICLE 9 \u2013 Rights of persons<\/p>\n<\/div>\n<\/div>\n With regards to the legal provision of the Data Protection Act 2018 and the European Data Protection Regulation, Users of the Site have the following rights:<\/p>\n 9.1 Right of access, rectification and right to erasure<\/span><\/strong><\/p>\n The User may read, update, modify or request the deletion of data concerning him, by sending an email to the personal responsible for processing personal data, specifying the subject of this request to the following email address:\u00a0<\/span>contact@test4u1.com<\/a>\u00a0<\/span>.<\/p>\n 9.2 Right to portability<\/span><\/strong><\/p>\n The User has the right to request the portability of his personal data, held by the Site or by the Seller, to another site, by making a request for the portability of his personal data to the data controller, by sending an email to the address provided above.<\/p>\n 9.3 Right to restriction and opposition of data processing<\/span><\/strong><\/p>\n The User has the right to request the limitation or to oppose the processing of his data by the Seller, without the latter being able to refuse, except to demonstrate the existence of legitimate and compelling reasons, which may prevail over the interests and the rights and freedoms of the user.<\/p>\n The User must make a request to limit the processing of his personal data to the data controller, by sending an email to the address provided above.<\/p>\n 9.4 Right not to be the subject of a decision based exclusively on an automated process \u00a0<\/span><\/strong><\/p>\n In accordance with the provisions of Regulation 2016\/679, the User has the right not to be the subject of a decision based exclusively on an automated process if the decision produces legal effects concerning him, or significantly affects him in similar way.<\/p>\n 9.5 Right to determine the fate of data<\/span><\/strong><\/p>\n The User is reminded that he can organise what should be the future of his data collection and processing if he dies, in accordance with the Data Protection Act 2018.<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n ARTICLE 10 \u2013 Exercise of Rights<\/p>\n<\/div>\n<\/div>\n 10.1 How to exercise the rights?<\/span><\/strong><\/p>\n To exercise one of your rights, all you need to do is:<\/span><\/p>\n By indicating your surname, first name, address and attaching proof of identity.<\/span><\/p>\n The data controller is Mr\u00a0<\/span>Carlo Ela\u00a0<\/span>contact@test4u1.com<\/a>\u00a0<\/span><\/strong>.\u00a0<\/span><\/p>\n Requests will be processed within one month, unless there is a compelling reason put forward and justified by the Seller justifying an extension of the period.<\/p>\n
It has been established in accordance with the provision of:<\/p>\n
By providing their data, the User therefore consents to the collection and processing of the personal data provided by the Seller for the exclusive purposes as detailed in article 5 of the Policy. This consent, together with other grounds, serves as the legal basis for the processing of the data collected.<\/p>\n
Customer data is used for the purposes of:<\/p>\n
\u2013 Create your customer account;
\u2013 Communicate with the Customer;
\u2013 Ensure after-sales follow-up.<\/p>\n
\u2013 Process the Customer\u2019s order;
\u2013 Provide the services covered by the order;
\u2013 Provide after-sales service.<\/p>\n
\u2013 Manage subscription membership (billing, termination, renewal);
\u2013 Provide after-sales service.<\/p>\n
User data and communication data are used only for the purposes of:<\/p>\n
\u2013 Respond to the User\u2019s request.
The legal basis is the User Consent.<\/p>\n
data will be made to an unauthorized third party without the prior, voluntary, informed, express and written consent of the User.<\/p>\n\n