Privacy Policy

Entry into force: March 30, 2023

INFINIWAVE LIMITED

77, LOWER CAMDEN STREET,

DUBLIN D02 XE80

Ireland

Registration number 737750 and VAT 4162209VH

Access to the Site and its features requires the collection and processing of Users’ personal data. It was therefore necessary to establish a personal Data Protection Policy to comply with the recommendations for use in the processing of personal data as established by applicable law and regulation.

The Site's Data Protection Policy has been established in accordance with the recommendations of the Data Protection Commission (DPC). Its purpose is to inform Site Users about how their personal data is processed and to outline the commitments and measures we have taken to ensure that the personal data of Site Users is respected.
It has been established in accordance with the provision of:

The Data Protection Act 2018;

The European Regulation on Personal Data, 2018

The Law of transposition of the European Regulation on the Protection of Personal Data, 2018.

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 legal obligations in force. Any changes to the Privacy Policy will be communicated to Users in order to obtain their consent to the new policy.

By browsing our Site, the User acknowledges having read, understood, and accepted this data protection policy. Any questions relating to this policy can be sent to the following address: contact@test4u1.com.

1.1 Technical terms related to the protection of personal data

On our Site, the terms below have the meaning attributed to them in the GDPR (Article 4);

Consent of 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;

Controller “the natural or legal person, public authority, service or other body which, alone or jointly with others, determines the purposes and means of processing of personal data; where the purposes and means of such processing are determined by Union law or by the law of a Member State, the controller or the specific criteria for the designation of the controller may be provided for by Union law or by the law of a Member State‘.;

Processor “the natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller”;

Processing: “any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, 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 resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of personal data transmitted, stored or otherwise processed, or unauthorized access to such data”

1.2 Other terms used herein

“Customer designated according to the provisions of the introductory article of the Consumer Rights Act 2022, an individual acting for purposes that are wholly or mainly outside that individual's trade, business, craft or profession;

“Site means the Site https://test4u1.com/ operated by the Seller and made available to the User;

“User: refers to any individual using our Site and having access to its content.

Personal data means any information that can directly or indirectly identify a natural person (last name, first name, email, phone number, postal address, etc.).

As such, the GDPR defines personal data as: “any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an “identifiable natural person” 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”.

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.

Users under the age of fifteen (15) are invited to seek the agreement of a legal representative – required by the Seller – so that their personal data can be collected and to be able to use the services of the Site.

The Seller shall not be liable for the provision of personal data concerning a minor under the age of fifteen (15) by any user.

We collect your consent.

By browsing the Site, the User will, on several occasions, be required to provide some of their personal data (for the purposes indicated in Article 5).
By providing their data, the User thus 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, along with other grounds, serves as the legal basis for the processing of the collected data.

The Seller collects and processes 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.

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.

We collect user data only for the following processing purposes:

5.1 Account creation (optional)

Customers can create an account on the Site. To do this, they must provide the following data: last name, first name, and email address.
Customer data is used for the purposes of:

– Validate the creation of his account;
– Create your customer account;
– Communicate with the customer;
– Ensure after-sales follow-up.

The legal basis is the execution of a Contract, resulting from the placement of an order, with the latter party accepting these provisions.

5.2 Placing the order

For the purpose of placing an order on the Site, Customers must provide the following information: surname, first name, email, and billing address.

User data and communication data are used only for the purposes of:

– Validate the customer's order;
- Process the customer's order;
– Provide the services covered by the order;
– Provide after-sales service.

The Customer is also informed that by placing an order, they will receive transactional communications from the Seller (invoices, password changes, personality test results). They can unsubscribe at any time by using the functionalities provided for this purpose in the communication emails sent by the Seller.

The legal basis is the execution of a contract due to the placement of an order, with the order accepting these provisions.

5.3 Payment for Services

Payment for orders through the Site is made via our payment provider, STRIPE, which acts as the controller of Customer payment data. The Seller does not have access to Customer payment data.

5.4 Subscription

By placing an order on the Site, the Customer automatically benefits from a Subscription to the Seller’s Subscription (see the GCS). If the Customer has not terminated their subscription after 24 hours, it is automatically extended for a period of one month, renewable by tacit agreement.

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:

– Provide subscription services;
– Manage subscription membership (billing, cancellations, renewals);
– Provide after-sales service.

5.5 Contact form

A contact form is available on the Site. To respond to his request, the User must provide their last name, first name, email, and phone number.
User data and communication data are used only for the purposes of:

– Process the User's request;
Respond to the user's request.
The legal basis is user consent.

5.6 Analysis 

By browsing the Site, the User may be required to enter their personal connection data (cookies, trackers).

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.

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.

The connection data is also used to prevent and combat computer fraud.

The legal basis is the response to a legal obligation.

We do not exceed legal data retention periods, and user data is only kept for the time necessary to fulfill the purposes for which it was collected.

The retention periods are as follows:

– Data relating to the identity of the User who is not a customer (surname, first name): this data will be deleted or anonymized three (3) years after the User's last contact, unless the User has previously exercised a right (under the GDPR) that resulted in the deletion of their data;

– 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 the latter has previously exercised a right (in application of the GDPR) which has led to the deletion of his data;

– 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; ;

– Connection data: They are kept, in accordance with the Cookies policy, for a maximum period of 13 months (except as indicated in article 13).

In establishing our data processing policy, we have created a reference grid for data retention periods, developed based on recommendations from the Data Protection Commission.

Additionally, the Seller may keep certain personal data to fulfill its legal or regulatory obligations, to allow users to exercise their rights, or for statistical purposes. At the end of the personal data retention period, it will be deleted or anonymized.

The data collected via the Site is intended exclusively for the following recipients.

7.1 Site Hosting

The Site is hosted by Scaleway , 8 rue de la Ville l’Evêque, 75008 Paris https://www.scaleway.com/

The host has access to the data within the limits of its respective responsibilities for the hosting of the Site. It has limited access to User data within the scope of its service performance and has a contractual obligation to use it in accordance with the provisions of applicable personal data protection regulations.

For more information, see Scalaway ‘s policy. .

7.2 Third-party providers

The Site and the Seller rely on certain third-party services to provide certain functionalities. These third parties have limited access to User data as part of the performance of these services and are contractually obligated to use it in accordance with the provisions of applicable data protection regulations.

Stripe handles payment management for orders on the Site..

User statistics data (cookies) are used to improve the user experience and enhance the Site's functionalities. The user is invited to refer to the site's cookies policy.

7.3 Legal Obligations

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
data will be made to an unauthorized third party without the User's prior, voluntary, informed, express, and written consent.

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 “inadequate” by the European Commission without first informing the data owner and obtaining their agreement.

The Seller has taken all reasonable and necessary precautions, in accordance with the state of the art, to protect your information in a secure environment and prevent any destruction, loss, alteration, unauthorized disclosure, or unauthorized access. However, 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 that they can take appropriate action. Our incident notification procedures comply with our legal obligations at both the national and European levels.

In the event your data's integrity and confidentiality are compromised, the controller agrees to follow the procedures established under the Data Protection Act 2018 and the European Data Protection Regulation (“GDPR”).

The Seller does not engage in any resale or outsourcing of User data.

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:

9.1 Right of Access, Rectification, and Erasure

The User may read, update, modify, or request the deletion of data concerning them by sending an email to the person responsible for processing personal data, specifying the subject of this request to the following email address: contact@test4u1.com .

9.2 Right to Portability

The User has the right to request the portability of their personal data, held by the Site or by the Seller, to another site, by making a request for the portability of their personal data to the data controller, by sending an email to the address provided above.

9.3 Right to restriction and objection to data processing

The User has the right to request the limitation or to object to the processing of their 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.

The User must submit a request to the data controller to limit the processing of their personal data by sending an email to the address provided above.

9.4 Right not to be the subject of a decision based exclusively on automated processing.  

In accordance with the provisions of Regulation 2016/679, the User has the right not to be subject to a decision based solely on automated processing, if the decision produces legal effects concerning them, or similarly significantly affects them.

9.5 Right to data self-determination

The user is reminded that they can organize what should happen to their data collection and processing in the event of their death, in accordance with the Data Protection Act 2018.

10.1 How to exercise the rights?

To exercise one of your rights, all you need to do is:

• To write a letter to the Seller, at the address of its head office;
• Or write an email to the following address: contact@test4u1.com .

By providing your surname, first name, address, and attaching proof of identity.

The data controller is Mr. Carlo Ela contact@test4u1.com . 

Requests will be processed within one month, unless the Seller provides a compelling and justified reason for an extension of the period.

10.2 Referral to the Data Protection Commission

If the Seller does not satisfy the User's request, the latter is entitled to contact the Data Protection Commission. https://www.dataprotection.ie/.

11.1 What is a Cookie?

Users are informed that a cookie is a small file placed on their computer, tablet, or mobile device by our Site when they visit it. It does not contain any personal information but allows us to link your device to your usage preferences and experience on our Site (e.g., location, language, font size).

11.2 User Consent

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, with some exceptions (see table Art.13), after which new authorization will be requested from the User.

In accordance with the deliberation of the S.I. No. 336/2011 – European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations
2011, the Seller informs the Site's Users that Cookies record certain information which is stored in the memory of their hard disk. This information is used to generate Site audience statistics and to offer services according to information previously selected during prior visits.

An alert message, in the form of a banner, asks each User visiting the Site, beforehand, if they wish to accept cookies. To guarantee the User's free, informed, and unequivocal consent when visiting the Site, the banner will not disappear until they have continued their navigation and configured their choices.

Without the User's prior consent, cookies will not be deposited or read.

If someone visits the Site (either the homepage or directly on another page from a search engine, for example) and does not continue browsing, a simple lack of action cannot be considered a manifestation of will.;

Or if they click on the link within the banner that allows them to configure cookies and, if necessary, refuse the deposit of cookies.
We use and collect cookies for the purposes of:

– To process statistics and information on traffic on our website 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 memorize information provided on the Site by the User.

The following is a list of cookies present on the Site:

All Users may oppose the registration of “Cookies” by configuring their browser software in the following way(s):

Open a private browsing window;
– Configuration of cookies via the “Cookies” Widget available on the homepage of our Site;
– Configuring the computer so that a message appears asking you to accept, personalize, or refuse cookies on each site or systematically;

Or any other means available to the User.

At any time, the User may choose to express and modify their preferences regarding Cookies. The Seller disclaims all responsibility for the consequences related to the operation of the Site and any services offered resulting from:

The user's refusal of cookies;
– And/or the inability of the site to save or access Cookies necessary for its operation due to the User's choice.

The user can configure their navigation software to set their choices regarding the use of cookies:

• For Microsoft Edge ^TM  : https://support.microsoft.com/en-us/microsoft-edge
• For SafariTM ^: http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
• For ^Chrome™  : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• For Firefox ^TM  : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
• For ^OperaTM: http://help.opera.com/Windows/10.20/fr/cookies.html

The User can also configure their browser to accept or refuse cookies on a case-by-case basis before they are installed, or to delete cookies from their terminal. The User is hereby informed that by configuring their browser to refuse cookies, certain features of our Site may not be accessible, and the Seller or the host shall not be held liable in this regard.

The Seller reserves the right to modify this Policy at any time. If a change is made to this Policy, the new version will be posted immediately on the Site. If the User does not agree with the terms of the new version of the policy, they have the option to stop using the Services of the Site and to stop browsing the latter.

By browsing the Site, the User certifies that they have read and understood this privacy policy and accept its terms, particularly regarding the collection and processing of their personal data, as well as the use of “Cookies“ files.