PRIVACY POLICY

Updated on

October 23rd, 2018

Preface

We attach a particular importance for the processing, confidentiality and security of your personal data. We are committed to offer you personalized services while respecting your private life and your personal choices.

This Privacy Policy ( the “Policy “) describes the way we use the personal data concerning you (“You”, “Your”, “Your”, customers and prospects) that you provide to us, or that we can be brought to collect through the various contacts that you can have with us (ex: shop, Customer service, sakoloko.com, social networks, digital applications, events etc.), their possible transfer to third parties and your rights and options you have to control your personal information and protect your privacy./p>

1 • Who are we?

“Sakoloko”, “Us”, “Our” and “Our” refer to:

SAKOLOKO, SAS (Société à Action Simplifiée) under French law with a capital of € 5,000, whose head office is located at 17 rue Claude Debussy, 78 100 Saint Germain-en-Laye, registered with the Trade and Companies Registry of Versailles, under the number: 842 868 382 and under the number of VAT: FR40 842868382 and represented by Mariane Henrique-Rech as CEO of Sakoloko.

Sakoloko is the data controller within the meaning of the regulations applicable to personal data and in particular the EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data and the free movement of such data ( “RGPD”).

2 • Your personal data

What are the personal data we collect about you?

• Coordinates, such as your: name, date of birth, nationality, e-mail address, mailing address, phone number and any other personal data that you provide us by filling out form on our Web site, especially if you subscribe to our newsletter or if you join and create an account on the Web site.

• Personal data contained in the communications you transmit to us, for example to report a problem or submit questions, concerns or comments concerning the Web site or its contents.

• Information from inquiries which we could, from time to time, lead on the Web site for purposes research, if you choose to answer it or to participate in it.

• The information concerning the way you use our Web site and your browsing on this site as your IP address and other identification of devices, your operating system and browser type and information concerning the pages of the sites that you consult, collected through cookies or other tracking technologies.

• Personal information collected from third parties, such as the data you agree to share with us on publicly available social networks (ex. Facebook, Instagram, etc.) and/or which we could collect from other publicly available databases.

• Information on the transactions you make.

• The information relative to your credit/debit card.

You are under no obligation to provide this information. The supply of these personal data (in particular including your contact information, e-mail address, address, credit / debit card number, bank code and telephone number) allows us however process your order of products on the website, to provide you , at your request, other services proposed on the Web site even to shape us to our legal or statutory obligations, if necessary. Refusal to provide us with the personal information necessary to enable us to fulfill the above purposes may, therefore, prevent us from processing your order for products sold on the Website or from complying with our legal or regulatory obligations. Therefore, the non-transmission of personal data may constitute, in some cases, a legitimate and justified reason not to process your order for products sold on our website or to not provide you with the services offered on the website.

The communication of personal data except those required to satisfy our legal or contractual obligations and to enable you to properly navigate our website and browse our services with the necessary traffic data is, on the contrary, optional and has no effect on the use of the website and the services attached to it or on the purchase of products on the site. We shall indicate to you to every stage if the communication of your personal data is mandatory or optional by marking with a suitable symbol (*) the information which are required or the data necessary for the purchase of products and/or for the supply of the services asked on the Web site.

3 • Minimum Age

To protect the safety and privacy of children is essential to us. We will not deliberately collect or use personal data about users who have not reached the age limit set by the law of their country of residence. When you register or make a purchase on the site you confirm being a person of major age in your country of residence (18 years in France). If you are the parent or the legal representative of a child who has registered on sakoloko.com, please contact us via the address indicated on the site, in order to cancel the registration of the child.

4 • Use made of your personal data and justifications

Whenever we process your personal data, we do so on the basis of a lawful “justification” (or legal basis) for processing. In the majority of cases, the processing of your personal data will be justified on one of the following bases:

The purposes for which we process your personal data are the following:

The processing of your personal data is justified by the following legal basis:

Process your purchases and to provide you with the services and information offered through the Website and which you request

Performance of a contract

Verify and carry out financial transactions in relation to payments you make

Performance of a contract

Improve and customise our products, services and our business in general, such as by tracking your product preferences, shopping history and interactions with the Website

Our legitimate interest to improve our products and services

Carry out data analytics and market research

Our legitimate interest to improve our products and services

Carry out data enrichment, such as by analysing your product preferences, shopping history and interactions with the Website together with data collected from third parties, such as data that you agree to share with us on social networks (e.g., Facebook, Instagram, etc.) and/or that we may collect from publicly accessible databases

Your prior explicit consent

Correspond with you to resolve your queries or complaints

Your prior explicit consent

Send you marketing communications containing news, information and updates about our products and services, offers, promotions and special events, and other marketing communications that may be of interest to you (by SMS, email or telephone), and customize your experience with us to your interests and shopping habits and improving our services, notably via profiling.

Your prior explicit consent and our legitimate interest in keeping our customers/prospects updated about our services and products

5 • Disclosure

We may, from time to time, share your personal data with our affiliates or service providers who help us supply the services which we offer, handle the transactions, answer the demands of information, receive and send communications, update the marketing lists, analyze data, provide support services or any task

We shall not share your personal data with a third company for marketing purposes

VYour personal data will be accessibleto the authorized members of staff of Sakoloko and in service providers acting on our behalf who need to access it.. Your personal data will be transferred from your country of residence to third countries where we operate. Some of these countries can rely on a European Commission adequacy decision on the level of data protection, while others, such as the United States, have not. To ensure that the protection of your personal data respects the law in force, these transfers outside your country of residence or the EEA will be made in accordance with the model EU standard clauses, the EU-E-U Privacy Shield certification or Switzerland-EU, binding corporate rules or other acceptable legal mechanisms.

We may also share your personal information with third parties in connection with the potential or actual sale or reorganization of our company or any asset of our company or any associated company, in which case personal data that we hold about our users could be one of the assets transferred.

We will also respond to requests for personal data when required by law or when we believe that the communication of such data is necessary to protect our rights and / or to comply with a court proceeding, court order, application regulator or any legal action that is notified to us.

6 • Security

We take all precautions to guarantee the confidentiality and the safety of your data and prevent it from being deformed, damaged, destroyed or unauthorized third parties having access to it.

In order to best protect your personal data outside the confines of our control system, your device must be protected (with up-to-date antivirus systems) and your internet service provider must take the necessary measures to ensure the security of your device. network data transmission (for example through firewalls and spam filters).

Even if we take all the reasonable measures to protect yout personal data, we can’t guarantee that the personal data you pass on to us will be 100% secure or exclude of data breach.

7 • Storing

Your data will only be stored in a form that allows you to identify yourself for as long as reasonably necessary for the pursuit of the purposes described above, or for the retention period permitted by law. The shelf life of your data is determined according to the following criteria:

Your data are processed for the purposes described in paragraph 5 for a period of:

•  three (3) years from our last contact, if you are a prospect (if you have not made any purchase from Sakoloko, but you are interested in our news)

•  ten (10) years after the end of our business relationship, if you are a customer (you have purchased one of our products or services)

Your data will then be archived, and may be used in the context of a dispute, action or litigation, during the applicable limitation period. In the case of a lawsuit, the data may be retained until exhaustion of legal remedies, and will then be deleted or archived in the limits allowed by law.

Your data is then destroyed or anonymized.

8 • Your Rights

You have the following rights with respect to your personal data:

• Right to withdraw consent – where applicable, you have the right to withdraw your consent at any time. For example, if you wish to opt-out of receiving electronic marketing communications, you can change your settings in your account on the Website, use the ‘unsubscribe’ link provided in our emails or text the STOP number in our SMS, or otherwise contact us directly and we will stop sending you communications.

•  Right of access, rectification and erasure – you have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances. You can see and update most of this data yourself online, or by contacting us.

•  Right of data portability – Under certain conditions, you have the right to receive all such personal data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.

•  Right to restriction of processing – you have the right to restrict our processing of your personal data where:
– you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
– the processing is unlawful but you do not want us to erase the data;
– we no longer need your personal data for the purposes of the processing, but you require such data for the establishment, exercise or defence of legal claims; or
– you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have overriding compelling legitimate grounds to continue processing.
Where personal data is subject to restriction in this way, we will only process it with your consent or for the establishment, exercise or defence of legal claims.

•  Right to object to processing justified on legitimate interest grounds – where we are relying upon legitimate interest to process personal data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a justification for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

•  Right to object to processing for marketing purposes – where we process personal data for direct marketing purposes, then you have the right to object to that processing at any time.

You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law.

For further information regarding your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data please contact m.henrique@sakoloko.com.

Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will endeavour to respond to your request as soon as possible and in any case within the applicable timeframes.

9 • Changes to this Policy

We may occasionally change this Policy, for example, to comply with new requirements imposed by the applicable laws or technical requirements. We will post the updated Policy on the Website. We may also notify you in case of material changes and seek your consent to those changes, where required by applicable law. You are thus encouraged to periodically review this page.