2. Purpose & Scope of KOBALANN Privacy Policy

This Privacy Policy applies to personal data processing operations carried out by KOBALANN, whether as data controller or subcontractor, in the context of its activities and, more specifically, the operation and provision to Data Subjects of its online store.

When processing personal data, KOBALANN takes great care to comply with applicable Regulations including the French Data Protection Act of January 6, 1978 as amended and European Regulation no. 2016/679/EU known as "RGPD" of April 26, 2016 (hereinafter " Applicable Regulations ").

The purpose of this Privacy Policy is to inform Data Subjects of the processing operations carried out on their personal data and of their rights.

Data Subjects are invited to consult this Privacy Policy regularly in order to be informed of any changes. They will nevertheless be informed of any substantial adjustments that may be made.

3. Contact details & KOBALANN identity

Information relating to Data Subjects is likely to be collected and processed by KOBALANN, a limited liability company with capital of €48,000, registered with the Épinal Trade and Companies Register under no. 521 477 299, whose registered office is located at 1 route de Dramont, 88120, Sapois, represented by its manager, Vincent Munier, acting in his capacity as data controller or subcontractor.

When acting in a relationship of subcontracting personal data to achieve the purposes described below, KOBALANN is bound by a subcontracting agreement in accordance with Article 28 of the RGPD Regulation.

4. How KOBALANN collects and processes personal data

KOBALANN undertakes not to process personal data collected for purposes other than those described below and in accordance with the terms of this article.

4.1 Categories of personal data collected by KOBALANN

In the context of its activities and the operation of its online store, KOBALANN may collect and process the following categories of personal data:

(i) Data identifying the Persons concerned, including: first name, last name, e-mail address, pseudonym, telephone number, postal address.

(ii) Data relating to the browsing activities of Data Subjects, including: information relating to the customer access account (login, password), IP address, operating system category, session ID, access logs, history of connection dates and times, browsing history.

(iii) Data relating to product orders placed through the online store, including :

• information relating to orders currently being processed (surname, first name, address, date and amount of orders, nature of products ordered, date and time of delivery, information relating to reservations made on receipt of products, information relating to the exercise of the right to cancel orders, etc.);
• information on content downloaded via the customer account (invoices).

(iv) Data relating to the content of exchanges with KOBALANN, including: notices, history of conversations with KOBALANN whatever the medium, processing of complaints relating to an order.

(v) Financial data: information and bank details required for payment of orders, account number, account name, bank, credit card number, quotations, invoices.

(vi) Data relating to requests to KOBALANN to exercise rights (information relating to the exercise of rights conferred by the RGPD, the right of withdrawal and/or application of legal guarantees).

KOBALANN never collects or processes sensitive personal data within the meaning of the applicable regulations, i.e. information relating to the racial or ethnic origin, political opinions, religious beliefs, health or trade union membership of the Persons concerned.

4.2 How KOBALANN collects personal data

KOBALANN may collect personal data in various ways, including :

(i) when browsing the www.vincentmunier.com website or the associated social networks;

(ii) during exchanges of any kind with the Person concerned via the contact form, by e-mail, by post, by telephone, by videoconference;

(iii) as part of the commercial relationship between KOBALANN and the Data Subject relating to the management and follow-up of his/her requests and/or orders.

Personal data may be collected directly by a positive act on the part of the Persons concerned (e.g. registration, making contact) or automatically by the deposit of tracers on users' terminals.

4.3 Necessity of personal data collection

The provision of certain information is necessary to enable KOBALANN to efficiently process requests made via the website.

If the Person concerned does not provide the required information, KOBALANN may be unable to respond to the requests of the Persons concerned, including at the stage of creating a customer account or placing and validating an order from the online store.

The fields of a form that are not filled in as compulsory are left to the discretion of the Person concerned, who may or may not choose to fill them in.

5. Legal basis and purposes of KOBALANN's processing of personal data

KOBALANN processes the personal data of Data Subjects only if the purposes pursued so require. Any personal data processing operation carried out by KOBALANN is lawful and founded on a legal basis that justifies it, pursuant to Article 6 of the RGPD Regulation.

 

Goal(s) & Sub-goal(s) treatments	Categories of personal data	Legal basis (Art. 6 RGPD)
Customer account creation(registration, account validation, management, closure, disconnection, account deletion)	Identification data	Consent of the Person concerned
Placing, managing & tracking product orders from the website www.vincentmunier.com : validation of orders, payment, dispatch of orders, recourse to third-party service providers, delivery, receipt of reservations, order-related complaints	Identification data, delivery data, billing data	Execution of the GTC between KOBALANN and the Person concerned
Promotional actions & sales prospecting: prospect management, sales offers, website & social network management, newsletters, customer reviews, newsletters	Identification data, navigation data (if applicable)	Consent of the Data Subject for commercial prospecting operations & KOBALANN's legitimate interest in communicating about its activity for other purposes
Improving site operation and statistics: cookie analysis, audience measurement, site performance	Navigation data	Consent of the Person concerned
KOBALANN accounting management: storage of invoicing information, general accounting, accounting, tax and social reporting obligations	Identification data, event data, billing data	Compliance with a legal obligation to which KOBALANN is subject
Management of requests to KOBALANN to exercise rights: receipt of requests, analysis, processing, archiving, deletion.	Data related to requests to exercise rights notified by the Data Subject to KOBALANN	Compliance with a legal obligation to which KOBALANN is subject

For further information on this subject, the Data Subject may contact KOBALANN in accordance with the procedures set out in Article 8.

6. How KOBALANN determines the length of time it keeps personal data

KOBALANN keeps personal data in an identifiable form for as long as is necessary for the purposes for which it was originally collected.

KOBALANN then deletes or archives the data, unless the Data Subject exercises his/her right to delete his/her personal data or if a longer retention period is expressly authorized or imposed by a legal or regulatory provision.

The criteria used by KOBALANN to determine retention periods are as follows:

(i) the duration of KOBALANN's contractual relationship with the Data Subject;

(ii) the period during which KOBALANN is likely to perform a contract in relation to the pursuit of the purposes described above;

(iii) the fulfilment of a legitimate interest pursued by KOBALANN ;

(iv) the existence of a legal or regulatory obligation to which KOBALANN is subject.

For further information on this subject, the Data Subject may contact KOBALANN in accordance with the procedures set out in Article 8.

7. Recipients of personal data processed by KOBALANN

Access to and processing of personal data collected by KOBALANN is strictly limited. Nevertheless, KOBALANN may transfer personal data to third-party recipients, including :

(i) KOBALANN teams responsible for processing operations identified as part of their duties and subject to a specific confidentiality obligation.

(ii) External service providers that KOBALANN may call upon to perform services in connection with the processing operations identified above, such as the following: technical service providers, commercial service providers, hosting service provider, secure payment service provider (Crédit Agricole), IT maintenance service provider, IT developer, logistics service provider (La Poste).

(iii) To any category of third parties, if such transfer is required by law or regulation, a court order or in order to respond to a claim and ensure the security of personal data.

In connection with the purposes described above, when acting in a personal data subcontracting relationship, KOBALANN is bound by a subcontracting agreement in accordance with Article 28 of the RGPD Regulation.

In the event of transfer outside the European Union, KOBALANN undertakes to ensure a sufficient level of security and protection of personal data and to take all appropriate and adequate guarantees in application of the applicable Regulations.

8. Exercise of rights to personal data processed by KOBALANN

In accordance with the applicable regulations, the persons concerned by the above-mentioned processing of personal data have the following rights with regard to their personal data:

(i) Right of access to know exactly what data is processed by KOBALANN and/or the external third-party service providers that KOBALANN may use;
(ii) Right of erasure if the Data Subject wishes KOBALANN and/or its external third-party service providers to cease processing all or part of his/her personal data;
(iii) Right of rectification in order to modify any personal data that proves to be out-of-date or incorrect;
(iv) Right of portability if the Data Subject wishes to recover his/her personal data or have a third party recover it in his/her name and on his/her behalf;
(v) Right of opposition if the Data Subject wishes his/her personal data to no longer be processed by KOBALANN and/or any external third-party service providers that KOBALANN may use;
(vi) the right of restriction, if the Data Subject wishes to suspend the processing of his/her personal data;
(vii) Right to define whether the Data Subject intends to give instructions on the fate of his/her personal data after his/her death.

Any Data Subject may exercise his or her right directly with KOBALANN, which, if necessary, will forward the request to its external third-party service providers.

Any Person concerned has, at any time, and without having to justify any reason, a right to oppose the processing of his/her personal data for commercial prospecting purposes and a right to withdraw any consent he/she may have given to KOBALANN and/or to external third-party service providers used by KOBALANN.

In the event of KOBALANN collecting telephone contact details, in application of article L. 223-2 of the French Consumer Code, any Person concerned is informed that he or she has the option of registering on the Bloctel telephone anti-solicitation list.

Any Person concerned may exercise his or her rights by contacting KOBALANN by post or by e-mail at the following address: privacy@vincentmunier.com

Any Person concerned may also lodge a complaint directly with the CNIL (Commission Nationale de l'Informatique et des Libertés) online from its website or by post at the following address: 3 Place Fontenoy - TSA 80715, 75334 Paris Cedex 07.

9. Cookie management

When browsing the website, cookies may be deposited and read by KOBALANN on the user's terminal.

Cookies are files saved on a data storage medium which store specific parameters for an exchange of information with the KOBALANN system via a browser.

By saving these parameters, we can design the website to suit the user and make it easier to use.

KOBALANN uses the following cookies in order to operate its website, optimize user navigation and improve the user's experience on the website: technical and functional session cookies, which are required to activate basic site functions (such as providing a secure connection or adjusting consent preferences), statistical cookies, marketing cookies.

Cookie category	Placed cookies
Functional cookies	WooCommerce, Stripe, Uncode, WordPress, Matomo, Complianz, Vimeo, SoundCloud, PHP, Google reCAPTCHA
Statistical cookies	Google Analytics, Automatic, Matomo, Vimeo, JetPack
Marketing/tracking cookies	Google reCAPTCHA

 

Cookies are stored for a maximum of 13 months from the time they are first deposited.

KOBALNN collects the consent of users for the deposit of cookies. If the user does not accept the deposit of cookies, this will not affect his/her visit to the website.

KOBALANN informs the user that this cookie policy may be subject to change, in particular as a result of changes in applicable legal or regulatory provisions.

For more information on this subject, please consult the Cookie management policy.