Our privacy policy at a glance

1. Who are we?

We are SPINALI DESIGN, SAS and we process your personal data as data controllers. This means that we are responsible for the processing and protection of your personal data.

2. What do we use your personal data for?

Permitted for other purposes, we will use your data (obtained online or physically) to manage your registration as a user, to manage the purchase of products or services, to answer your questions and to send you personalized communications, if you wish.

3. What is the basis for the processing of your personal data?

We are competent to process your data for various purposes. The most important is that they are necessary to execute the contract you entered into with us when you registered and made a purchase or when you take advantage of one of our services or features, although there are other reasons that authorize us to do so, such as the interest in answering your questions or the consent given to send you our newsletters, among others.

4. With whom do we share your data?

We share your data with service providers who help us or provide necessary support.

5. Your rights:

You have the right to access, correct and delete your personal data. In some cases, you also have other rights, for example the right to object to the processing of your data or the right to portability, which will be described in more detail below.

For more information, you will find our privacy policy detailed below. We invite you to read our Privacy and Cookie Policy in its entirety to fully understand how we will use your personal data and what rights you have with respect to your personal data.

Introduction:

• In this Privacy and Cookie Policy, you will find all relevant information applied to our use of our customers' and users' personal data, regardless of the channel or means (online or physical) of SPINALI DESIGN that you use to interact with us.

• We are transparent about what we do with your data, to enable you to understand the implications of the processing carried out or the rights you have over your data:

All information is made available to you, permanently, in this Privacy and Cookie Policy, which you can consult at your discretion and, in addition,

Information regarding each processing of your personal data will also be provided to you as you interact with us.

• Regarding some of the terms we will use in this Privacy and Cookie Policy: When we refer to our "Platform", we mean our website: www.spinali-design.com.

1. Who is responsible for the processing of your personal data?

The persons responsible for the processing of your personal data are:

SPINALI DESIGN, SAS, the company that currently sells SPINALI DESIGN brand products:

• Postal address: 21 rue de Thann, 68200 Mulhouse, France.

• E-mail address of the Data Protection Officer: contact@spinali-design.fr.

2. What do we use your personal data for?

We will process some of your data according to the products, services or features you want at any given time. In general, this will be as follows:

• your identification data (for example, your first name, last name, language and country from which you interact with us, contact data, etc.) ;

• connection, geolocation and navigation data (if you interact with us from your cell phone, for example).

When we ask you to enter your personal data to enable your access to one of the Platform's features or services, please remember that certain boxes will be marked as mandatory, since this is data that we need to provide the service in question or to enable you to access that feature. Thus, if you decide not to provide us with this data, it is possible that your registration as a user may not be successfully completed or that you will not be able to take advantage of these services or features.

In specific cases, a third party may have provided us with information about you by using features or services on the Platform, for example, by sending an order to your address. In such cases, we process your data only when it is relevant to that function or service.

Depending on how you interact with our Platform, your personal data will be processed for the following purposes:

Purpose To know more about it
1. To manage your registration as a user of the Platform If you decide to register as a user of our Platform, we will need to process your data to identify you as a user of our Platform and to enable you to access the different types of features, products and services that are available to you as a registered user by contacting us via Customer Service.
2. For the implementation, application and execution of the purchase or service contract concluded with us in the Platform This purpose includes the processing of your data, in particular for:

• To contact you regarding updates or communications of information regarding the features, products or services entered into, including the possible sending of quality surveys on the products or services provided.

• Activate the mechanisms necessary to prevent and detect unauthorized uses of the Platform (for example, during the purchase and return processes and in the event of potential fraud committed against you and/or us). If we believe the transaction may be fraudulent or we detect unusual behavior that signals an attempt to fraudulently use our features, products or services, this processing may result in consequences such as blocking the transaction or deleting your user account.

• Manage possible exchanges or returns after purchase and manage requests for information on the availability of items, the reservation of products through the Platform, depending on the availability of these options at each moment.

• For billing purposes and to make available tickets and invoices for purchases made on the Platform.

3. To respond to requests or queries made through Customer Service channels We only process personal data that is strictly necessary to manage or resolve your query or request.

If you contact us by telephone, the call may be recorded for quality control purposes so that we can respond to your request.

4. Ergonomics and quality analysis for the improvement of our services If you access our Platform, you are informed that we will process your browsing data for analysis and statistical purposes, i.e. to understand how users interact with our Platform and with the actions implemented on other sites and applications, so that we can improve our services. Please read our Cookie Policy for more information.

Similarly, we sometimes carry out quality actions and surveys designed to find out the degree of satisfaction of our customers and users and to detect areas in which we can improve our performance.

3. What is the basis for the processing of your personal data?

The legal basis that allows us to process your personal data depends on the purpose for which they are processed, as explained in the following table:

Purpose Foundation
1. Manage your registration as a user of the Platform The processing of your data is necessary for the execution of the conditions governing the use of the Platform. In other words, the processing of your personal data is necessary to register you as a user of the Platform.
2. Implementation, application and execution of the purchase or service contract The processing of your personal data is necessary for the execution of the purchase or service contract through which we are bound.

The activation of certain data processing associated with the purchase process takes place only if you request it or if you authorize it, in these cases the legal basis on which we process your personal data is your own consent.

We consider that we have a legitimate interest in carrying out the necessary checks to detect and prevent possible fraud or fraudulent use of the Platform, for example, when you make a purchase or a return. We believe that the processing of such data is beneficial to all parties involved: to you, because it allows us to put in place measures to protect you against fraud attempts by third parties; to us, because it allows us to prevent unauthorized uses of the Platform; to all our customers and society in general, because it also protects their interests by ensuring that fraudulent activities are discouraged and detected when they occur.

3. Customer Service We consider that we have a legitimate interest in responding to the requests or queries you make to us through the various existing means of contact. We consider that the processing of this data is also in your interest as long as it allows us to properly manage your requests and respond to the requests made.

When you contact us, in particular for the management of incidents concerning your order or the product/service purchased on the Platform, the processing is necessary for the execution of the purchase contract.

When your request concerns the exercise of the rights on which we inform you below, or complaints about our products or services, we are legally authorized to process your data on the basis of compliance with the legal obligations that bind us.

4. Ergonomics and Quality Analysis We consider that we have a legitimate interest in analyzing the ergonomics of the Platform and the degree of user satisfaction since we believe that the processing of this data is also in your interest since its purpose is to improve the user experience and offer a better quality service.
4. How long will your data be kept?

The length of time your data is kept depends on the purposes for which it is processed, as explained below:

Purpose Shelf life
1. Manage your registration as a user of the Platform Your data will be processed as long as you remain a registered user (i.e. until you decide to delete your user account).
2. The implementation, application and execution of the purchase or service contract We will process your data for the time necessary to process your purchase of the products or services you have purchased, including any returns, complaints or claims associated with the purchase of the particular product or service.
3. Customer Service We will process your data for the time necessary to respond to your query or request.
4. Ergonomics and Quality Analysis We will occasionally process your data for the duration of carrying out a particular action or quality survey or until your navigation data is pseudonymized.

Regardless of the processing of your personal data for the time strictly necessary to fulfill the corresponding purpose as indicated above, your personal data will then be kept, properly safeguarded and protected with restricted access for the time during which liability may be incurred as a result of the processing, in compliance with the regulations in force at each moment. The personal data will be deleted once the possible actions in each case have been prescribed.

5. Will your data be shared with third parties?

In order to fulfill the purposes indicated in this Privacy and Cookie Policy, access to your personal data may allow third parties that we use to provide you with certain services, i.e. :

• financial institutions,

• fraud detection and prevention entities,

• technology and analytical service providers,

• Suppliers and partners of services related to logistics, transport and delivery and/or their partner establishments.

6. What are your rights when you provide us with your data?

We undertake to respect the confidentiality of your personal data and to guarantee the exercise of your rights. These can be exercised by sending us an e-mail to the address: contact@spinali-design.fr simply indicating the reason for your request and the right you wish to exercise. If we consider it necessary to be able to identify you, we may ask you for a copy of an identity document.

Regardless of the purpose or legal basis under which we will process your data, you are particularly entitled to:

• Request access to the data we have about you.

• Ask us to rectify any data we already have in our possession. However, please remember that by actively providing us with your personal data by any means, you ensure that it is true and accurate and that you undertake to inform us of any changes or modifications to it. Any damage or loss caused to the Platform or to the person in charge of the Platform or to any other third party due to the communication of erroneous, inaccurate or incomplete information in the registration forms is the exclusive responsibility of the user. Please bear in mind that as a general rule you should only provide your own personal data and not those of third parties, except as permitted in this Privacy and Cookie Policy.

• Please ask us to delete your data to the extent that they are no longer necessary for the purpose for which we may have needed to process them, as already stated above, or for which we are no longer competent to do so.

• To provide instructions regarding the storage, deletion or disclosure of your personal data after your death.

If you have given your consent to the processing of your data for any purpose, you also have the right to withdraw it at any time.

We would like to inform you of your right to lodge a complaint with the corresponding data protection supervisory authority: https://edpb.europa.eu/about-edpb/board/members_en.

7. What happens if you provide us with data from third parties or if a third party provides us with your data?

We offer features or services that require the processing of personal data from a third party that you, as a user or customer, must provide to us, including when you authorize a third party to withdraw an order intended for you. If you provide us with personal data relating to third parties or if it is necessary for us to request them so that a third party can withdraw an order on your behalf, you assure us that they have been informed of the purposes and the way in which we need to process their personal data.

If a third party has provided us with your data or you have provided it yourself in connection with a feature or service requested by one of our users, we will use it to administer the feature or service in question in each case, within the limits of the purposes set out in this Privacy and Cookie Policy.

8. Changes to the Privacy and Cookies Policy

The information contained in this Privacy and Cookie Policy may be changed as we deem appropriate. If so, this will be notified to you through several channels through the Platform, or even communicated to your e-mail address if the change in question is particularly important for your privacy, so that you can review the changes, evaluate them and, if necessary, oppose or withdraw from a service or feature. In any event, we suggest that you review this Privacy and Cookie Policy from time to time to take notice of minor changes or the introduction of interactive enhancements, taking advantage of the fact that it will always be a permanent repository of information on our site.

9. Cookie Information

We use cookies and similar devices, subject to your consent, to make it easier for you to navigate the Platform, to find out how you interact with us. Please read our Cookie Policy to learn more about the cookies and similar devices we use, their purpose and other information.

Cookie Policy

Introduction

You will find information about our use of cookies in this cookie policy. The use of cookies can sometimes be related to the processing of personal data of our customers and users, on how to enforce your rights or on the terminology we use to refer to our platform.

Information on cookies

1. What is a cookie?

A cookie is a small text file that a website, amplifier or other platform inserts into your computer, tablet, smartphone or other similar device containing information about your browsing or usage, such as a tag that identifies your device. Cookies are necessary, for example, to facilitate navigation and to learn how users interact with platforms in order to improve them. Cookies do not damage your computer or device.

2. What types of cookies do we use?

a. Strictly necessary (technical) cookies: these are those that allow the user to navigate a website, platform and to use the different options or services offered: traffic control, identification of data or for connection, access to restricted sections or content, memorization of the elements that make up an order, execution of the process of purchasing an order, control of fraud related to the security of the service, use of security elements during navigation, request for registration or participation in an event, storage of content for video or sound broadcasting, implementation of dynamic content or sharing of content through social networks. Technical cookies, being strictly necessary, are downloaded by default when they allow to display the platform or to provide a service requested by the user.

b. Functionality or personalization cookies: These cookies are those that allow the storage of information so that the user can access the service or platform with certain characteristics that may differentiate his experience from that of other users, such as, for example, language, the number of results to be refined when the user performs a search, the appearance or content of the service according to the type of browser of the user or the region from which he accesses the service, etc..

c. Analysis cookies: These are used to determine the number of users, the sections visited in the platform and the way they interact with it, in order to measure and statistically analyze how users use the platform or service, and to introduce improvements based on the analysis of the data of this use.

3. Why do we use cookies on our platform?

Cookies are an essential part of the operation of our platform. The main purpose of our cookies is to make your browsing experience as pleasant and efficient as possible. They are, for example, used to remember your preferences (language, country) during navigation and during your future visits. We also use our cookies to constantly improve our services and our platform.

The information collected in the cookies also allows us to improve our platform through estimates of statistical data and usage patterns (number of visits, most-visited sections, length of visit, etc.), to find out through statistical indicators how users interact with the platform in order to improve our services, as well as to adapt the platform to your individual interests, speed up searches, etc.

In any case, the cookies we use never store sensitive information such as passwords, credit or debit card data, etc.

4. Who uses the information stored in cookies?

We only use the information stored in the cookies on our platform.

For more information on the processing of your personal data in the context of our collaboration with third parties, we recommend that you read our Privacy Policy available on our platform.