DEFINITIONS
Capitalized terms have the following definitions:
“Company” or “we” or “us” refers to HF PERSPECTIVE whose registered office is located at 10 Rue de Penthièvre 75008 Paris, registered with the Trade and Companies Register under number 84981010600021 whose intra-community VAT number is FR88849810106.
“Site” refers to the web page(s) accessible from the link https://my-skull-jewelry.com/ and any sub-site allowing access to a content consultation space, a space reserved for customers, etc., which are provided by the Company.
“You” refers to the persons concerned by the Processing carried out on the Site (users, prospects, customers, etc.).
“Policy” refers to this privacy policy.
“Data” means any information about an identified or identifiable natural person (“data subject”) directly or indirectly, in particular by reference to an identifier (name, identification number, location data, online identifier, etc.) or to one or more specific elements of his or her identity.
A “Processing” corresponds to any operation applied to the Data (collection, recording, organization, storage, storage, adaptation, communication by transmission, dissemination, erasure, etc.).
A “controller” is the one who, alone or jointly with others, determines the purposes and means of the processing, and a “processor” is the one who processes the data on behalf of the controller. On the Site, unless otherwise stated, we are the Data Controller.
A “Recipient” is the natural or legal person, public authority, department or other body that receives personal data, whether or not it is a third party.
“Regulation” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”); Law No. 78-17 of 6 January 1978 on data processing, files and freedoms; the rules applicable to commercial canvassing7 provided for in the French Post and Telecommunications Code; and, more generally, the laws and regulations applicable to the Data Processing that we carry out.
SHOWCASE AND COMMERCIAL PROSPECTING
The Site presents our company’s activities and various forms (contact, newsletter subscription, etc.). By completing the forms and communicating with us through the Site, you transmit to us the following categories of information:
Identity data: job title/gender; last name; first name; and, optionally, we may ask for your date of birth in order to propose birthday offers;
Contact and correspondence data: e-mail address; postal address (address, zip code, town); telephone number; in case of customer service request, the nature of your request and the content of your request.
Data on opinions and contributions: pseudonym, date of the opinion, content of the opinion, product or service in question, if applicable, profile picture attached to the opinion; The Company may enrich its Site by collecting and republishing opinions and contributions issued in relation to its offers by its customers on other sites (in particular social networks) when these contributions are freely accessible to the public;
Data necessary to carry out loyalty building activities, prospecting, research, surveys, product testing and promotion;
Data relating to the organization and processing of contests, lotteries and any promotional operations;
Data collected through the exercise of the rights enshrined in the Regulation.
In accordance with our legitimate interest, and provided it is necessary for the execution of pre-contractual measures taken at your request or a contract, we carry out the processing of the above-mentioned data for the following purposes
Presentation of the company’s products and services;
Management, processing and follow-up of requests and exchanges with the Company, through the Site (where appropriate, by offering you a chatbot, a call booking tool, etc.);
Management of the relationship with prospects;
Management of people’s opinions about the Company’s products, services or content;
Collection and/or sending of information, management of the technical operations of collection, selection of people to carry out loyalty actions, prospecting, surveys, product testing;
Organization of contests, lotteries or any promotional operation on the Site.
The data used for the management of commercial prospecting are kept for a maximum of three years from the last active contact of the prospect or customer, and earlier in the event of withdrawal of their consent to receive messages from us. Data from advertisements and contributions are kept for the duration of public access to the advertisement on the Site.
In accordance with our legal obligations, identity and contact data will also be processed for the following purposes
Updating of your canvassing files by the body in charge of managing the list of objections to telephone canvassing, in application of the provisions of the Consumer Code.
Management of requests for rights of access, rectification and opposition, and more generally of the rights described in the Policy.
ONLINE SALES
The Site allows you to make purchases, which leads us to process the following data:
Identity and contact data.
Data relating to the contractual and commercial relationship: Details of the content of the order; Pre-contractual and order-related exchanges (purpose, date…); Communications with the Company.
Payment and transaction data: date of the transaction, amount, means of payment, order number, invoicing data;
This information is necessary for the management of our lead file, and more specifically for the following purposes in accordance with our GTC accepted at the time of the order on the Site and with our legal obligations:
To carry out operations relating to the management of files concerning: contracts, including registrations; orders; delivery of the product or service; legal and commercial guarantees; invoices; accounting and follow-up of the commercial relationship (after-sales service), including for opinions on the Company’s offers;
Prevention and fight against fraud and means of payment and, in particular, against bank card fraud;
Management of unpaid invoices and disputes, provided that they do not involve infringements and/or do not involve the exclusion of the person from the benefit of a right, a service or a contract.
Secure payment. All transactions made on our Site are secure. Credit card payments are handled by our payment service providers (“PSP”), as indicated in our terms and conditions or on the order page of our products and services. We have an SSL encryption system to protect your personal data and the payment methods used. At no time do we have direct access to your bank details through this process.
Retention periods. The personal data we process is retained for the periods indicated in the table below.
Data concerned
Retention period
Data processed for commercial prospecting purposes
3 years from the last active behavior of the potential customer or from the collection of the data.
Data necessary to process your order and manage contractual and commercial relations
3 years from the last active behavior of the customer or, failing that, from the end of the contractual relationship. For accounting documents (orders, delivery notes, customer invoices): 10 years from the end of the fiscal year.
Order contracts for an amount of less than 120.00 euros.
5 years from the conclusion of the contract.
Purchase contracts for an amount greater than 120,00 euros
10 years from the date of delivery or service.
Bank details: in case of single payment
13 months for immediate debit cards and 15 months for deferred debit cards from the date of debit (for the purpose of responding to any dispute).
Bank details: in case of tacit renewal of the subscription
13 months for immediate debit cards and 15 months for deferred debit cards, starting from the debit date of the last payment due at the end of the subscription (for the purpose of responding to any dispute).
CREATE AN ACCOUNT
Creating an account is optional to place an order on the Site.
On the Site, you can create an account and, in this case, the following information will be processed:
Identity and contact details
Account connection data: user name, password; which may be automatically recorded on the Site if you consent to it through your browser settings;
Account access and usage data: IP address, connection time, connection duration, account settings, use of any account functions.
The processing will be carried out in order to manage authentication procedures, procedures for loss of identifiers or passwords and in order to execute the order in accordance with the purposes established for the online sale.
The identity and contact information provided during account creation will be used with your consent to inform you about the Company’s products and services.
The Company may provide tools to create a profile by adding optional information to your account (identity, social networks, age, profile picture, profession…).
DELIVERY OF PHYSICAL PRODUCTS
To deliver products ordered on the Site, we will ask for your postal delivery address, if different from the billing address. If the delivery of a good is to a third party, you confirm that you are authorized to transmit your identity and delivery data. These data will be transmitted to the carrier in charge of the delivery.
Other data necessary for the delivery will be processed in accordance with our GTC and our legitimate interest (delivery method, package size, delivery tracking information, delivery date, delivery note, signature on the delivery note…).
The carrier in charge of the delivery applies its own privacy policy on the Data transmitted to it as part of the order or that it may collect during delivery.
SOCIAL NETWORKS AND THIRD PARTY SITES
Exchanges on social networks. We may contact you or respond to your inquiries through social networks, if you have contacted us in the first instance through this medium. You are informed that the use of social networks involves the processing of personal data by the providers of such networks (see their privacy policy).
Information to the public. The information about you that you have provided to us may be enhanced for commercial, prospecting, communication, solicitation or marketing purposes by means of other sources of information such as social networks. This includes so-called “public” information or information that we may have access to as an administrator of a page or group. The legal basis for this processing is our legitimate interest as a commercial enterprise.
Interconnection. In the event that your member area may connect to another service (e.g., a social network) for cross-publishing purposes, then the third-party service may share with us the information that you have authorized it to share. Please be advised that third party service providers may also collect information about your visit and/or use of the Site in accordance with their own personal data processing policies. More information about registering on the Site from a third party account, for :
Facebook: https://www.facebook.com/help/223184117694507 ; https://developers.facebook.com/docs/facebook-login/overview
Google: https://support.google.com/accounts/answer/112802?co=GENIE.Platform%3DDesktop&hl=fr
EXERCISING YOUR RIGHTS
For any request to exercise the above rights or for further information, you can contact the Company at: By mail at the address of the registered office of the Company indicated at the top of this page.
In accordance with the Regulation, you have the following rights with respect to your data:
Right of access to your data, including the right to request a copy, and to the information provided in this Privacy Policy (art. 15 GDPR). Where the lawful basis for processing the data is our legitimate interest, you have the opportunity to request information about the balancing we have performed between the interests of our customers and those of the company prior to such processing.
Right to rectification (art. 16 of the GDPR) and updating of your data held by us.
Right to erasure of your Data (art. 17 GDPR) when the data is no longer needed by us, you have withdrawn your consent to its Processing (if it was based on our consent) or you object to the Processing based on our legitimate interest or to the Processing carried out for prospecting purposes or for profiling related to prospecting.
Right to withdraw your consent at any time (art. 13-2c of the GDPR) for any data processing based on the lawful basis of your consent. In addition, with regard to commercial canvassing, you have the possibility to unsubscribe from our mailing lists at any time by clicking on the unsubscribe link in our communications or by contacting us to stop receiving solicitation messages.
Right to limitation of Processing, which, except for compelling reasons, can only be applied with your consent (art.18 RGPD) when:
You dispute the accuracy of the data, for the time necessary to verify them,
If the data processing is unlawful but you object to the deletion of the data and choose to limit the processing,
If we no longer need the data but it is still necessary for the establishment, exercise or defense of your legal rights.
When you have objected to the processing based on our legitimate interest, for the time necessary to balance our respective interests.
Right to portability of data provided directly by the data subject when they are subject to automated processing based on your consent or on a contract (art. 20 of the GDPR). This right means that you have the possibility to request the communication of this data in a structured, commonly used and machine-readable format so that it can be communicated to another data controller.
Right to object (art. 21 of the GDPR) to the processing of your data when such processing is lawfully based on our legitimate interest.
The right to define the destination of your data after your death (art. 40-1 of the law 78-17 of January 6, 1978) and to choose a trusted third party to whom the Company should entrust it.
More information is also available on the CNIL website.
In case of request, the Company reserves the right to ask you to specify your request and to provide proof of identity (which will be kept for one year in case of exercise of the right of access or rectification and three years in case of exercise of the right of opposition). If you are not entirely satisfied with our response, you always have the possibility of lodging a complaint with the authority responsible for the control and protection of personal data (in France, the CNIL).
RETENTION PERIODS
Commitments. The means of effective data deletion are put in place as soon as the retention or archiving period necessary for the achievement of the purposes determined or imposed is reached, in particular after the deletion of your account with our company or at the end of the contract with our company.
Minimization. In any case, the Data subject to Processing will not be kept beyond the time necessary for the fulfillment of the obligations defined at the time of the conclusion of the contract, or imposed by the legislation in force. Beyond that time, it may be anonymized and kept for statistical purposes, in particular in aggregate form.
Litigation. Similarly, we may store information proving the performance of our contractual obligations until the expiration of the statute of limitations/disclosure periods applicable to legal proceedings, in order to defend our interests in court in the event of subsequent litigation. This applies in particular, but not exclusively, to the time limits provided for in the Commercial Code, the Civil Code and the Consumer Code.
DESTINATION
Undertakings. We undertake that any recipient of data will provide sufficient and appropriate contractual safeguards to respect your rights, so that the processing complies with the requirements of the GDPR when this regulation applies (in particular with regard to outsourcing). On the basis of our legal obligations, your data may be disclosed pursuant to a law, regulation or decision of a competent regulatory or judicial authority.
The information you provide is for internal use by authorized persons, is strictly confidential and may not be disclosed to third parties, except as provided for in the Regulation in case of express agreement or if you have decided to make it public.
Outsourcing. Our external service providers (e.g. suppliers, carriers, etc.) may, in the context of the processing described above, receive personal data when necessary for the performance of their mission.
Transfer outside the EU. We are committed to ensuring compliance with applicable regulations regarding the transfer of data to countries outside the European Union, in particular in the following respects.
We will transfer the data of visitors, prospects and customers to countries recognized as offering an adequate level of protection;
Where the destination country does not have an adequate level of protection, we will use transfer tools that comply with the regulations (especially the European Commission’s standard contractual clauses).
Aggregation of non-personal data. We may publish, disclose and use aggregated information (information about site users, potential customers, clients, etc.) that we combine in such a way that no natural person is individually identifiable. This processing is carried out in accordance with our legitimate interest for statistical, industry and market analysis, trade presentation, promotional, advertising and other commercial purposes.
INFORMATION SECURITY
Commitments. We undertake to implement appropriate technical and organizational measures through physical and logistical security measures to limit the risks of accidental, unauthorized or unlawful access, disclosure, alteration, loss or destruction of your personal data.
Warning. We ask you to be careful about what you choose to make public on the Internet. This applies to personal data, including personal data relating to your private life or sensitive data made public on your initiative or inferred from your contributions, comments and statements of any kind on the Site, or on social networks in groups and/or conversations with other users of the Site.
Https protocol. The URL of the Site is accompanied by a closed padlock or key in the lower right corner of your browser indicating the existence of the Https security protocol, applicable to data storage in particular. This means that you are in a secure browsing area, especially when you are asked for your credit card number.
Data breach. In the event of an event leading to the ascertainment of the risks of modification, disappearance or unauthorized access to the Data, we undertake to :
Investigate the causes of the incident;
Take the necessary measures to limit the negative effects and damage that may result from the incident;
Notify the incident to the competent authority and/or the affected persons as soon as possible when required by law.
In no case shall the commitments set forth in the previous point be considered as an admission of fault or responsibility for the occurrence of the incident.
GENERAL
Mandatory or optional nature. On the Site, you are informed of the mandatory nature of the answers by the presence of an asterisk or any other type of mention. In the event of an incomplete request (for example: online registration or order, request for information, etc.), the Company reserves the right to request additional information or to exclude by any technical means the possibility of validating the form in question.
Hypertext links. The Site may provide links to other sites, applications and services that may be operated by third parties. We are not responsible for the processing of personal data by such third party sites, or sites linking to the Site, whose privacy policies the user should consult for more information. The Policy applies only to the activities of the Company, which is not responsible for any failure by third parties to comply with their obligations regarding the protection of personal data.
Scope of application. The Policy is not exhaustive as to its treatment and we reserve the right to supplement it by any means.
Language. The Policy is written in French. In the event that it is translated into one or more languages, only the French text shall be deemed authentic in the event of a dispute.
No waiver. The temporary or permanent inapplication of one or more of the clauses of this Policy shall not constitute a waiver of the other clauses of this Policy, which shall remain in effect.
Changes – Updates. We reserve the right to make changes to this Privacy Policy. Affected persons will be notified when required by applicable law. The date of the update is indicated in the header and we invite you to check back regularly.
INFORMATION ABOUT COOKIES
Introduction: Cookies and trackers (hereinafter referred to as “cookies”) refer to connection cookies and, more generally, to any file – deposited when consulting a website or mobile application, or when installing or using software on the user’s terminal equipment – whose purpose is to read or write information on that equipment. Cookies allow us to collect site consultation data (IP address, Internet access provider, hardware configuration, software configuration, browser type and language, etc.).
Cookies may be deposited by the Company or by third party companies without your consent when they are strictly necessary for the operation of the site or to facilitate communication with the online public, for example, when they are intended for authentication, to track the contents of a shopping cart, to generate traffic statistics or to limit free access to a sample of content requested by users.
Duration: The maximum duration of retention of cookies is 13 months from their first deposit on your terminal and this duration is not extended with each visit.
Consent to the deposit of cookies: You are informed of the presence of cookies not strictly necessary by means of an information banner on the Site. With the exception of cases of use not subject to consent, cookies and trackers will only be deposited on your terminal with your express consent. You may be asked periodically to reiterate your consent, to ensure that it remains valid.
Configuring cookies: You can always change your preferences through your browser settings (Firefox with enhanced tracking protection; Firefox with cookie deletion; Chrome; Internet Explorer; Safari; Safari; Opera; Microsoft Edge). You can also configure your terminal’s browser to activate the “Do Not Track” option, which will indicate to visited sites, advertising agencies or applications that you do not wish to be “tracked”. This function is available for the following browsers in particular: Firefox; Chrome; Internet Explorer; Safari; Opera; Microsoft Edge.
If you refuse cookies that are not essential to the operation of the Site: Some features of the Site, such as video players or interactive content, use services offered by third parties and deposit cookies that allow them to identify your consultation of the content. If you refuse to accept these cookies, the personalization functions will not work and the content offered to you (in particular, suggested videos or advertisements) will still be present, but will not be related to your interests.
Types of cookies: In addition to cookies whose sole purpose is to enable or facilitate communication through our Site or cookies strictly necessary for the provision of the Site or the Service to which you have subscribed, we use cookies and trackers for the following purposes:
Personalized advertising : Facebook/Google/Pinterest uses trackers to display personalized advertising based on your browsing and profile. These are the following third parties:
The Facebook pixel is an analytics tool that allows us to measure the effectiveness of our advertising by tracking the actions taken by internet users on the Site (https://www.facebook.com/policies/cookies/).
Non-personalized advertising and audience measurement: The company Facebook/Google/Pinterest uses/uses trackers in order to measure the audience of advertising on the Site without profiling, in order to optimize the Site based on statistics on its frequentation and the browsing of Internet users.
Terms and conditions for SMS marketing:
We use a text messaging platform, which is subject to the following terms and conditions. By subscribing to our SMS marketing and notifications, you agree to these terms and conditions.
By entering your phone number at checkout and initiating a purchase, subscribing via our subscription form or keyword, you consent to our sending you SMS notifications (for your order, including abandoned cart reminders) and SMS marketing offers. You acknowledge that consent is not a prerequisite for any purchase.
Your phone number, name and purchase information will be shared with our SMS platform “SMSBump Inc, a European Union company based in Sofia, Bulgaria, EU. This data will be used to send you targeted marketing messages and notifications. When sending SMS messages, your phone number will be transmitted to an SMS operator to ensure delivery.
If you wish to unsubscribe from receiving SMS marketing messages and notifications, please reply with a STOP to any mobile message we send you or use the unsubscribe link we have provided in any of our messages. You understand and agree that alternative methods of unsubscribing, such as the use of alternative wording or requests, will not be considered a reasonable way to unsubscribe. Message and data rates may apply.
If you have any questions, please send a text message with the word “HELP” to the number that sent you the messages. You can also contact us for more information. If you wish to unsubscribe, please follow the procedures outlined above.