PRIVACY POLICY

The company Apnée Swimwear, whose head office is located at 8 rue Dautancourt 75017 Paris (hereinafter “Apnée” or “we”), in its capacity as data controller within the meaning of the regulations in force regarding data protection of a personal nature, attaches great importance to the protection and respect of your private life.

This confidentiality policy (as well as our General Conditions of Use and any document referred to therein) aims to inform you, in accordance with Regulation No. 2016-679 of April 27, 2016 relating to the protection of natural persons with regard to the processing of personal data and the free movement of this data (hereinafter the “GDPR”), our practices concerning the collection, use and sharing of the information that you are required to provide to us by through our website https://apneeswimwear.com/ (hereinafter “the Site”).

This document aims to inform you about the categories of personal data that we may collect or hold about you, how we use it, who we share it with, how we protect it, and the rights you have over your personal data.

This confidentiality policy applies to all services published by Apnée that you use in particular via the Site (excluding services provided and operated by third parties, in which case, it is the confidentiality policy of these third parties which applies and not these provisions).

1. The data we collect

By using the Site, you are required to send us information, some of which is likely to identify you and therefore constitutes personal data (hereinafter the “Data”). This is particularly the case when you register on the Site, during your first connection.

This information contains in particular the following Data:

• Data relating to registration : refers to the Basic Data necessary for your registration on the Site, in particular to be able to place an order for our products. These Data are transmitted directly by you, by completing the form dedicated to this purpose. These Data are as follows:
  
  - Your last name ;
  - Your first name ;
  - Your email ;
  - A personal and confidential password.
  
  
• Data necessary to fulfill your order : means the information we need to fulfill your order and deliver our products to you. These Data are as follows:
  
  - Address and postal code;
  - Company name (optional);
  - City ;
  - Country ;
  - Telephone number.

• Transaction data : refers to the data you provide when you make purchases through our Site, such as information relating to your payment method. The banking data collected is transmitted to partner payment service providers who help process your transactions securely and satisfy your requests.

 

• Browsing data : refers to the data that we collect during your browsing on the Site, such as the date, time of connection and/or browsing, the type of browser you use, the browser language, your IP address.

 

In the event that you connect to our services using the social network features made available to you, we will have access to certain of the Data of your account on said social network in accordance with the general conditions of use of the social network concerned. We may also collect some of your Data when you interact with features of these social networks, such as “Like” features.

When collecting Data, you will be informed if certain Data must be provided or if they are optional.

2. How do we use the data we collect?

We use the aforementioned Data for the purposes listed below, and according to the following legal bases:

Purposes	Legal basis
Create and manage your account on the Site	Execution of a contract
Manage the commercial relationship (invoicing, delivery, after-sales service, product returns, etc.)	Execution of a contract
Send you our newsletters as well as marketing or advertising messages or content.	Consent
Improve and optimize our services and allow us to better understand our users and how our services are used	Legitimate interest of Apnée
Manage our Site and carry out internal technical operations as part of the resolution of malfunctions, data analysis, tests, research, analyses, studies, surveys	Legitimate interest of Apnée

When the processing of your Data is based on consent, please note that you can withdraw it at any time.

Apnée may also process your Data in response to a legal or judicial request (court order or otherwise) or to comply with its legal, regulatory, judicial or administrative obligations.

Apnée may finally process your Data to detect or prevent fraudulent activities or breaches of the security of our services, in application and in compliance with legal and regulatory provisions, or even analyze reports from users who have engaged in behavior that contravenes our Terms of Service.

3. Who are the recipients of the data we collect and why do we transmit this data to them?

3.1 Data transferred to authorities and/or public bodies

In accordance with current regulations, your Data may be transmitted to the competent authorities upon request and in particular to public bodies, court officers, ministerial officers, bodies responsible for debt recovery, exclusively to meet legal obligations. , as well as in the case of searching for perpetrators of offenses committed on the internet.

3.2 Data transferred to third parties

We work closely with third party companies who may have access to your Data, and in particular with:

• Our technical service providers (subcontractors) whom we use for the purposes of operating and improving our services, in particular concerning the hosting of Data, studies, analyzes and statistics, the use of our Site and/or the proper functioning of the Site and provide the necessary assistance to its users.

We only provide these third parties with the Data they need to perform their services, and we require that they not use your Data for any other purpose.

These third parties only act in accordance with our instructions and are contractually required to ensure a level of security and confidentiality of your Data identical to that which we guarantee to you, in accordance with the GDPR.

4. How long do we keep your data?

Your Data will not be kept beyond the period strictly necessary for the purposes pursued as set out in this Privacy Policy, in accordance with the GDPR.

In this regard, your Data is kept:

• For the entire duration of your registration on our Site;
  
  
• In any event, for a period of 3 years from the suspension/termination of your account;
  
  
• For the legal duration of 13 months for cookies and other tracking technologies that we use to optimize the use of our Site.
  
  

Your Data is deleted when the retention periods expire. However, your Data may be archived beyond the periods provided for above for the defense of our interests in court and for the purposes of research, detection and prosecution of criminal offenses with the sole aim of allowing, as where necessary, making your Data available to the judicial authority.

Archiving implies that your Data will no longer be viewable online but will be extracted and stored on an independent and secure medium.

5. Is your data transferred, how and where?

In principle, your Data is hosted securely within the European Union and is not subject to transfer outside the territory of the European Union.

However, in the event that we are required to transfer them (for example to technical service providers) outside the European Union, we will always do so securely and in accordance with the regulations in force:

• Either by transferring the Data to a recipient located in a country that has been the subject of an adequacy decision by the European Commission certifying that it has an adequate level of protection;
  
  
• Either by executing or having executed the European Standard Contractual Clauses which have been approved by the European Commission as ensuring an adequate level of protection of your Data;
  
  
• Either through the use of Binding Internal Corporate Rules validated by the competent data protection authorities;
  
  
• Or by using all appropriate guarantees referred to in Article 46 of the GDPR.
  
  

6. How is your data protected?

We take appropriate technical and organizational measures to prevent unauthorized access or modification, disclosure, loss or destruction of your Data. It is important that you maintain the confidentiality of your identifiers in order to prevent unlawful use of your account, in accordance with our General Conditions of Use .

7. What are your rights over your data

In accordance with the laws and regulations applicable to the protection of personal data, you benefit from a certain number of rights relating to your Data, namely:

• A right of access and information : you have the right to be informed in a concise, transparent, intelligible and easily accessible manner of the way in which your Data is processed. You also have the right to obtain (i) confirmation that Data concerning you is being processed and, where applicable (ii) to access this Data and obtain a copy.

• A right of rectification : you have the right to obtain the rectification of inaccurate Data concerning you. You also have the right to complete incomplete Data concerning you, by providing a supplementary declaration. If you exercise this right, we undertake to communicate any rectification to all recipients of your Data.

• A right to erasure : in certain cases, you have the right to obtain the erasure of your Data. However, this is not an absolute right and we may for legal or legitimate reasons retain this Data.

• A right to restriction of processing : in certain cases, you have the right to obtain limitation of the processing of your Data.

• A right to Data portability : you have the right to receive your Data that you have provided to us, in a structured, commonly used and machine-readable format, for your personal use or to transmit it to a third party of your choice. This right only applies when the processing of your Data is based on your consent, on a contract or when this processing is carried out by automated means.

• A right to object to processing : you have the right to object at any time to the processing of your Data for processing based on our legitimate interest, and for commercial prospecting purposes. This is not an absolute right and we may for legal or legitimate reasons refuse your request to object.

• The right to withdraw your consent at any time : you can withdraw your consent to the processing of your Data when the processing is based on your consent. Withdrawal of consent does not compromise the lawfulness of processing based on consent given before such withdrawal.

• The right to file a complaint with the CNIL : you have the right to contact the CNIL to complain about our personal data protection practices, if applicable.

• The right to give instructions regarding the fate of your data after your death : you have the right to give us instructions regarding the use of your Data after your death.

To exercise these rights, you can contact us at the following address: contact@apneeswimwear.com.

Please note that we may require proof of your identity to exercise these rights.

8. Changes to our Privacy Policy

We may occasionally modify this policy, in particular in order to comply with any regulatory, jurisprudential, editorial or technical developments. If applicable, we will change the "last updated" date and indicate the date the changes were made. When necessary, we will inform you and/or seek your consent. We advise you to regularly consult this page for any changes or updates to our policy.

9. Contact

For any questions relating to this policy or for any request relating to your Data, you can contact us by:

• Sending an email to the following address: contact@apneeswimwear.com
  
  
• Sending a letter to the following address: Apnée Swimwear 8 rue Dautancourt 75017 Paris

Version updated on June 26, 2020