Privacy Policy

The company Nuvanta de Law Irish Limited Company (LTD) registered at the Dublin business registration office under number 747679 whose head office is located 6 FERN ROAD D18 FP98 in Dublin in Ireland (hereinafter "Nuvanta") takes veryAt heart the protection of your personal data and undertakes to comply with the regulations applicable in this area, in particular the principles from the general European regulation on the protection of personal data n ° 2016-679 of April 27, 2016 entered in application on May 252018 ("GDPR").

Cette politique de confidentialité vise à vous fournir toutes les informations sur la manière dont vos données personnelles sont recueillies et traitées par NUVANTA en sa qualité de responsable de traitement à partir du site accessible à l’adresse suivante : lettre reco.com (ci-après le « Site »).

1. Definitions from the GDPR

Data recipient

The natural or legal person Public authority The service or any other organization which receives communication of personal data whether or not a third party.

Personal data

Any information relating to an identified or identifiable natural person (also called "concerned").Is deemed to be an "identifiable natural person"a natural person who can be identified directly or indirectly in particular by reference to an identifier such as a name an identification number of location data an online identifier or one or more specific elementsspecific to his physiological physiological identity genetic economic cultural or social.

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Regulation

The entire regulations in force applicable to the processing of personal data and in particular the General Data Protection Regulations (GDPR) which came into force on May 25, 2018 which introduces new concepts in relation to the law "relating to'IT to files and freedoms "of January 6, 1978 modified (called"Data Protection Act ") and modifies the obligations of the actors involved in the processing of personal data.

Treatment manager

The natural or legal person Public authority The service or another body which alone or jointly with others determines the purposes and the means of treatment.

site

This website published and operated by Nuvanta and accessible from the following URL link: lettre reco.com

Subcontractor

The natural or legal person Public authority The service or any other body which processes personal data on behalf of the controller.

Treatment

Any operation or set of operations carried out or not using automated processes and applied to personal data or sets of personal data such as collecting the Recording the organization Structuring the conservation or modificationExtraction Consultation The use of transmission communication The diffusion or any other form of provision the rapprochement or interconnection limitation erase or destruction.

2. What is the personal data collected and how do we collect it?

Through its Nuvanta site can collect and process the following personal data:

Personal data that you communicate directly to us:

The personal data that is collected are those that you communicate directly to us through the collection forms available on the site (contact for contact opening a customer account, etc.) or by email sent directly to our email address.

The personal data that you communicate directly to us are collected in the following cases:

When you want to bring information to our knowledge or request information through our contact form:

• last name First Name ;
• email address.



When you want to create a customer account

• email address ;
• password.



When you place an online order (customer data):

• email address ;
• last name First Name.



When you want to send a letter:

• Your contact details as sender:
• Status (individual/professional)
• Title (M., Mme, Miss, Dr., Me, Pr.),
• last name First Name,
• address,
• phone,
• email address.
• If necessary, your electronic signature.
• The contact details of the recipient of the mail:
• Status (individual/professional)
• Title (M., Mme, Miss, Dr., Me, Pr.),
• last name First Name,
• address,



These data are necessary to send mail.Otherwise, the service cannot be performed.




When you constitute your digital address book:

• The contact details of the recipient of the mail / customer contacts:
• Status (individual/professional)
• Title (M., Mme, Miss, Dr., Me, Pr.),
• last name First Name,
• address,



When you register for our newsletter or Nuvanta addresses you with commercial prospecting:

• email address.



And more generally when you send us an email directly:

• information transmitted by you and most likely:
• last name First Name,
• email address.

The personal data that we collect on the occasion of our commercial relationship:

These include in your capacity as a customer:

• Information relating to the history of your commercial relationship with Nuvanta (orders, invoicing and payment),
• Flawed requests or incidents reported to our customer service or our accounting service.

Personal data that we automatically collect:

When consulting the site, data (including personal data) so -called navigation is automatically saved either:

• Through cookies,
• directly by the Nuvanta computer system,
• indirectly by the computer service provider in charge of site management.

Part of this data is collected in order to guarantee a perfect provision of the site, its improvement and the maintenance of a secure environment.Other data can be used to analyze your user behavior and traffic and/or to increase the interactivity of our site.

it could be :

• Data relating to your use of the Site:

These use data may include information such as the IP address of your computer, the type of browser, the browser version, the pages of our site that you visit, the time and date of your visit, timePassed on these pages, unique identifiers of devices and other diagnostic data.

• Equipment data that allows you to access the site:

Depending on the equipment you use and the activated settings, the following data can notably be collected: the type of equipment (mobile phone, tablet, PC, Mac, etc.) and the operating system you use as well as theirsettings.

This information can be obtained either directly by means of server events (log files) or via cookies or similar tools.

3. Why are we processing your personal data?

We use your personal data to carry out the processing whose purposes and legal bases are exposed within the table below.

These personal data is collected in one of the cases provided for in the regulations, namely:

• The execution of a contract that we have concluded with you and/or
• Respect for a legal and/or
• Your consent to the use of your personal data and/or
• Our legitimate interest in using your personal data being specified that legitimate interest is a set of commercial reasons and/or reasons relating to security which justifies the use of your personal data by Nuvanta.

You will find all this information within the table below.

Consent to the use of cookies.

For the proper functioning of our website, we use cookies.In order to obtain your valid consent for the use and storage of cookies in the browser you use to access our website and to properly document this, we use a consent management platform: Cookiefirst.This technology is supplied by Digital Data Solutions BV, Middenlaan 42A, 1018 DH, Amsterdam, Netherlands.Website :: URL designated under the name of Cookiefirst.

When you access our website, a connection is established with the cookiefirst server to give us the possibility of obtaining a valid consent on your part for the use of certain cookies.Cookiefirst then stores a cookie in your browser so that you can only activate the cookies to which you have consented and document it correctly.The data processed is stored up to the expiration of the predefined storage period or until you request the deletion of the data.Certain compulsory legal retention periods may apply notwithstanding the above.

Cookiefirst is used to obtain the legally required consent for the use of cookies.The legal basis for this is article 6, paragraph 1, point c), of the General Data Protection Regulation (GDPR).

Data processing agreement

We have concluded a data processing agreement with Cookiefirst.This is a contract required by the data protection law, which guarantees that the data of visitors to our website are only processed in accordance with our instructions and in compliance with the GDPR.

Server newspaper files

Our website and CookIefirst collect and automatically store information in what is called server log files, which your browser automatically transmits us.The following data is collected:

• Your consent status or withdrawal of consent.
• Your anonymous IP address
• Information on your browser
• Information on your device
• The date and time of your visit to our website
• URL of the web page where you have recorded or updated your consent preferences
• The approximate location of the user who recorded his consent preferences.
• A unique universal identifier (Uuid) of the website visitor who clicked on the Cookie banner.

4. Who are the recipients of your personal data?

Nuvanta only communicates your personal data to authorized recipients and determined in accordance with the provisions of applicable regulations.

In strict compliance with the purposes set out above your personal data is processed first by the internal services of Nuvanta within the framework of the exercise of their usual missions.

They are also communicated to some of our subcontractors and providers (subsidiary of the post manager of the website hosting service provider) which are bound by the same security and confidentiality obligations as Nuvanta.

We demand from all of these third parties that they apply at least the basic safety rules defined by the CNIL both on technical administrative aspects and organization in order to protect your personal data against any disclosure Use Modification and illegal destruction.

To do this, we have strictly selected our subcontractors according to the safety of the accommodation they provide (in terms of the strict standards) reinforced the infrastructures used and hardened the contracts concluded with them.

Your personal data can thus be transmitted to the following providers and/or subcontractors:

• Technical subcontractors:
• Amazon Web Services Inc which takes care of the accommodation of our site and sending emails;
• Google LLC in the context of the Nuvanta use of the Google Analytics tool to collect statistical data relating to the site;
• MailGun which offers an email sending solution;
• Maileva a subsidiary of the La Poste group and leader in mail outsourcing which takes care of the delivery and monitoring of letters;
• The Meta Platforms Inc. group as part of advertising targeting by Nuvanta;
• HubSpot as part of advertising targeting carried out by Nuvanta.

Personal data that you are likely to communicate to us may also be communicated in response to legal or administrative procedure of any kind or to the application of the law claimed by the competent authorities.

Nuvanta undertakes not to transmit your personal data to third parties unless:

• You have given your prior agreement for sharing your personal data with third parties
• The sharing of your personal data with said third party is necessary for the provision of services/services requested
• A competent judicial or administrative authority requires that Nuvanta communicates the said personal data as recalled above.

5. How long is your personal data kept?

Your personal data is kept during the duration necessary for the realization of the purposes described above and this in compliance with the legislation in force.

If you are a customer of our company we keep your personal data the time necessary to follow up on your relationship with us and then for a period of 3 years from the end of the commercial relationship.

However, personal data to establish the proof of a right or a contract to be kept under compliance with a legal obligation will be during the period provided for by law in force.

Regarding connection data (IP address Date and time of connection pages consulted) they are kept for a maximum period of 6 months.

The details of the conservation durations is taken up in the table reproduced below:

6. Transfer of your personal data outside the European Union

We strive to keep your personal data within the European Union.However it is possible that your personal data can sometimes be transferred outside the European Union through our partners our subcontractors and/or providers or third-party platforms (eg Meta Google).

Some recipients are located in countries that have been the subject of a decision to adequate (total or partial) by the European Commission which considers them as a suitable level of protection of personal data.These countries are: the United States.

The United States has benefited from an adequacy decision since July 10, 2023.

Transfers of personal data from the European Union to organizations appearing on a list managed and published by the United States Ministry of Commerce can be carried out freely.In this case the Meta and Google groups are on this list.

For other countries which are not considered to be ensuring an adequate level of protection Nuvanta makes every effort to implement the necessary and sufficient guarantees in order to ensure the level of protection required by the regulation (in particular on a case -by -case basis by theRegularization of standard contractual clauses based on the European Commission model or any other mechanism in accordance with the regulations).

7. The use of your personal data by third -party platforms

The site may contain links to other sites.Likewise other sites may refer or contain a link to our site.We have no control over these other areas and websites.We invite our users to read the privacy policies of each website and each application with which they are likely to interact.We do not check, do not verify neither approve nor are not responsible for confidentiality practices or the content of such websites or applications.If you visit other websites or applications concerned you do it at your own risk and are subject to their Privacy Policy.

You can also consult the Nuvanta site using the private navigation mode.

8. Google's services

This site uses several features offered by Google.As such, some of your personal data and in particular your navigation data may be transferred to this company whose servers can be located outside the European Union and especially in the United States.

The use made of your personal data by Google is subject to the conditions of use decreed by the latter.We advise you to read them carefully in order to fully exercise your rights with regard to Google.

The services concerned are in particular Google Analytics.Google Analytics uses cookies to analyze your use of the site on the basis of your consent.

You can prevent the recording of cookies by refusing this cookie.

De plus en téléchargeant et installant le Browser Plugin qui est disponible sous le lien suivant : https://tools.google.com/dlpage/gaoptout?hl=fr vous pouvez empêcher :

• Google entry of personal data generated by Google Analytics cookies relating to your use of the Site (including your IP address)
• The processing of this data with Google.

By doing an opt-out cookie will be installed and will prevent the entry of your personal data during future site visits.

Vous trouverez plus amples informations relatives à l’utilisation des Données personnelles des utilisateurs chez Google Analytics dans la déclaration de confidentialité pour la protection des données de Google : https://support.google.com/analytics/answer/6004245?hl=fr.

9. Security

We are constantly doing our best to protect your personal data.Upon receipt of your personal data and throughout their life cycle, we apply strict safety procedures and measures to ensure their availability their integrity and prevent unauthorized access.

As a treatment managers we implement appropriate technical and organizational measures in accordance with the legal provisions applicable in order to protect your personal data against alteration accidental or illegal loss The use of unauthorized disclosure or access and in particular:

• raising awareness of the confidentiality requirements of our employees that have access to your personal data;
• Securing access to our premises as well as physical and logical access to our computer systems and platforms;
• securing access to sharing and transfer of personal data;
• A high degree of requirement in terms of personal data protection when selecting our subcontractors and partners.

cryptageSslOuTls :

For security reasons and in order to protect the transmission of confidential content such as the requests you send to us this site uses SSL or TLS encryption.A encrypted connection is identifiable that the browser address line goes from "http: //"to "https: //"and the padlock symbol appearing on this line.

When SSL or TLS encryption is activated the personal data you send us cannot be consulted by third parties.

10. What are your rights?

We will endeavor to allow you to exercise your rights on your personal data:

• You can access the personal data that Nuvanta collects and processes concerning you and obtaining a copy;


• You can request that your personal data be rectified updates or corrected;


• You can request the erasure of your personal data as soon as possible when one of the following reasons applies:
  • Personal data is no longer necessary with regard to the purposes for which it has been collected or processed in another way;
  • You remove your consent on which the treatment is founded and there is no other legal basis for the treatment concerned.The withdrawal of consent is worth for the future;
  • You exercise your right of opposition and there is no imperious legitimate reason for treatment;
  • Personal data has been the subject of illegal processing;
  • Personal data must be deleted to comply with a legal obligation.

The right to erasure may not apply if the treatment is necessary: ​​

• To comply with a legal obligation
• to the observation to the exercise or the defense of rights in court.
• You can request the limitation of processing your personal data when one of the following elements applies:
  • A verification of your personal data is necessary after a challenge on your part on the accuracy of your personal data;
  • The treatment is illegal and you oppose the erasure of your personal data and require instead the limitation of their use;
  • Nuvanta no longer needs personal data concerning you for processing but personal data is necessary for you for the observation or the defense of legal rights;
  • You opposed treatment and Nuvanta checks whether the legitimate reasons chased by it prevail over your legitimate reasons.


• You can object at any time for reasons relating to your particular situation to the processing of your personal data based on a legitimate reason;


• You can withdraw your consent from the processing of personal data at any time under the same conditions as those in which you provided it insofar as the treatment is based on consent (in particular with regard to the treatment of cookies);


• You have a right to portability allowing you to receive the personal data that you have provided in Nuvanta in a commonly used structured format and readable by machine when in a cumulative manner:
  • Treatment is based on consent or a contract;
  • Treatment is carried out using automated processes.

As part of the exercise of this right you have the right to obtain from Nuvanta that your personal data is transmitted directly by Nuvanta to another controller when this is technically possible.

The right to portability must not infringe the rights and freedoms of third parties.

• In accordance with French law Nuvanta gives you the opportunity to decide your personal data in advance after your death.



Any rectification or erasure of your personal data or any limitation of the processing carried out at your request will be communicated by Nuita to each recipient to which your personal data may have been transmitted in accordance with these provisions unless such a communication is impossibleor requires disproportionate efforts.

In the event that personal data concerning you is erroneous or not up to date you can inform Nuvanta so that the required corrections and/or update are carried out.

11. How to exercise your rights?

To exercise your rights, please send:

• electronically at the address: service.client@lettre-reco.com
• PARTY ONE ATTENTION TO THE FEWNER FOIL - 6 Fern Road D18 FP98 - Dublin - Ireland.

If Nuvanta has reasonable doubts about the identity of the natural person presenting the request, she may ask him for additional information necessary to confirm his identity (e.g. a copy of the identity document).

Pour vous aider dans votre démarche pour exercer vos droits vous trouverez un modèle de courrier élaboré par la Commission Nationale de l’Informatique et des Libertés (CNIL) sur le lien suivant : https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces .

Nuvanta has a period of one (1) months to meet you from receipt of your request.This period may be extended by (2) two months due to the complexity of your request and the number of requests made to it.Nuvanta will inform you in the month of your request.

If you believe that your rights are not respected enough you have the right to file a complaint with the CNIL (National Commission for Data Protection).

12Modifications

Nuvanta will be able to update this privacy policy at any time to adapt it to possible new practices and service offers.In this case the date of updating the privacy policy will be updated and indicates the day the changes have been made.If Nuvanta makes changes that it considers important you will be notified through information on our site.

13. Use of connection witnesses ("cookies")

You are informed that during your visits to our cookies site (connection witnesses) can be installed on your navigation software to allow you in particular optimal navigation.Cookies are data stored in the user terminal equipment.They are used by our site to send information to the user browser and allow this browser to return information to the original site (for example a session identifier the choice of a language or a date).Other types of tracers such as pixel beacons can also be used.