1. PREAMBLE
All processing of personal data is carried out under the responsibility of Vivometric Limited, a limited liability company under Irish law with a capital of 100 euros, with registration number 756836, whose registered office is located at REGUS BLOCK 1, BLANCHARDSTOWN CORPORATE PARK 1, DUBLIN Dublin 15 D15 AKKI1, Ireland, and whose business address is located at Office 14, 40 Patrick Street, Waterford, X91 X3KF, Ireland (Hereinafter "VIVOMETRIC"). VIVOMETRIC can be contacted by email at the following address: contact@espace-vehicule.com
Any data transfer to a partner is carried out with your consent, and the processing of data by the latter is subject to the partner's privacy policy.
2. TYPE OF DATA COLLECTED
The mandatory or optional nature of the data is specified during their collection. If this information is incomplete, obsolete, or inaccurate, it may be impossible to create an account on the Site.
VIVOMETRIC may collect and process all or part of the following data:
| Processing category | Description of the personal data category |
|---|---|
| Data processed as part of the use of the User's Personal Account on the Site | These are the personal data collected from the User during the creation and management of a Customer account on the Site and/or the placing of an order. They may include in particular:
|
| Contact form | These are the personal data provided to make contact via the Site. They include name, first name, email, subject, and content of the message. |
| Newsletter subscription | This is the email address provided to subscribe to a newsletter via the Site. |
| Connection and navigation data | These connection and navigation data include cookie data. |
3. PURPOSE AND LEGAL BASIS OF PROCESSING
Your personal data is collected for the following purposes:
| Legal basis | Purposes |
|---|---|
| Contract execution |
|
| Consent |
|
| Legitimate interest |
|
| Legal obligations | VIVOMETRIC may process your data for evidence purposes and in the context of compliance with its legal obligations. |
4. RETENTION PERIOD OF PERSONAL INFORMATION
The retention period of personal data varies according to the purpose of their collection:
- Data relating to your credit card is kept by our payment provider until the last payment due date and, for evidence purposes in the event of a claim, for 13 months, or 15 months if it is a deferred debit payment card.
- Data relating to your use of the Site is kept for a period of 5 years after your request to unsubscribe from the Site, particularly for evidence purposes, it being specified that after a period of inactivity of 3 years, the account may be deleted.
- Data relating to the management of your contract and your orders are kept for a period of 5 years after each order, particularly for evidence purposes. In the event of a dispute, the data necessary for the processing of the dispute may be kept beyond this period, until the end of the dispute.
- Data relating to the sending of newsletters and information and commercial offers related to our services (email, telephone) are kept until your request for unsubscription or deletion of your personal data, or after a maximum period of 3 years after the last contact from the person concerned.
- Information necessary for compliance with legal obligations is kept for the legal retention period:
- Data declared to the tax administration under the regulations are kept for 10 years.
- Documents and accounting records are kept for 10 years, as accounting evidence.
- Data that may be subject to a judicial requisition (connection data, identity, contact details, data relating to transactions on the Platform) are kept for 12 months from their collection.
- Cookies placed on your device will only keep your data for the time necessary to achieve their purpose (for example, session identification cookies are only kept for the duration of a session) and for a maximum of 13 months.
5. RECIPIENT OF PERSONAL DATA
We undertake to process all your personal data confidentially. VIVOMETRIC's internal team may have access to your personal data but only in the exercise of their functions and within the framework of the purposes provided for in this Policy. We do not share your data with third parties, except in the limited cases below:
- Subcontractors. VIVOMETRIC may use the services of other companies or independent persons which provide certain services on its behalf: Technical providers, Payment services. These providers may have access to the personal information necessary for the execution of their services but are not authorized to use it for other purposes.
- Transfer of companies or activities. As part of the development of its activities, VIVOMETRIC may sell all or part of its assets or acquire other companies, businesses, subsidiaries, or branches of activity. During such transactions, personal data processed by the company generally forms part of the transferred assets but remains subject to any pre-existing privacy policy, unless otherwise agreed by the individuals concerned.
- Authorized administrative and judicial authorities. In order to comply with its legal obligations, VIVOMETRIC may transfer your personal data to authorized administrative and judicial authorities.
- With your agreement. Unless VIVOMETRIC were required to comply with a legal obligation, VIVOMETRIC will notify you if its information were to be transmitted to a third party, it being specified that you have the possibility of not giving your agreement to such a transmission.
6. TRANSFER OF DATA OUTSIDE THE EU
Some of our subcontractors may be located outside the European Union. Thus, your personal data may be stored in various countries, including the United States. In the event of data transfer in this context, we verify that the processing is carried out in accordance with this privacy policy and that a sufficient level of protection is guaranteed in compliance with the applicable regulations, either within the framework of contractual obligations or within the framework of adequacy decisions.
7. EXCLUSION OF SENSITIVE DATA
VIVOMETRIC does not collect any sensitive data about you.
These sensitive data concern the processing of personal data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
If such data were provided to VIVOMETRIC, please contact us by email at the following address: contact@espace-vehicule.com so that they can be deleted.
8. MINORS
The Site has not been designed to be used by minors (under 18 years of age). In no case do we authorize the use of our services by minors under 18 years of age. We do not knowingly collect personal data from minors. If a parent notices that their child has provided us with personal data (or if a guardian realizes that the child for whom they are responsible has provided us with personal information), he or she should contact us by email.
9. VOS DROITS EN MATIÈRE D’ACCÈS À VOS DONNEES PERSONNELLES
In accordance with Article 13 of Regulation (EU) 2016/679 of 27 April 2016 and Article 32 of Law 78-17 of 6 January 1978, you are informed that you have the following rights:
- Right of access: This is your right to obtain confirmation of whether your data is being processed or not, and if so, to access this data.
- Right of rectification: This is your right to obtain, without undue delay, the rectification of inaccurate data, and to have incomplete data completed.
- Right of deletion/Erasure: This is your right to obtain, without undue delay, the erasure of your data, subject to our legal retention obligations and our legitimate interest in keeping this information.
- Right to restriction: This is your right to obtain restriction of processing when you object to it, when you contest the accuracy of your data, when you think that their processing is unlawful, or when you need them for the establishment, exercise, or defense of legal claims.
- Right to object: This is your right to object at any time to the processing of your data by VIVOMETRIC, except in the case of legitimate reasons of VIVOMETRIC. You can also object to processing for direct marketing purposes.
- Right to data portability: This is your right to receive your data in a structured, commonly used, machine-readable, and interoperable format, and to transmit it to another data controller without hindrance from us.
- Right not to be subject to a decision based on automated processing: You have the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you or similarly significantly affects you, except when this decision is necessary for the conclusion or performance of a contract, or is legally authorized.
- Directives in the event of death: You have the right to give directives for the fate of your personal data in the event of death.
How to exercise your rights: You can send any request accompanied by a copy of an ID by email or by post. In accordance with Article 17 of Regulation (EU) 2016/679 of 27 April 2016, the exercise of these rights must not deprive VIVOMETRIC of its right of retention in order to comply with its legal obligations and for evidentiary purposes.
10. VOS DROITS EN MATIÈRE D’OPPOSITION AUX PROPOSITIONS COMMERCIALES
10.1 — Commercial proposals by email or SMS
On the forms you fill out, your consent may be requested to receive offers from us and, where applicable, from our partners.
However, your express and prior consent is not mandatory when you are already a customer of VIVOMETRIC and the purpose of our solicitation is to offer you products or services similar to those we already provide to you.
In all cases, you always have the possibility of objecting to the reception of these solicitations by carrying out the following actions:
- For email: by clicking on the unsubscribe link provided in each email, by going to your online account, or by contacting us by email
- For SMS: by sending a STOP SMS to the number indicated in it or by contacting us by email
10.2 — Commercial proposals by telephone
If you do not wish to receive commercial proposals on your personal telephone number (in the event that it has been communicated to us), you can object:
- By contacting us by email
- By registering on the telephone marketing opposition list "Bloctel" at the following address: https://conso.bloctel.fr in accordance with Articles L223-1 and L223-2 of the Consumer Code
11. SECURITY OF PERSONAL DATA
VIVOMETRIC has implemented physical and electronic security measures as well as backup procedures in connection with the collection, storage, and communication of your personal data, including:
- Securing access to our premises and our IT platforms
- Raising awareness of the confidentiality requirements of our employees who may access your personal data
- Securing access, sharing, and transfer of data
- The high level of requirement for data protection during the selection of our subcontractors and, as the case may be, from our partners.
12. MODIFICATION OF THE POLICY
This Policy may be modified, supplemented, or updated, in particular to comply with any legal, regulatory, jurisprudential, or technical developments. However, your personal data will always be processed in accordance with the Policy in force at the time of their collection, unless you agree otherwise or if a mandatory legal prescription provides otherwise.