Data protection policy

Last update made on: February 16, 2021

Preamble

Our data protection policy has been established in accordance with the recommendations of the Commission Nationale de l’Informatique et des Libertés. Its objective is to inform the users of our site (www.lockall.fr) of the commitments and measures we have taken to ensure that the personal data of visitors, users and customers of Sodeval France is respected.

It has been established in accordance with the provisions of the French Data Protection Act of January 6, 1978, the European Regulation on Personal Data (R.G.P.D.) of May 23, 2018, and the Law transposing the European Regulation on Personal Data Protection (R.G.P.D.) of June 20, 2018.

1. Definitions

On our site, the terms below have the meaning attributed to them in the sense of the RGPD (art.4): 

• Consent : « of the data subject means any freely given, specific, informed and unambiguous expression of will by which the data subject consents, by means of a declaration or a clear positive act, to personal data relating to him being processed; »
• Personal data : « any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity; »
• Person in charge of the treatment : « the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing; where the purposes and means of such processing are determined by Union law or by the law of a Member State, the controller may be designated or the specific criteria applicable to his designation may be provided for by Union law or by the law of a Member State; »
• Processor : « the natural or legal person, public authority, department or other body which processes personal data on behalf of the controller; »
• Processing : « any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, limitation, erasure or destruction;” »
• Personal Data Breach : « a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed; »
• The data collected 

1. Consent

Our company collects and processes data that is strictly necessary for the purposes for which it is processed. We commit to our users that we will not process data for purposes other than those mentioned below. If we were to offer a new service on our website, requiring the collection and processing of your data, we undertake to collect the consent of our users once again before offering the new service in question. 

Whenever our site processes personal data, it takes all reasonable steps to ensure that the personal data is accurate and relevant to the purposes for which it is processed. 

• Data access

The data we collect on our site is for our exclusive use. The personal data of our users is not disclosed to third parties and is only accessible to authorized employees of our company. 

The person in charge of processing your data for the Lockall Company can be reached at the following address: contact@lockall.fr. As the person in charge of processing the data that he collects, he undertakes to respect the legal provisions in force. In particular, it is his responsibility to provide prospects, customers and users with complete information on the processing of their personal data and to maintain a register of processing in accordance with the reality. 

• The purpose of the processing 

We collect our users’ data only for the following processing purposes: 

1. Contact our customer service : On our website, several services are available to the user to contact our company (a “contact us” module, a “make an appointment” module, a “free call back” module, a chat module). The data collected allows us to quickly contact our users to process their requests or their orders if necessary; 

• Creation of a customer account: for all orders placed on our website, users must create a customer account. To create a customer account, we ask the user to enter their email address and set a password. Users can request the deletion of their customer account by sending an email to the following address: contact@lockall.fr
  
• Order management : for any order placed on our site, we collect the following data: telephone number, address and delivery information, buyer’s identity. The data on your means of payment are collected by our partner payment organization, STRIPE, and their protection is therefore its responsibility. The user is responsible for the veracity of the information provided. Lockall will not be held responsible for any incorrect information provided during the ordering process.  
• Browsing our site : Our company collects your browsing information for statistical purposes only. We invite you to refer to our corresponding policy on cookies. 
• Prevent and fight against computer fraud (spamming, hacking, etc.): computer equipment used for navigation, IP address, password.

We do not exceed the legal retention periods and your data is kept only for the time necessary to process the purposes for which it was collected.

• Non-disclosure of personal data 

Our Site will not process, host or transfer the Information collected about its Customers and users to a country outside the European Union or recognized as “non-adequate” by the European Commission without first informing the owner of the data. 

However, Lockall remains free to choose its technical and commercial subcontractors provided that they present sufficient guarantees with regard to the requirements of the General Data Protection Regulation (GDPR: No. 2016-679). The User’s Personal Data may be processed by subsidiaries of our Company and subcontractors (service providers), exclusively in order to achieve the purposes of this policy.

Our Company undertakes to take all necessary precautions to preserve the security of the Information and in particular that it is not communicated to unauthorized persons. 

• Data security and incident reporting 

Our site and our company have taken all reasonable and necessary precautions, in accordance with the state of the art, to protect your information in a secure environment to prevent its destruction, loss, alteration, distribution or unauthorized access. Despite our best efforts, no method of transmission over the Internet and no method of electronic storage is completely secure. Therefore, we cannot guarantee absolute security. If we become aware of a security breach, we will notify affected users so that they can take appropriate action. Our incident notification procedures take into account our legal obligations, whether at national or European level. 

In the event that the integrity and confidentiality of your data is compromised, the data controller undertakes to respect the procedures put in place under the French Data Protection Act of 6 January 1978 and the European Data Protection Regulation (“RGPD”).

However, the user is responsible for the security of his login and password of his customer account. Lockall will not be liable for the loss or theft of User’s login and password or for access to User’s account by a third party due to the theft of User’s login and password.

• People’s rights 

With regard to the legal provisions of the Data Protection Act of January 6, 1978 and the European Data Protection Regulation (“E.D.P.R.”), the users of our Site have the following rights: 

1. right of access (article 15 RGPD) and rectification (article 16 RGPD), update, completeness of Users’ data, right of blocking or deletion of Users’ personal data (article 17 RGPD), when they are inaccurate, incomplete, equivocal, outdated, or whose collection, use, communication or storage is prohibited
2. the right to withdraw consent at any time (Article 13-2c GDPR)
3. the right to limit the processing of Users’ data (Article 18 GDPR)
4. right to object to the processing of Users’ data (Article 21 GDPR)
5. the right to portability of the data provided by the Users, when such data are subject to automated processing based on their consent or on a contract (Article 20 GDPR)
6. the right to define the fate of the Users’ data after their death and to choose to whom Lockall shall communicate (or not) their data to a third party that they have previously designated. 

Our site and our company cannot oppose the request of users to exercise their rights. This request can be made at any time by e-mail to the following address: contact@lockall.fr.  

Requests will be processed within ten (10) working days, except for compelling reasons put forward and justified by our company that justify an extension of the deadline. 

• Referral to the CNIL 

If our Company does not satisfy the user’s request, the latter is entitled to refer the matter to the CNIL (Commission Nationale de l’Informatique et des Libertés, https://www.cnil.fr) in order to assert his rights. 

• Minimum age

In accordance with the provisions of Article 8 of the GDPR, we do not collect, directly or indirectly, Personal Data from persons under the age of sixteen (16). Users under the age of sixteen (16) are invited to seek the consent of a legal representative – required by Lockall – in order for their personal data to be collected. 

Sodeval reserves the right to request proof of consent from the legal representative. Sodeval shall not be liable for any personal data provided by any user under the age of sixteen (16). 

• Definition of cookies 

The user is informed that a cookie is a small file deposited on the terminal of any user (computer, tablet or mobile device), by our site, during its consultation. It does not contain any personal information, but allows us to link the user’s device to his or her preferences for use and experience on our site (e.g., location, language, font size). 

1. Consent to the use of cookies 

For the use of “cookie” files involving the storage and analysis of personal data, the user’s consent is always requested. This consent is valid for a period of thirteen (13) months, at the end of which the user will be asked for a new authorization.

1.  Use of cookies 

We use and collect cookies for the following purposes : 

• To process statistics and information on the traffic on our site and to optimize the latter; 
• To offer our users a smooth browsing experience by adapting the presentation of our site to the display preferences of the user’s terminal; 
• To memorize information provided on the platform by the user (access to his account, contents of an order basket, etc.). 

The cookies present on our site are the following: 

1.  Opposition and configuration

All users of the site www.lockall.fr can oppose the recording of “cookies” by configuring their navigation software in the following way(s): 

• Open a private browser window; 
• Configure cookies via the “Cookies” widget available on the home page of our site; 
• Configure your computer to display a message asking you to accept, personalize or refuse cookies on each site or systematically; 
• Or any other means available to the user. 

At any time the user can choose to express and modify his wishes regarding cookies. Our Company declines all responsibility for the consequences linked to the functioning of the site and the services that may be offered resulting from 

• The refusal of cookies by the user 
• And/or the impossibility for the site to record or consult the cookies necessary for their functioning because of the user’s choice. 

1.  Setting up the navigation software

The user can configure his navigation software in order to parameterize his choices regarding the use of cookies: 

• For Microsoft Edge^TM : https://support.microsoft.com/en-us/microsoft-edge
• For Safari^TM : http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
• For Chrome^TM : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• For Firefox^TM : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
• For Opera^TM : http://help.opera.com/Windows/10.20/fr/cookies.html

The user can also set his browser to accept or refuse cookies on a case-by-case basis before their installation, or delete cookies from his terminal. The user is informed that by setting his browser to refuse cookies, certain features of our site may not be accessible and the responsibility of our company or the host could not be sought in this regard.

1.   Setting up social networks 

By clicking on the icons dedicated to social networks, Facebook, Twitter, YouTube, LinkedIn and Instagram appearing on our site and if the user has accepted the deposit of cookies by continuing to browse the site, these social networks can also deposit cookies on the user’s terminals. 

The user can consult the data protection policy of these social networks to set up the cookies: 

• Facebook : https://www.facebook.com/about/privacy/
• YouTube : https://support.google.com/youtube/?hl=fr#topic=9257498
• Twitter : https://help.twitter.com/fr
• LinkedIn : https://www.linkedin.com/help/linkedin?lang=fr
• Instagram : https://help.instagram.com/

1.   Changes to the privacy policy 

The version currently posted on our website is the current version of this policy. 

Lockall reserves the right to change this policy at any time to comply with applicable legal requirements. It is therefore the responsibility of each user to review this policy regularly to be aware of any changes to this policy. 

By browsing our site, the user acknowledges having read, understood and accepted this data protection policy.