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PRIVACY POLICY
OUR PERSONAL DATA PROTECTION POLICY

MIND THE TEA undertakes to comply with the French Data Protection Law (loi « Informatique et libertés ») and with all current legislation regarding personal data processing. The ELOCANCE Website has been registered with the French Commission nationale de l’informatique et des libertés (CNIL n°1979110).

1. Preamble and Scope

This Privacy Policy (hereinafter the "Policy") informs you of how and why the MIND THE TEA corporation (hereinafter “MIND THE TEA”) which publishes the ELOCANCE website and application (hereinafter respectively the “Website”, the “Application” or “Elocance”) collects, processes, uses, shares, protects, and stores your personal data.

This Policy also enumerates your rights and details what means you have at your disposal to control the use that is made of your personal data as part of the Elocance services.

Elocance’s privacy policy and personal data protection policy fully complies with the strict legislative framework for privacy and personal data protection laid down both by the provisions of the General Data Protection Regulation 2016/679 of 27th April 2016 (“GDPR”) and of the French law n°78-17 of 6th January 1978 in its latest version in force (“French Data Protection Law”).

It applies to all personal data processing performed by MIND THE TEA, as data controller, that involves any visitor to the Website or user of our Application and of the Elocance services.

2. Identifying the Titular Data Controller

The data controller of your personal data is the MIND THE TEA corporation, a French société par actions simplifiée with a registered capital of 71 630 Euros, registered with the Paris Companies Register under number 819 411 430, and whose registered headquarters are located at 8 rue Lemercier, 75017 Paris, and which is represented by its President, Alexis BOTAYA.

3. Acceptance of our Privacy Policies

This Policy is an integral part of the General Terms and Conditions of Sale and Use (hereinafter “GTCSU”) you have agreed to.

As stipulated by said GTCSU, by browsing or creating an account on our Website or Application, you affirm that you have read, understood and, without limitation, reservation, or qualification, accepted the terms of the present Privacy Policy and our GTCSU. Therefore, if you disagree with any stipulation of either this Policy or the GTCSU, you may decide not to use our services and accordingly must not communicate any personal data to us.

4. Type of Information Collected

Our business makes it necessary for us to collect some personal data from you. However, MIND THE TEA takes care to apply the principle of minimization, and therefore we only collect the data that is strictly necessary for the purposes listed herein.

5. Purposes of Collection

Any use of personal data for any other purpose shall require your prior authorization.

6. Recipients of collected data

MIND THE TEA neither sells nor leases personal data provided by users of the Elocance services.

Your personal data can only be used to improve our services.

Therefore, for external processing needs, your personal data may, as needed, be sent to third-party data processors for proper performance of our agreement and with the sole aim of carrying out the purposes intended at the time of collection.

We use third-party services for:

billing: from GOOGLE and APPLE, whose respective privacy policies are available at the following addresses https://policies.google.com/privacy and https://www.apple.com/legal/privacy;

hosting of personal data: from OVH, whose privacy policy is available at the following address https://www.ovh.com/fr/protection-donnees-personnelles;

sending Elocance newsletters and notifications: from SENDGRID, whose privacy policy is available at the following address https://sendgrid.com/policies/privacy;

analyzing data for improving and optimizing the Elocance services: your Data may be sent to our publisher partners or to service providers for analysis and compilation of statistics about the use of Elocance services in order to improve or personalize the service provided by Elocance.

User-chosen Application access settings: your data may be sent to Facebook, Google, or LinkedIn, if you have linked your Elocance account to your user account of one of the aforementioned services when signing up for the Website or in the settings of your Elocance account. MIND THE TEA encourages you to read those websites’ privacy policies.

These trusted partners will process your personal information on behalf of MIND THE TEA, in accordance with our instructions, in agreement with the provisions of this Policy and of the Elocance GTCSU you have agreed to, and they shall be bound by the same privacy and security obligations as MIND THE TEA.

Moreover, MIND THE TEA stores your personal data mainly in France and in the European Union.

Nonetheless, data collected as part of our service may possibly be sent to subcontractors located outside of the European Union and therefore subject to personal data privacy legislation that is less stringent than in France.

We may use their services to answer your questions, provide online payment tools, and to provide us with emailing and SMS services.

They may also be Elocance partner publishers located outside of the European Union and to whom we may possibly send some of your data in order to enable us to provide our services in those countries.

Lastly, pursuant to applicable legal provisions, we may be required to disclose your personal data to a third party if:

Therefore, MIND THE TEA cannot disclose its Users’ Personal Data to third parties except when expressly authorized to do so by the owner of such data; upon the order of legally authorized authorities; upon legal requisition or as part of a court trial.

7. Third-Party Websites or Applications

When you browse our Website or Application, as a normal visitor or user, Elocance, as an aggregator of content freely available online, will suggest third-party content and source links to third-party owner websites or applications.

MIND THE TEA has no control over the cookies or other functionalities used by those third-party websites or applications, nor over what type of personal data processing they may employ.

In the event you visit or use those third-party websites, we suggest you refer to the terms of use and privacy policies of those websites/applications.

8. Data Retention

Your personal data are retained for a limited time period in order to carry out the purposes for which they were collected and processed. Your personal information may, however, be retained for a longer period of time in order to ensure our compliance with legal obligations, and particularly with applicable statute of limitations.

Data regarding your subscription, your use of our Application, and your payments, will be kept for the entire duration of our contractual relationship. Closing your personal account will lead to the deletion of all personal data enabling you to be identified.

Nonetheless, we may retain some of your data as archives after you close your user account in order to comply with our legal, accounting, and tax obligations, and we may do so for the length of the applicable statute of limitations.

9. Personal Data Security

MIND THE TEA has implemented organizational, technical, software and physical digital security measures to protect personal data against alteration, destruction and unauthorized access.

MIND THE TEA, directly or via its subcontractors, implements appropriate measures to ensure the safety and integrity of personal data, including:

From an organizational standpoint, only MIND THE TEA employees and service providers who need to process your personal data as part of their jobs will have access to them. Additionally, these people are bound by a confidentiality agreement and are liable to penalties in the event of misconduct.

However, given the state of technology and the probability of the risk occurring, no security measure is infallible and MIND THE TEA cannot guarantee absolute security.

Moreover, as indicated in the Elocance GTCSU you have accepted, you are reminded that as a User, you own your Elocance account and you are responsible for controlling your account and who has access to it. MIND THE TEA suggests, in particular, that you choose a sufficiently secure password when you create your Elocance account, that you share it with no one, and that if you share your computer or your smartphone, that you log off or switch sessions before you quit the Application.

10. What are your rights and how can you exercise them?

Pursuant to applicable regulations, and in particular Articles 15 to 22 of the GDPR and Articles 38 to 40 of the French Data Protection Law of 6th January 1978 in its most recent version in force, you may, at any time, provided you prove your identity, exercise:

You may exercise the abovementioned rights by contacting us at the following email address: privacy@elocance.com. We will answer your email within one month following receipt of your request.

Pursuant to the GDPR, we reserve the right to extend our response time by two months because of the complexity and the number of requests. If we do, you will be informed of the reasons for the delay within one month following receipt of your request.

In the event of dispute or disagreement, you may file a complaint with a data protection authority such as the CNIL (www.cnil.fr).

11. The particular case of lotteries, sweepstakes and surveys

The Elocance Services will occasionally offer you the chance of participating in promotions, such as lotteries, sweepstakes, offers and/or surveys (“Special Promotions”).

A Special Promotion may be governed by a special privacy policy or terms and conditions that can add to or diverge from this Policy and/or the Elocance GTCSU. In the event of a contradiction between several provisions, these specific supplementary provisions shall prevail.

When you sign up for a special promotion, MIND THE TEA may collect, with your express agreement, other personal data than those indicated in this Policy. These other data will be processed, stored, used, and retained in accordance with the stipulations of this Policy.

12. Updates and Modifications to our Policy

As a result of technological advances and given the constant rate of legislative and regulatory change, we reserve the right to update this Policy at any time. In this event, the date on which the Policy was updated will appear at the bottom of this document.

If we make changes to our privacy policy that we feel are substantial, you will naturally be informed of the same by a notification published on our Website and an email sent to the email address you provided.

Protecting your privacy is a priority for MIND THE TEA, so if you have any questions about this document, please don’t hesitate to contact us at the following email address: privacy@elocance.com.

Updated on 10 December 2019

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