PRIVACY POLICY

 

Applicable from October 2022


We value your privacy and the protection of your personal data. 

This policy informs you about how your data are collected and used in connection with any contact with our Company, in accordance with the applicable data protection laws and regulations, including the local data protection laws in your country (such as the "Information Technology and Freedoms" Act No. 78-17 of January 6, 1978) and the European regulation in force resulting from the General Data Protection Regulation 2016/679 of April 27, 2016 ("GDPR"). 

 
1.    Data controller and recipients of personal data
The personal data collected ("Data") in connection with the use of our Products and more generally, in connection with contacts you may have with our Company, are processed by Shenzhen Skyworth Digital Technology Co., Ltd., as the data controller ("Data Controller").

Data means any information relating to an identified or identifiable natural person, directly or indirectly, including by reference to an identifier such as a name, a mail address, an email address, a phone number, an identification number, location data or an online identifier.

Depending on the processing purpose, the Data collected and/or transferred are intended to be used by the Data Controller; the Data Controller's support services (purchasing/sales administration, after-sales, logistics, supplier management, HR/recruitment, IT service, accounting and marketing) shall have access to them. 

They will also be made available to the following third parties (including "data processors" or "third party recipients" as defined in the GDPR) for the strict needs of their mission, in particular: 
•    technical service providers;
•    financial/accounting service providers: auditors, banks;
•    logistics service providers: carriers;
 
Access is strictly governed by the existing security policies, we will enter into strict contractual terms with such third parties and require them to process Data in accordance with our requirements, this Privacy Policy, and the confidentiality and security measures required by applicable data protection laws and regulations.

In addition, the Data Controller may be required to disclose your Data to third parties in cases where such communication is permitted and required by law or a court decision, or if such communication is necessary to protect and defend its rights.

When third parties that act as data controllers are involved in processing your Data, please refer directly to their privacy policies on their official websites or other platforms and learn more about their data processing practices.

 
2.    Data processing purposes 
The Data that is required to conduct commercial relationships with our Company, in particular the use of the products and/or services, to ensure our legitimate interests or to meet a regulatory obligation, shall be reported to you as such when collected.

The following Data are processed:
•    Identification data (last name, first name, name of the company for which you work, position, relations with any person within our Company);
•    contact data (postal address, email address, phone number);
•    location data (postal address) ;
•    any other data you send us in order to contact us or obtain the supply/use of products and/or services.
 
The Data shall be used in different way:
•    For the purposes of the performance of the commercial relationship and in particular the sale or provision of services contract you or your company have entered into or that of the supply contract (such as creation of customer or supplier accounts, fulfillment of orders, invoicing, monitoring of the performance of the contract, delivery, after-sales and complaints, organization of satisfaction surveys, customer or supplier file management, unpaid invoices and litigation management);
•    To process and respond to requests that may give rise, where appropriate, to the conclusion of a contract (request for information);
•    To meet legal, accounting and tax obligations (in particular the retention of accounting supporting documents; management of rights, rectification and objection requests; maintenance of a list of objections to canvassing), or to establish, exercise and defend legal rights; 
•    On the basis of your consent, which you may withdraw at any time without calling into question the initial legality of the use of your Data (infra, Art. 3 “Your Rights”), for sending newsletters or delivering the prize to you as a winner in our promotion activity.
 
Unless you object, and within the limits of your interests and rights, to fulfil meet the legitimate interests of the Data Controller, in particular:
•    Canvassing, customer relationship monitoring and customer loyalty;
•    Creation of customer/supplier accounts and profiles, and performing all due diligence necessary to protect the Data Controller’s interests and to prevent conflicts of interest;
•    Product optimization;
•    Carrying out reach-out operations to develop sales;
•    Management of people’s opinions about products, services or content in the interest of improving the products and services;
•    Personalization of the customer experience; 
•    Preparation of statistics (sales in particular), in order to analyze the sales activity;
•    Management of the prospects file in order to develop sales;
•    Completion of satisfaction surveys;
•    Combating payment fraud;
•    Conducting promotion and marketing activities.
 
3.    Your rights regarding the Data
The person whose Data are processed by the Data Controller have a right of access, rectification of erroneous personal Data, and, in the cases and according to the limits laid down in the applicable data protection laws and regulations, objection, erasure of some of their Data and a right to withdraw their consent, restrict use thereof, define their fate after their death, or request their portability for transmission to a third party.

Should you have given your consent to the processing of your Data, you can withdraw it at any time with effect for the future.

To exercise your rights, simply write to one of the two addresses stated in Article 6 below and enclose, if necessary, any document which proves your identity and justifies your request. 

 
4.    Length of retention of the Data
Your Data shall be retained for a period not exceeding that required for the purposes for which they are collected, and in particular for the following periods:
•    For a period of 3 years following the last consent, and then kept in intermediate archives for the duration of the applicable legal requirement (5 years) for all data except banking data and cookies;
•    For a period of 13 months from their storage/creation for cookies.
 
However, if any applicable laws (e.g., the local laws in your countries or regions) require us to retain your Data for a longer period, we will comply with the legal requirements and delete the Data only after the expiration of the retention period.

At the end of these periods, the Data shall be erased from the active databases and, if necessary, archived for a period not exceeding the applicable statutory limitation periods or archiving obligations. Once these periods have expired, the Data will be destroyed.