Data protection

 

  1. Introduction
    1. The following information is provided to you so that you can become aware of the personal data protection commitments of the company OLIBAM™ which acts as the data controller for the personal data processing mentioned in this document.
    2. OLIBAM™ has committed to a policy of respecting and maintaining high standards in terms of ethics, particularly regarding the protection of personal data.
    3. On the Olibam.com website, OLIBAM™ implements personal data processing as the data controller. The identity and contact details of OLIBAM™ are specified in the "legal notice" section of the said website.
    4. The purpose of this personal data protection policy is to inform you about how this data is processed by OLIBAM™ and the extent of your rights.
    5. It may evolve depending on the applicable legal and regulatory context.
  2. Principles applicable to personal data
    1. OLIBAM™ strives to comply with the following principles in the collection and use of personal data.

2.1 Legitimate and proportionate use of your data

  1. Personal data is collected, on an ongoing basis, by OLIBAM™ for specific, explicit, and legitimate purposes.
  2. Personal data collected by OLIBAM™ may be used later in a manner incompatible with the initial purposes for which it was collected.
  3. For each processing operation, OLIBAM™ undertakes to collect and process only data strictly necessary for the purpose pursued.

2.2 Fair and transparent collection

  1. In the interest of fairness and transparency towards users of the Olibam.com website, OLIBAM™ takes care to inform the data subjects of each processing operation it implements through information notices.
  2. This data is collected fairly; no collection is carried out without the knowledge of the data subjects and without them being informed.

2.3 Relevance, adequacy, and minimization of collected data

  1. The personal data collected is strictly necessary for the purpose pursued by the collection. OLIBAM™ strives to minimize the data collected and to keep it accurate.
  2. The personal data collected is regularly updated and stored by OLIBAM™ in its secure databases.

2.4 Data protection by design and by default

  1. OLIBAM™ has adopted internal policies and processes and implements measures that comply with the principles of data protection by design and by default.
  2. Thus, during the development, design, selection, and use of applications, services, and products that rely on the processing of personal data, OLIBAM™ takes into account the right to personal data protection or ensures with their publishers that they meet the legal requirements and allow for the protection of the data that will be processed there.
  3. In this regard, for example, OLIBAM™ proceeds with pseudonymization and encryption techniques for personal data whenever possible or necessary.
  4. Your data processing

3.1 Legal bases and purposes of processing

  1. OLIBAM™ implements various processing operations whose legal bases are as follows: contractual execution, your consent, its legal and regulatory obligations, its legitimate interest.
  2. The purposes associated with each legal basis are listed below:
    • Based on the execution of pre-contractual measures taken at your request and/or on the execution of the contract you have entered into, we implement processing operations pursuing the following purposes:
    • management of your orders on the Olibam.com website, including in particular the confirmation and validation of your order as well as its tracking and shipment, if applicable;
    • management of our relationship with you, as users of the Olibam.com website, including in particular:
      • creation of a personal account on the site;
      • use of the site and the services it offers;
      • management of communications and tracking of exchanges with users.
    • Based on your consent, we implement processing operations pursuing the following purposes:
    • sending communications concerning promotions and personalized or non-personalized offers, by post or electronically, including by mobile notifications;
    • sending communications on any medium such as the websites or mobile applications of OLIBAM™, the websites of OLIBAM™ group companies, or third-party websites or applications that you may consult;
    • management of cookies subject to consent;
    • management of your participation in our contests.
    • Based on compliance with our legal and regulatory obligations, we implement processing operations pursuing the following purposes:
    • management of general accounting;
    • management of responses to official requests from public or judicial authorities authorized for this purpose;
    • compliance with the regulations applicable to our activity;
    • retention of invoices and other mandatory documents relating to transactions in accordance with our obligations;
    • information of loyalty program members and users of the com site regarding product recalls;
    • management of requests for the exercise of rights.
    • Based on our legitimate interests, we implement processing operations whose purposes are as follows:
    • management of your requests for information and complaints;
    • prevention and fight against fraud, including also the management of the consequences of this fraud;
    • establishment of any means of proof necessary for the defense of our rights;
    • production of statistics and analyses for the purpose of improving the loyalty program offer and the use of the olibam.com site;
    • production of statistics and analyses to improve our products and services;
    • management of cookies not subject to consent;
    • use of your data in your capacity as a customer, loyalty program member, or site user
  • Olibam.com in order to be recognized as such by other services offered by other companies of the Olibam.com group;
  • retention of computer traces to proactively detect security incidents.
  1. The purposes pursued on the basis of our legitimate interests are carried out in compliance with your rights and freedoms.
  2. If OLIBAM™ is required to process your data for purposes other than those listed in the paragraph above, we will inform you and take any additional necessary steps.

3.2 Data collection

  1. OLIBAM™ undertakes to the users of the com site to collect and process only the data necessary for its activities. Consequently, OLIBAM™ collects various personal data concerning you.
  2. Some data processed by OLIBAM™ is collected indirectly from the following sources:
  • third parties, such as fraud prevention organizations or data providers.

 

3.3 Data subjects

  1. The data subjects concerned by the processing carried out by OLIBAM™ are:
    • OLIBAM™'s customers and prospects;
    • any user of the Olibam.com. site

 

3.4 Data recipients

  1. To achieve the purposes described above and within the limits necessary for the pursuit of these purposes, the data collected by OLIBAM™ may be transmitted to all or part of the following recipients:
  • OLIBAM™'s internal departments authorized to manage our relationship with you (all persons in charge of the conclusion, management and execution of contracts in particular);
  • persons responsible for the marketing department, the commercial department, the departments responsible for customer relations, complaints, prospecting, the administrative services, the IT services, as well as their hierarchical superiors;
  • the OLIBAM™ group legal entity which centrally manages the customer database;
  • the site's partners for the purposes of performing the services;
  • our service providers and subcontractors (in particular IT service providers, service providers acting as a secure third party in the advertising sector);
  • lawyers, legal auxiliaries and ministerial officers, administrative or judicial authorities seized of a dispute if applicable, within the framework of compliance with the legal obligations incumbent on OLIBAM™ or to enable OLIBAM™ to ensure the defense of its rights and interests;
  • the control services such as auditors and internal control services.

 

3.5 Data retention periods

  1. OLIBAM™ retains the personal data it collects only for the period necessary for the purposes of processing and in accordance with applicable law.
  2. The data collected by OLIBAM™ will thus be retained for the duration necessary to achieve the purposes described above, increased by the period of legal limitation.

3.6 Security of your data

  1. OLIBAM™ attaches particular importance to the security of your personal data.
  2. It has implemented technical and organizational measures adapted to the degree of sensitivity of the personal data, with a view to ensuring the integrity and confidentiality of the data and protecting it against any malicious intrusion, any loss, alteration or disclosure to unauthorized third parties.
  3. OLIBAM™ regularly conducts audits to verify the proper operational application of data security rules.
  4. Thus, it undertakes to take the necessary physical, technical and organizational security measures to:
  • protect its activities;
  • preserve the security of personal data of users of the com site. Against any unauthorized access, modification, deformation, disclosure, destruction or access to the personal data it holds.
  1. Nevertheless, the security and confidentiality of your personal data rely on everyone's good practices, so you are invited to remain vigilant on the matter.
  2. In accordance with its commitments, OLIBAM™ carefully selects its subcontractors and service providers and requires them to:
  • a level of personal data protection equivalent to its own;
  • use personal data or information only to manage the services they must provide;
  • strict compliance with applicable legislation and regulations regarding confidentiality and personal data;
  • the implementation of all adequate measures to ensure the protection of personal data they may be required to process;
  • the definition of necessary technical and organizational measures to ensure security.
  1. OLIBAM™ concludes contracts with its subcontractors, in accordance with legal obligations, precisely defining the conditions and terms of personal data processing.

3.7 Data transfer outside the European Union

    1. The various categories of data collected and processed within the framework of the olibam.com site may be transmitted to service provider companies located in countries outside the European Union such as the United States.
  1. These data transfers are governed by:
  • either by the "Privacy Shield" mechanism, a register maintained by the American administration guaranteeing that the American companies listed therein comply with a level of personal data protection equivalent to that set in the European Union;
  • or by a cross-border flow agreement established in accordance with the standard contractual clauses from controller to processor issued by the European Commission and currently in force.
  1. Your rights and how to exercise them

4.1 The content of your rights

  1. You benefit from the following rights related to your data:
  • right of access;
  • right to rectification;
  • right to erasure (unless they are necessary for the performance of the services, or they are necessary for OLIBAM™ to comply with its legal obligations or to establish or exercise its rights);
  • right to define directives relating to the fate of your data after your death, with a trusted third party, certified and responsible for enforcing your will, in accordance with the requirements of the applicable legal framework.
  1. Under the right of access, OLIBAM™ may ask you to pay reasonable fees based on administrative costs for any additional copy of the data to that which will be communicated.
  2. You also have:
  • a right to obtain restriction of processing;
  • a right to data portability;
  • a right to object.

4.2 The right to object

  1. You can request to exercise your right to object to the processing of personal data concerning you for reasons relating to your particular situation when the processing is based on the legitimate interest of OLIBAM™. This right to object also applies to profiling.
  2. In the event of exercising such a right to object, OLIBAM™ will cease processing unless there are legitimate and compelling reasons for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
  3. You can also object to any processing related to prospecting without having to invoke reasons relating to your particular situation.

4.3 Exercising your rights

  1. The communication of specific post-mortem directives and the exercise of your rights are carried out by email to the address contact@olibam.com, specifying the information allowing your identity to be established.

4.4 Withdrawal of consent

  1. You can also withdraw your consent at any time, in cases where it has been requested.

4.5 Filing a complaint

If you believe, after contacting us, that your data rights are not respected, you can file a complaint with the Commission nationale de l’informatique et des libertés (3 place de Fontenoy - TSA 80715 – 75334 Paris cedex 07; Tel: 01 53 73 22 22).