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Personal data protection policy

ARTICLE 1 – PURPOSE

SMEG Développement (hereinafter "SMEG Développement") takes seriously the personal data protection of any person, identified or not, who navigates and uses the sites and services it offers (the "Users"). The procedures applied by SMEG Développement guarantee Users' rights in this respect.

These personal data protection measures apply to all websites, web applications, and mobile applications made available by SMEG Développement (hereinafter the "Sites"). Websites and services offered by third parties, to which any hypertext links may refer, are explicitly not covered by these measures. SMEG Développement shall not be responsible for any personal data breaches resulting from visits to third-party sites or the use of third-party services.

This personal data protection policy is referenced at the bottom of the Sites and may therefore be consulted at any time. It applies in conjunction with the general terms and conditions of use of the Sites and the general terms and conditions of sale of EVzen services. It may be amended at any time, in particular to take account of changes in the technologies used, the introduction of new services, and new regulations.

 

ARTICLE 2 – DATA CONTROLLER

The data controller is:

SMEG Development

Public limited company under Monegasque law (SAM) with capital of EUR 150,000

Registered office: c/o SMEG, 10 avenue de Fontvieille, 98000 Monaco

RCI Monaco n° 20 S 08489

NIS: 7112B21922

Email: support@evzen.com

Phone: +33 9 69 39 09 03

SMEG Développement collects and processes personal data concerning Users in its capacity as the data controller.

In this respect, SMEG Développement undertakes to comply with all Monegasque regulations applicable to the processing of personal data, in particular Act no. 1.165 of 23/12/1993 on the protection of personal data, as it is established in Monaco.

SMEG Développement also declares that it complies with the provisions of the General Data Protection Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR") with regard to the processing of the personal data of Users who are residents of the European Union.

 

ARTICLE 3 - DATA RELATING TO BROWSING AND USE OF THE SITES AND PROCESSING PURPOSES

It is possible to browse the Sites without providing access to personal data. However, the User is informed that the services offered by SMEG Développement may not be available without prior provision of personal data.

General browsing data are recorded, such as IP address, web browser, operating system, and date and time of visit.

The use of the Sites and services offered by SMEG Développement may require the processing of Users' personal data, such as identification data (name, address, email address, phone number), usage data (consumption, billing) and correspondence data (in particular via the use of contact forms). This data is only recorded and processed if the User contacts SMEG Développement, and the use of this data is necessary for the proper performance of the services offered by SMEG Développement, with the exception of data explicitly indicated as non-mandatory.

SMEG Développement uses this personal data for the following purposes:

  • Creating and managing a User account
  • Commercial relations: managing client relations (complaints, support, etc.); managing payment methods; charging service use
  • Communication: requesting information and contact (via contact forms); sending newsletters about the services offered by SMEG Développement.

Connection information and data relating to charging sessions are also collected and stored for statistical purposes, to improve the services offered, and to develop new services; these data are collected anonymously, with no possibility to identify any User in particular.

 

ARTICLE 4 – MOBILE APPLICATION USAGE DATA

In the particular case of mobile applications, information is transmitted to the third party managing the application catalogue (e.g. Apple, Google) when the application is downloaded. SMEG Développement has no influence on the data transmitted to these third parties and is not responsible for the use of such data by these third parties.

When using mobile applications, the User's geographic location may be recorded in order to display relevant information. The User can deactivate access to this geographic location in the phone settings; in this case, the User is informed that the mobile applications will be less efficient.

Users may also use mobile applications anonymously, i.e., without prior registration or transmission of identification data.

The online payment systems made available are provided by third parties, who apply their own personal data policies.

Data relating to use of the mobile applications are collected for statistical purposes and to improve the services offered; these data are collected anonymously, with no possibility to identify any User in particular.

 

ARTICLE 5 – CONTACT FORM

The Sites offer contact forms. When a contact form is used, the information communicated by the User is recorded for processing purposes and is necessary to manage the request.

This information is intended for SMEG Développement and will only be accessible to the persons in charge of processing the request.

 

ARTICLE 6 – NEWSLETTERS

Users have the option of subscribing to newsletters. The related personal data, such as name, phone number, email and address entered in the registration form may thus be used for the purpose of sending newsletters.

Newsletters may contain tracking devices such as web beacons or pixel tags. These may be used to compile statistics relating to online marketing campaigns and to improve newsletters. This data is anonymous and can absolutely not be used to identify a specific User.

 

ARTICLE 7 – COOKIES

When Users browse the Sites, certain information may be stored in the form of a file on the User's device, known as a cookie. Cookies are used to recognise Users on subsequent visits, to save their password for faster browsing, and to adapt the Sites to the User's profile.

Users may refuse cookies by changing their browser settings or by deleting the cookies stored on their device.

 

ARTICLE 8 – DATA RECIPIENTS

SMEG Développement may disclose to its staff Users’ personal data reasonably required for the purposes set out in this policy. SMEG Développement staff are bound by strict confidentiality agreements.

Some of SMEG Développement's external service providers may also have access to data in order to carry out the tasks entrusted to them by SMEG Développement, such as: IT service providers, billing service providers, printers, consultants, and installation or maintenance service providers.

SMEG Développement may have to communicate information relating to Users if required by regulations or any legal proceedings, as a result of an external request for information, or due to a need to perform the services offered by SMEG Développement (see the article relating to the use of external analysis tools), to the following third parties: electricity distribution network operators, energy suppliers, chartered accountants, auditors, public administrations, courts, lawyers, or notaries.

In all cases, SMEG Développement shall ensure that third parties are not able to access Users' personal data beyond what is reasonably necessary to achieve the specified purpose.

Under no circumstances shall SMEG Développement sell personal data to third parties.

 

ARTICLE 9 – DATA STORAGE AND DESTRUCTION

Personal data shall be deleted as soon as they are no longer required for the purposes for which they were processed, unless SMEG Développement is required by law to store such data or if a claim is pending.

Data that has been previously anonymised for statistical and service improvement purposes shall be stored for as long as necessary for these purposes.

 

ARTICLE 10 – USER RIGHTS

Users have the following rights with regard to their personal data:

  • Right to access: all Users have the right to be informed of the personal data concerning them and the purposes for which they are processed, and to request a copy thereof
  • Right to rectification: all Users have the right to obtain the rectification of inaccurate personal data concerning them
  • Right to erasure: under certain conditions, all Users have the right to request the erasure of their personal data
  • Right to limit processing: under certain conditions, all Users have the right to request that the use of their personal data be limited in certain cases
  • Right to data portability: all Users have the right to receive a copy of the personal data they provided for their own use or to transmit their data to a third party of their choice
  • Right to object: under certain conditions, all Users have the right to object to the processing of their personal data based on SMEG Développement's legitimate interests or for prospecting purposes
  • Right to withdraw consent: all Users have the right at any time to withdraw the consent they have given for the use of their personal data when the processing of their data is based on their consent, it being specified that the withdrawal of consent shall not compromise the lawfulness of the processing based on consent conducted prior to withdrawal thereof
  • "Post-mortem" right: all Users have the right to define instructions relating to the conservation, deletion, and communication of their personal data after their death.

For more information, visit https://www.cnil.fr/fr/reglement-europeen-protection-donnees/chapitre3

 

ARTICLE 11 – DATA SECURITY

Personal data transmission and storage is protected by the use of secure servers using encryption technologies such as SSL (Secure Sockets Layer). This protects data from loss, destruction, manipulation, or unauthorised access by third parties.

As technology improves, so do the security measures taken. Web browsers themselves display information proving that encryption technologies have been correctly implemented on the Sites.

Although SMEG Dévelopment makes every effort to protect personal data, it cannot guarantee the security of data when it transmitted via the Internet from the User to SMEG Development.

 

ARTICLE 12 – PRECAUTIONS

SMEG Développement advises Users to keep their login details carefully and not to reveal them to third parties. When a device is used by multiple people, Users are advised to close their browsers on the Sites and, if necessary, to log out after each connection to their User account, in order to ensure that their connection with SMEG Développement has been successfully terminated.

SMEG Développement recommends following the best practices recommended by the CNIL when creating passwords. For more information, visit https://www.cnil.fr/fr/generer-un-mot-de-passe-solide

 

ARTICLE 13 – USE OF EXTERNAL ANALYSIS TOOLS AND LINKS TO THIRD-PARTY SERVICES AND CONTENT

SMEG Développement uses services and content provided by third parties on its Websites in order to improve the services offered to Users.

Third-party content providers may use Users' IP addresses to send information to their browsers. This use of IP addresses is necessary for the display of third-party content.

Third parties may also use tracking devices for statistical or marketing purposes, the information about which is then stored in cookies on Users' devices.

Users are informed that they are solely responsible for deactivating the tracking functions on the Sites. It is not possible to centrally manage Users' tracking preferences. An explanation is provided below for each tracking device used.

 

ARTICLE 14 – QUESTIONS AND COMPLAINTS RELATING TO THE PROTECTION OF PERSONAL DATA

To exercise their rights or for any questions or complaints relating to the protection of personal data, Users may contact the SMEG Group's Data Protection Officer (DPO) at the following address and phone number:

Email: dpo@smeg.mc

Address: Data Protection Officer, c/o SMEG, 10 avenue de Fontvieille, Monaco

 

Users may also contact the competent authority for the protection of personal data:

  • In France

Commission Nationale de l'Informatique et des Libertés (CNIL)

3 Place de Fontenoy

TSA 80715

75334 Paris Cedex 07