User data protection Policy

Definition and nature of personal data When using the Welkeys.com site (hereinafter referred to as the "Site"), we may ask you to provide us with personal data about you.

The term "personal data" refers to all data that identifies an individual, including your name, surname, pseudonym, photograph, postal and email addresses, telephone numbers, date of birth, data your transactions on the Site, details of your purchases and subscriptions, credit card numbers, as well as any other information you choose to communicate to us about you.

Purpose of this charter The purpose of this charter is to inform you about the means we use to collect and process your personal data, in the strictest respect of your rights.

We inform you that we comply, in the collection and management of your personal data, with the law n ° 78-17 of January 6th, 1978 relating to data processing, the files and the liberties, in its current version.

Identity of the person responsible for the collection and processing of data
The person responsible for the collection and processing of your personal data is CONCIERGE PERSONAL, a simplified joint-stock company, registered in the Paris Trade and Companies Register under number 807 787 312, with registered office at 4 bis. rue saint sauveur 75002 Paris (hereinafter referred to as "Us").
Collection and processing of personal data
Your personal data is collected and processed to fulfill one or more of the following purposes:

Manage your access to certain services accessible on the Site and their use,
Perform the operations related to the management of the customers concerning the contracts, invoices, followed by the relation with the customers,
Constitute a file of registered members, users, customers and prospects,
Send newsletters, solicitations and promotional messages. In case you do not wish it, we give you the option to express your refusal on this subject when collecting your data;
Develop business and attendance statistics for our services,
Organize contests, sweepstakes and all promotional activities excluding online gambling submitted to the approval of the Online Games Regulatory Authority,
Manage the management of the opinions of the people on products, services or contents,
Manage unpaid and potential litigation regarding the use of our products and services
Respect our legal and regulatory obligations.

When you collect your personal data, we inform you if certain data must be completed or optional. We also tell you what are the possible consequences of a failure to answer.

Recipients of the data collected and processed Only the personnel of our company, the services in charge of the control (auditor notably) and our subcontractors will have access to your personal data.

The public bodies may also be the addressees of your personal data, exclusively to fulfill our legal obligations, the judicial officers, the ministerial officers and the bodies responsible for collecting debts.

Transfer of personal data
Your personal data will not be sold, rented or exchanged for the benefit of third parties.
Retention period of personal data
(i) Regarding data relating to the management of customers and prospects: Your personal data will not be retained beyond the time strictly necessary to manage our business relationship with you. However, the data allowing to establish the proof of a right or a contract, to be conserved for the respect of a legal obligation, will be it for the duration envisaged by the law in force.

Regarding possible prospecting operations for customers, their data may be retained for a period of three (3) years from the end of the business relationship.

Personal data relating to a prospect, non-client, may be retained for a period of three (3) years from their collection or the last contact from the prospect.

At the end of this three (3) year period, we will be able to contact you again to find out if you wish to continue receiving commercial solicitations.

(ii) Regarding the data relating to bank cards: The financial transactions relating to the payment of purchases and fees via the Site are entrusted to a payment service provider who ensures the smooth running and security.

For the purposes of the services, this payment service provider may be required to receive your personal data relating to your credit card numbers, which it collects and stores on our behalf and on our behalf. We do not have access to this data.

To allow you to regularly make purchases or pay related fees on the Site, your credit card data are kept during the time of your registration on the Site and at least until you realize your last transaction.

By having ticked on the Site the box expressly provided for this purpose, you give us your express consent for this conservation.

The data relating to the visual cryptogram or CVV2, registered on your bank card, are not stored.

If you refuse that your personal data relating to your credit card numbers are kept under the conditions specified above, we will not keep this data beyond the time required to complete the transaction.

In any case, the data relating to these may be retained, for a proof purpose in case of possible dispute of the transaction, in intermediate archives, for the duration provided for by Article L 133-24 of the Code monetary and financial, in this case thirteen (13) months following the debit date. This period may be extended to fifteen (15) months in order to take into account the possibility of using deferred debit payment cards.

(iii) Concerning the management of the opposition lists to be received from prospecting: The information allowing to take into account your right of opposition is kept at least three (3) years from the exercise of the right of opposition.

(iv) Concerning audience measurement statistics: The information stored in the users' terminal or any other element used to identify the users and allowing their traceability or attendance will not be kept beyond six (6) months.

Security
We inform you to take all necessary precautions, organizational and technical measures to preserve the security, the integrity and the confidentiality of your personal data and in particular, to prevent that they are deformed, damaged or that unauthorized third parties have access to it . We will also use secure payment systems that comply with the state of the art and applicable regulations.
Cookies
Cookies are text files, often encrypted, stored in your browser. They are created when the browser of a user loads a given website: the site sends information to the browser, which creates a text file. Each time the user returns to the same site, the browser retrieves this file and sends it to the server of the website.

There are two types of cookies, which do not have the same purpose: technical cookies and advertising cookies:

Technical cookies are used throughout your navigation to facilitate and perform certain functions. A technical cookie can for example be used to memorize the answers filled in a form or the user's preferences regarding the language or the presentation of a website, when such options are available.

Advertising cookies can be created not only by the website on which the user is browsing, but also by other websites displaying advertisements, ads, widgets or other items on the displayed page. These cookies may in particular be used to carry out targeted advertising, that is to say advertising determined according to the navigation of the user.
We use technical cookies. These are stored in your browser for a period of thirteen (13) months.

We do not use advertising cookies. However, if we use them in the future, we will inform you in advance and you will have the possibility if necessary to disable these cookies.

We use Google Analytics which is a statistical audience analysis tool that generates a cookie to measure the number of visits to the Site, the number of pages viewed and the activity of visitors. Your IP address is also collected to determine the city from which you are connecting. The shelf life of this cookie is mentioned in article 7 (v) of this charter.

We remind you for all practical purposes that you can oppose the deposit of cookies by configuring your browser. Such a refusal could however prevent the proper functioning of the Site.

Consent
When you choose to provide your personal data, you expressly consent to the collection and processing of your personal data in accordance with this charter and the applicable legislation.
Access to your personal data
In accordance with the law n ° 78-17 of January 6th, 1978 relating to data processing, the files and the liberties, you have the right to obtain the communication and, if necessary, the rectification or the suppression of the data concerning you. You can also contact:

email address: contact@welkeys.com
postal mail address: 4 bis rue saint Sauveur 75002 Paris

Changes
We reserve the right, in our sole discretion, to modify this charter at any time, in whole or in part. These changes will come into effect as of the publication of the new charter. Your use of the Site following the coming into force of these changes will be worth recognition and acceptance of the new charter. Failing that, and if this new charter does not suit you, you will no longer have to access the Site.
Entry into force
This policy came into effect on January 1, 2018

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