PRIVACY POLICY

The company HINAHYA BIJOUX EI BONNEMERE, registered with the Paris Trade and Companies Register under sire number 979537982 and whose head office is located at 113 rue du Général leclerc 95130 Franconville (hereinafter "HINAHYA BIJOUX"), undertakes to comply with the legislation in force in France (Law No. 78-17 of January 6, 1978 "Informatique et Libertés") and in Europe (Regulation 2016/679 of April 27, 2016 "GDPR"), to ensure the protection, confidentiality and security of personal data, as well as to respect the privacy of its customers and all visitors to its platform.


This Privacy Policy (hereinafter “the Policy”) describes how HINAHYA BIJOUX collects and processes the Personal Data of people browsing its website or placing an order with it.

The Policy also specifies the legal bases on which HINAHYA BIJOUX relies to process Personal Data and sets their retention periods.

In any event, HINAHYA BIJOUX undertakes to respect the following principles:

• Your data is used only for explicit, legitimate and specific purposes in connection with the various functionalities offered on the Site, in particular to place orders for the products referenced there.

• Only the Personal Data necessary for these purposes are collected and processed by HINAHYA BIJOUX.

• You are informed in a clear and transparent manner about the purpose of use of the Personal Data collected about you and about your data protection rights.


Article 1: Definitions

• “Customer”: Refers to any person placing an order for products through the Site.

• “Cookies”: Refers to tracers allowing access to information stored in the terminal equipment of the Visitor to the Site.

• “Order”: Means any order placed by the Customer through the Site.

• “Recipient”: Means the natural or legal person receiving the communication of Personal Data, whether or not a third party.

• “Personal data”: Any information relating to an identified or identifiable natural person directly (by name or first name, for example) or indirectly (in particular by reference to an identifier such as a number, location data, an online identifier, etc.).

• “Data Subject” / “You”: The identified or identifiable natural person whose Personal Data is processed by HINAHYA BIJOUX as a Website Visitor or Customer.

• “Data Controller”: The natural or legal person determining the purposes and means of processing Personal Data. Here, HINAHYA BIJOUX acts as Data Controller.

• “Site”: Refers to the website published by HINAHYA BIJOUX, accessible at the following URL address: https://www.hinahya.com.

• “Subcontractor”: The natural or legal person processing Personal Data on behalf of the Data Controller.

• “Processing”: Any operation carried out on Personal Data (collection, recording, storage, modification, transmission, deletion, etc.).

• “Third Party”: Any authorized natural or legal person, public authority, service or body other than the Data Subject, the Data Controller or the Subcontractor.

• “Visitor”: Any person browsing the Site, whether or not a customer of HINAHYA BIJOUX.


Article 2: When is your data collected?

Your Personal Data may be collected in the following situations:

• When visiting and browsing the Site.

• When creating a personal account on the Site.

• When placing an Order (purchase of a product).

• During exchanges related to the delivery of a product.

• When contacting after-sales service.

• When subscribing to the newsletter.

• During any exchange between you and HINAHYA BIJOUX .


Article 3: For what purposes is your data processed?
The Processing of your Personal Data carried out by HINAHYA BIJOUX has the following purposes:

• Lead management.

• Sending newsletters.

• The creation of a personal account on the Site.

• Placing and managing an order.

• Payment of the order.

• Delivery of the order.

• Monitoring of the contractual relationship with customers.

• After-sales service.

• Monitoring of statistics and audience measurement on the Site.

• Improving navigation on the Site.


Article 4: On what legal bases is your data collected? How long is it kept?

Purposes

Data collected

Legal basis

Shelf life

Prospect management, development and management of communication and prospecting operations (newsletter)

Contact details (name, first name, email address)

Consent

Up to 3 years from the last contact with the person concerned

Product Order Management & Delivery

Identification data and contact details (name, first name, email address, postal address, telephone number)

CONTRACT

Duration linked to that of the contract (if a contract is concluded), and during the applicable limitation periods

Remote payment by bank card

Card number, expiration date

CONTRACT

Until full payment plus the withdrawal period for the sale of products

After-sales service

Contact details and billing data

Legal obligations

Duration linked to that of the contract (if a contract is concluded), and during the applicable limitation periods

Interaction analysis (Audience measurement)

Contents, establishments, pages consulted

Consent

6 months

Regarding retention periods , it is understood that HINAHYA BIJOUX only keeps your Personal Data for the time necessary to achieve the purposes for which they were collected, including to satisfy any legal or accounting requirements.


Article 5: Who are the recipients of your data?

Personal data concerning you may be processed by the following persons: • Authorized members of the HINAHYA BIJOUX team;

• Service providers authorized by HINAHYA BIJOUX to deliver products;

• Suppliers of IT systems and support for the HINAHYA BIJOUX business (e.g.: IT, hosting and maintenance provider, supplier of secure payment solutions).

Your Data will not be communicated to other people without your consent.

Third parties with whom HINAHYA BIJOUX shares your Data are limited (by law and by contract) in their ability to use your Personal Data for the specific purposes that HINAHYA BIJOUX has identified.

In any event, HINAHYA BIJOUX makes every effort to ensure that the recipients of your Personal Data are subject to confidentiality and security obligations in accordance with this Privacy Policy, applicable laws and in particular the GDPR and the Data Protection Act in its latest version in force.

Finally, you are informed that HINAHYA BIJOUX may share your Personal Data in order to comply with legal obligations (for example, transmission of data to administrations).


Article 6: Is your data transferred outside the European Union?

In principle, all your Data is stored within the territory of the European Union and is not transferred outside this territory.

However, if the processing of your Personal Data involved a transfer outside the European Union, these transfers would be carried out in return for appropriate guarantees in terms of security and confidentiality in accordance with the applicable regulations (in particular standard contractual clauses, in accordance with the model clauses validated by the European Commission).


Article 7: What are your rights?

As a Data Subject concerned by the Processing of Personal Data, you have various rights.

These are nevertheless not absolute and are subject to certain conditions, in accordance with the GDPR and other texts in force applicable in particular to Law n° 78-17 of January 6, 1978 known as “Informatique et Libertés”.


7.1 The right of access

You have the right to obtain from HINAHYA BIJOUX confirmation as to whether or not your Personal Data is processed by HINAHYA BIJOUX , as well as information on how it is processed.

You also have the right to obtain a copy of the Personal Data concerning you processed by HINAHYA BIJOUX .


7.2 The right of rectification

You may request HINAHYA BIJOUX to take steps to correct your Personal Data if it is inaccurate or incomplete.

For example, if HINAHYA BIJOUX has the wrong name or address to deliver the Products that are the subject of your Order.


7.3 The right to erasure (“right to be forgotten”)

You can request the erasure or deletion of your Personal Data.

For example, when there is no (or no longer is) a compelling reason for HINAHYA BIJOUX to continue using them.


7.4 The right to restrict processing

You have the right to request the limitation of the Processing of Personal Data or to prevent further use of your Personal Data.


7.5 The right to data portability

You have the right to retrieve and reuse certain Personal Data concerning you.

This right applies only to Personal Data that you have provided to HINAHYA BIJOUX , which the latter processes with your consent, for the purposes of performing the contract and processed by automated means.

Where applicable, HINAHYA BIJOUX will provide you with a copy of your Personal Data in a structured, commonly used and machine-readable format (where technically possible).

HINAHYA BIJOUX may also, if you wish, transmit (to the extent possible) this type of Personal Data directly to another data controller.


7.6 The right to object

You have the right to object to certain types of processing, for reasons relating to your particular situation, at any time, to the extent that such processing has taken place for the purposes of the legitimate interests pursued by HINAHYA BIJOUX .

In any event, HINAHYA BIJOUX will be authorized to continue processing your Personal Data if it is able to demonstrate that the Processing of Personal Data is justified by freedoms or if this Personal Data is necessary for the establishment, exercise or defense in legal proceedings.


7.7 The right to withdraw your consent

When HINAHYA BIJOUX processes your Personal Data on the legal basis of your consent, you have the possibility to withdraw your consent at any time.

However, you are hereby informed that the withdrawal does not affect the lawfulness of the processing that took place before the exercise of this right of withdrawal.


7.8 The right to provide us with instructions on the use of your personal data after your death

You have the right to provide HINAHYA BIJOUX with instructions on the management (e.g. retention, deletion and disclosure) of your Personal Data after your death.

You may change or revoke your instructions at any time.


7.9 Right to file a complaint with the CNIL

In the event that you are not satisfied with HINAHYA BIJOUX 's response to your complaint or if you believe that the Processing of your Personal Data does not comply with the applicable regulations on the protection of personal data, you may file a complaint with the competent supervisory authority for data protection.

The Commission Informatique et Libertés (CNIL) is the data protection authority in France.

Here is the updated version with HINAHYA BIJOUX :


Article 8: How can you exercise your rights?

If you wish to exercise any of your rights, you can contact us at the following email address: hinahyabijoux@gmail.com .

To learn more about your rights, you can visit the CNIL website ( www.cnil.fr/fr/comprendre-vos-droits ).

When requesting to exercise rights, an identity document may be requested if necessary, in particular in order to preserve the security of the processing which is the subject of the request.

A response will be sent to you, depending on the complexity of your request, within the time limits prescribed by article 12.3 of the GDPR.


Article 9: How is your personal data protected?

HINAHYA BIJOUX ensures that Personal Data is processed securely and confidentially, including when certain operations are carried out by Subcontractors.

To this end, HINAHYA BIJOUX implements appropriate technical and organizational measures to prevent the loss, misuse, alteration and deletion of your Personal Data.

These measures are adapted according to the level of sensitivity of the Personal Data processed and the level of risk presented by the Processing of this data or its implementation.

If a breach of the security of your Personal Data occurs, HINAHYA BIJOUX will inform you within the time limits and in accordance with the procedures specified by the legal and regulatory provisions in force.


Article 10: Can this Policy be modified?

HINAHYA BIJOUX reserves the right to modify this Privacy Policy.

• If the changes are technical changes, the new policy will apply immediately.

• If the modifications or updates are substantial (for example, insertion of a new purpose), a communication will be made to the Data Subjects.

• If the collection of consent were necessary again, HINAHYA BIJOUX would obviously proceed with a new collection of consent.