Privacy policy of https://www.spirit-brothers.com/

This site collects personal data from its users.

Data controller
Sobeautiful - 79 rue Michel Ange 75016 Paris
E-mail address of the controller: contact@spirit-brothers.com

Types of data collected
The Personal Information collected by this Site, either independently or through third parties, includes: email, name, first name, occupation, country, company name, cookies, usage data and telephone number.

Detailed information on each type of data collected is provided in the dedicated sections of this privacy policy or through specific information texts displayed prior to data collection.
Personal data may be provided free of charge by the user or, in the case of usage data, collected automatically during the use of this website.
Unless otherwise stated, all data requested by this website is mandatory. If the user refuses to provide it, it may be impossible for this website to provide the service. In the event that this website indicates certain data as optional, users are free to refrain from providing such data, without this having any consequences for the availability of the service or its operation.
Users who are in doubt about the mandatory data are invited to contact the owner.
Any use of cookies - or other tracking tools - by this website or by third party service providers used by this website, unless otherwise specified, is intended to provide the service requested by the user, in addition to the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared on this Site and guarantees that he/she has the right to communicate or disseminate them, thus releasing the Owner from any liability towards third parties.

How and where the data collected is processed
Processing method
The Controller takes appropriate security measures to prevent unauthorised access, disclosure, alteration or destruction of the Personal Data.
Processing is carried out using IT and/or telematic tools, with organisational methods and logic strictly related to the purposes indicated. In addition to the data controller, other parties involved in the organisation of this website (administrators, sales, marketing, legal, system administrators) or external parties (third party technical service providers, postal carriers) may have access to the data. In addition, third parties (e.g. hosting providers, IT companies, communication agencies) have also been appointed as data processors by the data controller, if necessary. The updated list of processors can always be requested from the data controller.

Legal basis for processing
The holder processes personal data relating to the user in the event that any of the following conditions exist:

  • the User has given consent for one or more specific purposes; Note: in some jurisdictions, the owner may be allowed to process personal data without the user's consent or another of the legal bases specified below, as long as the user does not object ("opt-out") to such processing. However, this does not apply if the processing of personal data is regulated by European legislation on the protection of personal data;
  • the processing is necessary for the execution of a contract with the user and/or the execution of pre-contractual measures;
  • the processing is necessary to fulfil a legal obligation to which the data controller is subject;
  • the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the holder;
  • the processing is necessary to pursue the legitimate interest of the owner or third parties.

In any case, it is always possible to ask the Owner to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on law, provided for by a contract or necessary to conclude a contract.

Location
Data is processed at the operational headquarters of the data controller and at any other location where the parties involved in the processing are located. For more information, contact the owner.
The user's personal data may be transferred to a country other than that in which the user is located. For more information on the processing site, the user can refer to the section on processing of personal data.

You have the right to obtain information about the legal basis for the transfer of data outside the European Union or an international organisation under international public law or two or more countries, such as the UN, as well as about the security measures taken by the data controller to protect the data.

If any of the transfers described above take place, the user can refer to the respective sections of this document or request information from the data controller by contacting him/her on the opening dates.

Retention period
Data is processed and stored for the time required for the purposes for which it was collected.

Therefore:

  • Personal data collected for purposes related to the execution of a contract between the owner and the user will be kept until the end of the execution of the contract.
  • Personal data collected for purposes related to the legitimate interest of the data controller will be kept until such interest is satisfied. The user can obtain further information about the legitimate interest pursued by the owner in the relevant sections of this document or by contacting the data controller.

Where processing is based on the user's consent, the data controller may retain personal data for a longer period until such consent is revoked. In addition, the data controller may be obliged to retain personal data for a longer period in accordance with a legal obligation or an order from an authority.

At the end of the retention period, the personal data will be deleted. Therefore, at the end of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purposes of processing collected data
User Data is collected to enable the Owner to provide its Services, as well as for the following purposes: Contacting the User, Managing contacts and sending messages, Analytics, Displaying content from external platforms, Hosting and backend infrastructure, Tag management and interaction with data collection platforms and other third parties.

For more detailed information on the purposes of the processing and on the Personal Data specifically relevant to each purpose, the User may refer to the relevant sections of this document.

Details on the processing of personal data
Personal data is collected for the following purposes and using the following services:

  • see the RGPDpage

User's rights
Users may exercise certain rights in relation to data processed by the data controller.

In particular, as a User you have the right to:

  • withdraw consent at any time. The user may withdraw his consent to the processing of his personal data previously expressed.
  • object to the processing of your data. You may object to the processing of your data where this occurs on a lawful basis other than consent. Further details on the right to object are set out in the section below.
  • access your Data. The User has the right to obtain information about the Data processed by the Data Controller, about certain aspects of the processing and to receive a copy of the processed Data.
  • verify and request correction. The user may check the accuracy of his or her data and request its update or correction.
  • obtain a limitation of processing. When certain conditions are met, the User may request the limitation of the processing of his/her Data. In this case, the Data Controller will not process the Data for any other purpose than its conservation.
  • obtain the cancellation or deletion of their personal data. When certain conditions are met, the user can request the cancellation of their data by the owner.
  • receive your data or have them transferred to another holder. You have the right to receive your data in a structured format, commonly used and readable by an automatic device and, when technically possible, to have it transferred without hindrance to another holder. This provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures related to it.
  • file a complaint. The user may file a complaint with the competent authority for the protection of personal data or take legal action.

Details on the right to object
Where Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or in the pursuit of a legitimate interest of the Owner, Users have the right to object to the processing on grounds relating to their particular situation.

Users are reminded that, if their data is processed for direct marketing purposes, they may object to the processing without providing reasons. To find out whether the owner is processing data for direct marketing purposes, users can refer to the respective sections of this document.

How to exercise rights
To exercise User rights, Users may send a request to the Owner's contact details listed in this document. Requests are submitted free of charge and processed by the Owner as soon as possible, but in any case within one month.

More information on the processing
Defence in court
The User's Personal Data may be used by the Owner in court or in the preparatory stages of its possible implementation for the defence against abuses of the use of this Site or associated Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of the public authorities

Specific information
At the user's request, in addition to the information contained in this privacy policy, this website may provide the user with additional, contextual information regarding specific services or the collection and processing of personal data.

System logs and maintenance
For operational and maintenance purposes, this website and third party services used by it may collect system logs, which are files that record interactions and may also contain personal data, such as the user's IP address.

Information not contained in this policy
Further information on the processing of personal data can be requested at any time from the data controller using the contact details.

Response to "Do Not Track" requests
This website does not support "Do Not Track" requests.
To find out if any of the third party services used support them, the user is advised to consult their respective privacy policies.

Changes to this privacy policy
The data controller reserves the right to make changes to this privacy policy at any time by informing users on this page and, if possible, on this website and, if technically and legally possible, by sending a notification to users. Please check this page regularly, referring to the date of the last modification indicated at the bottom.

If the changes relate to processing operations for which the legal basis is consent, the Controller will seek the User's consent again, if necessary.

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