Privacy policy
1. Preamble
This privacy policy applies to the website: www.brad.ag.
The purpose of this privacy policy is to inform users of the website about:
- How their personal data is collected and processed. Any data that could identify a user is considered personal data. This notably includes first and last name, age, postal address, email address, the user's location and IP address;
- The rights users have regarding this data;
- Who is responsible for the processing of the personal data collected and processed;
- To whom this data is transmitted;
- Where applicable, the website's policy regarding "cookies".
This privacy policy complements the legal notice and the Terms of Service, which users may consult on the website.
2. General principles for the collection and processing of data
In accordance with Article 5 of European Regulation 2016/679, the collection and processing of data of website users respect the following principles:
- Lawfulness, fairness and transparency: data may only be collected and processed with the consent of the user who owns the data. Each time personal data is collected, the user will be informed that their data is being collected and the reasons for doing so;
- Limited purposes: the collection and processing of data are carried out to meet one or more objectives defined in these terms of use;
- Minimisation of collection and processing of data: only the data necessary for the proper performance of the website's purposes are collected;
- Limited data retention over time: data is kept for a limited period, which the user is informed of. When this information cannot be communicated, the user is informed of the criteria used to determine the retention period;
- Integrity and confidentiality of collected and processed data: the data controller undertakes to guarantee the integrity and confidentiality of the data collected.
In order to be lawful, and in accordance with the requirements of Article 6 of European Regulation 2016/679, the collection and processing of personal data may only take place if at least one of the following conditions is met:
- The user has expressly consented to the processing;
- The processing is necessary for the proper performance of a contract;
- The processing meets a legal obligation;
- The processing is justified by a necessity related to safeguarding the vital interests of the data subject or of another natural person;
- The processing is justified by a necessity related to the performance of a public-interest task or the exercise of public authority;
- The processing and collection of personal data are necessary for the legitimate private interests pursued by the data controller or a third party.
3. Personal data collected and processed when browsing the website
3.1 Data collected and processed, and method of collection
The personal data collected on the Brad Technology website is as follows:
First name, last name, email address, physical address, and bank details where applicable.
This data is collected when the user performs one of the following actions on the website: when filling in a contact form, when making a purchase on the website, or when adding a comment.
In addition, when a payment is made on the website, proof of the transaction including the order form and the invoice will be retained in the website publisher's IT systems.
The data controller will keep all collected data in its IT systems and under reasonable security conditions for the following durations: accounting data: 10 years, job applications: 2 years, commercial contractual data, visit analytics cookies: 13 months.
The collection and processing of data serve the following purposes: processing orders, shipping parcels, and answering questions sent via the contact form.
The data processing operations carried out are based on the following legal grounds: performance of the contract, user consent, and legal obligation.
3.2 Transmission of data to third parties
Data may be transmitted to the following third parties:
- Google Analytics — analysis of visits to the Brad.ag website
- Odoo — customer management software
- Mailjet — newsletter sending software
3.3 Data hosting
The Brad Technology website is hosted by: SCALEWAY SAS, whose registered office is at the following address:
BP 438 75366 Paris CEDEX 08, France
The host can be contacted at the following telephone number: +33 (0)1 84 13 00 00.
The data collected and processed by the website is transferred to the following countries: Poland and the Netherlands.
4. Data controller
4.1 The data controller
The controller of personal data is: Olivier Lépine, CEO of Brad Technology. He can be contacted as follows: data@brad.technology or at +33 (4) 84 51 20 92.
The data controller is responsible for determining the purposes and means used for the processing of personal data.
4.2 Obligations of the data controller
The data controller undertakes to protect the personal data collected, not to transmit it to third parties without informing the user, and to respect the purposes for which this data was collected.
The website has an SSL certificate to ensure that the information and data transfers transiting through the website are secure.
An SSL ("Secure Socket Layer") Certificate aims to secure the data exchanged between the user and the website.
In addition, the data controller undertakes to notify the user in the event of rectification or deletion of data, unless this entails disproportionate formalities, costs, or steps for the controller.
In the event that the integrity, confidentiality, or security of the user's personal data is compromised, the data controller undertakes to inform the user by any means.
5. Rights of the user
In accordance with the regulations on the processing of personal data, the user has the rights listed below.
In order for the data controller to act on the request, the user must provide their first and last name as well as their email address, and where relevant, their customer, personal-space or subscriber account number.
The data controller must respond to the user within a maximum of 30 (thirty) days.
5.1 Overview of the user's rights regarding the collection and processing of data
5.1.a Right of access, rectification and right to erasure
The user may obtain knowledge of, update, modify or request the deletion of data concerning them by sending an email to the following address: data@brad.technology.
If they have one, the user has the right to request the deletion of their personal account by sending an email to: data@brad.technology.
5.1.b Right to data portability
The user has the right to request the portability of their personal data held by the website to another website by sending an email to: data@brad.technology.
5.1.c Right to restriction of, and objection to, processing
The user has the right to request restriction of, or object to, the processing of their data by the website, without the website being able to refuse, unless it can demonstrate the existence of legitimate and compelling grounds that may prevail over the interests, rights and freedoms of the user.
To request the restriction of the processing of their data or to formulate an objection to the processing, the user must send an email to: data@brad.technology.
5.1.d Right not to be subject to a decision based solely on automated processing
In accordance with the provisions of Regulation 2016/679, the user has the right not to be subject to a decision based solely on automated processing if the decision produces legal effects concerning them or similarly significantly affects them.
5.1.e Right to determine the fate of data after death
The user is reminded that they may organise what is to become of their collected and processed data should they die, in accordance with French Law No. 2016-1321 of 7 October 2016.
5.1.f Right to lodge a complaint with the competent supervisory authority
In the event that the data controller decides not to respond to the user's request, and the user wishes to challenge this decision, or if they believe that one of the rights listed above has been infringed, they are entitled to bring the matter before the CNIL (Commission Nationale de l'Informatique et des Libertés, https://www.cnil.fr) or any competent court.
5.2 Personal data of minors
In accordance with the provisions of Article 8 of European Regulation 2016/679 and the French Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data.
If the user is a minor under 15, the agreement of a legal representative will be required for personal data to be collected and processed.
The website publisher reserves the right to verify by any means that the user is over 15, or that they have obtained the agreement of a legal representative before browsing the website.
6. Conditions for modifying the privacy policy
This privacy policy may be consulted at any time at the following address:
www.brad.ag/politique-de-confidentialite
The website publisher reserves the right to modify it in order to ensure its compliance with the law in force.
Consequently, the user is invited to consult this privacy policy regularly in order to stay informed of the latest changes made to it.