Legal Notes

Legal Notes

DATA PROTECTION POLICY

While browsing the Nrg Clever Platform and using the online sale Services offered there, we will harvest and process your personal data.

The purpose of this data protection policy is to provide you with information concerning:

·  the way in which we harvest and process your personal data;

·  the cookies which we place on your browser device.

YOUR PERSONAL DATA

1. Controller

Your personal data, which is harvested in order to execute the orders you made on the NrgClever platform, is jointly processed by NRG CLEVER, the company which runs the NrgClever Platform, and by each Retailer with whom you place an order.

Your personal data is also processed under the responsibility of NRG CLEVER for the purposes of marketing, analysis of browser behaviour, audience measurements, behavioural advertising and statistical studies, and in order to conduct customer satisfaction surveys and prevent bank fraud.

2. Why do we process your data and what is the legal basis for it?

3. What personal data do we process?

We harvest and process the following data, in particular:

• the personal data which you provided on our Platform when you created your account (email, surname, first name, address, password, etc.);

• the information relating to the orders which you place on the Platform (product purchased, transaction number, delivery address, etc.);

• the information relating to your means of payment (bank card number, bank card expiry date, security code) through the intermediary of a secure payment service provider, which has sole access to such data;

• the information which you send us when you contact customer services or the retailer through the NrgClever Platform (contents of any exchanges, nature of complaint, return of products, etc.);

• your login and browsing data for the NrgClever Platform (IP address, the products and pages which you viewed or searched for);

• the data relating to your consultation of the emails which we send for statistical and marketing purposes;

• the information which you provide when you leave a comment on the Platform;

• information on your viewing of our ads;

• the information which you provide when you take part in promotions, competitions or events which we organise.

4. How long do we keep your data?

We only keep your data in our database for the period of time required in order to achieve our objectives and then we archive it, with restricted access, for an additional period of time in order to comply with our legal and/or regulatory archiving obligations and for the applicable limitation periods. At the end of this additional period, your data will be permanently erased from our databases.

5. Who is your data sent to?

5.1 To our service providers

Your data can be accessed by the service providers which we use in order to subcontract all or part of the processing of your data (the hosting of the Platform and data, maintenance, sending order confirmation emails, emailing, secure payment, etc.).

The subcontractors that we use provide the guarantees required by the applicable regulations on data protection. They only have access to the data which they need in order to perform their services and are not authorised to process your data for other uses. We have, moreover, executed agreements with each of them in order to guarantee the security and integrity of your data and that it is processed in compliance with the applicable regulations.

5.2 To the retailers on the Platform and their transporters

The data required in order to manage your orders is sent to the retailers from which you have purchased a product through the NrgClever Platform.

The data which makes it possible to ensure the delivery of your order is also forwarded to the transporter that you have selected or that is proposed when you place your order.

5.3 To the administrative authorities

Your personal data may be disclosed to the administrative authorities pursuant to a law, regulation or a decision of an appropriate regulatory or judicial body.

In general, we undertake to comply with all the legal rules which might prevent, limit or regulate the distribution of information or data, including in particular the data protection regulations.

5.4 In the event of an acquisition, merger or business transfer

If NRG CLEVER or part of its business activities is acquired by a third party company or in the event of a merger, we will notify you in advance of the transfer of your data and of your right to object to that transfer.

6. What rights do you have over your data and how can you exercise them?

6.1 What are your rights?

You have the right to obtain the following from us:

·         confirmation concerning whether or not your personal data is processed and the right to access it, if so;

·         the rectification of any of your personal data which is inaccurate or incomplete;

·         in certain circumstances, the deletion of your personal data;

·         in certain circumstances, a restriction on the processing of your personal data;

·         the portability of your personal data;

·         the organisation of the fate of your personal data in the event of your death (preservation, deletion or disclosure to a named person).

You also have the right to refuse, in certain circumstances, the processing of your personal data.

For further information on your rights with regard to your data, please consult the CNIL (French Data Protection Agency) site: www.cnil.fr.

You can also, at any time, refuse that your data be used for marketing purposes and withdraw your consent to any data processing which we have undertaken for the purposes of behavioural advertising, analysis of browser behaviour and audience measurements.

We also remind you that you have the right to make a complaint to the CNIL, if you consider that your rights have not been respected.

6.2 How can you exercise your rights?

For any requests concerning your right of access, right to object, right to rectification, right to data portability, right to restriction of processing and the fate of your data in the event of your death: Please send an email to the following address: store@nrg-clever.com:

·         stating the purpose of your request;

·         stating your surname and first name;

·         attaching a photocopy of both sides of your national ID card or passport, so that we can check your identity.

We will reply as soon as practicable and in any event within a period of one month from receipt of your request.

To refuse that your data be used for marketing purposes:

You can send us an email to the following address: store@nrg-clever.com or click on the unsubscribe link in our marketing emails and in our newsletter.

We undertake to remove you from our mailing list as soon as practicable.

To withdraw your consent to the processing of your data for the purposes of behavioural advertising, analysis of browser behaviour and audience measurements:

You can send us an email at the following address: store@nrg-clever.com or configure your cookie settings.

7. Is your data transferred outside the European Union?

Certain processing acts which we entrust to our subcontractors are performed outside the European Union. Agreements have been executed with each of these service providers in order to ensure that your data is transferred in a secure manner and in compliance with the applicable data protection regulations.

8. Contacting the Data Protection Officer

For any question concerning the processing of your personal data or in order to exercise your rights with regard to your data, the Data Protection Officer (DPO), designated by NRG CLEVER, can be contacted:

• by email at the following address: store@nrg-clever.com;

• by post at the following address:

• NRG CLEVER CO. LTD
  Via Konstantin Velickov 13 rione Odesos
  9000 Varna, Bulgaria
  
  

OUR COOKIES

1. What is a cookie?

A cookie is a small file of letters and numbers which is stored on the User's computer, smartphone, tablet, mobile device, etc, when he logs in to the Platform.

2. What cookies are used on the Platform?

On our Platform, we use cookies to make it possible for us to:

• improve your browsing experience on the Platform and thus enable you to use its various features, for example to enable you to log in and sign in to your user account;

• prepare statistics, count the volume of traffic and see how visitors use the various elements which make up the Platform (sections and contents viewed, browsing pattern, date and time of viewing...), which helps us make the Platform more interesting and easier to use;

• recognise your browser as a registered past visitor, remember all the preferences which may be sent by your browser when using the Platform, including keeping track of your shopping basket;

• measure the traffic on our Platform;

• grant you access to restricted and personal spaces on our Platform, such as your account, thanks to the login names or data which you may have provided us with at an earlier date;

• implement security measures.

As such, and with regard to cookies which are not exclusively intended to enable or facilitate browsing or which are not strictly required for the management of your orders or the supply of services, an information banner is displayed when you log in to the Platform so that you are notified before any cookies are downloaded, (1) of their presence and (2) so as to allow you, if you wish, to refuse the downloading of cookies on your device.

The cookies stored when you use the Platform do not make it possible for us to identify you personally but information is saved regarding your device's browsing experience of the Platform which we can then read when you later return to the Platform.

The information harvested is for our own exclusive use and that of our partners, and will in no event be transferred to third parties.

3. How can you disable the cookies?

There are several ways in which you can manage cookies.

You are informed that any setting which you may configure may change your web-browsing experience and your terms of access to certain services which require the use of cookies. Your attention is drawn to the fact that a certain number of features which are required for browsing the Platform may be adversely affected by the settings which you have configured (problems with saving or displaying information...).

We will in no event be held liable for any problems noted, if applicable.

You can decide to express your wishes and modify your settings with regard to cookies at any time, by the means described below.

The choices offered by your browser software for cookie settings:

You can configure your browser software so that cookies are saved in your device or, on the contrary, are refused, either automatically or depending on the person who creates them.

You can also configure your browser software so that you are offered the specific choice to accept or refuse cookies, before a cookie can be saved in your device.

The configuration of each browser is different with regard to the management of cookies and your choices. It is described in your browser's help menu, which will provide you with information on how to change your cookie settings.

• For Internet Explorer™ 7 and 8:http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

• For Internet Explorer™ 9 : http://windows.microsoft.com/fr-fr/windows7/how-to-manage-cookies-in-internet-explorer-9

• For Safari™ : http://support.apple.com/kb/PH5042

• For Chrome™ : version 30 and plus http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

• For Firefox™ : version 24 and plus https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

For site traffic cookie settings:

If you do not want us to save audience measurement cookies in your device, you can click on the following link: https://tools.google.com/dlpage/gaoptout?hl=fr,, which will save a cookie in your device, the sole purpose of which is to opt out of the audience measurement services which we operate.

N.B. Compliance with your wishes is based on the creation of a cookie. If you delete all the cookies saved on your device (through your browser), we will no longer be aware that you have chosen this option.

For Snowplow web analysis cookie settings:

Cookies from the tracking solution provided by Snowplow Analytics Limited, at 32-38 Scrutton Street, London, United Kingdom ("Snowplow"), which are installed on our Platform, provide us with information concerning the number of users who visited our Platform and the time when they did so, what browser or operating system they use and the site they came from in order to arrive at our Platform.

These cookies provide us with information about:

• the contents and value, in euros, of your shopping basket, even if the transaction is not finalised;

• the contents of your searches on the site;

• your time stamp;

• your location (geolocation to the nearest town, based on your IP address);

• the landing page URL and the URL for the website which you came from;

• your pseudonymised IP address;

• the name, version, language and window size of your browser and operating system, as conveyed by your browser.

This information enables us to improve our services and the user experience.

You can configure your browser settings to block Snowplow cookies. For further information, see Snowplow's privacy policy: consultez la politique de confidentialité de SnowPlow:

For Content Square cookie settings:

ContentSquare is a solution which aggregates data concerning the number of visitors to and the use of our Platform, in order to improve the user experience. The statistics obtained are anonymous.

You can block the harvesting and storage of Content Square cookies at any time by clicking on the following link: http://optout.contentsquare.net/.

An opt-out cookie is stored on your device. If you delete your cookies, you will have to click on the link again.

For the cookie settings for Google Inc.'s remarketing or "Similar Audiences" features

We use Google Inc.'s Remarketing and Similar Audiences features on our website (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, "Google") to analyse the behaviour and interests of visitors to our Platform. The placing of cookies by Google makes it possible to analyse your use of the Platform and thus create ads based on your interests, including in particular to:

• create similar user profiles to that of the visitors to our Platform (Similar Audiences);

d’afficher des annonces personnalisées en fonction de votre parcours sur la Plateforme lorsque vous visitez un autre site Web sur le

• display ads which are tailored to the way in which you browse the Platform when you visit another website on Google Display Network (Remarketing).

You can permanently disable the use of cookies by Google by clicking on the following link and by downloading and installing the plug-in which is provided: https://support.google.com/ads/answer/7395996?hl=fr

You can also disable the use of third-party cookies by selecting the Network Advertising Initiative opt- out page at the following address: https://www.networkadvertising.org/choices/

For further information on Google's privacy policy, see: https://www.google.com/privacy/ads/

For AppNexus cookie settings:

NWe use the tracking technology from AppNexus Inc., 28 W 23rd Street, 4th floor, New York, NY - 10010, USA ("AppNexus") to analyse traffic on our Platform for the creation of user profiles under pseudonyms, in order to send targeted ads to users with a similar profile.

To block the harvesting and storage of cookies by AppNexus, you can configure your browser settings and/or consult AppNexus's privacy policy at the following address: https://www.appnexus.com/fr/company/platform-privacy-policy-fr

For the Google Adwords conversion tracking cookie settings

We use the online advertising programme "Google AdWords" on our website and, in that context, conversion tracking (rating of views), an analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, "Google").

When you click on an ad delivered by Google, a conversion tracking cookie is placed on your computer. These cookies have a limited period of validity, do not contain any personal data and are not, therefore, used for personal identification. If you visit certain pages of our Platform and the cookie has not expired, we can identify, as can Google, the fact that you have clicked on the ad displayed in the Google search engine and that you were redirected to that page.

The information obtained from the conversion cookie is used to create conversion statistics. This provides us with the total number of users who clicked on one of our ads and who were redirected to a conversion tracking tag page. However, we do not receive any information which identifies the users personally.

You can prevent cookies being stored by selecting the appropriate technical settings on your browser software. However, we draw your attention to the fact that, in that case, you will not be able to use all the features of the Platform as a whole and you will not be included in the conversion tracking statistics.

You can also disable personalised ads in the Google Ads settings. For further information, see: https://support.google.com/ads/answer/2662922?hl=fr

You can also configure the use of third-party cookies by clicking on the following link: https://www.networkadvertising.org/choices/

For further information and for Google's privacy policy, refer to: https://www.google.com/policies/privacy/

For Criteo cookie settings

Criteo harvests information on your browsing behaviour through the use of cookies installed on our Platform which record the following pieces of information:

• Events connected to your activity on our Platform (e.g. the number of pages seen, the products viewed, the searches made);

• Information on your device (type of device, operating system, version)

• General information regarding your location and information concerning your abbreviated IP address. Accordingly, you can only display ads for products which are actually available in your country, region or town.

• Events connected to the running of Criteo ads, such as the number of ads you see.

We also automatically harvest the following information:

• IP addresses,

• the browser which you use,

• your internet service provider (ISP),

• the reference or the pages which you have viewed on our Platform (such as the HTML pages, images, etc.),

• your operating system,

• the date and time of log-in or aggregate data on the aggregate clicks, which we need in order to analyse trends and optimise our services.

You can configure your browser settings to block Criteo cookies. For more information, see: https://www.criteo.com/fr/privacy/

For the Facebook remarketing cookie settings:

We use the Facebook "Custom Audiences" remarketing feature on our website (1601 S. California Ave, Palo Alto, CA 94304, USA, "Facebook").

The Facebook remarketing tracker installed on our Platform allows for information concerning the pages visited on our Platform to be sent to the Facebook server. Facebook allocates this information to your personal Facebook user account. When you visit the Facebook social network or a site on the Facebook network, you will then see personalised ads which are based on your interests.

You can disable the "Custom Audiences" remarketing feature in your browser settings.

For more information on the harvesting and use of data by Facebook, on your rights and options concerning the protection of your privacy in Facebook's privacy policies, see: https://www.facebook.com/about/privacy/

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