The company KILMA JONAK (hereinafter "JONAK"), concerned about respect for your privacy and compliance with Law No. 78-17 of January 6, 1978 relating to data, files and freedoms in its amended version and other applicable French and EU legislation and in particular the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 - hereinafter "GDPR"), hereby informs you of how your personal data are collected and processed during your visit to the website www.jonak.fr.
 
Thank you for your attention to the following information.
 
In the context of your visit to the website https://www.jonak.fr/ and the dedicated application (collectively referred to as the "Site") published by JONAK, JONAK may collect and process personal data.
 
For a better understanding of the present policy, it is specified that :

 

JONAK implements and operates the processing of personal data relating to Internet users and Customers in order to ensure the proper functioning of the Site and the services offered therein.
 
The purpose of this policy is to satisfy KILMA JONAK's obligation to provide information and to formalize the rights and obligations of Internet users and customers with regard to the processing of their personal data.
 
The present personal data protection policy applies to visits to the Site and orders placed on the Site.
 
The processing of personal data may be managed directly by JONAK or through a subcontractor specifically appointed by JONAK.

 

Personal data is any type of information that can be directly or indirectly attributed to you. This may include name, address, e-mail address, telephone number, payment information and order form.
 
Usage history, IP address and member ID may also constitute personal data, as may other types of information you provide when contacting our customer service department.

 

No processing is carried out by JONAK concerning Internet users' or Customers' data if it does not concern personal data collected by or for JONAK or processed in connection with visiting the Site or placing an order on the Site and if it does not comply with the general principles of the RGPD.

Any new processing, modification or deletion of existing processing will be brought to the attention of Internet users and Customers by means of an amendment to this policy.

 

NON-TECHNICAL DATA (as applicable) :
 

• Identification: surname, first name, title, date of birth
• Contact details: telephone number, e-mail address, postal address and country of residence, postal billing address, postal delivery address
• Information relating to orders and the follow-up of the commercial relationship: details of products purchased, quantities, amounts, terms of payment, any discounts granted.
• Information relating to the person placing the order: size, shoe size, gender, etc.
• Information relating to participation in competitions and/or promotional operations: date, frequency, responses to competitions, prizes awarded, etc.

.
TECHNICAL DATA (depending on use)
 

• Identification data (IP, MAC, cookies and other online identifiers)
• Connection data (connection and usage logs, IP address, login, password to access customer account)
• Information on the device and browser used, including location data.
• Origin of data collected by JONAK

 
JONAK collects your data from :
 

• Data provided by the Internet user when visiting the Site or creating a Customer Account
• Data provided by the Customer when creating a Customer Account, logging in to a Customer Account, placing an order on the Site, requesting the return of a JONAK item.
• Data provided by a JONAK recruitment candidate
• Data provided by a customer when writing a comment or review on a JONAK article
• Registration or subscription to our online services (access to social network accounts, newsletter subscription, etc.);
• Exchanges via Customer Service.
• When the customer shares a review with a friend by sending an e-mail from an item file,
• When the customer shares a review via Facebook, Google +, Twitter, or Pinterest from an item file.

This list is not exhaustive.
 
JONAK does not knowingly collect personal data directly from minors.
 
The Site is intended for the general public but exclusively for natural persons of legal age, and is not intended for children and is not intended to be used by them.

 

As the case may be, KILMA JONAK processes your data for the following purposes:
 

• Management and follow-up of the creation of an online Customer Account by an Internet user
• Management and follow-up of orders placed on the Site
• Management and tracking of delivery operations for orders placed on the Site
• Tracking and management of payment operations for orders placed on the Site
• Management of newsletter subscriptions
• Follow-up and management of the relationship with the Customer(s): Management of complaints and the implementation of guarantees related to the JONAK product, Management of product returns and refunds,
• Answering customer service queries
• Implementation and improvement of the Site's services and functionalities
• Responses to administrative obligations;
• Allocation of a store near you
• Management of commercial prospecting operations by e-mail, sms, mobile notification, social networks
• Management of participation in competitions and/or promotional operations, including via social networks
• Sending your unfinished shopping cart by e-mail
• Processing applications for recruitment at JONAK
• Depositing cookies to offer content and targeted advertising tailored to your interests
• Statistics

JONAK collects personal data in order to offer you its products and services in the best conditions.
 
JONAK does not pass on this data to third parties, nor does it market the data it collects.
 
If you do not provide the requested data, JONAK may not be able to provide you with the Site or its products and services.

 

The purposes of the data processing described above are based on the following conditions of lawfulness:
 

• Consent of the data subject, i.e. the Internet user or Customer
• Pre-contractual or contractual performance,
• Legitimate interest,
• When required by law. 

 
For the majority of the processing operations listed above, JONAK seeks your consent to use your personal data. However, your consent is not required in certain situations, as we may use your data for our own legitimate interests, to fulfill a contract with you, or to comply with legal obligations imposed on us. 
For example, when you visit the Site, JONAK has a legitimate interest in using your browsing data to improve the operation of the Site, and when you interact with JONAK online, it has a legal obligation to ensure that you do not attempt to defraud it or a third party.
You are informed that JONAK may deny you access to certain information or products and services if you do not consent to provide the necessary personal data.

If you disclose to JONAK, or to its service providers and subcontractors, personal data concerning other persons, you declare that you have the authority to do so and that you allow JONAK to use this information in accordance with this privacy policy.
 
JONAK is not in a position to verify the accuracy or authenticity of the data you provide.

 

For certain services on the Site, your transmission of personal data to JONAK is imperative (for example, to create a Customer Account, to place an order, to subscribe to the newsletter).
 
In these cases, you will be informed on each personal data collection form of the compulsory or optional nature of the answers to be provided by means of an asterisk.
 
In the case of compulsory answers, JONAK will not be able to provide access to the service sought by the Internet user or Customer.
 

KILMA JONAK makes several third-party payment services available to you in order to finalize your order.
 
The banking service providers chosen when the order is placed collect and process data concerning your means of payment (credit card number, identification of the credit card holder, expiry date of the credit card, visual cryptogram - the latter is not retained, etc.).

Payment processes are secure.
 
JONAK has no control over, and is not responsible for, the collection, use or disclosure of your personal data by this third party.

 

KILMA JONAK is granted the right to use and process the personal data collected for the purposes set out above.
 
However, enriched data resulting from processing and analysis by KILMA JONAK, otherwise known as enriched data, remains the exclusive property of KILMA JONAK (usage analysis, statistics, etc.).
 

JONAK ensures that the personal data you provide is only accessible to authorized internal or external recipients.

Internal recipients :
 

• Staff of KILMA JONAK or any other natural or legal person that KILMA JONAK may appoint or substitute for the management of its Website or for the execution of contracts entered into with Customers.
• Trainees
• Communication department
• IT department

External technical recipients:
 

• Service providers or support services (e.g. IT service provider, reprographics, etc.)
• Administration

External recipients :
 

• Any participant or employee of KILMA JONAK
• Any public authority or administration

 

KILMA JONAK is a French company.
The personal data collected is stored on a database located in France.

Some data, such as payment information, may be stored in other databases.
Your personal data may be subject to the laws of the countries in which it is stored or used.
By providing personal data to KILMA JONAK, you understand that your data may be transferred, processed or stored outside your country of residence, which may have a different data protection regime to that of the country in which you reside.
In certain circumstances, the courts, law enforcement agencies, regulatory bodies or authorities responsible for security in these other countries may have the right to access your personal data.
The data retention period is defined by KILMA JONAK according to the purposes for which the data is processed.
 
JONAK will only process your data for as long as is necessary:
 

• To fulfill its contractual obligations
• To provide your customer account. Information collected and processed for this purpose will be deleted when the account is closed.
• To assist you with our Customer Service. We may continue to retain and use your data if we have outstanding obligations to you or if, for any other reason, we do not have the right to delete it.
• To fulfil the purposes of competitions and any associated legal obligations
• To provide you with marketing offers and promotions. We will stop processing your data for marketing purposes if you close your customer account or actively refuse any further marketing communications from us.
• Where data is collected for law enforcement purposes, the retention period will vary depending on the purpose, context and specific local legal requirements.

 
Once this period has elapsed, the data is either deleted or stored anonymized.
 
Internet users and customers are reminded that deletion or anonymization are irreversible operations and that KILMA JONAK is no longer able to restore them.


 

Right of access (right to copy)
 
You have the right to ask JONAK to confirm whether or not data concerning you is being processed.
 
Internet users and customers also have a right of access, subject to compliance with the following rules:
 

• The request must be made by the person concerned, accompanied by a copy of an up-to-date identity document;
• The request must be made in writing to the following e-mail address: sav@jonak.fr

 
Internet users and customers have the right to request a copy of their personal data processed by KILMA JONAK.
 
Please note that this right of access does not apply to confidential information or data that may not be disclosed under the law.
 
Updating and rectification
 
Internet users and customers have the right to rectify, update or update their personal data transmitted to KILMA JONAK.
 
In order to regularly update the personal data collected by KILMA JONAK, KILMA JONAK may request Internet users and customers to update and update the data collected.
 
KILMA JONAK will not be held responsible for a lack of updating if Internet users and customers do not update their data.

Right to erasure
 
The right to erasure of data does not apply in cases where processing is carried out in order to comply with a legal obligation.
 
Apart from this situation, it is possible to request the deletion of data in the following limited cases:
 

• When personal data is no longer required for the purposes for which it was collected or processed;
• When the data subject objects to processing that is necessary for the purposes of the legitimate interests pursued by KILMA JONAK and there is no compelling legitimate reason for the processing;
• Where the personal data collected has been processed unlawfully.

 
Right to restriction
 
You have the right to ask us to restrict the processing of your personal data in the following circumstances:
 

• If you object to processing based on our legitimate interest, we are obliged to pause any processing of such data pending verification of the legitimate interest ;
• If you have declared that your personal data is incorrect, we must restrict any processing of that data pending verification of its accuracy;
• If we no longer need your personal data, but it is necessary to assert your rights.

You are informed that this right is not intended to apply insofar as the processing carried out by KILMA JONAK is lawful and all personal data collected is necessary for the performance of the services offered on the Site.
 
The right to limitation is subject to compliance with the following rules:
the request must be made by the individual himself/herself and be accompanied by a copy of an up-to-date identity document;
the request must be made in writing to the following e-mail address: sav@jonak.fr
 
Right to portability
 
Whenever we process your personal data, by automated means based on your consent or on the basis of a contract, you have the right to request that a copy of your data be transferred to you or to another party. This only applies to personal data that you have provided to us.
 
Post-mortem rights
 
Internet users and customers are informed that they have the right to formulate directives concerning the conservation, deletion and communication of their post-mortem data.
 
The communication of specific post-mortem directives and the exercise of their rights can be made by e-mail to the address: sav@jonak.fr accompanied by proof of identity.

 

For all the above-mentioned rights to which you are entitled in accordance with European legislation on the protection of personal data, you are informed that these are rights of an individual nature which can only be exercised by the natural person concerned in relation to his or her own information and data.
 
To meet this obligation, we will do our best to verify the identity of the person wishing to exercise any of the above rights.
 
KILMA JONAK shall not be held liable in the event of a fraudulent request or the transmission of an inauthentic identity document.

The company KILMA JONAK informs you that it may involve any subcontractor of its choice in the processing of personal data of Customers or Internet users.
 
In this case, JONAK ensures that the subcontractor complies with its obligations under the RGPD.
 
KILMA JONAK undertakes to sign a written contract with all its subcontractors and imposes the same data protection obligations on subcontractors as it does.
 
JONAK further reserves the right to audit its subcontractors in order to ensure the compliance of the subcontractor's activity with the legislation.

 

KILMA JONAK is responsible for defining and implementing the physical or logical technical security measures it deems appropriate to prevent the accidental or unlawful destruction, loss, alteration or unauthorized disclosure of the data collected.
 
These measures mainly include:
 

• Security of access to our computers and smartphones (access codes modified regularly);
• Data access authorization management (specific to our finance, accounting and communications departments);
• VPN for remote connections;

 
To this end, KILMA JONAK may engage the assistance of any third party of its choice to carry out vulnerability audits or penetration tests at intervals it deems necessary.
 
In any event, JONAK undertakes, in the event of a change in the means used to ensure the security and confidentiality of personal data, to replace them with means of superior performance. No change may lead to a reduction in the level of security.
 
In the event of subcontracting all or part of the processing of personal data, JONAK undertakes to contractually impose security guarantees on its subcontractors by means of technical data protection measures and appropriate human resources.

 

In the event of a personal data breach, the company KILMA JONAK undertakes to notify the competent authority under the conditions prescribed by the RGPD.
 
If said violation poses a high risk to Internet users and/or Customers and the data has not been protected, the company KILMA JONAK :
 

• Will immediately notify the Internet Users and Customers concerned;
• Provide the Internet users and customers concerned with the necessary information and recommendations.

In such a context, JONAK reminds you that you also have the right to lodge a complaint with a supervisory authority, depending on the country in which you reside, if you consider that the processing of personal data does not comply with European data protection regulations.

 

The present policy may be modified or amended at any time in the event of changes in legislation, case law, decisions and recommendations by the competent authorities or practices.
 
Any new version of this policy will be brought to the attention of Internet users and Customers by any means chosen by KILMA JONAK, including electronic means (e.g. distribution by e-mail or online).

Customer: refers to any natural person who has placed or is placing an order or purchase online.
 
Customer Account: designates the personal account created by a future Customer in order to proceed with an online order or purchase, or a personal account created by a Customer during an online order.
 
Recipients: refers to the natural or legal persons who receive communication of personal data. Data recipients may therefore be both internal recipients and external organizations (support service providers, government agencies, etc.).

Personal data: refers to information, in any form whatsoever, relating directly or indirectly to an identified or identifiable individual, such as surname, first name, date of birth, membership number, social security number, IP address, connection data....

Internet user: refers to any person who visits the Website for information purposes, regardless of their status (visitor, JONAK recruitment applicant or customer).
 
Data controller: refers to the natural or legal person who determines the purposes and means of processing personal data. For the purposes of this policy, the data controller is JONAK;
 
"Sub-processor": refers to any natural or legal person who processes personal data on behalf of the controller. In practice, this means the service providers with whom JONAK works and who process personal data;
 
Site: refers to the website accessible at https://www.jonak.fr/