PREAMBLE

This privacy policy informs you about how Glowe Studio uses and protects the information you provide us when you use this website available at the following URL: glowe-studio.com (hereinafter referred to as the "Site").

Please note that this privacy policy may be modified or supplemented at any time by Glowe Studio, in particular to comply with any legal or technological changes. In such a case, the update date will be clearly identified at the beginning of this policy. These modifications engage the user as soon as they have been informed of the updated privacy policy being posted and have accepted it.

ARTICLE 1. PARTIES

This privacy policy is applicable between the Site publisher, hereafter “the Publisher”, and any person connecting to the Site, hereafter “the User”.

ARTICLE 2. DEFINITIONS

“Site Contents”: elements of any nature published on the Site, protected or not by intellectual property rights, such as texts, images, designs, presentations, videos, diagrams, structures, databases, or software.

“Publisher”: Glowe Studio, acting as the publisher of the Site.

“User”: any person connecting to the Site.

“Site”: internet website accessible at the URL glowe-studio.com, as well as sub-sites, mirror sites, portals and URL variations thereof.

ARTICLE 3. SCOPE OF APPLICATION

This privacy policy is applicable to all Users. Clicking on “I accept” during your registration on the Site will constitute your full and complete acceptance of it. Similarly, clicking on “I accept” in the information banner regarding cookies displayed on the Site confirms your acceptance, while allowing you to personalize the cookies that will or will not be applied to you. You acknowledge by the same fact to have fully understood and accept them without restriction.

The User acknowledges the proof value of the Publisher’s automatic recording systems and, except for him or her providing evidence to the contrary, he or she renounces to contest them in case of a dispute.

Acceptance of this privacy policy assumes that Users have the necessary legal capacity for this, or that they are at least 16 years old, or if not, that they have the authorization from a guardian or curator if they are incapable, from their legal representative if they are under 16, or that they hold a mandate if they act on behalf of a legal entity.

ARTICLE 4. PERSONAL DATA

In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on April 14, 2016, and the national law in force, the Publisher provides you with the following information:

4.1. IDENTITY OF THE DATA CONTROLLER

The data controller for the collection and processing of data on the Site is Glowe Studio.

4.2. DATA COLLECTION BY THE PUBLISHER

4.2.1. DATA COLLECTED

4.2.1.1 DATA COLLECTED DURING NAVIGATION ON THE SITE

When navigating on the Site, you consent to the Publisher collecting information related to: the content you view and click on; demographic data; the device used and its software environment; your location; your connection data (times, IP address…).

4.2.1.2. DATA COLLECTED WHEN USING THE CONTACT FORM OR CONTACT EMAIL ADDRESS

Using the contact form or the contact email address by the User implies the collection by the Publisher of the following personal data: first name, last name, email address*, phone number.

Personal datamarked with an asterisk are mandatory for the use of the contact form. Users not wishing to provide the information required for the use of the contact form will not be able to send a message to the Publisher directly from the Site.

4.2.1.3. DATA COLLECTED DURING REGISTRATION ON THE SITE

Using the registration form by the User implies the collection by the Publisher of the following personal data: first name*, last name*, postal address*, email address*, date of birth, phone number.

Personal data marked with an asterisk are mandatory for registration on the Site. Users not wishing to provide the information required for the use of the registration form will not be able to register directly from the Site.

4.2.1.4. DATA COLLECTED WHEN USING THE NEWSLETTER FORM

In the context of using the newsletter form, the Publisher may be led to collect and process: your email address.

4.2.2. PURPOSES OF COLLECTING PERSONAL DATA

The data collected during navigation are subject to automated processing with the purpose of:

• Verifying the identity of persons;
• Ensuring and improving the security of services;
• Developing, operating, improving, providing, and managing the Site;
• Contextualizing and improving the User's experience;
• Sending information and contacting persons, including by email;
• Targeting advertising content;
• Avoiding any illicit or illegal activity;
• Enforcing the terms of use of the Site.

The data collected during the use of the contact form or the contact email address are subject to automated processing with the purpose of:

• Verifying the identity of persons;
• Ensuring and improving the security of services;
• Contextualizing and improving the User's experience;
• Sending information and contacting persons, including by email;
• Targeting advertising content;
• Avoiding any illicit or illegal activity.

The data collected during registration are subject to automated processing with the purpose of:

• Executing its contractual commitments;
• Verifying the identity of persons;
• Ensuring and improving the security of services;
• Developing, operating, improving, providing, and managing the Site;
• Contextualizing and improving the User's experience;
• Sending information and contacting persons, including by email;
• Avoiding any illicit or illegal activity;
• Enforcing the terms of use of the Site.

The data collected during the use of the newsletter form are subject to automated processing with the purpose of:

• sending newsletters to the User.

4.2.3. LEGAL BASIS FOR PROCESSING

The data collected during navigation are based on the legitimate interest of the Publisher, namely to perform an analysis of behaviors on the Site and to obtain improved security and functioning of the Site. Some of these data, like those resulting from the placement of certain cookies, may have the consent of the persons as their legal basis.

The data collected during the use of the contact form or the use of the contact email address are based on the consent of the concerned persons.

The data collected during registration are based on a contractual relationship.

The data collected during the use of the newsletter form are based on the consent of the concerned persons.

4.2.4. RECIPIENTS OF THE DATA

The collected data are accessible only to the members of the Publisher's management, the staff in charge of preparing your order as well as the staff in charge of the management of the Site, and are never freely viewable by a third-party individual.

4.2.5. DURATION OF STORAGE OF PERSONAL DATA

Personal data collected during navigation are stored for a reasonable duration necessary for the proper administration of the Site and for a maximum of 12 months, or until the withdrawal of consent by the concerned persons.

Personal data collected during the use of the contact form or when sending to the contact email address are stored for a reasonable duration necessary for the proper management of the User's request, and for a maximum of 12 months.

The data collected during registration are stored for the duration of the contractual relationship between the Publisher and the User.

The data collected during the use of the newsletter form are stored until the withdrawal of consent by the concerned persons.

At the end of each of these periods, the Publisher will archive these data and keep them for the period during which its liability could be invoked.

After this retention period, the Publisher commits to definitively delete the data of the concerned persons.

4.2.6. SECURITY AND CONFIDENTIALITY OF PERSONAL DATA

Personal data are stored in secure conditions, according to the current means of the technique, in compliance with the provisions of the General Regulation for the Protection of Data and the national law in force.

4.2.7. MINIMIZATION OF PERSONAL DATA

The Publisher may also collect and process any data voluntarily transmitted by a User, notably via the free field of the contact form.

The Publisher guides Users as much as possible when they provide unnecessary or superfluous personal data.

The Publisher commits to keep and process only the data strictly necessary for its activities and will delete any data received not useful as soon as possible.

4.3. RESPECT OF RIGHTS

You have the following rights concerning your personal data, which you can exercise by writing to our postal address or by sending an email to the following address: contact@glowe-studio.com or by phone at 0756924901.

4.3.1. RIGHT TO INFORMATION, ACCESS, AND COMMUNICATION OF DATA

You have the possibility to access the personal data concerning you.

Due to the obligation of security and confidentiality in the processing of personal data which is incumbent on the Publisher, your request will only be processed if you provide proof of your identity, notably by producing a scan of your valid identity document (in case of a request via our electronic form) or a signed photocopy of your valid identity document (in case of a written request), both accompanied by the phrase “I certify on the honor that the copy of this identity document is conform to the original. Done at … on …”, followed by your signature.

To help you in your approach, you will find here a model letter elaborated by the CNIL.

4.3.2. RIGHT TO RECTIFICATION, DELETION, AND RIGHT TO FORGET DATA

You have the possibility to request the rectification, updating, locking, or even the deletion of your personal data which may turn out to be inaccurate, erroneous, incomplete, or obsolete.

You can also define general and specific directives regarding the fate of personal data after your death. In such case, the heirs of a deceased person may demand to take into consideration the death of their relative and/or to make the necessary updates.

To help you in your approach, you will find here a model letter elaborated by the CNIL.

4.3.3. RIGHT TO OPPOSITION TO DATA PROCESSING

You have the possibility to oppose a processing of your personal data.

To do so, you will need to send an email to the following address: contact@glowe-studio.com. In this email, you will need to specify the data you wish to delete and the reasons justifying this request, except in the case of commercial prospecting.

4.3.4. RIGHT TO DATA PORTABILITY

You have the right to receive the personal data that you have provided to us in a transferable, open, and readable format.

4.3.5. RIGHT TO LIMITATION OF PROCESSING

You have the right to request that the processing of your personal data by the Publisher be limited. Thus, your data can only be stored and no longer used by the Publisher.

4.3.6. WITHDRAWAL OF CONSENT

Your consent is essential to the processing of your data by the Publisher. However, it is possible for you to withdraw it at any time. This withdrawal will lead to the deletion of the personal data concerning you.

Nevertheless, the services requiring the processing of your data by the Publisher will no longer be accessible.

4.3.7. RESPONSE TIMES

The Publisher commits to respond to your request for access, rectification, or opposition or any other additional request for information within a reasonable timeframe which shall not exceed 1 month from the receipt of your request.

4.3.8. COMPLAINT TO THE COMPETENT AUTHORITY

If you consider that the Publisher does not comply with its obligations regarding your personal information, you can submit a complaint or request to the competent authority. In France, the competent authority is the CNIL to which you can send a request electronically.

4.4. TRANSFER OF COLLECTED DATA

4.4.1. TRANSFER TO PARTNERS

The Publisher informs you that we use authorized service providers to facilitate the collection and processing of the data you have communicated to us. These providers may be located outside of the European Union and have communication of the data collected through the Site.

The Publisher has previously ensured the implementation of adequate guarantees and the compliance with strict conditions regarding confidentiality, use, and data protection, for example through the US Privacy Shield.

4.4.2. TRANSFER UPON REQUISITION OR JUDICIAL DECISION

The User also consents to the Publisher communicating the collected data to any person, upon requisition of a state authority or by judicial decision.

4.4.3. TRANSFER IN THE EVENT OF A MERGER OR ACQUISITION

If the Publisher is involved in a merger, asset sale, financing operation, liquidation, or bankruptcy, or in the acquisition of all or part of its business by another company, the User consents to the data collected being transmitted by the Publisher to this company and that this company operates the personal data processing referred to in this privacy policy instead of the Publisher.

ARTICLE 5. POLICY RELATING TO COOKIES/TRACKERS

When you first connect to the Publisher's Site, you are warned by a banner at the bottom of your screen that information relating to your navigation may be stored in files called "cookies". Our cookie use policy allows you to better understand the provisions we implement in terms of navigation on our Site. It informs you about all of the cookies present on our Site, their purpose, and gives you the procedure to set them.

5.1. USE OF TRACKERS/COOKIES

The Publisher of this Site may implant a cookie and other trackers on the hard drive of your terminal (computer, tablet, mobile etc.) to guarantee you a smooth and optimal navigation on our website.

"Cookies" (or connection witnesses) are small text files of limited size that enable us to recognize your computer, tablet, or mobile for the purpose of personalizing the services we offer you.

To better inform you about the information that cookies identify, you will find below a table listing the different types of cookies that may be used on the Publisher's site, their name, purpose as well as their storage duration.

5.2. PURPOSES OF TRACKERS

With the help of the information contained in the trackers and cookies used, the Publisher can analyze the attendance and use made of the Site and, if necessary, facilitate and improve the navigation, perform prospecting operations, compile commercial statistics, or display targeted advertisements.

5.3. TRACKERS USED

 

5.4. SETTING YOUR COOKIE PREFERENCES

When you first connect to the Publisher's Site, a banner briefly presenting information about the deposit of cookies and similar technologies appears at the bottom of your screen. This banner warns you that by continuing your navigation on the Publisher's Site (by loading a new page or by clicking on various elements of the Site for example), you accept the deposit of cookies on your terminal. You are deemed to have given your agreement to the deposit of cookies by clicking on the "I accept" icon, either globally or individually. Conversely, you are deemed to have refused the deposit of cookies by clicking on the "I refuse" icon, again, this choice can bear on all or only some of the cookies. In the absence of choice, you are deemed to have refused the deposit of cookies. Your decision is kept for 6 months and can be modified at any time.

5.4.1 COOKIES EXEMPT FROM CONSENT

In accordance with the recommendations of the National Commission for Information Technology and Civil Liberties (CNIL), certain cookies are exempted from prior collection of your consent insofar as they are strictly necessary for the operation of the website or have the sole purpose of enabling or facilitating communication by electronic means. This includes session ID, authentication, load balancing session cookies as well as cookies for personalizing your interface. These cookies are fully subject to this policy insofar as they are issued and managed by the Publisher.

5.4.2 COOKIES REQUIRING THE PRIOR COLLECTION OF YOUR CONSENT

This requirement applies to third-party cookies that are termed "persistent" as they remain in your terminal until they are deleted or expire.

As such cookies are issued by third parties, their use and deposit are subject to their own privacy policies which you will find a link to below. This family of cookie includes audience measurement cookies, advertising cookies, and social network sharing cookies (Facebook, Twitter, YouTube, Instagram, etc.).

Audience measurement cookies establish statistics concerning the visit and the use of various elements of the Site (such as the content/pages you have visited). These data contribute to the improvement of the ergonomics of the Publisher's Site.

5.5. MAXIMUM CONSERVATION PERIOD OF TRACKERS

Trackers are intended to be kept on the User's terminal for a period of up to 12 months. These data are stored in secure conditions, according to the current means of the technique, in compliance with the provisions of the General Regulation on the Protection of Data and the national law in force.

5.6. OPPOSITION TO THE USE OF TRACKERS

5.6.1. POSSIBILITY OF OPPOSITION TO THE USE OF TRACKERS

You can accept or refuse the deposit of cookies at any time.

The User can delete or deactivate the use of trackers at any time by changing the settings of his or her browser. It is possible to consult the Site without trackers. However, some secondary functions of the Site may not work if the User has deactivated the use of trackers, such as form auto-completion or navigation indicators.

5.6.2. SETTINGS

For more information on the tools to control cookies, you can consult here the dedicated page on the CNIL's website.

5.6.2.1. BROWSER SETTINGS

Each Internet browser offers its own cookie management settings. The User can configure his or her browser software so that cookies are rejected, either systematically or according to their issuer. The User can also configure his or her browser software so that the acceptance or refusal of cookies is proposed punctually, before a cookie is likely to be registered in his or her terminal.

For the management of cookies and User choices, the configuration of each browser is different. It is described in the help menu of the browser, which will allow knowing how the User can modify his or her wishes regarding cookies:

• For Internet Explorer;
• For Safari;
• For Chrome;
• For Firefox;
• For Opera.

5.6.2.2. SETTINGS USING ADD-ONS

The User can also delete or oppose the placement of cookies on his or her terminal by installing an extension on his or her browser.

ARTICLE 6. INTELLECTUAL PROPERTY

6.1. LEGAL PROTECTION OF SITE CONTENT

The Site Contents are likely to be protected by copyright and database rights. Any representation, reproduction, translation, adaptation, or transformation, full or partial, carried out unlawfully and without the consent of the Publisher or its rights holders or beneficiaries is a violation of the Books I and III of the Intellectual Property Code and could lead to legal proceedings for infringement.

6.2. CONTRACTUAL PROTECTION OF SITE CONTENT

The User contractually commits to the Publisher not to use, reproduce, or represent, in any way whatsoever, the Site Contents, whether or not they are protected by intellectual property rights, for any purpose other than their reading by a robot or a browser. This prohibition is not applicable to indexing robots whose sole purpose is to scan the content of the Site for indexing purposes.

ARTICLE 7. FINAL PROVISIONS

7.1. MODIFICATIONS

This Privacy Policy can be modified at any time by the Publisher. The conditions applicable to the User are those in effect at the time of his or her connection to the Site. Any substantial modification of this privacy policy will be subject to information at the first connection of the User following their entry into force. This new privacy policy will then have to be accepted anew.

7.2. ENTIRETY

The nullity of one of the clauses of this contract does not entail the nullity of the other clauses of the contract or of the contract as a whole, which will retain their full effect and scope. In such a case, the parties shall, as far as possible, replace the canceled stipulation with a valid stipulation corresponding to the spirit and object of these presents.

7.3. NON-WAIVER

The lack of exercise by the Publisher of the rights acknowledged herein shall in no case be interpreted as a waiver of asserting said rights.

7.4. LANGUAGES

These conditions are proposed in French.

7.5. ABUSIVE CLAUSES

The stipulations of these conditions apply subject to compliance with the imperative provisions of the Consumer Code concerning abusive clauses in contracts concluded between a professional and a consumer.

ARTICLE 8. DISPUTES

8.1. APPLICABLE LAW

This Privacy Policy is subject to the application of French law and European regulation, in particular the European Regulation on the protection of data.

8.2. DISPUTES

Under the ordinance no. 2015-1033 of August 20, 2015, all disputes which could arise in the framework of the execution of these general conditions and whose solution has not been found beforehand amicably between the parties shall be submitted to the competent courts.

Since January 1, 2016, mediation is mandatory for all. Thus, any professional selling to private individuals is required to communicate the coordinates of a competent Mediator in case of a dispute, regardless of whether they sell at a distance or in a physical store (Source: FEVAD).