Privacy policy

For SEECLY, respecting your privacy is essential. When you use our services, you entrust us with your personal data, and we are committed to taking care of it. This policy has been designed to help you understand how we collect and process your personal data and what your rights are.

Data is stored in France with an approved hosting provider. This host is certified under the French label "HDS" ("Hébergeur de Données de Santé" or Health Data Host) in accordance with the law and standards established by the "Agence du Numérique en Santé" (Digital Health Agency), in consultation with the "Commission nationale de l'informatique et des libertés" (National Commission for Information Technology and Civil Liberties).

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

The company NASOLHI, a simplified joint-stock company with a share capital of €16,880.27, headquartered at 6384 RUE OBSIDIENNE 13510 EGUILLES, registered with the Aix-en-Provence Trade and Companies Register under number 877 986 430 ("SEECLY"), which operates the online intermediation platform under the name "SEECLY" (the "Marketplace"), is responsible for processing your data.

2. WHAT DATA DO WE COLLECT?

We collect the following personal data:

- Data you provide to us: When you create a Client or Seller account, use our services, or contact us (including via our contact form, email, or phone), we collect the personal information you provide. For example, to create an account and use our services, you need to provide us with your name, email address, phone number, and set a password. For professional sellers, we also collect company name and identity of the legal representative, as well as VAT number.

The data we request that is essential for providing our services or responding to your requests is identified by an asterisk or an equivalent method on the collection forms or specified orally at the time of collection. If you do not fill in the mandatory fields or provide the indicated information, we will not be able to respond to your requests.

- Data related to your device, account, and activity: Information about your device, account, and activity, including IP address, session information, cookies and trackers, consent and refusal, consent date and time, user profile, language, preferences, browser used by your device, content and URLs you access, date and time of your connections, model and manufacturer of your device, operating system used by your device (iOS, Android).

- Data related to your interactions with the Marketplace and other users: Usernames of those you communicate with, messages, message date and time, other data included in the messages, reviews, ratings, review date and time, review response, your public comments and messages on the Marketplace, your responses to our satisfaction surveys, your consumption habits.

- Data related to your items for sale and/or in the deposit process: Item description, item photos, item price, photos of the item's invoice or receipt, photo of the item's certificate of authenticity.

- Transactional data: We collect data related to your orders, including transaction numbers and order details.

- Payment data: We collect data related to your payment card (number, expiration date, CVV).

- Usage data: We collect data on user interaction with the website, including access dates and times, visited pages, and the type of browser used. We collect this data automatically through cookies.

Our services are not intended for minors, and we do not knowingly collect information from minors or ask them for any information. Anyone providing their information to SEECLY as part of an order expressly declares that they have reached the legal age of majority. If we discover that we

 have collected information from a minor without the consent of their parents or legal guardians, we will delete it. Please contact us using the contact information provided in Article 7 below if you believe you have provided us with information about a minor without the consent of their parents or legal guardians.

3. WHY DO WE COLLECT YOUR DATA?

We only process your personal data when we have a legal basis to do so:

- Processing necessary for the performance of the contract with you: We use your data to manage contracts and services, fulfill our contractual obligations, including:

- Providing the services you have requested through the SEECLY Marketplace, processing transactions and billing, including internet and payment fraud management and payment incidents.

- Managing your personal account.

- Processing based on your consent:

- Adjusting and fitting prescription lenses (based on a standard pupillary distance or according to the indications provided in the Client's prescription communicated as part of the order). Regarding health data, the Client expressly agrees to transmit them to SEECLY so that their order can be tailored to their specific needs.

- Sending our newsletter.

- Sending information and promotions about SEECLY services and certain products sold online.

- Storing payment card data to facilitate future purchases.

- Processing necessary for our legitimate interests:

- Sending information and promotions to our customers regarding the Marketplace.

- Handling requests and complaints.

- Conducting business statistics, after rendering your data anonymous or implementing measures to prevent your reidentification.

- Processing necessary for compliance with legal obligations: Some of your data is also processed to comply with our legal obligations (e.g., accounting and tax obligations or managing requests to exercise rights under personal data protection rules) and to protect our interests in the event of a dispute or legal action.

4. HOW LONG DO WE RETAIN YOUR DATA?

In general, we retain your personal data for a duration that does not exceed the time necessary for the purposes for which it was collected. Specifically:

- Data associated with your account: When you create an online account, your personal data is retained as long as you use our services through your account. Your data and account will be deleted if:

- You decide to permanently delete your account, or

- Your account is inactive, meaning you have not used any of our services for 5 consecutive years and have ceased to interact with us during this 5th year (particularly, you have not opened our emails, logged into your account, etc.).

- Subscription to our newsletter and electronic marketing options: If you have created an account, this data will be retained until you unsubscribe through your account or by using the unsubscribe link provided in the newsletter and promotional emails. If no customer account is associated with your email address, your data will be deleted 3 years after your last interaction (click) with an email we have sent you.

- Payment card data: By default, this data is not retained beyond the transaction. If you have chosen to store this information for future purchases, we retain it until you delete it or until the payment card expires.

- Accounting and tax data: We retain this data in an intermediate archive database for the legal retention period.

- Managing an opposition list: We retain your data for 3 years from the exercise of the right.

Please note that your data may be retained for a longer period, for example, to establish evidence of a right or due to a legal obligation. In any case, your data will not be retained beyond what is strictly necessary for the purposes for which it is processed. When your data is no longer necessary, we will ensure that it is either deleted or anonymized.

5. WHO DO WE SHARE YOUR DATA WITH?

We only share your data with:

- Authorized personnel of SEECLY who need access to your data for the purposes described above.

- Our service providers and subcontractors involved in providing

 you with certain services.

- Organizations, judicial officers, and public authorities in the context of their debt recovery mission.

- External advisors (lawyers, auditors, etc.) when necessary for the legitimate interests pursued by SEECLY.

- Public or judicial authorities when legally required.

We may also share your personal data with third parties in the context of a potential or actual sale or restructuring of our company or some of our assets, in which case your data may be included in the transferred assets.

We also engage subcontractors who process your personal data on our behalf. In this context, your personal data may be transferred outside the European Economic Area (EEA) to countries (such as the United States) that do not provide a level of data protection equivalent to that within the EEA. In the absence of an adequacy decision by the European Commission under Article 45 of the GDPR, the transfer of your personal data will be governed by appropriate transfer mechanisms under Articles 46 and following of the GDPR (such as standard contractual clauses adopted by the European Commission). You can obtain a copy of such clauses (excluding confidential provisions) by contacting us using the contact details provided in Article 7 "Contact."

6. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

You have several rights regarding your data:

- You can revoke your consent to any processing of your data based on your consent at any time.

- You can ask us to confirm whether we are processing your data and, if so, inform you of the characteristics of the processing, allow you to access it, and obtain a copy of the data.

- You can ask us to correct or complete your data if it is inaccurate or incomplete.

- You can, in certain cases, ask us to delete your data or restrict its processing.

- You can, in certain cases, request that your data be provided to you in a structured, commonly used, machine-readable format, or request that it be transmitted directly to another data controller.

- You have the right to define (general or specific) directives regarding the fate of your data after your death.

- You can object to any processing of your data based on our "legitimate interest." If you exercise this right, we must cease processing, unless we demonstrate compelling legitimate grounds that override your rights and freedoms or for the establishment, exercise, or defense of legal claims.

- You can object at any time to the processing of your data for marketing purposes.

You can exercise your rights by contacting us using the contact information provided in Article 7 "Contact."

You also have the right to lodge a complaint with the competent supervisory authority regarding the processing of your data. In the United Kingdom, the supervisory authority for personal data protection is the Information Commissioner's Office (ICO) (www.ico.org.uk).

7. CONTACT

For more information about your rights, to exercise them, or for any questions or complaints regarding the protection of your personal data, you can contact us via email at [email protected].

8. MODIFICATION OF THE POLICY

We may occasionally modify this privacy policy, for example, to account for legal changes, technological advancements, and best business practices. We will inform you of any substantial changes.