DEVIALETPrivacy Policy

This Privacy Policy describes the way that Devialet S.A. and its subsidiaries (”Devialet”, “we” or “us”) collect, use, store and disclose the information obtained from the users (“the users”, “your” or “you”) from the website devialet.com, from our related apps and products and when our users interact with us through our services via email, phone, our people in our stores and at our stands (together, the “Products and Services”).

We pay great attention to your personal data and handle it with care. Please read this Privacy Policy carefully to understand our practices regarding your information and how we will treat it. By using or submitting information to us via the Products and Services, you are acknowledging and agreeing to this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Products and Services, nor submit any information, however you are informed that you will not be able to benefit from the services or to purchase products from us. This Privacy Policy may change from time to time (see “Modifications to this Privacy Policy” below). Your continued use of our Products and Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

We may gather your personal information or non-personal information (“Collected Information”) either directly or indirectly. Such information may include your name, e-mail address, postal address, any details necessary for the shipping and delivery of our products or for any assistance you may need, phone number, your order data, your product data, unique ID number customer account and in some cases, your IP address (Internet Protocol), your payment details, your audio sources, the network that you use, etc.

We only collect and process the Collected Information where we have a legal ground to do so, i.e. if at least one of the following applies: − you have given your consent to the processing of the Collected Information, for one or several purposes; − processing of the Collected Information is necessary for the performance of our contractual obligations towards you; − processing of the Collected Information is necessary to comply with our legal obligations; − processing of the Collected Information is necessary in order to protect your safety, of any of your vital interests or the ones of another physical person; − processing the Collected Information is necessary for the purposes of our legitimate interests or the ones of our partners, except where such interests are overridden by your interests or fundamental rights and freedoms. We determine the legal grounds based on the purposes for which we have collected and used your personal data.

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We gather Collected Information in a variety of ways including but not limited to when a user creates an account on our Products and Services, issues a purchase, fills a form, takes part in a game or a promotion online, participates in various activities on social networks, and when he or she uses a service, resource, or an activity proposed by our Products and Services.

Personal data that we receive about you from our partners: we may also gather some of the Collected Information, i.e. name, address; delivery details, telephone number, date of birth, etc.: indirectly, through our partners, for the same purposes as mentioned above.

Our website can make use of Cookies or similar technology such as Pixels and Tags (the “Cookies”). A Cookie is a small file that can be placed on your device that allows us to recognize and remember you. We may use Cookies to improve the user experience and make sure that the website functions properly. For more details on what we do with Cookies and if you wish not to allow the use of Cookies, please report to our Cookie Policy. Unless the cookie is strictly necessary, you can withdraw your consent to our cookies at any time even if you have previously consented. However, if you do not consent to our functionality cookies, parts of our Products and Services may not work.

https://business.safety.google/intl/fr/privacy/
https://policies.google.com/privacy?hl=fr#europeanrequirements

If you choose to participate in activities we propose on a variety of social networks, such as Twitter, Facebook or Instagram, it is your strict responsibility to review the security and privacy policies of such social networks along with their specific conditions of use.

We have implemented appropriate technical and organizational controls to protect the Collected Information against unauthorized processing and against accidental loss, damage or destruction.

We may disclose the Collected Information to third parties, to the extent required by law or by a decision rendered by a judicial/administrative authority.

In addition, we may disclose Collected Information to third parties, such as:

our authorized dealers, third-party vendors and service providers acting on our behalf, including billing, sales, marketing, IT support, advertising, analytics, research, customer service, product service support, shipping and purchase order fulfillment, data storage, logistics validation, security, fraud prevention, payment processing, and legal services;

partners hosting events to which you may wish to participate;

music streaming services providers, if it is required to enable delivery of the music content;

other third parties subject to your consent.

Such third-parties have access to the Collected Information in order to perform the related services but are prohibited from using it for other purposes;

Collected Information is generally stored and processed within the European Economic Area (EEA). All transfers are made in compliance with the General Data Protection Regulation (GDPR). In some situations, we need to transfer the Collected Information outside of the EEA. The laws of the countries to which we transfer your personal data may not always offer the same level of personal data protection butsuch transfers are made with the appropriate safeguards, notably contractual, in accordance with the regulations applicable to personal data protection.

If we disclose your Collected Information to a third party, we take all reasonable actions to ensure that such third party complies with applicable confidentiality and privacy obligations, and namely that the Collected Information is only processed in accordance with our instructions, applicable law and regulations and for the purpose specified by us and to ensure adequate security measures.

The transfers of Collected Information to the Devialet entities located outside of the EU are covered by a data transfer agreement. The transfers of Collected Information to other entities outside of the EEA, such as in the United States, are covered by Standard Contractual Clauses.

In situations where we transfer the Collected Information to third party partners, it can be for different purposes, such as: to complete an order and issue an invoice, to deliver products and services, to ensure a high level of service regarding our products and services, to enhance our products and perform software upgrades, if any, to increase the quality of our customer experience, to obtain third party help for the Products and Services and our IT system, to perform surveys, research, advertising, marketing, and analytics, to ensure data storage, to obtain legal services, and other operations in our name.

We may also share the Collected Information to comply with laws and/or respond to lawful requests and legal process, to protect our rights and property, and those of our agents, customers, and others (which may include enforcing our agreements, policies, and terms of use); or in an emergency (including protecting the safety of our employees and agents, our community of users, or any person).

Unless clearly outlined in the section above, or in such circumstances where you have given your consent, we will not share your Collected Information to third parties.

We do not sell or disclose the Collected Information to third parties for their direct marketing purposes.

We do not retain the Collected Information for longer than necessary needed. For clients, in consideration of the life expectancy of our products, their technical nature, and the need to properly maintain and upgrade the implemented software, we hold the Collected Information for a period of up to ten (10) years from the date of purchase. The only exceptions to the abovementioned period are where: − you consented with receiving personal benefits or customized direct marketing;
 − the law requires us to hold your Collected Information for a longer period, or delete it sooner; − where you have raised a legal claim, complaint or concern regarding a product or service offered by us, in which case we will retain your Collected Information for the entire duration of the claim, complaint or query. For prospects and simple users of our Website, the Collected Information in relation to your request for registration to our newsletters, events, demo of products, offers will be retained for a period of three (3) years as of their collection or your last contact with us, unless during that period we form a relationship with you e.g. you purchase or loan one of our products. We hold your Collected Information for this period to give us an opportunity to form a relationship with you. After such period, we may recontact you in order to know whether you wish to continue to receive our communications. The Collected Information we gather through Cookies will be retained for a period of twelve (12) months as of their collection or your last contact with us, unless during that period we form a relationship with you e.g. you purchase or loan one of our products or you have been active in opening our marketing communication or otherwise showing interest in our Products.

You have right to access the Collected Information, and in some instances, request the portability of the Collected Information, meaning to receive them in a structured and commonly machine-readable format, and have the right to transmit such Collected Information to any third party of your choice. The Collected Information processed by us can be transmitted upon request at privacy@devialet.com (“Contacting us”).

You also have the right to rectify the Collected Information, in this respect, we encourage you to update the data you have provided to us any time there are changes in your Collected Information by logging in to your account on our Products and Services or by Contacting us. In order to ensure that the Collected Information is up-to-date, we recommend that you check your Collected Information at least once a year, and if needed update it. You may also contact us to review, update or delete the Collected Information.

You can request us to delete your Collected Information by Contacting us, but we may decide to keep and process such information regardless of your consent, to the extent permitted or required under applicable laws and regulation.

If we do not decide to keep and process your Collected Information for any of the reasons abovementioned, the Collected Information will be deleted within a maximum period of one (1) month following your request.

Please note that prior to accessing and making changes to your account, we will need to verify your identity properly.

In such event where you do not want to delete your Collected Information, you may still request to have such Collected Information restricted from being processed, in the conditions of article 18 of the GDPR. Nonetheless, we keep the right to store the Collected Information for the establishment, exercise or defence of legal claims. In accordance with the applicable rules, you may at any time, on grounds relating to your particular situation, object to the processing of the Collected Information by us when such processing is based on our legitimate interests. Furthermore, you have the right to object to processing of your Collected Information for direct marketing purposes. You can do so by unsubscribing from our marketing information by clicking on the unsubscribe link in the bottom of marketing communication from us or by accessing your profile on the Website.

Some of our processing activities may be based on your consent. You have the right to withdraw your consent at any time. You can do so using the simple detailed protocol located at the bottom of each e-mail we send. You can also contact us by e-mail at privacy@devialet.com Withdrawal of your consent will not affect the lawfulness of processing based on your given consent before withdrawal. Upon the withdrawal of your consent, we and third parties involved will cease to process your Collected Information within one (1) month as of your withdrawal, unless and to the extent the continued processing or storage is permitted or required according to applicable laws and regulations. Please note that the withdrawal of your consent may result in us not being able to meet your requests or provide you with our services.

You may provide us instructions as to the fate of your personal data in case of death.

If you wish to exercise your rights as described above, or if you have a privacy related matter please contact Devialet S.A. by sending your request to Devialet S.A., 35 rue la Boetie, 75008 Paris, France or by sending an e-mail to privacy@devialet.com.

We will do our best to respond to requests as quickly as possible and at latest, within one (1) month from the date of receipt of the request. In case a response from us would require more time, then we will inform you of the relevant reason and the estimated timeline.

If you consider that the handling or outcome of your request is not satisfactory, you may contact the competent supervisory authority.

Our Website is not intended for, and we do not knowingly collect Collected Information from, children under 13 years of age. If we are notified that we have collected or received Collected Information from a child under 13, we will delete that information.

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals.

We are entitled at our sole discretion to update our Privacy Policy at any time. Following any substantial update, the date at the bottom of our Privacy Policy will change, and the updated Privacy Policy will be posted on our website. You will be notified of these substantial changes by email or directly through our website and the continued use of our Products and Services will be deemed acceptance of the updated policy.

Devialet S.A. 10 Place Vendôme, 75001 Paris, France is the data controller and is responsible for the processing of your Collected Information.

If you have any questions regarding this Privacy Policy, the practices of our Products and Services or your interactions with our Products and Services, feel free to contact us at:

Devialet S.A.

Customer Service

35 rue la Boetie

75008 Paris

privacy@devialet.com

You can always contact us by phone at the relevant Devialet Support number for your country.

Last update: October 1, 2020