Privacy policy
(Last update: September 2020)

NOTILO PLUS SAS, is a company duly organized under the laws of France, registered under the number 818 400 415 and having its registered office at Le Castel, HĂŠritage, 61 boulevard des Dames, 13002, Marseille – France (hereinafter designated as the ‘Company’ or ‘NOTILO PLUS’) undertakes that the Processing of Personal Data made on all website it owns and notably www.ibubble.camera and www.seasam.notiloplus.com (hereinafter the ‘Site(s)), comply with applicable regulations on the protection  of data (European General regulation 2016/679 on data protection ‘RGPD’) and the French law “Informatique et LibertĂŠs” n°78-1! On 6th January 1978 modified.


The purpose of the Privacy Policy is to inform any User of the Site on how Notilo Plus collects and processes Personal Data.

Notilo Plus is Data Controller of Personal Data collected via the Site.

ARTICLE 1 – DEFINITIONS

data subject
Refers to any natural person whose Personal Data is collected and processed by Notilo Plus.

DATA CONTROLLER

Refers to the person who determines the purposes and means of Personal Data Processing.

DATA PROCESSOR

Refers to the person who processes Personal Data as instructed by the Data Controller for specific services and purposes.

PERSONAL DATA

Refers to any information that directly or indirectly identifies or makes identifiable a natural person.

PROCESSING
Refers to any operation or set of operations carried out using automated or manual processes on an electronic or paper medium, such as collection, recording, organization, structuring, preservation, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination of Personal Data.

USER

Refers to any person who visits the Site and who uses or not the services offered there.

ARTICLE 2 – PERSONAL DATA PROCESSING

  • Processing n°1 – The purpose of the Processing is to manage the Site

It allows:

  • Preparation and publication of contents;
  • The technical administration in connection with the service providers (hosting, domain name registar);
  • Management of the security of the Site (equipment and security logs)

Legal basis:

Article 6 (1) f) GDPR: the Processing is necessary for the purpose of the legitimate interest pursued by Notilo Plus.

Categories of Personal Data:

  • Connection data: IP address, event logs; OS type; device type, navigator type 

Data Subject:

Site Users

Automated decision making

The Processing does not include automated decision making.

  • Processing n°2 – The purpose of the Processing is to respond to the User’s request made via the ‘Contact’ form of the Site:

It allows:

  • To respond to requests sent via the form by Users.

Legal basis:

Article 6 (1) a) GDPR: the Data Subject has given consent to the Processing of his or her Personal Data;

Categories of Personal Data:

  • Name of the Data Subject;
  • Email address

Data Subject :

The Users of the Site

Personal Data collection for this purpose is compulsory. Otherwise, the Data Subject will not be able to use the “contact” form.

Automated decision making

The Processing does not include automated decision making.

  • Processing n°3 – The Purpose of the Process is the sending of the Newsletter

It allows to:

  • Send the Newsletter
  • Send commercial offers

Legal basis:

Article 6 (1) a) GDPR : the Data Subject has given consent to the Processing of his or her Personal Data;

Categories of Personal Data

  • Email address

Data Subject :

Users of the Site

Personal Data collection for this purpose is compulsory.

Automated decision making

The Processing does not include automated decision making.

  • Processing n°4 -The purpose of the Processing is the managing of the chat

It allows to:

  • Contact Users who send a message to Notilo Plus via the chat while Notilo Plus was not online (example: outside the business hours)

Legal basis:

Article 6 (1) a) GDPR: the Data Subject has given consent to the Processing of his or her Personal Data;

Categories of Personal Data:

  • Email address

Data Subject:

The Users of the Site

Personal Data collection for this purpose is compulsory. Otherwise, the Data Subject will not be able to use the “contact” form.

Automated decision making

The Processing does not include automated decision making.

  • Processing n°5 – The purpose of the Process is the execution of the order

It allows to:

  • Manage the order
  • Establish the invoice
  • Deliver the product
  • Manage the commercial relation

Legal basis:

Article 6 (1) a) GDPR: the Data Subject has given consent to the Processing of his or her Personal Data;

Article 6 (1) b) GDPR: the Process is necessary for the performance of a contract to which the Data Subject is party.

Categories of Personal Data:

  • Name
  • Surname
  • Country
  • Postal address
  • Email address
  • Credit card information

Data Subject:

The Users of the Site who purchase a product online

Personal Data collection for this purpose is compulsory. Otherwise, the Data Subject will not be able to order a product online.

Automated decision making

The Processing does not include automated decision making.

ARTICLE 3 – RECIPIENT OF THE PERSONAL DATA

The Personal Data collected are intended for internal recipient and for Data Processor:

  • The personal responsible for overseeing the security of the Company’s information systems;
  • The personal of Notilo Plus responsible of the processing of contact requests and newsletter demands;
  • Notilo Plus’ staff responsible for creating connection identifier to order online;
  • Notilo Plus’ staff responsible for execution of the order;
  • The Data Processor responsible for the host of the Site (Datatailor);
  • The Data Processor responsible for the payment module (PayPal).

Notilo Plus guarantees any User that the Data Processors provide sufficient and adequate guarantees in terms of Personal Data security.

ARTICLE 4 – TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES

Notilo Plus does not transfer any Personal Data to third Countries.

In case of transfer of all or part of Personal Data to a third country, ie located outside the European Union or not having a level of protection recognized as adequate within the meaning of the regulations, or to an international organization, Notilo Plus undertakes to provide the appropriate guarantees provided in the regulations and to have them respected by its subcontractors.

ARTICLE 5 – STORAGE LIMITATION

  • Personal Data collected via the “contact” form, the newsletter and the chat are stored for a maximum duration of three years from the last contact from the Data Subject;
  • Personal Data needed to access the Service are stored for five years from the termination date of the contract concerned;
  • Data logs are stored for twelve months;
  • Data necessary for the production of audience statistics and use of online services are kept in a format that does not allow the identification of persons by their IP address.

ARTICLE 6 – SECURITY MEASURES

Notilo Plus is committed to:

  • Security measures to prevent access to Personal Data by unauthorized persons;
  • Identity and access checks via an authentication system and a password policy;
  • An authorization management system ;
  • Processes and devices to trace all actions performed on the information system and to perform in accordance with the regulations reporting actions in case of incidents impacting Personal Data.

ARTICLE 7 – INFORMATION REGARDING YOUR DATA PROTECTION RIGHTS

In accordance with the provisions of the French Data Protection and Freedom of Information Law of January 6, 1978, modified and the GDPR, you have a right of access, rectification, deletion, limitation, opposition and a right to the portability of Personal Data concerning you.

  • Right of access

You have a right of access to Personal Data concerning you processed by Notilo Plus. It allows you to read the Personal Data we have about you and, if you wish, to request a copy.

  • Right to rectification

According to the regulations applicable to the protection of Personal Data, you may request us to correct Personal Data about you that are inaccurate. You may also request that the incomplete Personal Data concerning you be completed, including by providing, in support, a supplementary declaration.

In order to allow you to exercise this right as easily as possible, we invite you to proceed directly with these modifications and additions to your account. If you believe that other Personal Data about you needs to be changed or supplemented and that you are unable to make this change on your own, please contact us at contact@notiloplus.com

  • Right to be forgotten and erased

You have the right to obtain from us the erasure, as soon as possible, of your Personal Data subject to our legitimate interest or any legal obligation requiring us to keep it.

For security reasons and to avoid an unwanted deletion of the account, we invite you to do this by contacting us at the following address: contact@notiloplus.com

  • Right to limitation of Processing

You may request from Notilo Plus the limitation on the Processing of your Personal Data, when one of the following applies:

  • you dispute the accuracy of your Personal Data. In this case, we will hide your Personal Data for a period of time allowing us to verify its accuracy;
  • you believe that the Processing of your Personal Data is unlawfully implemented and you oppose their erasure and instead require the limitation of their use;
  • we no longer need the Personal Data about you for Processing purposes but these are still necessary to enable you to have a formal record of something, or exercise or defend a right in court;
  • you exercised your right to object under Article 21 (1) of the GDPR.

We will limit the Processing of your Personal Data during the audit as to whether the legitimate grounds we are pursuing prevail over your right.

If we decide to lift the limitation of the Processing of your Personal Data, we will keep you informed.

  • Right to object

You may object to sending communications, especially commercial communication, by Notilo Plus. To this end, we provide you with an unsubscribe link in all e-mails that we send you.

You may also object, for legitimate reasons, to the Processing of your Personal Data, unless it meets a legal obligation imposed on Notilo Plus.

  • Right to portability

You may always request the portability of your Notilo Plus Personal Data. By exercising this right, we undertake to send you, within a reasonable period of time and in a machine-readable format, the Personal Data that you have provided to us whether it has been declared by you or generated by your activity on the platform.

  • Right to withdraw consent

You have the right to refuse at any time the Processing of your Personal Data for personal reasons. As well, you have the right to refuse the Processing of your Personal Data for direct marketing purposes.

  • Right to lodge a complaint with a supervisory authority

The supervisory authority responsible for any request concerning us, including, where appropriate, the complaint of a User, is the National Commission of Computing and Liberties (CNIL).

If you wish to file any complaint with the CNIL, you will find their contact information below:

CNIL (COMMISSION NATIONALE DE L’INFORMATIQUE ET DES LIBERTÉS)

3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07

Tel.: 01 53 73 22 22

(from Monday to Thursday from 9am to 6.30pm/ Friday from 9am to 6.00pm)

Fax: 01 53 73 22 00

Important! The CNIL does not receive the public and does not provide any information at their offices.

If you wish to file a complaint with the CNIL, you may fill in the online complaint form available at the following address: https://www.cnil.fr/fr/plaintes

If you have a question about your IT rights and freedoms, you may consult the CNIL website: www.cnil.fr.

ARTICLE 8 – COOKIES

Browsing the site https://seasam.notiloplus.com/ may cause the installation of cookie(s) on the User’s terminal (computer, mobile or tablet).

  • Definition

A cookie is a small text file, deposited on a User’s terminal, via his internet browser, for example when visiting a site, reading an email, installing a software, etc. A cookie does not allow the identification of the User, but records information relating to his navigation.

  • Different types of cookies and their purposes

The consultation of the Site entails the deposit, by Notilo Plus, of cookies on the User’s terminal in order to simplify and improve the navigation of the User on the Site and to personalize the services which are offered to him, under the conditions defined below.

  • The necessary cookies

These cookies are strictly necessary for the proper functioning of the Site (eg identification and connection to the User’s account, storage of the shopping cart for placing an order). These cookies help to ensure the technical operation of the Site and may not be disabled.

  • Functional cookies

These cookies make it possible to improve the navigation on the Site and in particular to make this navigation more fluid and personalized, without being essential to the proper functioning of the Site (for example memorization of the connection information to the Site, live assistance via chat, etc.).

  • Analytical cookies or audience measurement

These cookies enable Notilo Plus to know the use and performance of the Site and to improve its functioning (for example, the most visited pages of the Site, searches made by Users, etc.).

  • Advertising cookies

These cookies allow the User to offer advertisements adapted to his interests, on the Site or on other sites when browsing the Internet. These cookies record information about visits and browsing habits of the User on the Site but also outside the Site.

These cookies are not essential for the proper functioning of the Site and may therefore be disabled. The refusal of this type of cookie will not however prevent the posting of advertising on the Site or on the Internet in a general way. These ads will simply not take into account the interests and preferences of the User.

  • Cookies storage duration

Notilo Plus stores the cookies listed above, subject to the consent and settings of the User, for a maximum of 13 months.

  • Cookies settings

By connecting to the Site, the User is invited to set its cookie preferences. He may modify his choices at any time.

The setting of cookies is however likely to have effects on the User’s navigation on the Site. It is therefore advisable to set cookies according to their respective purposes.

ARTICLE 9 – MODIFICATION OF THE PRIVACY POLICY

This Policy have been updated on the date indicated page 1. Notilo Plus reserves the right to modify the Privacy Policy. In case of modification of the Privacy Policy, Notilo Plus undertakes not to lower the level of protection of your Personal Data.