Privacy policy

Preamble

Entry into force: March 30th, 2023

CLICKBUSTER LTD
63-66 Hatton Garden
London EC1N 8LE
Company number 13014667
VAT number GB 363 9346 71

Access to the site and its functionalities requires the collection and processing of users' personal data. It was therefore necessary to establish a personal data protection policy in order to comply with the recommendations for use in the processing of personal data, as established by the applicable law and regulations.

The site's data protection policy has been drawn up in accordance with the recommendations of the Data Protection Commission (DPC). Its purpose is to inform site users about how their personal data is processed, and about the commitments and measures we have taken to guarantee respect for users' personal data.

It has been drawn up in accordance with the following provisions:

• The Data Protection Act 2018;
• The European Personal Data Regulation 2018;
• The European Data Protection Regulation Transposition Act 2018.

The version currently published on the site is the current version of this policy. The seller reserves the right to modify it at any time in order to comply with current legal obligations. Any changes to the privacy policy will be communicated to users in order to obtain their consent to the new policy.

By browsing our site, the user acknowledges having read, understood and accepted this data protection policy. Any questions relating to this policy may be sent to the following address: contact.psona@gmail.com.

ARTICLE 1 - DEFINITIONS

1.1 Technical terms relating to the protection of personal data

On our site, the terms below have the meaning attributed to them in the RGPD (Article 4):

• Consent Consent: of the data subject, any manifestation of free, specific, informed and unequivocal will by which the data subject accepts, by a declaration or a clear positive act, that personal data concerning him be "processed";

• Data controller the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing operation; where the purposes and means of such processing are determined by Union law or by the law of a Member State, the controller may be designated or the specific criteria applicable to his designation may be laid down by Union law or by the law of a Member State";

• Subcontractor the natural or legal person, public authority, agency or any other body that processes personal data on behalf of the controller";

• Treatment any operation or set of operations which may or may not be performed upon personal data or sets of personal data by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction";

• Violation of personal data a breach of security resulting in the destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed, whether accidental or unlawful".

1.2 Other terms used here

• Customer Consumer: designated according to the provisions of the introductory article of the Consumer Rights Act 2022, a person acting for purposes wholly or mainly outside his trade, business, craft or profession;

• Website designates the site https://persna1.com operated by the seller and made available to the user ;

• User means any person using our site and having access to its content.

ARTICLE 2 - Personal data

Personal data refers to any information that can directly or indirectly identify a physical person (surname, first name, e-mail address, telephone number, postal address, etc.).

Thus, the RGPD defines personal data as: "any information relating to an identified or identifiable natural person (hereinafter referred to as 'data subject'); an 'identifiable natural person' is considered to be a person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity."

ARTICLE 3 - Data concerning minors

In accordance with the provisions of Article 8 of European Regulation 2016/679 and the Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data.

Users under the age of fifteen (15) are asked to obtain the consent of a legal representative - required by the Seller - in order for their personal data to be collected and for them to be able to use the site's services.

The Vendor shall not be held liable in the event of a user providing personal data concerning a minor under the age of fifteen (15).

ARTICLE 4 - Collection of personal data

We collect your consent.

When browsing the site, the user must, on several occasions, provide some of his/her personal data (for the purposes indicated in article 5). By providing his or her data, the user therefore consents to the collection and processing of personal data provided by the Seller, exclusively for the purposes detailed in article 5 of the policy. This consent, together with other legal bases, constitutes the legal basis for the processing of the data collected.

The Seller collects and processes data that is strictly necessary for the purposes for which it is processed. We undertake to our users that we will not process data for purposes other than those mentioned below. If we were to offer a new service on the site, or any other functionality requiring the collection and processing of data, we undertake to obtain users' consent once again before offering the new service in question.

Whenever the site processes personal data, the Seller takes all reasonable steps to ensure that the personal data is accurate and relevant to the purposes for which it is processed.

ARTICLE 5 - Purpose of the process

We collect user data solely for the following processing purposes:

5.1 Account creation (optional)

Customers can create an account on the site. To do so, they must provide the following details: surname, first name, e-mail address.
Customer data is used for the following purposes:

- Validate the creation of their account;
- Create a customer account ;
- Communicating with customers ;
- After-sales follow-up.

The legal basis is the execution of a contract, due to the placing of an order, with the customer accepting these provisions.

5.2 Placing an order

To place an order on the site, customers must provide the following information: surname, first name, e-mail address and billing address.

User and communication data are used solely for the following purposes:

- Validate the customer's order ;
- Process the customer's order;
- Supply the services covered by the order;
- After-sales service.

The customer is also informed that by placing an order, he/she will receive transactional communications from the seller (invoices, password changes, personality test results). The customer may unsubscribe at any time by using the functions provided for this purpose in the e-mails sent by the seller.

The legal basis is the execution of a contract through the placing of an order, with the customer accepting these provisions.

5.3 Payment for services

Payment for orders placed via the site is made via our payment service provider STRIPE, who is responsible for the customer's payment data. The seller has no access to customer payment data.

5.4 Subscription

By placing an order on the site, the customer automatically benefits from a subscription to the seller's subscription (see GTC). If the customer has not cancelled the subscription after 24 hours, it is automatically extended for a period of one month, renewable by tacit agreement.

The data used to conclude the subscription are those provided by the customer when placing the order and are used for the following purposes:

- Provide subscription services;
- Manage subscription (billing, termination, renewal) ;
- After-sales service.

5.5 Contact form

A contact form is available on the site. To respond to a request, users must provide their first and last name, e-mail address and telephone number.
User data and communication data are used solely for the following purposes:

- Process the user's request ;
- Respond to user requests.

The legal basis is the user's consent.

5.6 Analysis

When browsing the site, users may be asked to enter personal connection data (cookies, tracers).

Connection data and navigation information are used solely for statistical studies (analysis of site traffic and user experience) and for other purposes mentioned in the cookie policy.

The processing is necessary for the purposes of the legitimate interests pursued by the seller, in particular to provide users with a smooth and improved browsing experience.

Connection data is also used to prevent and combat computer fraud.

The legal basis is the fulfilment of a legal obligation.

ARTICLE 6 - Data retention periods

We do not exceed the legal retention periods, and user data is kept only for as long as is necessary to process the purposes for which it was collected.

Retention periods are as follows:

- Data relating to the identity of the user who is not a customer (surname, first name): this is deleted or anonymized three (3) years after the user's last contact, unless the user has previously exercised a right (in application of the RGPD) that has led to the deletion of his/her data ;

- Communication data of non-customer users (e-mail, telephone number, postal address): these are deleted or anonymized three (3) years after the user's last contact, unless the user has previously exercised a right (pursuant to the RGPD) resulting in the deletion of his/her data ;

- Data relating to customers who have placed an order: this is deleted five (5) years after the end of the commercial relationship with the customer, unless the customer has previously exercised a right (in application of the RGPD) that has led to the deletion of their data ;

- Connection data: in application of the cookie policy, this is kept for a maximum of 13 months (unless otherwise indicated in article 13).

In establishing our data processing policy, we have put in place a reference grid for data retention periods, developed thanks to the recommendations of the Data Protection Commission.

In addition, the Seller may retain certain personal data in order to fulfil its legal or regulatory obligations, to enable users to exercise their rights or for statistical purposes. At the end of the retention period, personal data will be deleted or anonymized.

ARTICLE 7 - Data access

Data collected via the Site is intended exclusively for the following recipients.

7.1 Site hosting

The site is hosted by Scaleway, 8 rue de la Ville l'Evêque, 75008 Paris. https://www.scaleway.com/

The host has access to data within the limits of its respective remit, for the purposes of hosting the Site. It has limited access to user data in connection with the provision of these services, and is contractually obliged to use such data in accordance with the provisions of applicable regulations on the protection of personal data.

For more information, see Scaleway's policy.

7.2 Third-party service providers

The Site and the Seller rely on certain third-party services to provide certain functionalities. These third parties have limited access to user data in the context of providing these services and are contractually obliged to use it in accordance with the provisions of the applicable regulations on the protection of personal data.

Payment for orders placed on the Site is handled by Stripe.

User statistics (cookies) are used to improve the user experience and optimize the Site's functionalities. The user is invited to refer to the site's cookie policy.

7.3 Legal obligations

Data may also be transmitted by the Vendor to third parties and competent authorities in order to meet legal, judicial, fiscal or regulatory obligations. The Seller guarantees users that no transfer of personal data will be made to an unauthorized third party without the user's prior, voluntary, informed, express and written consent.

The Seller is prohibited from processing, hosting or transferring information collected about its users to a country outside the European Union or recognized as "unsuitable" by the European Commission without first informing the owner of the data and obtaining its consent.

ARTICLE 8 - Data protection

The Seller has taken all useful and necessary precautions, taking into account the state of the art in the field, to protect your information in a secure environment in order to avoid any destruction, loss, alteration, distribution or unauthorized access. Despite our best efforts, no method of transmission over the Internet or method of electronic storage is completely secure. We therefore cannot guarantee absolute security. If we become aware of a security breach, we will inform the users concerned so that they can take appropriate action. Our incident notification procedures take account of our legal obligations, whether national or European.

In the event that the integrity and confidentiality of your data is compromised, the data controller undertakes to comply with the procedures put in place in accordance with the Data Protection Act 2018 and the European Data Protection Regulation (RGPD).

The Seller does not resell or outsource user data.

ARTICLE 9 - Personal rights

In accordance with the legal provisions of the Data Protection Act 2018 and the European Data Protection Regulation, users of the site have the following rights:

9.1 Right of access, rectification and deletion

Users may consult, update, modify or request the deletion of data concerning them by sending an e-mail to the person responsible for processing personal data, specifying the purpose of the request at the following e-mail address: contact.psona@gmail.com.

9.2 Right to portability

The user has the right to request the portability of his/her personal data, held by the site or by the seller, to another site, by making a request for the portability of his/her personal data to the data controller, by sending an e-mail to the address indicated above.

9.3 Right to limit and object to data processing

The user has the right to request the limitation or to object to the processing of his/her data by the seller, without the latter being able to refuse, except in the case of legitimate and overriding reasons which could prevail over the interests, rights and freedoms of the user.

The user must send a request to restrict the processing of his/her personal data to the data controller, by sending an e-mail to the above address.

9.4 Right not to be subject to a decision based exclusively on an automated process

In accordance with the provisions of Regulation 2016/679, the user has the right not to be subject to a decision based exclusively on an automated process if that decision produces legal effects concerning him or her or significantly affects him or her in a similar way.

9.5 Right to determine the fate of data

Users are reminded that they can arrange the fate of their collected and processed data in the event of their death, in accordance with the Data Protection Act 2018.

ARTICLE 10 - Exercising your rights

10.1 How to exercise your rights

To exercise any of your rights, simply :

• Send a letter to the Seller at the address of its registered office;
• Or send an e-mail to : contact.psona@gmail.com.
  Indicate your full name, address and provide proof of identity.

The data controller is Mr Carlo Ela, contact.psona@gmail.com.

Requests will be processed within one month, except in the case of a compelling reason put forward and justified by the Seller, justifying an extension of this deadline.

10.2 Recourse to the Data Protection Commission

If the Seller does not comply with the user's request, the user has the right to contact the Data Protection Commission via the website https://www.dataprotection.ie/.

ARTICLE 11 - Cookie policy

11.1 What is a cookie?

Users are informed that a cookie is a small file deposited on the terminal of any user (computer, tablet or mobile device) by our site during its consultation. It does not contain any personal information, but makes it possible to establish a link between the user's device and their preferences for using and experiencing our site (for example: location, language, font size).

11.2 User consent

For the use of "cookie" files involving the storage and analysis of personal data, the user's consent is always requested. This consent is valid for a period of thirteen (13) months, with certain exceptions (see table Art.13), after which a new authorization will be requested from the user.

ARTICLE 12 - Use of cookies

In accordance with S.I. deliberation no. 336/2011 - European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011, the Vendor informs site users that cookies record certain information that is stored in the memory of their hard disk. This information is used to generate site audience statistics and to offer services based on the information they have already selected during their previous visits.

An alert message, in the form of a banner, asks each user visiting the site whether they wish to accept cookies. In order to guarantee free, informed and unequivocal consent, the banner will not disappear until the user continues browsing and configures his/her choices.

Without the user's prior consent, cookies will not be deposited or read:

• If a person visiting the site (home page or directly another page of the site from a search engine, for example) does not continue browsing: a simple absence of action cannot be assimilated to a manifestation of will;
• Or if you click on the link in the banner allowing you to configure cookies and, if necessary, refuse the deposit of cookies.

We use and collect cookies for the following purposes:

- To process statistics and information about the traffic on our site and to optimize it;
- To offer our users a fluid browsing experience by adapting the presentation of our site to the display preferences of the user's terminal;
- To store information provided on the site by the user.

ARTICLE 13 - List of cookies on the site

ARTICLE 14 - Opposition and configuration

All users may oppose the recording of "Cookies" by configuring their browser in the following way:

- Open a private browser window ;
- Configure cookies via the "Cookies" widget available on the home page of our site;
- Configure your computer so that a message appears asking you to accept, personalize or refuse cookies on each site or systematically;

Or by any other means available to the user.

At any time, users may choose to express and modify their preferences with regard to cookies. The Vendor declines all responsibility for any consequences linked to the operation of the site and the services offered resulting from :

- Refusal of cookies by the user ;
- And/or the impossibility for the site to record or consult the cookies necessary for its operation due to the user's choices.

ARTICLE 15 - Browser configuration

Users can configure their browser software to define their choices concerning the use of cookies:

• For Microsoft Edge™ : https://support.microsoft.com/fr-fr/microsoft-edge
• For Safari™ : http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
• For Chrome™ : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• For Firefox™ : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
• For Opera™ : http://help.opera.com/Windows/10.20/fr/cookies.html

The user may also configure his browser to accept or refuse cookies on a case-by-case basis prior to their installation, or delete cookies from his terminal. The user is informed that by configuring his browser to refuse cookies, certain functionalities of our site may not be accessible, and neither the Vendor nor the host can be held responsible in this respect.

ARTICLE 16 - Modification of the privacy policy

The Seller reserves the right to modify this policy at any time. If a modification is made to this policy, the new version will be immediately published on the site. If the user does not agree with the terms of the new version of the policy, he/she has the option of no longer using the site's services and of no longer browsing it.

ARTICLE 17 - Acceptance of the privacy policy by the user

By browsing the site, the user certifies that he/she has read and understood this privacy policy and accepts its conditions, in particular with regard to the collection and processing of his/her personal data, as well as the use of "Cookies" files.