CONNECTED PRODUCTS, a simplified joint stock company with capital of €10,000.00, whose registered office is located at 1, rue de Stockholm, 75008 Paris, registered with the Paris Trade and Companies Register under number 930 457 080, hereinafter referred to as “SORGA,” attaches the utmost importance to protecting individuals’ privacy. Any information collected about you, when you have decided to provide it to us, is intended to enable us to use the Services as described in the Terms of Use. The personal data collected by SORGA is protected by the French Data Protection Act Informatique et Libertés” (Data Protection Act) No. 78-17 of January 6, 1978, amended in 2004, and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. (Hereinafter referred to as “Personal Data”). All User data remains confined to our premises and those of our trusted third parties. Only personnel who need this data in the course of their duties have authorized access to your Personal Data. In addition, all employees are informed of the latest practices to be followed in terms of security and Personal Data.
Unfortunately, no transmission over the Internet can be guaranteed to be 100% secure. Therefore, despite our efforts to protect your Personal Data, SORGA cannot ensure or guarantee the security of any data you transmit to us via the Internet. Any information transmitted in this manner is at your own risk.
0.1 – Collection of Personal Data
The Personal Data collected on this website (or “Site”) is as follows:
Account Creation
When creating a User Account, SORGA records the following data:
title, last name, first name, mobile phone number, email address, year of birth, gender, and city of residence.
Login
When the User logs in to sorga.app, the application records, in particular, their username and password.
Profile
Using the Services provided on sorga.app allows you to create a profile, which may include the following data:
Products added to “My Wishlist,” added to “My Products,” messages exchanged anonymously with the brand, content added to events for a purchased product.
Cookies
SORGA only uses cookies intended for authentication with a service, including those designed to ensure the security of the authentication mechanism, for example by limiting automated or unexpected access attempts.
0.2 – Use and Retention of Personal Data
The Personal Data collected from Users is used to provide the Services of sorga.app, improve them, and maintain a secure environment. More specifically, the uses are as follows:
- access to and use of sorga.app by the User;
- internal communications in connection with the use of sorga.app between SORGA and the User;
- management of the operation and optimization of sorga.app;
- verification, identification, and authentication of data transmitted by the User;
- implementation of user support;
- prevention and detection of fraud, malware (malicious software), and management of security incidents;
- management of any disputes with Users;
- use of the SORGA encrypted email tool, which allows the User to communicate directly with companies marketing products added by the User to their “My Wish List” or “My Safe” and, conversely, allows these companies to communicate with the User, It being specified that in the context of these exchanges, the User’s anonymity is guaranteed by SORGA, except in the event that the User discloses their identity in one of their messages. SORGA is not responsible for the content of communications sent by brands.
- those referred to in Article 0.7 below in the context of relations with subcontractors
Personal Data is retained for as long as the account is active, in particular to enable the User to access the products they have saved in “My Box,” add a product to “My Wish List,” and write to a brand using the SORGA tag. The account is deactivated upon request by the User.
0.3 – Sharing Personal Data with Third Parties
Personal Data may be shared with third-party companies in the following cases:
- when SORGA uses service providers to provide user support. These service providers have limited access to User data in the context of performing these services and are contractually obligated to use it in accordance with the provisions of applicable regulations on the protection of personal data;
- If the User has opted to participate in a customer relations program (such as, but not limited to, loyalty benefits, games, discounts, gift vouchers, etc.) as part of the services offered by partner companies, SORGA may communicate the necessary personal information to the partner company concerned to enable the User to participate in said program. The User may manage each consent given for each partner company from their profile page.
- if required by law, SORGA may transmit data in order to respond to claims made against SORGA and comply with administrative and judicial procedures;
- If SORGA is involved in a merger, acquisition, asset sale, or bankruptcy proceeding, it may be required to sell or share all or part of its assets, including Personal Data. In this case, Users will be notified before Personal Data is transferred to a third party.
0.4- Security and confidentiality
SORGA implements organizational, technical, software, and physical measures in terms of digital security to protect Personal Data against alteration, destruction, and unauthorized access. However, it should be noted that the Internet is not a completely secure environment, and SORGA cannot guarantee the security of the transmission or storage of information on the Internet.
0.5 – Implementation of User Rights
In accordance with the regulations applicable to Personal Data, Users may update, modify, or delete Data concerning them by logging into their account and configuring the settings for that Account. In addition, by writing to the email address: rgpd@sorga.org, Users may exercise the following rights:
they can delete their Account,
they may exercise their right of access to find out what Personal Data is held about them. In this case, before implementing this right, SORGA may request proof of the person’s identity in order to verify its accuracy.
if the Personal Data held by SORGA is inaccurate, they may request that the information be updated.
0.6. Changes to this clause
SORGA reserves the right to make any changes to this clause relating to the protection of Personal Data at any time.
If a change is made to this Personal Data protection clause, SORGA undertakes to publish the new version on Sorga.app.
SORGA will also inform Users of the change by email, at least 15 days before the effective date. If the User does not agree with the terms of the new version of the Personal Data Protection clause, they may request the deletion of their Account.
0.7. Relationship with Subcontractors within the meaning of the GDPR
The User remains responsible for the processing, within the meaning of the applicable regulations, of the Personal Data of its customers and/or employees, which it may implement in connection with the use of the services.
The Parties agree that with regard to the European Regulation on the protection of Personal Data:
– The Data Controller is: The User
– The Processor: SORGA
– Tier 2 Processors: Scaleway, the company hosting the data
It is specified that Tier 2 Processors will not have access to Personal Data processed by the User, as this data is encrypted when it reaches Tier 2 Processors, making it impossible for them to access the content of the
data.