Personal data protection policy

  1. INTRODUCTION

This personal data protection policy, as well as any document to which it refers, details the conditions under which BioforceSAS, Bio Force SAS whose head office is located at 26 a rue de la gare F-68730 Blotzheim (France) registered with the Register of the Commerce of Mulhouse under the number 878 918 010 RCS Mulhouse hereinafter referred to as Bio Force SAS  (hereinafter referred to as “We” or “Bioforce SAS”), as the data controller, carries out the processing operations described hereinafter and relating to the personal data of any user and/or customer of the website www. train4dynamics.com (hereinafter the “Site”).

We are committed to adopting and maintaining high standards of customer care and ethics, including the protection of personal data.

As such, We process your personal data in compliance with the principles set out in the regulations applicable to the protection of personal data, and in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such personal data, and Law No. 78-17 of 6 January 1978 relating to data processing, files and freedoms, as amended (hereinafter together the “Personal Data Regulations”).

In accordance with the Personal Data Regulations, the term “personal data” refers, within the framework of this policy, to any information concerning you and enabling you to be identified directly or indirectly as a natural person.

This personal data protection policy may change according to the applicable legal and regulatory context or the evolution of our activity, and in particular the products or services that We offer you.

 

  1. PRINCIPLES APPLICABLE TO THE PROCESSING OF YOUR PERSONAL DATA

Within the framework of the collection and processing of your personal data, We are committed to respecting the following principles:

Lawfulness: your personal data are collected for specific, explicit and legitimate purposes, and on the basis of an appropriate legal basis;

Transparency: you are informed of each processing operation that we carry out and of the characteristics of these operations by means of information notices, no processing of your personal data being carried out without your knowledge. 

Minimization: We undertake to collect and process only the personal data concerning you that are strictly necessary for the purpose we are pursuing and to update them regularly;

Data protection by design and by default: when developing, designing, configuring and using applications, services and products that rely on the processing of personal data, we take into account your right to the protection of personal data and we ensure that our partners meet the legal requirements and can effectively ensure the protection of personal data that will be processed;

Security of personal data: We have put in place technical and organizational measures, adapted according to the degree of sensitivity of the personal data collected, in order to ensure the integrity and confidentiality of your personal data and to protect them against any malicious intrusion, loss, alteration or disclosure to unauthorized third parties. In particular, we use encryption and/or pseudonymization techniques for your personal data whenever possible, useful or necessary;

Commitments of our service providers and partners: We choose our subcontractors, service providers and partners carefully and require them to: (a) to ensure a level of protection of your personal data equivalent to ours, (b) to use your personal data only to the extent necessary to provide the services We have entrusted to them, (c) to comply with the Personal Data Regulation.

 

  1. PROCESSING OF YOUR PERSONAL DATA

3.1 Persons concerned

The persons concerned by the processing that We carry out are :

  • any user of the Site;
  • any customer of the Site;

3.2 Collection of personal data

We collect personal data about you directly from you.

In addition, We collect personal data about you indirectly from the following sources

  • the advertising and media agency of the Bioforce SAS;
  • Bioforce SAS’s commercial partners;

third parties, such as fraud prevention organizations or personal data providers;

3.3 Cookies

We use cookies and other tracking devices to collect personal data about you for some of the processing purposes described in section 3.4 of this policy.

You can configure these cookies and trackers by clicking on this LINK. All the information concerning them in the cookies policy is available https://train4dynamics.com/cookie-policy.

3.4 Purposes of processing, legal bases and retention periods

We implement various processing operations relating to your personal data, the purposes of which are detailed below and the legal bases of which are as follows: your consent, the performance of a contract concluded with you, our legitimate interest, or our legal and regulatory obligations.

  • In accordance with the Personal Data Regulations, the personal data that We collect will be used for the purposes for which they were collected and for the period detailed in the table below, it being specified that :
  • a user and/or customer of the Site is considered “active” when he/she logs in or modifies his/her personal space on the Site, makes an online purchase using his/her personal account, and/or makes an offline purchase or other interaction with Us by logging in;
  • a Member is considered “active” when he/she logs in or modifies his/her personal space on the Site, makes an online purchase.

At the end of the retention periods described below, your personal data will be deleted or, for those that We are legally obliged to retain or that are necessary to safeguard our rights, placed in an archive and kept for an additional period corresponding to the period detailed in the table below. At the end of this period, your personal data will be deleted.

The legal bases and retention periods associated with each of the purposes for which your personal data is processed are described below:

TABLE

 

If We are required to process your personal data for purposes other than those listed in the table above, you will be informed in advance and We will take any additional steps that may be necessary to ensure the legal compliance of all processing carried out.

3.5 Recipients of your personal data

In order to achieve the purposes described above and only to the extent necessary for the pursuit of these purposes, the personal data that We collect may be transmitted to all or part of the following recipients:

within the Bioforce SAS:

the entities of the Bioforce SAS in charge of the conclusion, management and execution of contracts and orders;

Bioforce SAS entities in charge of marketing (in particular the advertising department and the media agency), customer relations, complaints, prospecting, administrative services and IT services;

the Bioforce SAS entities in charge of the centralized management of our customers’ databases;

any other entity of the Bioforce SAS whose intervention would be necessary for the execution of the processing implemented in accordance with this policy;

outside the Bioforce SAS:

our service providers involved in all or part of the processing identified (in particular IT service providers responsible for maintaining the Site, technical intermediaries in the field of advertising and personalized communications, those responsible for the routing and delivery of products);

our partners who operate services available on our Site and/or services accessible through the use of the Program;

our partners who sell products or services directly from our Site;

our partners involved in the realization and sending of commercial prospecting campaigns;

our partners involved in the process of delivering personalized advertisements (including social networks and a partner responsible for pseudonymizing, sorting, enriching and cross-referencing your personal data), in particular in order to allow Us to obtain relevant information on your interests, to better understand your profile and to send you personalized advertisements and offers corresponding to your choices and your interests;

the suppliers of products and services of the Bioforce SAS companies who may access your personal data in pseudonymized form as separate data processors (subject to obtaining your consent, where required) via the services of our advertising agency or our media agency, in order to use them as advertisers. The list of advertising partners who may receive your personal data is available here [or: “upon request, using the form available HERE”] ;

In addition, when you log in to your customer or loyalty account using a Google or social network account, or when you interact with links or advertisements on our Site that link to other sites or applications, the third parties operating those sites, services or advertisements may, as separate data controllers, process your personal data under their own responsibility. We invite you to read their policies relating to the protection of personal data in order to know the terms and conditions applicable to the processing of your personal data that these actors implement.

 

3.6 Transfer of personal data outside the European Union

Your personal data collected and processed for the purposes described above may be transferred to companies located in countries outside the European Union, including the United States.

In this case, transfers of personal data are governed by an international data transfer agreement drawn up in accordance with the standard contractual clauses for data controllers and processors established by the European Commission and currently in force.

In addition, and when the legislation of the third country does not offer protection equivalent to that offered by the Personal Data Regulation, we ensure the implementation of additional measures to guarantee a level of protection of your personal data essentially equivalent to that provided in the European Union and to ensure the effectiveness of this protection.

 

  1. YOUR RIGHTS AND HOW TO EXERCISE THEM

4.1 Content of your rights

With regard to your personal data, you have the right to access, rectify, delete, oppose, limit the processing of your personal data, port your personal data and the right to give instructions concerning the fate of your personal data after your death.

You may also withdraw your consent at any time, in cases where it has been requested.

Right of access

You may request access to your personal data that We collect and process.

If you make a request for access, We will provide you with a copy of your personal data in Our possession and all legally required information.

Right to object

You may object at any time, on grounds relating to your particular situation, to the processing of your personal data where this is based on our legitimate interest, unless our legitimate interest overrides your own interests and rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.

You may also, at any time, object to the processing of your personal data by us when such processing is carried out for the purpose of commercial prospecting by electronic or postal means, including when the processing concerned constitutes profiling.

Right of rectification

You may at any time ask us to rectify any personal data concerning you that are inaccurate or incomplete.

Right of erasure

You may request the deletion of your personal data under the conditions provided for by the Personal Data Regulation, except where such data must be kept to enable us to comply with legal obligations, or to enable us to exercise or defend our rights, or where it is necessary for the performance of the contract between us.

Right to limit processing

You may request the limitation of the processing of your personal data under the conditions provided for in the Personal Data Regulation.

Right to portability

You have the right to the portability of the personal data that you have provided to Us and that We process by automated means, where the processing that We implement is based on your consent or on the performance of a contract or pre-contractual measures, provided that the exercise of this right does not infringe the rights and freedoms of third parties. Right to define directives concerning the fate of your data after your death

You have the possibility of defining general or specific directives concerning the way in which you wish to exercise, after your death, the rights guaranteed to you by the applicable regulations.

The general directives concern all of your personal data, and you can revoke them at any time. They can be registered with a trusted digital third party certified by the Commission Nationale de l’Informatique et des Libertés.

Specific directives concern the processing mentioned in these directives and are registered with Us: they are subject to a specific consent from you and you can revoke them at any time.

 

4.2 Exercising your rights

In order to exercise your rights, you can :

Send us an e-mail or a letter to the addresses below, specifying the right you wish to exercise, your personal data concerned by your request and indicating your first and last name as well as the e-mail address associated with your customer or loyalty account (if applicable):

E-mail: shop@train4dynamics.com

Postal mail: Bioforce SAS -26 a rue de la gare F-68730 Blotzheim (France)

 

4.3 Making a complaint

If you believe, after having contacted Us in this respect, that your rights relating to your personal data are not respected, you may submit a complaint to the Commission Nationale de l’Informatique et des Libertés (3 place de Fontenoy – TSA 80715 – 75334 Paris cedex 07 – telephone: 01 53 73 22 22).