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 law and applicable 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 users of the site about how their personal data is processed, and about the commitments and measures we have taken to ensure that users' personal data is respected.

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, users acknowledge that they have 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 means any freely given, specific, informed and unequivocal indication of his wishes by which the data subject signifies his agreement, by means of a declaration or a clear positive act, to personal data relating to him being "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; 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 specific criteria for such designation may be laid down in Union law or in the law of a Member State";

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

• Treatment Any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organisation, 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 accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed".

1.2 Other terms used here

• Customer Consumer: as defined in the introductory article of the Consumer Rights Act 2022, a person acting wholly or mainly for purposes outside his trade, business, craft or profession;

• Website refers to the site https://psna99.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 natural person (surname, first name, e-mail address, telephone number, postal address, etc.).

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 one 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 invited to obtain the agreement 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 Seller 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 the 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 not to 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 the consent of users 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 purposes:

5.1 Creating an account (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:

- Confirm the creation of their account;
- Create their customer account;
- Communicating with customers;
- After-sales support.

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

- Confirm the customer's order;
- Processing customer orders;
- Provide the services covered by the order;
- Provide after-sales service.

Customers are also informed that by placing an order, they will receive transactional communications from the seller (invoices, password changes, personality test results). They 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 by placing an order, with the customer accepting these provisions.

5.3 Payment for services

Payment for orders via the site is made via our payment service provider STRIPE, which acts as the party 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 their 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 is that provided by the customer when placing the order and is used for the following purposes:

- Providing subscription services ;
- Manage subscriptions (billing, termination, renewal) ;
- Provide after-sales service.

5.5 Contact form

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

- Processing the user's request ;
- Responding 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 browsing information are used solely for statistical studies (analysis of site traffic and user experience) and for other purposes mentioned in the cookies 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 data retention periods and user data is only retained for as long as is necessary to process the purposes for which it was collected.

The 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 made anonymous three (3) years after the last contact with the user, unless the user has previously exercised a right (in application of the RGPD) resulting in the deletion of his/her data;

- The communication data of the user who is not a customer (e-mail, telephone number, postal address): this is deleted or made anonymous three (3) years after the last contact with the user, unless the user has previously exercised a right (in application of the RGPD) which has led to the deletion of his/her data;

- Data relating to customers who have placed an order: this data 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) which has led to the deletion of the data;

- Connection data: in accordance with the cookies 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 in line with 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 made anonymous.

ARTICLE 7 - Access to data

The 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 the data within the limits of its respective remits, for the purposes of hosting the Site. It has limited access to user data for the purposes of providing these services and is contractually obliged to use it in accordance with the provisions of the 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 to optimise the Site's functionalities. Users are invited to refer to the site's cookies policy.

7.3 Legal obligations

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

The Seller is prohibited from processing, hosting or transferring information collected about its users to a country outside the European Union or recognised 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 unauthorised access. Despite our best efforts, no method of transmission over the Internet and no method of electronic storage is completely secure. We cannot therefore guarantee absolute security. If we become aware of a breach of security, we will inform the users concerned so that they can take appropriate action. Our incident notification procedures take into account 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 (GDPR).

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

Users have the right to request the portability of their personal data, held by the site or by the seller, to another site, by making a request for the portability of their personal data to the data controller, by sending an e-mail to the address given above.

9.3 Right to limit and object to data processing

The user has the right to request the limitation of or to oppose 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.

Users must send a request to limit the processing of their personal data to the data controller, by sending an e-mail to the address given above.

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 organise 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 the following address contact.psona@gmail.com.
  Please state your full name and address and enclose proof of identity.

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

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

10.2 Appeals 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 enables a link to be established between the user's device and their preferences for use and experience on 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 the user will be asked for a new authorisation.

ARTICLE 12 - Use of cookies

In accordance with S.I. No. 336/2011 - European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011, the Seller informs users of the site 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 according to 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 from users visiting the site, the banner will not disappear until the user has continued browsing and configured their choices.

Cookies will not be deposited or read without the user's prior consent:

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

We use and collect cookies for the following purposes:

- To process statistics and information on the traffic on our site and to optimise it as much as possible;
- 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 refuse to accept 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, personalise 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 relating 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 regarding 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

Users may also configure their browser to accept or refuse cookies on a case-by-case basis before they are installed, or delete cookies from their terminal. Users are informed that by configuring their browser to refuse cookies, certain functions of our site may not be accessible and neither the Seller nor the host may be held responsible in this respect.

ARTICLE 16 - Modification of the confidentiality policy

The Seller reserves the right to modify this policy at any time. If a change 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 services of the site and no longer browsing it.

ARTICLE 17 - Acceptance of the privacy policy by the user

By browsing the site, users certify that they have read and understood this privacy policy and accept its conditions, in particular as regards the collection and processing of their personal data and the use of "Cookies".