Effective as of September 18, 2019
ARTICLE 1: GENERAL INFORMATION
The SynerJ Health website and its platform are operated by SynerJ Health GmbH, registered under SIREN number 751 901 190, with its registered office at Heinrich Barth Strasse 22 - 66115 SAARBRUCKEN, represented by Ms. Claire Rouchon.
To ensure the security of your personal data, SynerJ Health is committed to providing the highest level of protection for your personal data in accordance with the European and French regulations applicable to the protection of personal data.
For any information regarding the protection of personal data, you can also visit the website of the Commission Informatique et Liberté (French Data Protection Authority) at www.cnil.fr.
The data controller is the person responsible for one or more personal data processing operations, determining their purpose and means. The management of SynerJ Health is responsible for processing your personal data within the scope of this policy.
SynerJ Health services are not intended for minors; therefore, SynerJ Health does not process data specifically related to minors. For example, we do not create marketing profiles related to minors. It is the responsibility of parents and legal guardians to decide whether their minor child is allowed to use SynerJ Health services.
1.2 Data Collected and Purposes of Processing:
The processing of data aims to integrate the distribution network of the company, allow users of the website to benefit from the offers, and manage orders and their follow-up (including deliveries, invoices, accounting, customer account management, complaints handling, and after-sales service). The processing also aims to manage payment securely through an identifier. The processing of data will also serve to manage your Independent Home Seller account and to declare your income.
Processing personal data is therefore a necessary condition for the successful completion of requests. Failure to provide this data would prevent the conclusion of an Independent Home Seller contract with SynerJ Health.
Specifically, we request Personal Data when you create your account on SynerJ Health.com, browse SynerJ Health.com, write a comment, pre-register, upload your contract supporting documents to our database, or provide new documents following a change in your personal/professional situation.
The Personal Data we request include your name, first name, address, email address, password, phone number, social security number with a copy of the card, IBAN with a copy, identity card or passport with a copy.
When you visit our website, we automatically collect the following information (including Personal Data):
- Technical data, including the IP (Internet Protocol) address used to connect your computer to the Internet, your login information, the type of browser you use and its version, time zone settings, browser plug-in types and versions, operating system, and platform.
- Data about your visit, including the complete URL, navigation path to, through, and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to navigate away from the page.
Some data is automatically collected based on your actions on the site.
Processing your data to provide you with an optimal service
We process your Personal Data in accordance with applicable law for the following purposes:
To answer any questions or provide information, products, or services you have requested, particularly with regard to user support.
To manage our accounts and records.
To manage our website and help us improve our products and services.
To prevent and detect fraud, including malicious software and any abuse of our site.
To manage security incidents.
To fulfill our obligations arising from a contract between you and us.
For the provision of services offered on the website, especially regarding your Independent Home Seller contract.
To conduct research and analysis.
To facilitate your access to and use of our website.
To manage the operation of our website and its optimization.
For verification, identification, and authentication of data transmitted by users.
To personalize your experience on the website and enable us to offer the type of content and product offers that best suit you.
To handle any disputes with users.
To comply with applicable law, regulations, and court decisions.
Following your order, you will receive several emails to allow you to track your order (order confirmation, information on the delivery of your package, etc.). These service messages are necessary for the proper execution of the orders and services you have requested. Receiving this information is not related to the choice you have made regarding the receipt of newsletters and commercial offers.
Service emails may also be sent to you to process your requests related to your customers, referrals, or your own contract.
If you have subscribed to them (particularly by accepting your registration in the mailing list), we also process your Personal Data to send you information about:
Special offers, sales, and promotional information
1.3 Data Retention Period:
Your personal data is retained for the time necessary to achieve the objective pursued when they were collected, namely:
For the management of product or service orders: 5 years from the last activity
For the use of the SynerJ Health.com account: 5 years from the last activity
For personalizing your services (emails, product recommendations): the last 200 views for site recommendations within a 3-year limit; and 3 years from the last activity for emails.
For sending messages by email or SMS (electronic commercial prospecting): 3 years from the last activity
For fraud prevention: until verification and validation of your order
For the retention of credit card data following a payment: 15 months
Your data will then be archived with restricted access only for the purposes of defending the publisher's rights and at the request of the authorities or the judiciary for an additional period and until the statute of limitations is acquired (except for ongoing actions, requests, or procedures). The limitation period for consumer matters is 3 years, and for other matters, it is 10 years.
After these dates, your data will be deleted, except for data strictly related to your professional activity within the company, which will be archived indefinitely to meet regulatory requirements.
1.4 Data Recipients:
The processing of data is primarily intended for the service providers (subcontractors) that SynerJ Health engages to carry out its services within the aforementioned purposes.
The publisher does not disclose or sell your Personal Data, and only authorized personnel within our company will have access to your Personal Data to the extent necessary and for the purposes mentioned above.
However, we may also be required to disclose your Personal Data to third parties:
To SynerJ Health service providers for compliance with accounting, tax, and administrative regulations.
More specifically, when our website uses the services of providers to provide user support, advertising, and payment services. These providers have limited access to user data within the scope of providing these services and have a contractual obligation to use them in accordance with the provisions of the applicable personal data protection regulations.
When you post information in the free comment areas of a website that is accessible to other internet users.
When you authorize a third-party website to access your data.
When it is necessary to protect the security or integrity of our databases or website.
When it is necessary in the context of legal proceedings and to take precautions against liability.
In the event of a sale, merger, reorganization, change in legal form, dissolution, or any similar event and/or to a potential or actual successor, where permitted by applicable law.
When required by applicable law. For example, if the law requires it, we may transmit data to respond to claims against the publisher and comply with administrative and judicial proceedings.
Your data will not be transferred outside the European Union.
However, in any case, the internet is not a perfectly secure environment, and SynerJ Health cannot guarantee the security of information transmission or storage on the internet.
ARTICLE 2: UPDATES
This policy may be updated periodically and without notice.
If you do not agree with the terms of the new version of the personal data protection policy, you have the option to exercise your rights as outlined above, including your right to erasure and right to object, in compliance with legal, regulatory, and contractual conditions.
ARTICLE 3: COOKIES
3.1 What is a Cookie?
A cookie is a text file deposited on your computer when you visit a website or view an advertisement. Its purpose is to collect information about your browsing and provide services tailored to your device (computer, mobile, or tablet). Cookies are managed by your web browser.
3.2 What Cookies Do We Use?
- Navigation cookies: These are cookies that are "strictly necessary" for the proper functioning of our website and usability features (such as remembering your cart until order confirmation, for example).
- Performance cookies: We use these cookies to collect anonymous statistics about user navigation on the site. This data allows us to improve our site, address navigation issues encountered by visitors, and evaluate the success of our commercial operations while preserving your strict anonymity and without any means of personally identifying you.
- Functional Cookies: These cookies are used to remember the choices you make on the site (such as remembering products you recently viewed or your delivery country). These cookies personalize your browsing based on the choices you made during your previous visits.
- Advertising Cookies: Advertising cookies are provided by third parties. They allow us to know your searches when you visit our site and your browsing habits to personalize the advertising addressed to you. Cookies are anonymous and do not allow you to be personally identified.
- Social Media Cookies: These cookies allow you to connect to your social networks and share content from our website through social networks. In some cases, these cookies involve the processing of your Personal Data. If you disable these cookies, you will not be able to effectively connect to social networks such as Twitter, Google+, Pinterest, and Facebook, and you will not be able to share content effectively.
We remind you that SynerJ Health is not responsible for the content, security, and privacy policies of these social networks, over which it has no control.
3.3 Accepting or Refusing Cookies
You can choose to disable these cookies at any time. Your browser can also be set to notify you of cookies placed on your computer and ask you to accept or decline them.
If your browser is configured to refuse all cookies, you may not be able to enjoy essential features of our site, such as storing items in your cart or receiving personalized recommendations. You may even be unable to browse the site.
To manage cookies as closely as possible to your preferences, we invite you to configure your browser taking into account the purposes of cookies as mentioned above.
Here's how to control or prevent the storage of cookies:
If you are using Internet Explorer: http://windows.microsoft.com/fr-FR/windowsvista/Block-orallow-cookies
If you are using Safari: https://support.apple.com/kb/PH21411?viewlocale=fr_FR&locale=fr_FR
If you are using Firefox: https://support.mozilla.org/fr/kb/cookies-informationssitesenregistrent# w_paramaetres-des-cookies
If you are using Chrome: https://support.google.com/chrome/answer/95647
If you are using Opera: http://help.opera.com/Windows/10.20/fr/cookies.html
If you are using iOS: http://support.apple.com/kb/HT1677?viewlocale=fr_FR
If you use different devices, be sure to configure the corresponding browser according to your preferences.
To comply with current law, we must ask for your consent to set some of the cookies described above. If you or another user of your computer wish to withdraw your consent at any time, you can do so by visiting the "cookie settings" of this policy again or by changing your browser settings.
ARTICLE 4: RIGHTS OF THE DATA SUBJECT
The rights mentioned below only apply to the processing of personal data concerning offers and orders as well as their management. Data related to the Independent Home Seller contract and, more specifically, its ongoing management with authorities cannot benefit from the rights provided by law. Such a restriction is based on the administrative significance of the documents generated through the provision of personal data.
4.1 Right to Confirmation of Data Processing or Not
The person concerned by the processing of personal data has the possibility to request confirmation of whether their data is being processed or not, and, if so, the right to access their personal data and receive a copy in accordance with legal provisions.
4.2 Right to Rectification
The person concerned has the right to rectify inaccurate personal data as soon as possible. They can also complete data that was previously incomplete.
4.3 Right to Erasure
A right to erasure of personal data is granted to the person concerned. However, this request must be legitimate and can only be made under certain legal and regulatory conditions to preserve your rights and those of SynerJ Health. The right to erasure is also granted if the person concerned withdraws their consent or objects to processing for direct marketing purposes or for reasons related to their particular situation. This right can also be exercised in cases of unlawful data processing or to comply with a legal obligation provided for by Union or Member State law.
4.4 Right to Restriction of Processing
The person concerned has the right to request the restriction of the processing of their data if they contest the accuracy of the data, for a period allowing SynerJ Health to verify its accuracy.
4.5 Right to Data Portability
If the person concerned meets the legal conditions, they have the right to request the communication of their personal data in a commonly used, machine-readable format. If the legal conditions are met, the person concerned can also request the direct transfer of personal data from SynerJ Health to another data controller.
4.6 Right to Object and Withdraw Consent
You have the right to object to the provision of your personal data. In this case, your experience with SynerJ Health may be limited or non-existent if your requested personal data is necessary for the relationship between SynerJ Health and you, or your request may not be able to be processed for the same reasons. You have the right to withdraw your consent for the future processing of your personal data, with the same potential consequences as those expressed in these articles. If you withdraw certain consents, your contract as an Independent Home Seller with SynerJ Health will be automatically terminated.
4.7 Exercise of Rights
Within the limits provided by applicable law, the person concerned has various rights concerning the protection of their personal data, namely:
- The right to confirmation of data processing or not
- The right to rectification
- The right to erasure
- The right to restriction
- The right to data portability
- The right to object and withdraw consent to the processing of personal data
These rights can be exercised directly by email at the following address (in this case, in accordance with regulations, your request must be accompanied by a clear and understandable copy of a valid official identification document): firstname.lastname@example.org.
These rights can also be exercised upon request in the "contact" section.
If you believe that the processing of personal data concerning you does not comply with the regulations, you have the possibility to file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL www.cnil.fr). If you wish to obtain additional information about your rights, you can also visit the CNIL's website.