Effective date: 9 June 2018

V plus habitat S?rl (“us”, “we”, or “our”) operates the www.vplushabitat.com website and all related services (collectively, the “Service”).

This page informs you about our policies regarding the collection, use, and disclosure of Personal Data when you use our Service, for instance by accessing and navigating this website, and the choices you have associated with such Personal Data. Furthermore, it points out your statutory privacy rights.

We use your Personal Data to provide and improve the Service. By using the Service, you agree to the collection and use of Personal Data in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.vplushabitat.com

Our Privacy Policy strictly adheres to the principles and provisions of EU Regulation 2016/679 (the General Data Protection Regulation – “GDPR”) and any other applicable law.

DEFINITIONS

PERSONAL DATA

Personal Data mean data and information about an individual, legally known as the ”data subject”, who can be identified from those data or from those and other information (either in our possession or likely to come into our possession).

Personal data also include usage data, meaning data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit) and other data.

COOKIES

Cookies are small pieces of data stored on a User’s device. For additional information on cookies, please visit our Cookie Policy.

DATA CONTROLLER

Data Controller means a person who, either alone or jointly or in common with others, determines the purposes for which and the manner in which any personal data are processed.

For the purpose of this Privacy Policy, the Data Controller is us:

V plus habitat Sarl

Rue de Chaux, 21

2800 Del?mont

Switzerland

DATA PROCESSOR

Data Processor means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Data Processors in order to process your Personal Data more effectively.

COLLECTION AND USE OF PERSONAL DATA

We collect several types of Personal Data for various purposes, mainly to provide and improve our Service.

TYPES OF DATA COLLECTED

USAGE DATA

We may collect various categories of usage data, including but not limited to: your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

The processing of usage data is necessary for us to supply the Service and to improve the user experience.

LOCALIZATION DATA

Conditional upon your explicit consent, we may process information about your territorial location (-Localization Data). Localization Data is required to provide some features of our Service, to improve and customize our Service.

You can enable or disable location services at any time through your device settings.

TRANSACTIONAL DATA

For the purpose of fulfilling orders on this website, we will ask you to provide us additional Personal Data, including but not limited to:

• First name and last name;
• Email address;
• Delivery and billing address;
• Phone number.

The submission of these items of Personal Data is required for you to complete purchase orders and their processing is based on the necessity of the Data Controller to perform a contract of sale (e.g., to deliver products, answer to customer enquiries, etc.).

The submission of Personal Data not necessary to fulfil purchase orders will always be optional.

MARKETING DATA

We may ask you to provide Personal Data to submit newsletters, marketing or promotional materials and other information that may be of interest to you. In all these cases, your consent will be optional.

You may opt out of receiving any, or all, of these communications by following the unsubscribe link or instructions provided in any email.

Based on our legitimate interest to improve the relationship with customers, we regularly send email communications with promotions, discounts, feedback requests and/or other commercial updates to our customers. Customers are always free to unsubscribe from such email communications by following the unsubscribe link or instructions provided in any email.

TRACKING & COOKIES DATA

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

PURPOSES OF PROCESSING

We process Personal Data in order to:

• Provide and maintain our Service;
• Notify you about changes to our Service;
• Allow you to participate in interactive features of our Service when you choose to do so;
• Provide customer support;
• Gather analysis or valuable information so that we can improve our Service;
• Monitor the usage of our Service;
• Detect, prevent and address technical issues;
• Provide customers with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about, unless you have opted not to receive such information;
• Submit marketing and commercial communications to users who have opted for such service.

We commit to ensure that processing of Personal Data will be adequate, relevant and limited to what is necessary in relation to the purposes for which Personal Data are processed.

RETENTION OF PERSONAL DATA

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

In order to determine the appropriate retention period for Personal Data processed under consent of the relevant data subject, we will consider multiple factors, also to ensure that Personal Data are not stored for longer than the necessary or appropriate period. These criteria will also include:

• The purpose for which we hold Personal Data;
• The type of ongoing relationship with the concerned user or customer;
• Any specific user request in relation to the deletion of personal information;
• Any legitimate business interests.

We will retain and use your Personal Data when processing is necessary for compliance with a legal obligation to which we are subject, to enforce our rights, resolve disputes and in all other circumstances prescribed by law.

We will also retain usage data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when these data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

TRANSFER OF PERSONAL DATA

Your Personal Data may be transferred to servers located in Switzerland.

Please be aware that the European Commission has the power to determine, on the basis of article 45 of the GDPR, whether a country outside the EU offers an adequate level of data protection, whether by its domestic legislation or of the international commitments it has entered into.

The EU Commission considers Switzerland as a country that provides an adequate level of data protection (2000/518/EC: Commission Decision of 26 July 2000 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of personal data provided in Switzerland)

Your consent to this Privacy Policy represents your full agreement to the transfer of Personal Data to Switzerland. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to any other country outside the European Economic Area unless there are adequate controls in place including the security of your Personal Data or unless you have provided consent to such transfer.

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our Service (“Service Providers“), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. They will act as Data Processors accordingly.

We will make our best effort to ensure that all Data Processors will apply their industry best practice to protect your Personal Data and that they will not use Personal Data for any other purposes than those agreed with us.

A list of the current Service Providers/Data Processors can be requested by email at: info@vplushabitat.com

DISCLOSURE OF PERSONAL DATA

BUSINESS RESTRUCTURINGS

In full compliance with the applicable law, if the Data Controller is involved in a business restructuring, your Personal Data may be transferred to any acquiring or resulting entity. We will notify you if and when your Personal Data is transferred and becomes subject to a different Privacy Policy.

DISCLOSURE FOR LAW ENFORCEMENT PURPOSES

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

OTHER LEGAL REQUIREMENTS

We may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation;
• Protect and defend the rights or property of the Data Controller;
• Prevent or investigate possible wrongdoing in connection with the Service;
• Protect the personal safety of users of the Service or the public;
• Protect us against any legal liability.

SECURITY OF PERSONAL DATA

We process your Personal Data with IT, automated and electronic tools. In accordance with the GDPR, specific security measures have been implemented to prevent Personal Data loss, unlawful or improper use and unauthorized access.

Only our authorized employees, and authorized employees of the third-party suppliers, acting as Data Processors on our behald, have access to your Personal Data. Data processing agreements are in place with Data Processors to ensure that they always meet the level of security required by the GDPR while processing Personal Data.

The security of your Personal Data is important to us. Nonetheless, you should be aware that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

YOUR PRIVACY RIGHTS

We aim to take any reasonable steps to allow you to correct, amend, delete, or limit our use of your Personal Data.

Whenever possible, you can update your Personal Data directly within your account settings. If you are unable to change your Personal Data, please contact us, so that we can make the required changes.

If you wish to be informed about any Personal Data we may hold about you, please contact us.

Under specific statutory conditions, you have the right to:

• Be informed on the Personal Data we hold about you;
• Access and receive a copy of your Personal Data;
• Have any of your Personal Data rectified, when incomplete, inaccurate or out-of-date;
• Request the erasure of your Personal Data (”the right to be forgotten”), unless we are still obliged or allowed to retain such Person Data on grounds other than user consent;
• Object to direct marketing, including profiling, and any processing based on our legitimate interest;
• Withdraw consent to the processing of your Personal Data;
• Object to processing of your Personal Dara based on legitimate interests;
• Object our decision to use your Personal Data to make an automated decision about you;
• Lodge a complaint with a competent supervisory authority;
• Obtain data portability for the Personal Data you provide to us (under specific conditions). Please be aware that we may reserve the right to verify your identity before responding to any of such requests.

ANALYTICS

We may use Service Providers to monitor and analyze the use of our Service.

• Google Analytics Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. Personal Data are shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, you can visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
• Piwik or Matomo Piwik or Matomo is a web analytics service. You can visit their Privacy Policy page here: https://matomo.org/privacy-policy
• Clicky Clicky is a web analytics service. You can visit the Privacy Policy for Clicky here: https://clicky.com/terms

PAYMENTS

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• PayPal or Braintree You can view their Privacy Policy at: https://www.paypal.com/webapps/mpp/ua/privacy-full

LINKS TO OTHER SITES

Our Service may contain links to other third-party sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

CHILDREN?S PRIVACY

Our Service does not address anyone under the age of 16 (“Children”).

We do not knowingly collect Personal Data from anyone under the age of 16. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data without your authorization, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take the appropriate steps to remove such Personal Data from our servers.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any enquiries, questions or observations about this Privacy Policy or you aim at exercising your privacy rights, please contact us by email at the following address: customer.care@vplushabitat.com