Privacy Policy
Published 2020-04-25
All rights reserved
©2020 Funkey Project
FunKey Project SAS
21 Avenue du Parc
33610 Canéjan
France
All rights reserved
©2020 Funkey Project
Introduction
FunKey Project SAS manages your personal data in association with your purchase of our products and the provision of our services at funkey-project.com that is made accessible by us.
Your privacy is key to us and we always want to make sure that you feel safe and informed when using our services. this privacy policy is intended to give you all the information you need (and which you are entitled to) on how we collect and process your personal data by visiting or using our services.
Please read this policy carefully all the way to the end.
We fully understand if you do not wish to share your personal data with us. Unfortunately, you will then not be able to use our services and purchase our products online as this requires certain sharing of data. an option is also to have a look at the privacy settings of your web browser – perhaps that will make you feel more secure.
Also, be aware that our websites might contain links to third party sites. We cannot take responsibility for anyone but ourselves and these sites will not be subject to this policy. We do not endorse and are not responsible for the privacy practices or the content on these sites.
What is personal data?
Personal data means all information that enables a person to be identified directly or indirectly. This includes obvious stuff like your name, address and personal id number but also a picture of you and your IP address. When it comes to “data portability”, data also include data that is generated by you such as order history.
Who is the controller of my personal data?
We are! And by we, we mean FunKey Project SAS, 21 Avenue du Parc, 33610 Canéjan, France.
Any age limit I need to know about?
You need to be at least 18 years old (or have your guardian’s approval) for us to be allowed to process your personal data.
What are you doing with my data?
We use it to…
…process purchase and services connected thereto.
This includes but is not limited to processing your orders, to process your payment or prevent or detect fraud, to be able to send text message notifications of delivery status, to be able to contact you in the event of any problem with the delivery of your items, to enable us to answer your queries, to provide warranty services and other customer services.
Lawful basis: agreement
…provide user account
Lawful basis: legitimate interest (to provide you with better, error-free services and products and to help you with troubleshooting).
…analyse how visitors uses the website, the products, the services and to improve the products and the services.
To enable error tracking across all our systems. To assure the technological operation of the services. Legitimate interest (to provide you with better, error-free services and products).
Lawful basis: agreement
…be able to send you marketing offers such as newsletters.
Lawful basis: consent
What data do you collect, when and why?
We collect your personal data in several different ways:
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When you make purchases on any of our websites and when we provide services to you regarding our products. We collect your name, e-mail address, postal address, telephone number, VAT number, IP address as well as other information provided by you when you make a purchase. We also collect information on all returns and exchanges. We and/or the payment processors with which we work may also collect and store your credit or debit card information (such as card type and expiration date). We collect and save all communication with our support function as well as information on warranty errands.
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When you set up a user account and when you use this account. Some of our services require you to register an account. If you choose to create an account by completing the registration form, you will be asked to provide contact details and identity data. We collect and process personal data that you enter in your customer account, information on how you use the app and software debug information.
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When you visit our websites. When surfing on our websites, we collect information about your IP address. We also collect information on the way you use our websites, including debug information, which you can read more about below in the cookies section.
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When you sign up to newsletters. When you sign to our newsletters, we will collect the contact information you provide us with.
For how long will you keep my data?
We will only keep your data for as long as is necessary to carry out our services to you or as long as we are required by law. After this your personal data will be deleted or anonymized.
We cannot remove your data when there is a legal storage requirement, such as book keeping rules or when there is a legal ground to keep the data, such as an on-going contractual relationship.
Will you keep my data safe?
No doubt about it. Security is one of our top priorities and we take all appropriate security measures to protect your personal data against things such as accidental loss, deletion, abuse, damage and unauthorized or illegal access. However, we kindly advise you to be aware that no information transfer via the internet or storage technology can be guaranteed to be 100 percent secure.
Will you share my data with someone else?
Yes, but only with trusted partners and only when it is necessary to fulfill any of our obligations to you.
We can come to share your personal data with:
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External service providers that help us provide the services to you and process your personal data on our behalf, such as ipayment gateways, couriers and helpdesk systems. Any such service providers will always be bound by security and confidentiality requirements in line with this policy and applicable law.
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Companies within the same group as us in order to develop and test new services and functions.
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To comply with legal or regulatory requirements, court rulings, writs or legal processes, if such is necessary to meet applicable regulations.
Where is data stored?
Your personal data is stored and maintained by us within the European Union (EU) and the European Economic Area (EEA). When we use your information as described in this policy, we may share your personal data with our selected suppliers who may process your data outside the EEA, when performing services on our behalf as set out in section 9 above. When we do this, we make sure that appropriate steps are taken to protect your personal information and your rights. We will only appoint trusted partners and appropriate safeguards are taken to ensure a safe and sound transfer of your personal data.
What about my rights?
You have the following rights and this is how you can claim them:
Right to be informed: You have a right to receive certain information. this is what this policy is all about. In it you receive all the information you are entitled to in connection with us obtaining your personal data.
Right of access: You have a right to know if we are processing data about you, to access this data and other supplementary info. This is so that you are aware of and can verify the lawfulness of the processing.
Right to rectification: You have a right to have personal data rectified if it is inaccurate or incomplete.
Right to erasure (a.k.a. the right to be forgotten): This right is to enable you to request the deletion or removal of personal data where there is no compelling reason for its continued processing.
Right to restriction of processing: In certain cases, you have a right to block or suppress process of personal data and this means that we would only be allowed to store your personal data but not to process it. This can be done for example during an investigation of whether your personal data is accurate or not.
right to object to processing: You have the right to object to us processing your data in certain cases, for example when it comes to marketing. This means that if you don’t want any more god damn newsletters, just let us know and we will stop immediately.
right to data portability: This right allows you to obtain the personal data you have provided to us, where processing is based on consent or agreement and when the processing is carried out by automated means, in a CSV-format so that you can reuse it in another service.
A request to claim any of these rights shall be sent to integrity@funkey-project.com
What if we don’t agree on something, can I complain to someone?
Yes box. The authority supervising our every step when it comes to data protection is the CNIL. If you think that we have acted in breach of data protection legislation you have the right to lodge a complaint with them.
Cookies
A “cookie” is a small text file that is saved to and during subsequent visits, retrieved from, your computer or mobile device. They are used to help websites work more effectively. Cookies help the website to recognize your device and remember information about your visit.
We do not use cookies to track you individually or to identify you, but to permit us to drive the services you have requested, to simplify how you navigate our website and give you the best surfing experience.
We use the Google Analytics tool to help us measure traffic and user statistics in order to understand how visitors access and use our website. We use the information collected via cookies to help improve our services and to obtain statistics on how our website is used by visitors. Please note that we use IP anonymization why Google only collects part of your IP address via Google Analytics on our website. If you want to prevent your data from being used by Google Analytics you can find their opt-out at https://tools.google.com/dlpage/gaoptout. Read more about how Google uses Google Analytics and how the tool collects and processes data at www.google.com/policies/privacy/partners/.
You can also manage your cookie preferences by editing the settings in your browser. Please note that if you block cookies, you might not be able to access all functions and pages on our website.
Changes to this policy
We can amend or update this policy from time to time and any changes to this policy will come into force on publication of the updated policy on our websites.
I still have questions….
Please contact us on integrity@funkey-project.com and we’ll do our very best to answer all your questions.