Penco PRIVACY POLICY
Document updated on 09/22/2023

LA DISQUETTELA DISQUETTE », « our », « we » et « our ») and our partners respect your privacy.

Please read this privacy policy carefully to understand how your personal data is collected, processed and stored when you use this website.penco.app, accessible via the url www.penco.app.

The term «personal data» means any information relating to a natural person and enabling that person to be identified, directly or indirectly, on the basis of a single item of data or a combination of items of data.

All personal data collected on this website is processed under the responsibility of the companyLA DISQUETTE, SAS (simplified joint stock company) with share capital of €15,000, registered with the Registre du Commerce et des Sociétés de lyon under number 921332128, and having its registered office at 3 RUE DE GENEVE, 69006 LYON, France and in compliance with Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms, in its current version, as well as Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

Within the meaning of the regulations applicable to personal data, LA DISQUETTE is therefore responsible for processing.

This privacy policy describes:
1. How LA DISQUETTE uses your personal data:
2. How LA DISQUETTE shares your personal data
3. How LA DISQUETTE protects your personal data
4. Where LA DISQUETTE hosts and transfers your personal data
5. How you can exercise your rights in relation to your personal data
6. Updates to the privacy policy
7. How to contact us

I. How LA DISQUETTE uses your personal data
LA DISQUETTE may use your personal data for the following purposes:

1. Take the necessary steps to manage contracts, invoices and customer relations
2. Publish and manage your opinions and/or comments left on the website
3. Send you our newsletter, if you have subscribed to it
4. Respond to your contact request from our website
5. Setting up a loyalty programme
6. Offer you advertising and content tailored to your needs
7. Build up a file of users, prospects and customers
8. Compiling sales and visitor statistics
9. Managing unpaid bills and any disputes that may arise
10. Meeting our legal obligations

The processing of your personal data is carried out as part of a pre-contractual contact process. This processing is based on your consent to be contacted in order to discuss our offers and obtain a quotation. You may withdraw this consent at any time and ask us to delete your information and stop contacting you.

When you voluntarily provide us with personal data, the collection of your personal data is based on the following legitimate interest: to better respond to your requests for information.

The processing of your personal data in order to send you our newsletter is, however, based solely on your consent to receive our newsletter, which you may withdraw at any time. If you do not consent to the newsletter being sent to you, please note that this will not prevent you from creating your customer account and placing orders on our website.
II. How LA DISQUETTE shares your personal data
Within LA DISQUETTE, and with regard to each processing purpose, personal data concerning you is collected, processed and stored by authorised LA DISQUETTE personnel, solely within the scope of their respective competencies, and in particular by the customer service, marketing and IT departments.
We do not share personal data with other companies, organisations and individuals unless one of the following circumstances applies:

(1) Sharing with prior consent : After obtaining your consent, LA DISQUETTE will share the information you have authorized with the specific third parties or categories of third parties identified at the time your consent was obtained.
(2) Sharing with our service providers : LA DISQUETTE may also disclose your information to companies that perform services for us or on our behalf. These service providers include companies that provide information technology services, such as our web host or email service provider, delivery services for our products, or marketing activities on our behalf. These service providers may use your information only for the purpose of providing services to you on behalf of LA DISQUETTE.
(3) In compliance with a legal obligation, sharing in accordance with laws and regulations : LA DISQUETTE may share your information as required by laws and regulations, in order to resolve legal disputes, or as required by judicial or administrative authorities under the law.

LA DISQUETTE will ensure the lawfulness of any sharing of personal data by entering into data processing agreements with the companies with which your personal data is shared, obliging them to comply with this Privacy Policy and to take appropriate security and confidentiality measures when processing personal data.

III. How LA DISQUETTE protects your personal data
LA DISQUETTE attaches great importance to the security of your personal data and has adopted industry standard practices to protect your personal data from unauthorized access, disclosure, use, modification, damage or loss.
We have also taken the necessary precautions to ensure the security and confidentiality of data, and in particular to prevent it from being distorted, damaged or communicated to unauthorised persons.

LA DISQUETTE also adopts the following organisational measures:

(1) We take reasonable and practicable steps to ensure that personal data collected is kept to a minimum and is only as relevant as necessary for the purposes for which it is processed.
(2) We keep your personal data for as long as is strictly necessary for the purposes for which it is processed, unless the retention of your data is required or permitted by law. By way of example, we retain data relating to the fulfilment of your orders for the period required by law for the retention of accounting records, i.e. a maximum of 10 years from the financial year in question.
(3) We deploy access control mechanisms to ensure that only authorised personnel can access your personal data.

In the event of a personal data breach, LA DISQUETTE will comply with the legal and regulatory requirements applicable to the notification of personal data breaches to the competent supervisory authorities and/or the persons concerned.

IV. Where LA DISQUETTE hosts and transfers your personal data
Your personal data will be hosted by our hosting provider, ovh, located in France.

V. How you can manage your rights relating to your personal data
You have the right to access, rectify, delete, limit and object to the processing of your personal data, as well as the right to define directives concerning the fate of your data after your death and the right to the portability of your personal data.
The CNIL defines personal data as «any information relating to an identified or identifiable natural person. But because it concerns individuals, they must retain control over it».

You also have the right to appeal to the Commission Nationale Informatique et Libertés in France and to a competent supervisory authority in any other Member State depending on your usual place of residence, your place of work or the place where the violation of your rights occurred, if you consider that the processing of your data does not comply with the applicable laws. This recourse may be exercised without prejudice to any other recourse before an administrative or judicial court, which also constitutes a right available to you.

You may contact us at any time at the addresses indicated in the «How to contact us» section below in order to exercise your rights with regard to personal data under the conditions laid down by the applicable regulations. You must indicate which right you wish to exercise and all the details necessary for us to respond to your request.

These rights are exercised under the conditions laid down by the applicable regulations.

The right of access means that you can ask us at any time to tell you whether we are processing personal data about you and, if so, what personal data is involved and the nature of the processing operation(s).

The right of rectification means that you can ask us to rectify your personal data if it is inaccurate. You may also request that your personal data, if incomplete, be completed insofar as this is relevant to the purpose of the processing in question.

The right to erasure means that you can ask for your personal data to be deleted in particular when:
1.Their retention is no longer necessary for the purposes for which they were collected ;
2.Your personal data is processed on the basis of your consent, you wish to withdraw that consent, and there is no other legal basis for processing ;
3. You have objected to the processing of your personal data and would therefore like it to be deleted ;
4. Your personal data has been processed unlawfully ;
5. Your personal data must be deleted to comply with a legal obligation under either European Union law or French law.

The right to limitation means that you can ask us to restrict the processing of your personal data:
1. If you dispute the accuracy of your personal data for a period of time that allows us to verify the accuracy of the data ;
2. When, following processing that has been established as non-compliant, you prefer the restriction of processing to the complete erasure of your personal data ;
3. When we no longer need your personal data for the purposes of processing, but it is still required for the establishment, exercise or defence of legal claims. ;
4. If you have objected to the processing of your personal data and would like us to restrict processing for a period that allows us to check whether the legitimate reason you are invoking is justified.
Restriction of processing means that the processing of your personal data will consist solely of the storage of your corresponding personal data. We will not carry out any other operation on the personal data in question.

The right of objection means that you may object to the processing of your personal data, where such processing is based on the pursuit of LA DISQUETTE's legitimate interests. The right to object is exercised subject to justification of a legitimate reason relating to your particular situation. We will then cease the processing in question unless there are compelling legitimate grounds for continuing it in accordance with the applicable regulations.

VI. Updates to this privacy policy
LA DISQUETTE reserves the right at any time to modify or update, in whole or in part, this privacy policy, due to changes in the applicable regulations on the protection of personal data or the data processing carried out.
Any substantial change to the confidentiality policy will be notified to you by e-mail when you have provided us with a valid e-mail address and will be published on the website. We recommend that you regularly read this privacy policy so that you are fully aware of our commitments in terms of security and protection of your personal data.

VII. How to contact us
If you have any questions, comments or suggestions, please contact us by sending an email to contact@penco.app..

If you are not satisfied with LA DISQUETTE's response to a request to exercise your rights in accordance with Article V above, or if you wish to report a breach of the applicable data protection regulations, you have the right to lodge a complaint with the CNIL by post (CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07) or on its website (www.cnil.fr), or with the data protection authority of the country in which you usually reside or work.