The company ESLAB, a simplified joint-stock company (SAS) with a share capital of €1,000, registered with the Strasbourg Trade and Companies Register under unique identification number 851836684, whose registered office is located at 1b rue de la Course, 67000 Strasbourg, processes the data collected about you and is responsible for the processing of personal data for any collection of data concerning you in connection with the services offered by ESLAB.

ESLAB operates the websites orinko.org and vibratis.fr.

FOR WHAT PURPOSES DO WE COLLECT AND PROCESS YOUR DATA?

ESLAB collects and processes your data for the purposes listed below and detailed hereafter. First and foremost, they are used for customer relationship management and to enable us to better interact with our customers, optimize user experience, and respond to requests and potential complaints from our customers. These processes include, in particular:

• The ability to create an account;

• Managing your consents and authorizations regarding the use of your personal data, particularly for sending newsletters and electronic marketing communications;

• Allowing you to benefit from ESLAB services, order products and services, track your orders and billing, subscribe to newsletters, etc.;

• Recognizing your loyalty customer status, once you have chosen to inform ESLAB of this, and if such information is requested. It is specified that the use of your personal data within the ESLAB loyalty program is subject to specific terms of use applicable to that program;

• Collecting your comments and reviews;

• Managing communications and tracking our exchanges, particularly in the context of potential disputes (notably via customer service accessible by phone or instant messaging/chat; these exchanges may be recorded for service improvement purposes);

• Managing your requests relating to the exercise of your rights, including rights of access, rectification, and objection, in accordance with personal data regulations;

• Managing the risk of fraudulent use of your data or the services you access via ESLAB. Depending on the results of the checks carried out, ESLAB may take any measures it deems appropriate to secure your data and our information systems used for ESLAB services, as well as to defend its interests. Where applicable, such measures may result in the suspension of your access to ESLAB and your online account;

• Managing product recalls initiated by suppliers or sending related information or documents;

• Preparing analyses or statistics to respond to surveys or requests conducted by public interest organizations, administrations, or judicial authorities (for example, in the event of food safety risks);

• Recording and administering evidence that ESLAB must provide to comply with its legal or regulatory obligations or for litigation management purposes (e.g., evidence relating to the exercise of your rights or your orders);

• Managing disputes, particularly those relating to the recovery of sums you may owe and payment incidents;

• Complying with legal or regulatory obligations applicable to ESLAB’s activities (e.g., responding to requests from tax authorities).

Your data may also be used for commercial prospecting operations or studies intended to improve customer knowledge and the services ESLAB can offer. Your data may therefore be used, subject to any required authorizations you have granted:

• To send you promotional messages or advertisements, personalized or not, by post or electronically, including mobile notifications, depending on your profile;

• To analyze your use of services (including online browsing and email interactions) so that we can better understand you, assess your interest in our services and communications, and offer you tailored offers, content, and services. These analyses are carried out in compliance with any authorizations you may have granted, particularly in the case of cookies or other tracking technologies.

For commercial prospecting involving profiling based on consent, you may withdraw your consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.

Your data may also be used for technical operations related to the processing of your personal data for the purposes described above, including:

• Technical operations related to address correction;

• Assigning a digital identifier linked to your data to enable interaction with you across various digital communication channels (websites, mobile applications, social networks), including for targeted advertising;

• Technical, organizational, or cybersecurity operations related to anomaly detection and securing your data and our information systems.

WHY IS YOUR PERSONAL DATA PROCESSED?

Your data may be processed for one or more of the following reasons:

• Because it is necessary to provide ESLAB services;

• Within the framework of any agreement you have given, for example, to allow us to communicate with you about our offers and products or those of third-party advertisers;

• In compliance with the interests, freedoms, and fundamental rights of users of ESLAB services, where processing is necessary for us or our partners to pursue legitimate interests, such as building customer loyalty, managing customer relationships effectively, improving customer knowledge, promoting products and services, combating fraud, and defending our interests in litigation.

WHAT DATA DO WE COLLECT?

The data processed by ESLAB comes from:

• Your registration: data included in subscription forms such as your surname, first name, date of birth, and contact details;

• Your use of ESLAB services, such as your purchases (directly from ESLAB or via ESLAB): identification and authentication data (login logs, IP address), purchase details, order locations and times, browsing history, consultation dates and times, and location data;

• Third-party websites and mobile applications: navigation information or advertisements addressed to you;

• Social networks such as Facebook, LinkedIn, Twitter. Data exchanges may occur between ESLAB and these networks when, for example, you are logged into Facebook while browsing ESLAB websites. Clicking a Twitter button on an ESLAB page allows Twitter to collect this information. If you do not wish such exchanges, you should log out of social networks before visiting ESLAB websites.

Data concerning you may also be transmitted by third parties, such as postal or email addresses or profile data, which will be integrated into our databases. These third parties have lawfully collected your data and obtained the necessary consent before transferring it to ESLAB.

We may also use open data sources.

Except for open data, the other data is not publicly accessible. Data may be collected directly from you, through your use of ESLAB services, from other group entities, or from partners or third parties. The collected data is necessary for ESLAB, its service providers, and/or partners to deliver services, better understand and interact with you, facilitate your relationship within the ESLAB ecosystem, and provide tailored content based on your profile and interests.

WHO MAY ACCESS YOUR DATA?

To fulfill the purposes described above, and within the limits necessary, your data may be shared with:

• Authorized personnel within ESLAB departments (e.g., marketing, analytics, customer panels, customer service, litigation, accounting and tax, IT, and information security);

• Payment service providers and debt recovery providers;

• ESLAB’s service providers and subcontractors (e.g., IT providers, advertising service providers);

• Partner advertisers or brands (in this case, they do not have direct or indirect access to your personal data; only non-identifiable profile data may be used);

• Administrative or judicial authorities where required to comply with legal obligations or defend our rights and interests.

DATA RETENTION PERIOD

Your data will be retained for the duration necessary to fulfill the purposes described above, plus the applicable statutory limitation period.

In principle:

• Account data is retained for the duration of your membership;

• It may then be retained for 3 years following your last contact for marketing purposes;

• It may be retained longer where required by specific legal obligations or limitation periods.

For example:

• 6 years for tax documents;

• 10 years for accounting documents;

• The duration of legal proceedings until all appeals are exhausted.

In the event of exercising your rights, identity document data may be retained for up to 3 years.

HOW IS YOUR DATA SECURED?

ESLAB takes into account the nature of personal data and associated risks to implement appropriate technical, physical, and organizational measures to ensure data security and confidentiality and prevent unauthorized access, alteration, or damage.

Subcontractors and service providers are selected based on guarantees of quality, security, reliability, and resources and must comply with confidentiality standards at least equivalent to those of ESLAB.

IS YOUR DATA PROCESSED OUTSIDE THE EUROPEAN UNION?

Data may be transferred to service providers located outside the European Union, particularly for IT services or social media-related operations.

To secure such transfers, subcontractors sign standard contractual clauses approved by the European Commission, are subject to binding corporate rules approved by data protection authorities, or are located in countries providing adequate protection.

WHAT ARE YOUR RIGHTS?

In accordance with personal data protection regulations, you have:

• The right to information;

• The right of access;

• The right to rectification;

• The right to erasure (unless required for contract performance, legal compliance, or legal claims);

• The right to define directives regarding your data after your death;

• The right to restriction of processing;

• The right to data portability (in certain cases);

• The right to object, on grounds relating to your particular situation, to processing based on legitimate interest, including profiling;

• The right to object to marketing processing and to withdraw consent at any time.

Requests may be sent to:
ESLAB – 1b rue de la Course, 67000 Strasbourg
Email: contact@orinko.org

Requests must be signed and accompanied by a copy of an identity document bearing your signature. A response will be provided as soon as possible.

You may also register free of charge on the “Bloctel” telephone opt-out list (https://conso.bloctel.fr/).

If you are not satisfied, you may lodge a complaint with the French Data Protection Authority (CNIL).

Data Protection Officer: ESLAB – Data Protection Officer – 1b rue de la Course, 67000 Strasbourg.

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