At CODE41, we care deeply about privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. We know you care about your privacy too, so we provide settings that allow you to choose how certain information is used by CODE41. This policy explains our privacy practices for code41watches.com.
1. Who are we?
1.1 Data controller
The following information is provided in order for you to be able to take note of the commitments regarding the protection of personal data made by the company Cosanova, operator of the website “code41watches.com”, SARL, based at Rue du Midi 10, 1003 Lausanne, Switzerland (“CODE41”). CODE41 acts as the data controller for the handling of the personal data mentioned in this document.
1.2 Individuals concerned
The individuals concerned by the handling of data are the prospective and current customers of CODE41, notably including Internet users browsing the website (the “Users” or “You”).
2. The personal data that we handle
In the framework of personal data handling, CODE41 notably collects and handles the following categories of data:
- The navigation data of prospective and current customers (IP address, device type…);
- The identifying data of the customer (surname, first name, postal and email addresses…);
- Order history;
- Contact history with our teams (by email or online chat);
- Certain marketing and logistical data (orders, sales, after-sales service etc.), reports on sales, claims and requests for information, email campaigns.
We may gather personal data through the following means:
- by way of signed contracts;
- through our website, during navigation or in the event of signing up to the CODE41 community or creating an account or upon registering a product to take advantage of the guarantee (serial number, order number);
- by way of contact with the CODE41 teams (online chat or calls);
- via social media and the brand’s communication channels (e.g. Facebook, Twitter);
- during sponsored transactions for which you are responsible;
- or when you voluntarily provide them, particularly within the framework of an online application (CV, surname, first name, contact details, skills…).
3. The purposes of and legal bases for our handling of data
3.1 The purposes of our handling of data
The purposes behind our handling of data are as follows:
- management and monitoring of requests for information made by current or prospective customers and the responses provided;
- management and monitoring of orders;
- management of the after-sales service;
- monitoring of and statistics on orders;
- management of the members of the community, including the sending of newsletters and commercial offers;
- providing the customer with special offers on similar products (unless opted out);
- management and monitoring of product guarantees;
- management and monitoring of sponsorship programs;
- management of claims and disputes;
- compliance with legal obligations, in particular in terms of accounting;
- combating fraud relating to payment methods and bank card fraud;
- management and monitoring of applications.
3.2 The legal bases for our handling of data
We only make use of the data that we handle when at least one of the following conditions is met:
- we have received your consent for data handling procedures;
- we, or a third party, have a legitimate interest justifying the handling of the personal data in question;
- fulfilling a contract binding us to you which requires the handling of the personal data in question;
- we are bound by legal and regulatory obligations which require the handling of the personal data in question.
When you become a member of the CODE41 community, you explicitly agree that CODE41 may contact you with news on the activity of the community and offers limited to members of said community.
4. The recipients of your data
The personal data that we collect, as well as any that is gathered at a later date, are intended for us in our role as data controller.
We ensure that only authorized individuals may have access to this data. Our service providers may also be recipients of this data to facilitate the performance of the services with which we entrust them. Some personal data may be provided to third parties or legally authorized authorities in order to fulfill our legal, regulatory and contractual obligations.
They may be provided in the context of a business divestiture or the acquisition by a third party of all or part of CODE41’s assets.
5. The transfer of your data
We transfer your personal data to partners located in the following countries:
- United States of America.
Each of these transfers is managed by legal instruments in compliance with the governing legal framework. Transfers made to said countries are covered by the following appropriate safeguard measures:
- Switzerland: Adequacy decision
- United States of America: Privacy Shield subscription
6. How long we keep your data
The duration for which we retain your personal data is proportionate to the purposes for which it has been collected. Consequently, we structure our data retention policy for the strict duration required for the handling of said data, in accordance with our duration of retention policy.
Furthermore, anonymous data and your data may be retained indefinitely as long as it does not contain any personal data.
7. The rights that you are entitled to
7.1 Your right to information
You acknowledge that this policy informs you of the purposes, legal framework, interests, recipients or categories of recipient with whom your personal data is shared, and the possibility of the transfer of data to a different country or to an international organization.
In addition to this information, and with the aim of ensuring the fair and transparent handling of your data, you declare that you have received further information regarding:
- the duration for which your personal data is retained;
- the existence of the rights that you are entitled to, and the modalities of exercising them.
Should we decide to use data for purposes other than those mentioned, you will be provided with information relating to said new purposes.
7.2 Your right to access and rectify your data
You have the right to access your personal data and have it rectified, which may be exercised by contacting our support team at the following address: support@CODE41.com.
In this capacity, you may receive confirmation of whether or not your personal data is being used, and when it is used, and you have access to your data along with information concerning:
- the purposes of its use;
- the categories of personal data in question;
- the recipients or categories of recipients, as well as the international organizations to whom the personal data has been or will be provided; in particular those recipients located in another country;
- when possible, the planned duration for which your personal data is to be retained, or, when this is not possible, the criteria used to determine said duration;
- the existence of the right to request that the data controller rectify or erase your personal data, the right to request the limiting of the use of your personal data, the right to the portability of your data, and the right to oppose its use;
- the right to file a claim with a supervisory authority;
- information relating to the source of the data when it is not collected directly from the individuals in question;
- the existence of an automated decision-making process, including profiling, and in the latter case, useful data concerning the underlying logic, as well as the importance and anticipated consequences of this data handling for the individuals in question.
You may request that your personal data be, according to circumstance, rectified or completed if inaccurate, incomplete, ambiguous or obsolete.
7.3 Your right to erase your data
You may request that we erase your personal data when one of the following motives is applicable:
- the personal data is no longer required for the purposes for which it was collected or handled in a different way;
- you withdraw your previously given consent;
- you oppose the handling of your personal data when there is no legal motive for said handling;
- the handling of personal data is not in compliance with the provisions of the governing legislation and regulations;
- your personal data was collected as part of the services offered by the information society to children under the age of 16.
Nevertheless, the exercise of this right will not be possible should the retention of your personal data be required in accordance with legislation or regulations, and especially, for example, for the observation, exercise or defense of rights in court.
7.4 Your right to limit the handling of your data
You may request that the handling of your personal data be limited under the circumstances stipulated by the legislation and regulations.
7.5 Your right to oppose the handling of your data
You have the right to oppose the handling of personal data concerning you when said handling is based on the lawful interest of the data controller.
7.6 Your right to the portability of your data
You will have the right to the portability of your personal data.
The types of data for which this right may be exercised are as follows:
- only your personal data, which excludes anonymous personal data and data which does not concern you;
- declarative personal data, as well as personal data with the previously described function;
- personal data which does not threaten the rights or freedoms of third parties, such as that protected by business confidentiality.
This right is limited to data handling based on consent or a contract, as well as the personal data that you have personally generated
This right does not cover either derived or inferred data, which is personal data created by CODE41.
7.7 Your right to withdraw your consent
When our handling of data is authorized by your consent, you may withdraw said consent at any moment. We will then cease our handling of your personal data, without the calling into question of any previous procedures for which you have already given your consent.
Each member of the CODE41 community may at any moment choose to leave said community; you will no longer receive the newsletters or offers limited to members. You also consent to occasionally receiving special offers, from which you may unsubscribe.
7.8 Your right to file a claim
You have the right to file a claim with the CNIL (national information science and liberties commission) on French territory, without prejudice to any other administrative or judicial appeal.
7.9 Your right to define post-mortem instructions
You have the option to define instructions relating to the retention, erasure and communication of your personal data after your death, by way of a trusted third party, certified and charged with ensuring that the will of the deceased is respected in accordance with the requirements of the governing legal framework.
7.10 Modalities for the exercise of your rights
Nevertheless, we may not be obligated to proceed with the exercise of the right to information if:
- you already have access to this information;
- the recording or communication of your personal data is expressly stipulated by law;
- the communication of information proves to be impossible;
- the communication of information would require disproportionate efforts.
The security of personal data is important to CODE41.
In compliance with legal obligations, CODE41 keeps this data in conditions of increased security and for a limited duration proportional to the purposes for which you provided us with said data.
CODE41 follows widely accepted standards for protecting the personal data submitted to them, both during its transmission and once it is received by CODE41.
This policy is liable to be amended or adjusted by CODE41 at any moment. You are encouraged to consult it regularly. Last modification: [●]
If you have any questions: Contact CODE41’s Support team via our contact page; Send an email to CODE41's at firstname.lastname@example.org. Write to us at one of the following addresses:
Rue du Midi 10