Personal data protection policy
Preamble
Entry into force: March 30th, 2023
INFINIWAVE LIMITED
77, LOWER CAMDEN STREET,
DUBLIN D02 XE80
Ireland
Registration number 737750 and VAT. 4162209VH
Access to the Site and its features requires the collection and processing of Users’ personal data. It was therefor necessary to establish a personal Data Protection Policy to comply with the recommendations for use in the processing of personal data as established by the applicable law and regulation.
The Site’s Data Protection Policy has been established in accordance with the recommendations of the Data Protection Commission (DPC). Its purpose is to inform Site Users of how their personal data is processed and of the commitments and measures we have taken to ensure that the personal data of Site Users is respected.
It has been established in accordance with the provision of:
The Data Protection Act 2018;
The European Regulation on Personal Data, 2018
The Law of transposition of the European Regulation on the Protection of Personal Data, 2018.
The version currently posted on the Site is the current version of this policy. The Seller reserves the right to modify it at any time in order to comply with the legal obligations in force. Any changes to the Privacy Policy will be will be communicated to Users in order to obtain their consent to the new policy.
By browsing our Site, the User acknowledges having read, understood and accepted this data protection policy. Any question relating to this policy can be sent to the following address: contact@urtest1.com.
Article 1 – Definitions
1.1 Technical terms relating to the protection of personal data
On our Site, the terms below have the meaning attributed to them with the meaning of GDPR (Article 4);
Consent: of the data subject, any free, specific, informed and unambiguous manifestation of will by which the data subject accepts, by a declaration or by a clear positive act, that personal data concerning him or her be the subject of a “treatment”;
Controller: “the natural or legal person, public authority, service or other body alone or jointly with others, determines the purposes and means of processing; where the purposes and means of such processing are determined by Union law or the law of a Member State, the controller may be designated or the specific criteria applicable to his designation may be provided for by the law of the ‘Union or by the law of a Member State’”;
Processor: “the natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller”;
Processing: “any operation or set of operations whether or not carried our using automated processes and applied to data or sets of personal data, such as the collection, recording, organisation, structuring, storage, adaption or modification, extraction, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, erasure or destruction”;
Personal Data Breach: “a security breach resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of personal data transmitted, stored or otherwise processed, or unauthorised access to such data”
1.2 Other terms used herein
“Customer”: designated according to the provisions of the introductory article of the Customer Rights Act 2022, an individual acting for purposes that are wholly or mainly outside that individual’s trade, business, craft or profession;
“Site”: means the Site https://urtest1.com/ operated by the Seller and made available to the User;
“User”: refers to any individual using our Site and having access to its content.
ARTICLE 2 – What is personal data?
Personal data means any information that can directly or indirectly identify a natural person (surname, first name, email, telephone number, postal address, etc.).
As such, the GDPR defines personal data as: “any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an “identifiable natural person” is deemed to be a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to his physical, physiological, genetic, psychic, Economic, cultural or social identity”.
ARTICLE 3 – Data of minors
In accordance with the provisions of Article 8 of European Regulation 2016/679 and the Data Protection Act, only minors aged 15 or over can consent to the processing of their personal data.
Users under the age of fifteen (15) are invited to seek the agreement of a legal representative – required by the Seller – so that their personal data can be collected and to be able to use the services of the Site.
The Seller’s liability cannot be sought in the event of the provision by any user of personal data concerning a minor under the age of fifteen (15).
ARTICLE 4 – Collection of personal data
We collect your consent.
By browsing the Site, the User must, on several occasions, provide some of their personal data (for the purposes indicated in Article 5).
By providing their data, the User therefore consents to the collection and processing of the personal data provided by the Seller for the exclusive purposes as detailed in article 5 of the Policy. This consent, together with other grounds, serves as the legal basis for the processing of the data collected.
The Seller collects and processes the data strictly necessary for the purposes for which they are processed. We undertake with our Users not to process data for purposes other than those mentioned below. If we were to offer a new service on the Site, or any other functionality of the Site, requiring the collection and processing of data, we undertake to collect the consent of the Users once again before offering the new service in question
Whenever the Site processes personal data, the Seller takes all reasonable measures to ensure the accuracy and relevance of the personal data with regard to the purposes for which they are processed.
ARTICLE 5 – Purpose of processing
We collect User data only for the following processing purposes:
5.1 Account creation (optional)
Customers can create an account on the Site. To do this, they must provide the following data: surname, first name, email address.
Customer data is used for the purposes of:
– Validate the creation of his account;
– Create your customer account;
– Communicate with the Customer;
– Ensure after-sales follow-up.
The legal basis is the execution of a Contract, due to the placing of an order, the latter accepting these provisions.
5.2 Placing the order
For the purpose of placing an order on the Site, Customers must provide the following information: surname, first name, email and billing address.
User data and communication data are used only for the purposes of:
– Validate the customer’s order;
– Process the Customer’s order;
– Provide the services covered by the order;
– Provide after-sales service.
The Customer is also informed that by placing an order, he will receive transactional communications from the Seller (invoices, change of password, results of personality tests). He can unsubscribe at any time by using the functionalities provided for this purpose in the communication emails sent by the Seller.
The legal basis is the Execution of a Contract due to the placing of an order, the latter accepting these provisions.
5.3 Payment for services
Payment for orders via the Site is made through our payment provider STRIPE, the latter acting as the controller of Customer payment data. The Seller does not have access to Customer payment data.
5.4 Subscription
By placing an order on the Site, the Customer automatically benefits from a Subscription to the Seller’s Subscription (see the GCS). If the Customer has not terminated his subscription after 24 hours, it is automatically extended for a period of one month, renewable by tacit agreement.
The data used for the conclusion of the subscription are the data provided by the Customer at the time of placing the order and are used for the purposes of:
– Provide subscription services;
– Manage subscription membership (billing, termination, renewal);
– Provide after-sales service.
5.5 Contact form
A contact form is available on the Site. To respond to his request, the User must provide his surname, first name, email and telephone number.
User data and communication data are used only for the purposes of:
– Process the User’s request;
– Respond to the User’s request.
The legal basis is the User Consent.
5.6 Analysis
By browsing the Site, the User may be required to enter their personal connection data (cookies, tracers).
Connection data and browsing information are used solely for the purposes of statistical studies (analysis of site traffic and user experience) and other purposes mentioned in the cookie policy.
The processing is necessary for the purposes of the legitimate interests pursued by the Seller, in particular to offer Users a smooth and improved browsing experience.
The connection data is also used to prevent and fight against any computer fraud.
The legal basis is the response to a legal obligation.
ARTICLE 6 – Duration of data retention
We do not exceed the legal data retention periods and User data is only kept for the time necessary to process the purposes for which it was collected.
The retention periods are as follows:
– Data relating to the identity of the User not having the quality of customer (surname, first name): they are deleted or anonymized three (3) years after the last contact from the User unless the latter has previously exercised a right (in application of the GDPR) having led to the deletion of his data;
– Communication data of the User not having the status of customer (email, telephone number, postal address): they are deleted or anonymized three (3) years after the last contact from the User unless this the latter has previously exercised a right (in application of the GDPR) which has led to the deletion of his data;
– Data relating to Customers who have placed an order: they are deleted five (5) years after the end of the commercial relationship with the Customer, unless the latter has previously exercised a right (in application of the GDPR) which has led to the deletion of their data ;
– Connection data: they are kept, in application of the Cookies policy, for a maximum period of 13 months (except as indicated in article 13).
In establishing our data processing policy, we have established a reference grid for the duration of data retention, developed thanks to the recommendations of the Data Protection Commission.
In addition, the Seller may retain certain personal data in order to fulfil its legal or regulatory obligations, to allow users to exercise their rights, or for statistical purposes. At the end of the retention period of the personal data, these will be deleted or anonymized.
ARTICLE 7 – ACCESS TO DATA
The data collected via the Site is intended exclusively for the following recipients.
7.1 Hosting of the Site
The Site is hosted by Scaleway , 8 rue de la Ville l’Evêque, 75008 Paris https://www.scaleway.com/
The host has access to the data within the limits of its respective attributions, for the hosting of the Site. It has limited access to User data, within the framework of the performance of these services and has a contractual obligation to use them in accordance with the provisions of the applicable regulations on the protection of personal data.
For more information, see Scalaway ‘s policy .
7.2 Third party providers
The Site and the Seller rely on certain third-party services to provide certain functionalities. The latter have limited access to User data, as part of the performance of these services and have a contractual obligation to use them in accordance with the provisions of the applicable regulations on the protection of personal data.
Payment management for orders on the Site is provided by Stripe.
User statistics data (cookies) are used to improve the user experience and allow the improvement of the Site’s functionalities. The user is invited to refer to the cookies policy of the site.
7.3 Legal obligations
The data may also be transmitted by the Seller to third parties and competent authorities to meet legal, judicial, tax or regulatory obligations. The Seller guarantees Users that no transfer of personal
data will be made to an unauthorized third party without the prior, voluntary, informed, express and written consent of the User.
The Seller is prohibited from processing, hosting or transferring the Information collected on its users to a country located outside the European Union or recognized as “unsuitable” by the European Commission without first informing the owner of the data and without having obtained his agreement.
ARTICLE 8 – Data protection
The Seller has taken all useful and necessary precautions, with regard to the state of the art in the matter, to protect your information in a secure environment in order to avoid any destruction, loss, alteration, dissemination or unauthorized access. No matter how hard you try, no method of transmission over the Internet, and no method of electronic storage, is completely secure. We cannot therefore guarantee absolute security. If we become aware of a security breach, we will notify affected users so that they can take appropriate action. Our incident notification procedures consider our legal obligations, whether at national or European level.
In the event that the integrity and confidentiality of your data are compromised, the controller undertakes to comply with the procedures put in place under the Data Protection Act 2018 and the European Data Protection Regulation(“GDPR”).
The Seller does not carry out any resale or outsourcing of User data.
ARTICLE 9 – Rights of persons
With regards to the legal provision of the Data Protection Act 2018 and the European Data Protection Regulation, Users of the Site have the following rights:
9.1 Right of access, rectification and right to erasure
The User may read, update, modify or request the deletion of data concerning him, by sending an email to the personal responsible for processing personal data, specifying the subject of this request to the following email address: contact@urtest1.com .
9.2 Right to portability
The User has the right to request the portability of his personal data, held by the Site or by the Seller, to another site, by making a request for the portability of his personal data to the data controller, by sending an email to the address provided above.
9.3 Right to restriction and opposition of data processing
The User has the right to request the limitation or to oppose the processing of his data by the Seller, without the latter being able to refuse, except to demonstrate the existence of legitimate and compelling reasons, which may prevail over the interests and the rights and freedoms of the user.
The User must make a request to limit the processing of his personal data to the data controller, by sending an email to the address provided above.
9.4 Right not to be the subject of a decision based exclusively on an automated process
In accordance with the provisions of Regulation 2016/679, the User has the right not to be the subject of a decision based exclusively on an automated process if the decision produces legal effects concerning him, or significantly affects him in similar way.
9.5 Right to determine the fate of data
The User is reminded that he can organise what should be the future of his data collection and processing if he dies, in accordance with the Data Protection Act 2018.
ARTICLE 10 – Exercise of Rights
10.1 How to exercise the rights?
To exercise one of your rights, all you need to do is:
To write a letter to the Seller, at the address of its head office;
Or write an email to the following address: contact@urtest1.com .
By indicating your surname, first name, address and attaching proof of identity.
The data controller is Mr Carlo Ela contact@urtest1.com .
Requests will be processed within one month, unless there is a compelling reason put forward and justified by the Seller justifying an extension of the period.
10.2 Referral to Data Protection Commission
If the Seller does not satisfy the User’s request, the latter is entitled to contact the Data Protection Commission on https://www.dataprotection.ie/.
ARTICLE 11 – Cookie policy
11.1 What is a Cookie?
The User is informed that a Cookie is a small file deposited on the terminal of any User ( computer, tablet or mobile device ), by our Site, during its consultation. It does not contain any personal information, but makes it possible to make the link between the User’s device and his preferences for use and experience on our Site (eg location, language, character size).
11.2 User Consent
For the use of “Cookie ” files involving the saving and analysis of personal data, the User’s consent is always requested. This consent is valid for a period of thirteen (13) months, with some exceptions (see table Art.13), after which a new authorization will be requested from the User.
ARTICLE 12 – Use of Cookies
In accordance with the deliberation of the S.I. No. 336/2011 – European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations
2011., the Seller informs the Users of the Site that Cookies record certain information which is stored in the memory of their hard disk. This information is used to generate Site audience statistics and to offer services according to the information they have already selected during their previous visits.
An alert message, in the form of a banner, asks each User visiting the Site, beforehand, if he wishes to accept cookies. To guarantee the free, informed, and unequivocal consent of the User visiting the Site, the banner will not disappear until he has continued his navigation and configured his choices.
Without the prior consent of the User, the deposit and reading of cookies will not be carried out:
If anyone who visits the Site (home page or directly on another page of the Site from a search engine for example) does not continue browsing: a simple lack of action cannot be assimilated to a manifestation of will;
Or if he clicks on the link present in the banner allowing her to configure cookies and, if necessary, refuses the deposit of cookies.
We use and collect cookies for the purposes of:
– To process statistics and information on traffic on our site and to optimize it as best as possible;
– To offer our users a smooth browsing experience by adapting the presentation of our Site to the display preferences of the user’s terminal;
– To memorize information provided on the Site by the User.
ARTICLE 13 – List of Cookies on the Site
The list of cookies present on the Site is as follows:
cookies Duration Raison Connected accounts only?
devicePixelRatio Default browser (1 year) Used to adapt the site to the screen size of the person visiting the site. Nope
wordpress_test_cookie Session Tests that the browser accepts cookies. Nope
_ga 2 years Google Analytics – Used to distinguish users. Nope
_gat_<property-id> 1 minute Google Analytics – Used to throttle request rate. Nope
_gid 24 hours Google Analytics – Used to distinguish users. Nope
tk_ai 24 hours Jetpack – Stores the unique identifier of the person who posted to enable data collection by Jetpack. Nope
tk_lr 1 year Jetpack – Stores the unique identifier of the person who posted to enable data collection by Jetpack. Nope
tk_or 5 years Jetpack – Stores the unique identifier of the person who posted to enable data collection by Jetpack. Nope
wp-settings-{user_id} 1 year Used for persisting an account’s wp-admin configuration. Yes
wporg_logged_in
wporg_sec 14 days if you select “Remember me” when logging in. Otherwise, the duration of the session. Used to check if the person currently visiting the site is logged into their WordPress.org account. Yes
wporg_locale 1 year Used to persist the user’s local configuration ice. Yes
ARTICLE 14 – Opposition and configuration
All Users may oppose the registration of “Cookies” by configuring their browser software in the following way(s):
– Open a private browsing window;
– Configuration of cookies via the “Cookies” Widget available on the home page of our Site;
– Configuring the computer so that a message appears asking you to accept, personalize or refuse Cookies on each site or systematically;
Or any other means available to the User.
At any time, the User can choose to express and modify his wishes in terms of Cookies. The Seller declines all responsibility for the consequences related to the operation of the Site and any services offered resulting from:
– The refusal of cookies by the User;
– And/or the impossibility for the site to save or consult the Cookies necessary for their operation due to the choice of the User.
ARTICLE 15 – Configuration of the navigation software
The User can configure his navigation software so as to configure his choices in terms of the use of cookies:
For Microsoft Edge TM : https://support.microsoft.com/en-us/microsoft-edge
For SafariTM : http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
For ChromeTM : http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
For Firefox TM : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
For OperaTM: http://help.opera.com/Windows/10.20/fr/cookies.html
The User can also configure his browser to accept or refuse Cookies on a case-by-case basis before their installation, or delete Cookies from his terminal. The User is informed that by setting his browser to refuse cookies, certain features of our Site may not be accessible and the Seller or the host may not be held liable in this regard.
ARTICLE 16 – Modification of the privacy policy
The Seller reserves the right to modify this Policy at any time. If a change is made to this Policy, the new version will be posted immediately on the Site. If the User does not agree with the terms of the new version of the policy, he has the possibility of no longer using the Services of the Site and of no longer browsing on the latter.
ARTICLE 17 – User acceptance of the privacy policy
By browsing the Site, the User certifies that he has read and understood this privacy policy and accepts its conditions, with particular regard to the collection and processing of his personal data, as well as the use of files “Cookies“.