Voice Memories Privacy Charter
Preamble
This privacy policy is intended to help you understand how your personal data is collected, processed and stored by VOICE MEMORIES via the Website. VOICE MEMORIES understands that data protection and privacy are key issues for all users visiting the Website.
In compliance with GDPR regulations, VOICE MEMORIES undertakes to respect your privacy and protect your personal data, meaning data that can identify you directly or indirectly as an individual. The purpose of this privacy policy is to present VOICE MEMORIES' commitments in this respect.
1 – DEFINITION
When you use our Website, we may ask you to provide us with personal data concerning you.
The term « personal data » means any information relating to an identified or identifiable natural person. In the context of the Website, this mainly covers information you provide when making a booking request, together with certain technical data necessary for the operation and security of the Website.
2 – PURPOSE
The purpose of this charter (hereinafter the « Charter ») is to inform you about the means we use to collect your personal data, in strict compliance with your rights.
In this respect, we inform you that, when collecting and managing your personal data, we comply with Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms, as currently in force (hereinafter: the « Data Protection Act »), as well as Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter: the « GDPR »).
3 – DATA CONTROLLER
The data controller for your personal data is VOICE MEMORIES SARL, registered with the Nice Trade and Companies Register under no. 929 271 070, with registered office at Palais Théodore, 27 rue Théodore de Banville, 06100 Nice, France (hereinafter: « We »).
For any question concerning the protection of your personal data, you may contact us at info@voicememories.fr.
4 – COLLECTION OF PERSONAL DATA
The Website collects the data needed for booking requests, performance of VOICE MEMORIES services and customer relationship management.
Depending on the case, processing is based on:
- performance of the contract or pre-contractual measures when you make a booking request, ask for availability, prepare delivery or finalise payment;
- VOICE MEMORIES' legitimate interest in responding to requests received, administering and securing the Website, preventing abuse and keeping evidence of necessary exchanges;
- legal, accounting and tax obligations applicable to invoicing, accounting and handling possible disputes.
The categories of data processed via the Website are as follows:
- identity and contact data: last name, first name, email address, telephone number and, where applicable, company name;
- address data needed for the booking, invoicing, shipment or return of equipment: address, additional address information, postal code, city and country;
- booking data: event type, requested date, selected package, options, phone model, delivery or pickup method, free message and related amounts;
- pickup point data when this method is selected: postal code, city, address optionally entered for the search, selected pickup point, identifier, name, address, carrier or network, geographic coordinates and pickup point country;
- technical and security data linked to submitting a booking request, including the IP address and user-agent stored with the request, as well as the CSRF token, anti-spam field and anti-spam check processed during submission;
The Website contact pages do not include a form: they offer contact by email or telephone.
When collecting your personal data, we inform you whether certain data must be provided or is optional (through visible asterisks on the Website).
5 – RECIPIENTS OF PERSONAL DATA
The following may access the data strictly necessary for their role:
- VOICE MEMORIES staff responsible for handling bookings, customer requests and administrative follow-up;
- advisers and services responsible for controls or legal compliance, including lawyers and accountants;
- the Website host, Hostinger;
- Google Fonts, solely for the technical information related to loading the Website font;
- OpenStreetMap, solely for the technical information related to displaying the pickup point map on the booking page;
- email providers used to route internal notifications and booking confirmations;
- the payment provider indicated on the Website, Stripe, for payment finalisation;
- delivery and pickup point providers, including Boxtal for pickup point search and the selected carriers or networks, for example Chronopost when that network is used.
Public bodies may also receive your personal data, exclusively to meet our legal obligations, as well as legal auxiliaries, ministerial officers and organisations responsible for debt collection.
6 – RETENTION PERIOD OF PERSONAL DATA
Regarding booking requests and customer relationship management
Data linked to a booking request is kept for the time needed to process the request, perform the service, follow up the customer relationship and manage any incidents, unpaid amounts or disputes.
Data needed to prove a right, contract, delivery, payment or compliance with accounting and tax obligations may be archived for the period provided by applicable rules.
Regarding requests received by email or telephone
Information sent directly by email or telephone is kept for the time needed to process the request and any follow-up to the commercial or contractual relationship.
Regarding payments
Financial transactions are carried out via the payment service provider indicated on the Website. Booking amounts, including package, options, delivery and total, are stored with the request in order to prepare the order and administrative follow-up.
The payment service provider processes the data necessary for the transaction in its secure environment. VOICE MEMORIES does not access or store the full bank card number or visual cryptogram (CVV/CVC).
Data processed by the payment service provider is retained according to its own obligations and security rules, in particular to execute, secure and prove the transaction or manage a dispute.
Regarding cookie preferences
The Website shows no cookie banner because it sets no analytics or marketing trackers. Only a strictly necessary session cookie is used during a booking, a payment or an administrator login; it disappears when the browser is closed. Website traffic is measured as anonymous totals, with no cookie, no stored IP address and no identifier.
7 – SECURITY
We inform you that we take all useful precautions and appropriate organisational and technical measures to preserve the security, integrity and confidentiality of your personal data and, in particular, prevent it from being altered, damaged, or accessed by unauthorised third parties. We also use secure payment systems compliant with the state of the art and applicable regulations.
8 – HOSTING
We inform you that your data is kept and stored, throughout its retention period, on Hostinger servers located in the European Union.
9 – TRANSFER OUTSIDE THE EUROPEAN UNION
The Website uses technical and service providers that may process technical data or data necessary for the service: Hostinger hosting, font loaded from Google Fonts, OpenStreetMap map background, pickup point search via Boxtal or the relevant carriers, and payment via Stripe.
The Website alone does not make it possible to determine the effective location of all processing carried out by these providers. Where personal data is processed outside the European Economic Area, such transfers must be covered by the safeguards provided by the GDPR, including an adequacy decision or standard contractual clauses.
10 – ACCESS, CORRECTION, LIMITATION AND ERASURE OF YOUR PERSONAL DATA
In accordance with European regulations on personal data protection, you benefit from the following rights:
- A right of access allowing you at any time to know whether your personal data is processed by our services and, when it is, to access said personal data and legally required information regarding the processing methods;
- A right of correction allowing you to request, as soon as possible, correction of any inaccuracy concerning your personal data;
- A right to erasure, allowing you to request as soon as possible that your personal data be erased, provided that this request complies with conditions required by applicable law;
- A right to restriction of processing of your personal data, provided that this request complies with conditions required by applicable law;
- A right to portability allowing you to receive your personal data in a structured, commonly used and machine-readable format, or to request that this personal data be transmitted to another controller, provided that this portability request complies with conditions required by applicable law;
- A right to object to processing of your personal data for reasons related to your particular situation, provided this objection complies with conditions required by applicable law;
- The right to withdraw at any time specific consent where the relevant processing is based on your consent;
- The right to define instructions regarding retention, erasure and communication of your personal data after your death.
You have the right to obtain restriction of processing of your personal data in the cases defined in Article 18 of the GDPR:
- During the verification period we implement when you dispute the accuracy of your personal data;
- When processing this data is unlawful and you wish to restrict such processing rather than delete your data;
- When we no longer need your personal data, but you want it retained to exercise your rights;
- During the verification period of legitimate grounds when you have objected to processing of your personal data.
Persons whose data is collected on the basis of our legitimate interest are reminded that they may at any time object to processing of their data. However, we may continue processing if there are legitimate grounds for processing that override your rights and freedoms, or if processing is necessary to establish, exercise or defend legal claims.
To exercise any of these rights or for any question concerning the processing of your personal data, you may write to us at info@voicememories.fr or send a letter to the registered office of VOICE MEMORIES: Palais Théodore, 27 rue Théodore de Banville, 06100 Nice, France.
We respond to requests as soon as possible and, in principle, within a maximum period of one month from receipt. This period may be extended by two months where justified by the complexity or number of requests; in that case, the data subject is informed within the initial one-month period.
Where there is reasonable doubt as to the identity of the requester, we may ask for the additional information strictly necessary to confirm their identity.
11 – PORTABILITY OF YOUR PERSONAL DATA
You have a right to portability of personal data you have provided to us, understood as data you have actively and knowingly declared when accessing and using services, as well as data generated by your activity while using services.
We remind you that this right does not concern data collected and processed on a legal basis other than consent or performance of the contract binding us.
This right may be exercised free of charge under the conditions provided for by the GDPR.
In this context, we will provide your personal data by any means deemed useful, in an open standard format commonly used and readable by computer systems, in accordance with the state of the art.
12 – LODGING A COMPLAINT WITH A SUPERVISORY AUTHORITY
You are also informed that you have the right to lodge a complaint with a competent supervisory authority, including the Commission nationale de l’informatique et des libertés (CNIL), the French supervisory authority, through its online complaints service: https://www.cnil.fr/fr/plaintes.
This remedy may be exercised without prejudice to any other remedy before an administrative or judicial court. Indeed, you also have a right to an effective administrative or judicial remedy if you consider that processing of your personal data under this charter constitutes a violation of applicable texts.
13 – CHANGES
We reserve the right, at our sole discretion, to modify this Charter in whole or in part at any time. These changes will take effect upon publication of the new charter.