Preamble

Last updated on: 26 March 2024

JMM PUBLISHING LTD

167-169 Great Portland Street W1W 5PF London

Company number 12642117 and VAT. GB 364 3536 90

In order to guarantee access to the Site's services and functionalities, the collection and processing of users' personal data is essential. This has made it necessary to draw up a Personal Data Protection Policy, in line with the guidelines on the processing of personal data defined by current laws and regulations.

This policy has been drawn up in accordance with the directives of the Data Protection Commission (CPD), with the aim of informing users about the processing of their personal data and the commitments made to ensure the protection of this data. It is based on the following legislative texts:

• The Personal Data Protection Act 2018;
• The European Personal Data Regulation 2018;
• The European Data Protection Regulation Transposition Act 2018.

The current version of this policy, available on the Site, is the one in force. We reserve the right to make changes to this policy at any time, in order to comply with legal obligations. Users will be informed of any changes in order to obtain their consent to the new policy.

By using our Site, you acknowledge that you have read, understood and accepted our data protection policy. If you have any questions about this policy, please contact us at contact.convert33@gmail.com.

Article 1 - Definitions

On our site, several terms specific to the protection of personal data are used in accordance with the definitions provided by the RGPD (Article 4):

• Consent : This is the consent given by the data subject, expressing in a free, informed, specific and unambiguous manner their approval for the processing of their personal data. This consent may be expressed by an explicit declaration or by a clear positive act.
• Data controller : This designation refers to the entity (individual, company, public authority or other) which defines, alone or jointly with others, the purposes and means of the data processing. Where the legal framework of the Union or of a Member State lays down the purposes and means of the processing, the controller may be designated directly by these legal provisions, or the criteria for his appointment may be specified therein.
• Subcontractor : This refers to any entity (individual, company, public authority or other) that processes personal data on behalf of the data controller.
• Treatment : This term encompasses any operation or set of operations, whether automated or not, applied to personal data or sets of personal data. This includes collecting, recording, organising, structuring, storing, adapting, modifying, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, interconnecting, limiting, erasing or destroying data.
• Personal data breach : This refers to any breach of security leading to the destruction, loss, alteration, unauthorised disclosure of or access to personal data stored, transmitted or otherwise processed.

Other terms used in the document :

• Customer : As defined by the Consumer Rights Act 2022, this is a natural person acting for purposes that are wholly or mainly outside their trade, craft, business or profession.
• Site : Represents the website https://convert33.com/ managed by the Seller and accessible to users.
• User : Refers to any person browsing our site and accessing its content.

Article 2 - What is personal data?

Personal data includes any information that enables an individual to be identified, directly or indirectly. This includes surname, first name, e-mail address, telephone number, postal address, etc.

The General Data Protection Regulation (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 one 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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person".

Article 3 - Data relating to minors

Under Article 8 of European Regulation 2016/679 and the Data Protection Act, only minors aged 15 or over may authorise the processing of their personal data.

Users under the age of fifteen (15) must have a legal representative to collect their personal data and use the Site's services.

The Seller cannot be held liable in the event of the supply of personal data concerning a minor under the age of fifteen (15).

Article 4 - Collection of personal data

We have received your consent.

By browsing the site, the user must provide personal information (as instructed in Article 5). By providing this data, the user agrees that the Seller may collect and process personal data for the sole purposes mentioned in Article 5 of the Policy. This consent is legal for processing the information collected.

The seller collects and processes the information necessary to process them. We ask Users not to use information for purposes other than those set out below. If we offer a new service on the site or any other feature that requires the collection and processing of information, we should obtain Users' consent before offering the new service.

The Seller takes all reasonable steps to ensure the accuracy and relevance of personal data.

Article 5 - Purpose of processing

User information is only collected for the following purposes:

• Create an account (optional) Customers can set up an account on the site. To do so, they need the following information: surname, first name, e-mail address. Customer data is used for the following purposes:
• Validating the creation of their account.
• Customer card management ;
• Communicating with customers ;
• Follow-up after the operation.
• 5.2 Order to be placed To order on the Site, customers must provide their surname, first name, e-mail address and billing address.
• User data and communication data are used solely for :
• Confirmation of customer payment ;
• The customer's order is still in progress.
• Order service provided ;
• Post-sales support.
• 5.3 Cost of services Orders are paid for via the Site using our HIPAY payment service, which manages the Customer's payment information. The Customer's payment information is not available to the Seller.
• 5.4 Appointment The Customer is automatically subscribed to the Vendor's Subscription when he/she orders on the Site (see the General Terms and Conditions of Sale). If the Customer has not cancelled their subscription within 24 hours, it is automatically extended by one month and may be renewed by tacit agreement.
• Subscription signature information is the information provided by the customer at the time of ordering and is used to :
• Provide subscription services.
• Subscription management (payment, cancellation, renewal) ;
• Provide after-sales service.
• 5.5 Contact request Contact: On the Site, you will find a contact form. Users must provide their surname, first name, e-mail address and telephone number in order to respond to their request. The User's data and communication data are used solely for :
• Return the user request ;
• In response to the User's request. The User's consent is the legal basis.
• 5.6 Comments Browsing the Site may require Users to enter their personal connection data (cookies, tracers).
• Connection data and browsing information are used solely for statistical studies (site traffic analysis and user experience) and other purposes mentioned in the cookies 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.
• Connection data is also used to prevent and combat computer fraud.
• The legal basis is the response to a legal obligation.

Article 6 - How long we keep your data

We comply with legal data retention periods and user data is only retained for as long as is necessary to process the purposes for which it was collected.

• Information on the identity of the User who is not a customer (surname, first name): this is deleted or made anonymous three (3) years after the last contact with the User, unless the User has exercised a right (in application of the RGPD) which has led to the deletion of his/her data ;
• Non-customer User communication information (e-mail, telephone number, postal address): this is deleted or made anonymous three (3) years after the last contact with the User, unless the User has exercised a right (in application of the RGPD) to have his/her data deleted;
• Data relating to customers who have placed an order is deleted five (5) years after the end of the commercial relationship with the Customer, unless the Customer has previously exercised a right (pursuant to the RGPD) to have his/her data deleted.
• Connection data is stored in accordance with the cookies policy for a maximum period of 13 months, unless otherwise indicated in article 13.

We have drawn up a reference grid for data retention periods in line with the recommendations of the Data Protection Commission when establishing our data processing policy.

In addition, the Seller may retain certain personal information to meet its legal or regulatory obligations, to enable users to exercise their rights or for statistical purposes. Once the retention period for personal data has expired, it will be deleted or made anonymous.

Article 7 - Access to your data

The data collected via the Site is intended exclusively for the following recipients.

• 7.1 Site hosting The Site is hosted by Namecheap, located at Inc, 4600 East Washington Street, Suite 305, Phoenix, AZ 85034, United States. Further information is available at https://www.namecheap.com/.
• The host has access to the data within the limits of its respective remits, for the purposes of hosting the Site. It has limited access to Users' data, as part of the provision of these services, and is contractually obliged to use it in accordance with the provisions of the applicable regulations on the protection of personal data.
• 7.2 Third-party service providers The Site and the Seller rely on certain third-party services to provide certain functionalities. These third parties have limited access to User data as part of the provision of these services and are contractually obliged to use it in accordance with the provisions of the applicable regulations on the protection of personal data.
• Payments for orders on the Site are handled by Hipay.
• User statistics (cookies) are used to improve the user experience and to enhance the functionality of the Site. The user is invited to refer to the site's cookie policy.
• 7.3 Legal obligations Data may also be transmitted by the Vendor to third parties and the competent authorities in order to comply with legal, judicial, fiscal or regulatory obligations. The Vendor guarantees Users that no transfer of personal data will be made to an unauthorised third party without the prior, voluntary, informed, express and written consent of the User.
• The Seller is prohibited from processing, hosting or transferring information collected about its users to a country outside the European Union or recognised as "inappropriate" by the European Commission without first informing the owner of the data and obtaining its consent.

Article 8 - Protection of your data

The Seller has taken all necessary precautions, taking into account the state of the art, to protect your information in a secure environment in order to avoid any destruction, loss, alteration, distribution or unauthorised access. The efforts made do not guarantee total security of Internet transmission and electronic storage. Absolute security cannot be guaranteed. In the event of a breach of security, we inform the users concerned so that they can take the appropriate measures. Our incident notification procedures take account of our legal obligations, whether national or European.

The data controller must comply with the procedures established under the Data Protection Act 2018 and the European Data Protection Regulation (GDPR) in the event that the integrity and confidentiality of your data is compromised.

The Seller does not resell or outsource User data.

Article 9 - Individual rights

Under the Data Protection Act 2018 and the European Data Protection Regulation, users of the Site have the following rights:

• 9.1 The right of access, rectification and deletion. Users may consult, update, modify or request the deletion of data concerning them by sending an e-mail to the person responsible for processing personal data, specifying the subject of the request at the following e-mail address: contact.convert33@gmail.com.
• 9.2 Law on mobility By sending an e-mail to the above address, the User may request the portability of his/her personal data held by the Site or the Seller to another site.
• 9.3 It is important to limit and prohibit the processing of data. The Vendor may request the limitation of or opposition to the processing of the User's data without the User being able to refuse, unless it can prove the existence of legitimate and overriding reasons, likely to prejudice the interests and rights and freedoms of the User.
• Users must ask the data controller to restrict the processing of their personal data by sending an e-mail to the above address.
• 9.5 Right to process information : Under the Data Protection Act 2018, the User can decide the future of the collection and processing of their data in the event of their death.

Article 10 - Exercising your rights

10.1 How can I assert my rights?

• Send a letter to the Seller at the address of its registered office.
• An e-mail can be sent to the following address: contact.convert33@gmail.com.
• Give your full name and address and enclose proof of identity.

If the Seller justifies an extension of the period, requests will be processed within one month.

10.2 Appeal to the Data Protection Commission

If the Vendor does not satisfy the User's request, the User may contact the Data Protection Commission via https://www.dataprotection.ie/.

Article 11 - Cookie policy

11.1 What does a Cookie mean?

A cookie is a small file that our Site places on the User's terminal (computer, tablet or mobile device) when they consult our Site. Users can establish a link between their device and their preferences for use and experience on our Site, without disclosing any personal information.

11.2 User decision

The User's consent is always sought for the use of "cookie" files which contain and analyse personal information. This consent is given for a period of thirteen (13) months with a few exceptions (see table Art.13), after which the User will be asked for a new authorisation.

Article 12 - Use of cookies

The Seller informs Users of the Site that cookies record certain information stored in the memory of their hard disk. This data is used to compile statistics on the Site's audience and to offer services according to the information they have already selected during their previous visits.

Each User visiting the Site is asked to accept cookies by means of a warning message in the form of a banner. In order to ensure the free, informed and clear consent of the User visiting the Site, the banner will not disappear until the User has continued to navigate and configure his/her preferences.

Cookies will not be deposited or read without the User's prior consent.

If there is no navigation for anyone visiting the Site (home page or directly on another page of the Site from a search engine, for example): the absence of action is not considered to be a manifestation of will;

Or if they click on the link in the banner that allows them to set their cookie parameters and, where applicable, refuse the installation of cookies.

We collect and use cookies to :

• To update statistics and information about traffic on our site and optimise it as far as possible.
• To provide our users with a smooth browsing experience by adapting the presentation of our Site to the display preferences of the user's terminal.
• To identify the 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:

Article 14 - Opposition and configuration

Users may object to the installation of "Cookies" by configuring their browser as follows:

• Launching a personal navigation menu ;
• Use the "Cookies" widget available on the home page of our Site to configure cookies.
• Set your computer so that cookies are accepted, personalised or refused on each site or systematically;
• The User may use any other available means.

Users may express and change their preferences regarding cookies at any time. The seller declines all responsibility for the consequences of the functioning of the Site and the services offered due to :

• The User has refused cookies.
• And/or the impossibility for the site to save or consult the Cookies essential to their operation due to the user's choice.

Article 15 - Browser software settings

Users can configure their browser software in such a way as to configure their choices regarding the use of cookies:

• For Microsoft EdgeTM : 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 FirefoxTM : 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 may also configure their browser to accept or refuse Cookies on a case-by-case basis before they are installed, or delete Cookies from their terminal. The User is informed that by configuring their browser to refuse Cookies, certain functionalities of our Site may not be accessible and the Vendor or the host cannot be held responsible in this respect.

Article 16 - Modification of the confidentiality policy

The Seller reserves the right to modify this Policy at any time. If this Policy is modified, the new version will be immediately published on the Site. If the User does not agree with the terms of the new version of the Policy, he/she has the option of no longer using the Site's Services and no longer browsing the Site.

Article 17 - Acceptance by the User of the privacy policy

By browsing the Site, Users certify that they have read and understood this privacy policy and accept its conditions, particularly with regard to the collection and processing of their personal data and the use of 'Cookies'.