ARTICLE 1: PREAMBLE

This privacy policy applies to the website: www.theluto.co.

The purpose of this privacy policy is to inform users of the site about: How their personal data is collected and processed. All data that may identify a user should be considered personal data. This includes, in particular, first name and last name, age, postal address, email address, user's location, or IP address; What are the rights of users regarding this data; Who is responsible for the processing of personal data collected and processed; To whom this data is transmitted; Possibly, the site's policy regarding "cookies" files.
This privacy policy complements the legal notices and the General Terms of Use that users can consult at the following address: https://theluto.co/CGU

ARTICLE 2: GENERAL PRINCIPLES FOR DATA COLLECTION AND PROCESSING

In accordance with the provisions of Article 5 of European Regulation 2016/679, the collection and processing of user data on the site comply with the following principles: Lawfulness, fairness, and transparency: data can only be collected and processed with the consent of the data owner. Each time personal data is collected, the user will be informed that their data is being collected and for what reasons it is being collected; Limited purposes: data collection and processing are carried out to meet one or more specific objectives set out in these general terms of use; Data minimization: only data necessary for the proper execution of the objectives pursued by the site is collected; Limited data retention period: data is stored for a limited period, of which the user is informed. When this information cannot be communicated, the user is informed of the criteria used to determine the retention period; Integrity and confidentiality of collected and processed data: the data controller undertakes to guarantee the integrity and confidentiality of the collected data.

To be lawful, and in accordance with the requirements of Article 6 of European Regulation 2016/679, the collection and processing of personal data can only take place if at least one of the following conditions is met: The user has expressly consented to the processing; The processing is necessary for the proper execution of a contract; The processing is required by a legal obligation; The processing is necessary to protect the vital interests of the data subject or another natural person; The processing may be justified by a necessity related to the performance of a task carried out in the public interest or in the exercise of official authority; The processing and collection of personal data are necessary for the purposes of the legitimate and private interests pursued by the data controller or by a third party.

ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED DURING BROWSING ON THE SITE

A. DATA COLLECTED AND PROCESSED AND METHOD OF COLLECTION

B. TRANSMISSION OF DATA TO THIRD PARTIES The personal data collected by the site is not transmitted to any third party and is processed only by the site editor.

C. DATA HOSTING The Théluto website is hosted by: Squarespace, whose headquarters are located at the following address: Squarespace Ireland Ltd. Le Pole House Ship Street Great Dublin 8 Ireland The host can be contacted at the following phone number: +35319058597 The data collected and processed by the site are exclusively hosted and processed in France.

ARTICLE 4: DATA CONTROLLER

THE DATA CONTROLLER

The data controller for personal data is: Alexandra Caillé. She can be contacted in the following ways: By mail at 148 Cours Maréchal Galliéni 33400 Talence France or by phone at 0033(0)606428452

The data controller is responsible for determining the purposes and means used for the processing of personal data.

B. OBLIGATIONS OF THE DATA CONTROLLER The data controller undertakes to protect the collected personal data, not to transmit it to third parties without the user being informed, and to respect the purposes for which this data was collected. The site has an SSL certificate to ensure that the information and data transfers through the site are secure. An SSL ("Secure Socket Layer" Certificate) aims to secure data exchanged between the user and the site. Furthermore, the data controller undertakes to notify the user in case of data rectification or deletion, unless this entails disproportionate formalities, costs, and procedures. In the event that the integrity, confidentiality, or security of the user's personal data is compromised, the data controller undertakes to inform the user by any means.

ARTICLE 5: USER RIGHTS

In accordance with the regulations concerning the processing of personal data, the user has the rights listed below. For the data controller to comply with their request, the user must provide: their first and last name as well as their email address, and if relevant, their account number or personal space or subscriber number. The data controller is required to respond to the user within a maximum of 30 (thirty) days.

A. PRESENTATION OF USER RIGHTS REGARDING DATA COLLECTION AND PROCESSING
a. Right of access, rectification and right to erasureThe user can access, update, modify or request the deletion of data concerning them, by following the procedure described below: The user must send an email to the personal data controller, specifying the subject of their request and using the contact email address provided above. If they have one, the user has the right to request the deletion of their personal space by following the procedure: ________

b. Right to data portability The user has the right to request the portability of their personal data, held by the site, to another site, by following the procedure below: ________
c. Right to limitation and opposition of data processingThe user has the right to request the limitation or to object to the processing of their data by the site, which the site cannot refuse, unless it demonstrates legitimate and compelling reasons that may override the user's interests, rights, and freedoms. To request the limitation of data processing or to object to data processing, the user must follow the following procedure: The User must send a request for limitation of their personal data processing to the data controller, by sending an email to the address provided above.

d. Right not to be subject to a decision based solely on automated processing In accordance with the provisions of Regulation 2016/679, the user has the right not to be subject to a decision based solely on automated processing if the decision produces legal effects concerning them or significantly affects them in a similar way.
e. Right to determine the fate of data after deathThe user is reminded that they can organize what should happen to their collected and processed data if they die, in accordance with Law n°2016-1321 of October 7, 2016.
f. Right to lodge a complaint with the competent supervisory authority In the event that the data controller decides not to respond to the user's request, and the user wishes to contest this decision, or if they believe that one of the rights listed above has been infringed, they have the right to contact the CNIL (Commission Nationale de l'Informatique et des Libertés, https://www.cnil.fr) or any competent judge.

B. PERSONAL 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. If the user is a minor under 15 years old, the agreement of a legal representative will be required for personal data to be collected and processed. The site editor reserves the right to verify by any means that the user is over 15 years old, or that they have obtained the consent of a legal representative before browsing the site.

ARTICLE 6: USE OF "COOKIES" FILES

The site may use "cookies" techniques. A "cookie" is a small file (less than 4 KB), stored by the site on the user's hard drive, containing information about the user's browsing habits. These files allow it to process statistics and traffic information, facilitate navigation, and improve the service for the user's comfort. For the use of "cookies" files involving the saving and analysis of personal data, the user's consent is necessarily requested. This user consent is considered valid for a maximum duration of 13 (thirteen) months. At the end of this period, the site will again request the user's permission to store "cookies" files on their hard drive.
a. User's opposition to the use of "cookies" files by the siteThe user is informed that they can object to the recording of these "cookies" files by configuring their browser software. For information, the user can find at the following addresses the steps to follow to configure their browser software to object to the recording of "cookies" files: Chrome: https://support.google.com/accounts/answer/61416?hl=frFirefox: https://support.mozilla.org/fr/kb/enable-and-disable-cookies-website-preferencesSafari: http://www.apple.com/legal/privacy/fr-ww/Internet Explorer: https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookiesOpera: http://www.opera.com/help/tutorials/security/cookies/
If the user decides to disable "cookies" files, they can continue browsing the site. However, any malfunction of the site caused by this manipulation could not be considered the fault of the site editor.
b. Description of "cookies" files used by the siteThe site editor draws the user's attention to the fact that the following cookies are used during their browsing: ________

ARTICLE 7: CONDITIONS FOR AMENDING THE PRIVACY POLICY

This privacy policy can be consulted at any time at the following address: https://theluto.co The site editor reserves the right to modify it to ensure its compliance with current law. Therefore, the user is invited to regularly consult this privacy policy to stay informed of the latest changes that will be made to it. The user is informed that the last update of this privacy policy was on: 03/05/2020.

ARTICLE 8: USER ACCEPTANCE OF THE PRIVACY POLICY

By browsing the site, the user attests to having read and understood this privacy policy and accepts its terms, particularly concerning the collection and processing of their personal data, as well as the use of "cookies" files.