Privacy Policy
The present Privacy Policy applies to personal data collected, processed, and stored during your use of the website opulenssia.com (hereinafter the "Site").
In the context of this Privacy Policy, the term "personal data" refers to all information that, alone or in combination with other information, allows the identification of an identified natural person, such as the name, email address, phone number, or IP address.
SLMCORP LTD is committed to processing your personal data in accordance with applicable laws and regulations, notably the Law No. 78-17 of January 6, 1978, as amended by the law of June 20, 2018, and the European General Data Protection Regulation No. 2016/679 (hereinafter the "GDPR").
**ARTICLE 1 - DATA CONTROLLER**
The data controller for the personal data collected during your use of the Site is SLMCORP LTD, a simplified joint-stock company registered with the Trade and Companies Register under number 14607072, with its registered office at M11 4NG 54 NORTH ROAD, UNITED KINGDOM (UK) (hereinafter "SLMCORP LTD" or "we").
**Personal Data Collected by SLMCORP LTD**
SLMCORP LTD collects and processes the following personal data concerning you:
1. Data you provide to SLMCORP LTD: This includes personal data you provide to SLMCORP LTD when you create a customer account on the Site, place orders, or contact us. These data include your name, surname, postal address, billing address, email address, customer account password, and phone number.
Unless stated otherwise, the information requested in the collection forms accessible on the Site (such as the customer account creation form) is mandatory. If you do not provide this information, you will not be able to validate the corresponding form. You are solely responsible for the accuracy of the data you provide to SLMCORP LTD. If you make a purchase through the Site, we do not collect or retain payment card data. This data is collected directly by our payment provider and is subject to the privacy policy of that provider.
**ARTICLE 2 - DATA RELATED TO YOUR SITE NAVIGATION**
SLMCORP LTD collects information every time you visit the Site, including the IP address used to connect your computer to the Internet, your login information, browser type and version, and time zone setting.
Moreover, SLMCORP LTD and its partners collect information about how you use the Site through cookies or other similar technologies, as indicated in Article 7 below.
**ARTICLE 3 - USE OF YOUR PERSONAL DATA**
SLMCORP LTD collects and processes your personal data for the purposes described in the table below.
| Data Processing Nature | Justification for Data Processing |
|------------------------|-----------------------------------|
| Management of your customer account (creation, modification, and deletion of the account) | Necessary for the execution of your customer contract, in accordance with our general terms and conditions of sale |
| Management of our commercial relations (tracking and sending orders, managing product return/exchange requests) | Necessary for the execution of your customer contract, in accordance with our general terms and conditions of sale |
| Management of your contact requests | Legitimate interest of SLMCORP LTD to respond to contact requests |
| Sending email invitations to finalize the order | Legitimate interest of SLMCORP LTD to enable you to finalize your order |
| Newsletter sending | Your consent |
| Management of your requests to exercise rights regarding personal data (as described in Article 8 below) | Legal obligation of SLMCORP LTD to respond to requests to exercise the rights of individuals whose data SLMCORP LTD processes |
| Management of pre-litigation and litigation | Legitimate interest of SLMCORP LTD to assert its rights in the context of pre-litigation or litigation |
**ARTICLE 4 - RECIPIENTS AND TRANSFERS OF YOUR PERSONAL DATA**
Within SLMCORP LTD, and for each processing purpose, your personal data is collected, processed, and stored by authorized personnel of SLMCORP LTD, solely within the scope of their respective competencies, including our sales, marketing, and IT departments.
Your personal data may be communicated to third parties in connection with the relevant processing purpose, including our providers responsible for order shipment, providers responsible for Site development, hosting, and maintenance operations, data storage, as well as potential investors or any other third party involved in a merger, acquisition of all or part of the business of SLMCORP LTD, change of control, or insolvency proceedings.
Your personal data is processed by our IT provider Shopify Inc., responsible for hosting and displaying our Site, located in Canada. In this regard, the appropriate level of data protection is guaranteed by a European Commission adequacy decision, which can be consulted [here](link_here).
**ARTICLE 5 - DURATION OF RETENTION OF YOUR PERSONAL DATA**
SLMCORP LTD retains your personal data only for the duration strictly necessary in light of the processing purpose. Specifically, your personal data is retained in accordance with the durations indicated in the list below.
- Management of your customer account: 5 years after the closure of your customer account or from a period of inactivity of 3 years.
- Management of our commercial relations: 10 years from the end of the commercial relationship.
-
Management of your contact requests: Duration necessary to process and respond to contact requests.
- Sending email invitations to finalize the order: 3 years from the last login to the customer account.
- Sending the newsletter: Duration of the newsletter subscription.
- Management of your requests to exercise rights regarding personal data: 5 years after closing the request.
- Management of pre-litigation and litigation: Until a definitive amicable resolution of pre-litigation or until exhaustion of legal remedies.
**ARTICLE 6 - SECURITY OF YOUR PERSONAL DATA**
We are committed to protecting the personal data we collect. To do so, SLMCORP LTD takes all useful physical, technical, and organizational measures to prevent any unauthorized or unlawful processing, as well as any loss, destruction, or accidental degradation of your personal data.
**ARTICLE 7 - POLICY ON THE USE OF COOKIES AND OTHER TRACKERS**
Cookies are small text files deposited on your device (phone, computer, tablet, etc.) by SLMCORP LTD and our partners when you browse our Site. In the context of this cookie policy, the term "cookie" also generally covers all tracking technologies used on our website that collect information about your navigation and interactions on it.
Cookies can be:
- Session cookies: when they are stored on your device exclusively for the duration of your navigation on the Site and deleted as soon as you close your browser.
- Persistent cookies: when they are stored on your device for a longer period, until their expiration or until deleted by the user.
In some cases, the cookies used on our Site may collect personal data about you.
When personal data is collected by SLMCORP LTD as a data controller, it will be processed in accordance with the provisions of this cookie policy.
Since April 1, 2021, site/application publishers must comply with the recommendations of the CNIL regarding cookies, which requires a thorough analysis of the cookies used and the resulting personal data processing.
When third-party cookies allow our partners to collect and process personal data about you, we invite you to consult their privacy policy to learn about the conditions under which your personal data will be processed.
**CATEGORIES OF COOKIES LIKELY TO BE DEPOSITED ON YOUR DEVICE**
Several categories of cookies may be deposited on your device: essential cookies strictly necessary for the operation of the site, audience measurement and analytical cookies intended to measure the performance of our Site, as well as advertising cookies.
1. **Essential Cookies**
Essential cookies, such as functionality, session, authentication, and security cookies, are essential for the proper operation and security of the Site and are strictly necessary for providing the services you wish to access through the site. They are enabled by default on the Site.
These cookies allow, among other things:
- Ensuring smooth navigation on our Site, facilitating and speeding up the loading of different web pages, and ensuring the proper functioning of all Site features.
- Memorizing the display preferences of the user interface (language used and presentation of the service) and adapting the presentation of the Site for a personalized experience when it is an intrinsic element of the services offered on the Site.
- Memorizing certain information in the context of your purchase journey (e.g., cookies that keep in memory the content of the shopping cart).
- Allowing access to reserved and personal areas of the site, such as your customer account, through the authentication mechanism.
- Implementing security measures and detecting any fraudulent connection to your customer account.
- Keeping your choice regarding cookies and ensuring the operation of our cookie management tool.
- Ensuring the operation of certain features of the purchase and ordering process (e.g., the payment process).
Through the use of some of these cookies, SLMCORP LTD may collect and process certain personal data to pursue the abovementioned purposes. This includes, in particular, your IP address, session identifiers, information about your browser and/or your device, your browsing data, and your preferences (including your choice regarding cookies).
The legal basis for processing this data is the legitimate interest of SLMCORP LTD in ensuring that the Site works correctly, securely, and according to the preferences indicated by each user. The data is shared within SLMCORP LTD with only those who need to know it for the purposes mentioned above, such as teams involved in Site management and those providing technical support. SLMCORP LTD may also share this data with external service providers for the same purposes. In the event of data transfer outside the European Economic Area, SLMCORP LTD will implement appropriate guarantees to frame the transfer in accordance with the GDPR. Your personal data is retained only for the time necessary to achieve the abovementioned purposes and, in any case, for a maximum period of 6 months. Data related to your consent may be retained longer to anticipate any action or investigation aimed at verifying or challenging SLMCORP LTD's compliance with its obligation to collect user consent.
**English Translation:**
2) **Audience Measurement and Analytical Cookies**
Our partners place audience measurement and analytical cookies on the Site to allow us to measure the Site's audience, optimize its performance, and improve our services. If you do not accept these cookies, we will not be able to take your navigation into account in our performance statistics and audience measurements.
These cookies allow, among other things:
- Establishing attendance statistics (e.g., the number of visits, the most visited pages, etc.) to understand how visitors interact with our Site and improve the quality of our services and the user-friendliness of the Site.
- Analyzing your behavior on our Site (e.g., mouse movement, scrolling height).
In the use of these cookies, SLMCORP LTD will only access aggregated statistical data.
3) **Advertising Cookies**
Our partners use cookies to provide you with relevant personalized advertising content on our Site as well as on third-party sites. If you do not accept these cookies, you will not be able to access these personalized advertising contents.
These cookies allow, among other things:
- Adapting advertising content inserted on our Site to your interests, location, and behavior on our Site.
- Limiting the number of times the same advertisement is presented to you.
- Conducting statistics regarding advertising on our advertising spaces and your interaction with these spaces to measure the effectiveness of an advertisement.
- Proposing advertising content related to our Site and services when you access third-party sites and social networks, following your visit to our Site.
**COOKIE MANAGEMENT**
Here is a list of cookies that we use. We have listed them here so that you have the option to choose whether to allow them or not.
- _session_id, unique session identifier, allows Shopify to store information about your session (referrer, landing page, etc.).
- _shopify_visit, no data retained, persists for 30 minutes from the last visit. Used by the internal statistics tracking system of our website provider to record the number of visits.
- _shopify_uniq, no data retained, expires at midnight (visitor's location) the next day. Calculates the number of visits to a store by a unique customer.
- cart, unique identifier, persists for 2 weeks, stores information about your shopping cart.
- _secure_session_id, unique session identifier.
- storefront_digest, unique identifier, indefinite if the store has a password, used to determine if the current visitor has access.
**ARTICLE 8 - YOUR RIGHTS REGARDING YOUR PERSONAL DATA**
You have the right to access, rectify, erase, limit, and object to the processing of your personal data, as well as the right to define directives regarding the fate of your data after your death and the right to data portability.
These rights are exercised under the conditions set by applicable regulations:
- The right of access means that you can ask us at any time to inform you whether we process personal data about you and, if so, to inform you about the personal data concerned and the characteristics of the processing.
- The right of rectification means that you can ask us to rectify your personal data when they are inaccurate. You can also request that your personal data, if incomplete, be completed to the extent that it is relevant to the purpose of the processing in question.
- The right to erasure means that you can request the erasure of your personal data, especially when: (i) their retention is no longer necessary in light of the purposes for which they were collected; (ii) your personal data are processed based on your consent, and you want to withdraw this consent, and there is no other legal basis that justifies the processing; (iii) you have objected to the processing of your personal data, and you want them to be erased as a result; (iv) your personal data have been unlawfully processed; (v) your personal data must be erased to comply with a legal obligation provided for either by European Union law or French law.
- The right to limitation means that you can ask us to limit the processing of your personal data (i) when you dispute the accuracy of your personal data for a period allowing us to verify their accuracy; (ii) when, following processing established as non-compliant, you prefer processing limitation to complete erasure of your personal data; (iii) when we no longer need your personal data for the purposes of processing, but you still need them for the establishment, exercise, or defense of legal rights; (iv) when you have objected to the processing of your personal data, and you want processing limitation for the period allowing us to verify whether the legitimate grounds you invoke justify it. Limitation of processing means that the processing of your personal data will then only involve the storage of your corresponding personal data. We will then no longer perform any other operation on the considered personal data.
- The right to object means that you can object to the processing of your personal data when this processing is based on the pursuit of the legitimate interest of ... [COMMERCIAL NAME OF THE COMPANY]. The right to object is exercised subject to demonstrating a legitimate reason relating to your particular situation. We will then cease the processing in question unless there are legitimate and compelling grounds justifying continued processing in accordance with applicable regulations.
- The right to define directives regarding the fate of your data after your death allows you to communicate your instructions regarding the retention, erasure, and communication of your personal data after your death.
- The right to data portability means that you can ask us to receive your personal data in a structured, commonly used, and machine-readable format and to have it transmitted to you, or to ask us to transmit it directly to a third party of your choice when this is legally and technically possible.
When we process your personal data based on your consent, you have the option to withdraw your consent at any time by contacting the addresses indicated in the Contact section below or by clicking on the unsubscribe link in each of our newsletters. However, the withdrawal of your consent does not affect the validity of the processing carried out before this withdrawal.
**ARTICLE 9 - CONTACT**
For any questions regarding the collection and processing of your personal data or to exercise your rights regarding data protection, you can contact SLMCORP LTD:
- By mail: M11 4NG 54 NORTH ROAD, UNITED KINGDOM
- By email at the address customersupport@vepulenssia.com
**ARTICLE 10 - MODIFICATION OF THE PRIVACY POLICY**
We reserve the right to modify this privacy policy at any time, so please check it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make changes to the content of this policy, we will notify you here that it has been updated so that you know what information we collect, how we use it, and under what circumstances we disclose it, if necessary.
If our store is subject to an acquisition by or merger with another company, your information may be transferred to the new owners so that we can continue to sell products to you.