ARTICLE 1 – PREAMBLE

The purpose of this privacy policy is to inform users of the site:

• About how their personal data are collected. Personal data are any information enabling the identification of a user. This may include: first and last names, age, postal or e-mail address, location or IP address (non-exhaustive list);
• About the rights they have regarding those data;
• About the person responsible for the processing of the personal data collected and processed;
• About the recipients of those personal data;
• About the Site’s cookie policy.

This policy complements the legal notice and the Terms of Use, which users can consult at:

Legal notice

ARTICLE 2 – PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA

In accordance with Article 5 of European Regulation 2016/679, personal data are:

• Processed lawfully, fairly and in a transparent manner with respect to the data subject;
• Collected for specified (see Article 3.1 below), explicit and legitimate purposes, and not further processed in a manner incompatible with those purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and, where necessary, kept up to date. All reasonable measures must be taken to ensure that personal data that are inaccurate, with regard to the purposes for which they are processed, are erased or rectified without delay;
• Kept in a form that permits the identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed;
• Processed in a manner that ensures appropriate security of the personal data collected, including protection against unlawful or unauthorised processing and against accidental loss, destruction or damage, by using appropriate technical or organisational measures.

Processing is lawful only if, and to the extent that, at least one of the following applies:

• The data subject has consented to the processing of his or her personal data for one or more specific purposes;
• Processing is necessary for the performance of a contract to which the data subject is party or for taking steps at the request of the data subject prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which the controller is subject;
• Processing is necessary to protect the vital interests of the data subject or another natural person;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

ARTICLE 3 – PERSONAL DATA COLLECTED AND PROCESSED IN THE CONTEXT OF NAVIGATING THE SITE

Article 3.1 – Data collected

The personal data collected in the course of our activity are as follows:

• First name, last name, postal address, e-mail address, telephone number.

The collection and processing of these data serve the following purpose(s):

• Order management, shipment of orders, monitoring service quality.
• Support in managing the quality of the users’ aquarium water via our Automatic Calculator.

In the latter case, data are sent to the Make platform, whose privacy policy can be consulted here.

The personal data collected on this site are transmitted securely to the site www.make.com, in compliance with the GDPR and the Data Privacy Framework (for which you can consult the list of participating companies, here “Celonis”).

Article 3.2 – Method of data collection

When you use our site, the following data are collected automatically:

[List of data automatically collected during a user’s visit to the site]

Other personal data are collected when you perform the following actions on the platform:

• First name, last name, e-mail address, when creating your customer account on the site;
• Postal address, telephone number, in the context of shipping orders.

They are retained by the data controller under reasonable security conditions for a period of three years.

The company may retain certain personal data beyond the periods stated above in order to fulfil its legal or regulatory obligations.

Article 3.3 – Data hosting

The site www.turtle-system.fr is hosted by:

OVH SAS
2 rue Kellermann
59100 Roubaix
France

Article 3.4 – Transmission of data to third parties

Data may be transmitted to our logistics partners in the context of order shipment, listed below:

• MBE France – 37 bis, rue du Général Leclerc – 92130 Issy-les-Moulineaux – France
• Sobotram – 33 rue Paul Sabatier – 71530 Crissey – France

Article 3.5 – Cookie policy

TO BE COMPLETED

ARTICLE 4 – DATA CONTROLLER

Article 4.1 – The data controller

Personal data are collected by Turtle System, SAS with a share capital of €3,000, registered under number 901050013.

The data controller can be contacted as follows:

• By post at: 9 rue de la gare – 71390 Buxy – France;
• By e-mail: contact@turtle-system.fr

If, after contacting us, you consider that your “Informatique et Libertés” rights are not being respected, you may lodge a complaint with the CNIL.

ARTICLE 5 – USER RIGHTS REGARDING THE COLLECTION AND PROCESSING OF DATA

Any user whose personal data are processed may exercise the following rights, pursuant to Regulation (EU) 2016/679 and the French Data Protection Act (Law No. 78-17 of 6 January 1978):

• Right of access, rectification and right to erasure of data (Articles 15, 16 and 17 of the GDPR respectively);
• Right to data portability (Article 20 of the GDPR);
• Right to restriction (Article 18 of the GDPR) and to object to processing (Article 21 of the GDPR);
• Right not to be subject to a decision based exclusively on automated processing;
• Right to determine the fate of one’s data after death;
• Right to refer the matter to the competent supervisory authority (Article 77 of the GDPR).

To exercise your rights, please send your correspondence to Turtle System SAS – 9 rue de la gare – 71390 Buxy – France or by e-mail to contact@turtle-system.fr.

In order for the data controller to comply with your request, the user may be required to provide certain information such as: first and last name, e-mail address and account, personal space or subscriber number.

Consult cnil.fr for more information on your rights.

ARTICLE 6 – CONDITIONS FOR MODIFICATION OF THE PRIVACY POLICY

The publisher of the site www.turtle-system.fr reserves the right to modify this Policy at any time in order to ensure its compliance with applicable law.

Any amendments shall not affect purchases previously made on the site, which remain subject to the Policy in force at the time of purchase and as accepted by the user when validating the purchase.

The user is invited to consult this Policy each time they use our services, without the need for formal notification.

This policy was issued on February 20, 2024.