Privacy Policy

ETOE seeks to offer high quality items for sale on its website https://etoeofficial.com/ and on its iOS mobile application.

In order to offer for sale, and deliver its products, ETOE collects personal data from users of its website and its mobile application.

The purpose of this privacy policy is to inform users of the means used to collect, access, process, and store users' personal data.

ETOE undertakes to comply with the provisions of Regulation (EU) No 2016/679 of April 27(th), 2016 on the protection of personal data.

The customer is informed that certain data must be collected by ETOE, in order to perform its services. If the customer does not wish to disclose this data, ETOE will not be able to perform its services.

This Privacy Policy ("Policy") may be modified at any time by ETOE, in particular, to comply with any regulatory, jurisprudence, editorial or technical changes. The user must refer to the latest version of the Policy before browsing.

ETOE collects users' personal data on the website https://etoeofficial.com/, on the iOS mobile application.

The personal data that may be collected are as follows:

- User account data: the data provided by the user, when creating an account by filling in the registration form (name, surname, billing and delivery postal address, email address, mobile phone number, password).

- Personal data of the user when he/she enters it in his/her customer account: date of birth.

- Transaction data: the data that the user provides when making purchases, information relating to orders, placed and returned items such as telephone number, address, e-mail address, and information relating to payment method.

- Exchanges with customer service.

- Browsing data: refers to the data collected by the publisher while the user is browsing the website and the application, such as the date, time of connection and/or browsing, browser type, browser language, IP address, location data and geolocation.

The data relating to the payment method (credit card number, expiry date, authorization number, security code) are collected directly by our service providers Stripe and Paypal.

Third-party providers of applications, tools, gadgets and plug-ins on our website and mobile application, as well as the networks on which we publish editorial and promotional content (such as Facebook and Instagram) may also use automated, context-based and interest related means to collect user data (interactions with functions and profiling of the online activity). This data is collected directly by such providers and/or third parties and is subject to their policies. To the extent permitted by applicable law, ETOE is not responsible for the practices of such service providers and third parties.

Some of the services may be altered or inaccessible if consent to the collection of the data mentioned in this Privacy Policy is not granted.

Data collected by the website, the application or in physical outlets are processed for the purposes described in the table below.

The regulations in force protect the privacy of users and require any controller to be able to provide legitimate grounds for such processing. The regulations thus provide, among the legal bases for treatment, the following:

- Performance of an agreement to which the relevant person is a party, such as a sales contract. For example, certain personal data of the customer is necessary to deliver the item, manage the customer's account and process any returned items.

- Compliance with a legal obligation, in particular an accounting obligation by retaining invoices.

-Prior consent of the relevant person.

- Legitimate interest of the controller, while complying with users' rights and freedoms. For example, improving customer experience or preventing fraud may justify data collection.

Purposes of the processing	Use of data	Legal bases for treatment
Management of orders, sales of products, and provision of services; management of customer complaints, withdrawals and product returns	Use of data to provide products and services (from shopping cart and orders; sale, return and refund of purchased products)	Fulfillment of the agreement by and between the customer and the seller
Carrying out transactions, in particular payment transactions	Our payment providers (Stripe and Paypal) use the information relating to the payment methods when performing the payment for each order. These data can also be used for the prevention of fraud upon payment of the order and/or management of any unpaid amounts after placed order.	Fulfillment of the agreement by and between the customer and the seller
Customer account creation and management	The personal data of a customer registered on the website are used (e-mail address, password)	- Fulfillment of the agreement by and between the customer and the seller - Compliance to legal obligations
Delivery of ordered products	Personal data (contact details, email address) are used to ensure deliveries.	Fulfillment of the agreement by and between the customer and the seller
Operating the website and fighting against fraud	Personal data (cookies) are used to update, enhance our Website and fight against Internet fraud	- Fulfillment of the agreement by and between the customer and the seller - Compliance to legal obligations
After-sales support: exchanges with customer service	Personal data are used to interact with customers. As such, the exchanges between customer service and the customer carried out by telephone or chat can be recorded in order to improve the service quality. Customers can refuse at any time	Fulfillment of the agreement by and between the customer and the seller
Taking part in special events (such as contests, games, random draws, offers) and participating in the loyalty scheme, with the exception of online gambling that is subject to approval by the French Online Gaming Control Authority	Personal data, including purchasing information, are used to manage participation in various special events, as well as the loyalty program	- Fulfillment of the agreement by and between the customer and the seller - Legitimate interest of the controller in order to propose products and services adapted to customer needs
Operating, assessing, improving products, services as well as user experience (including developing new products, analyzing the customer base, performing data analysis, accounting and auditing, profiling)	Personal data are used to assess and improve products and services, and to improve customer experience, products and services offered by Cuctos, through statistical operations and analysis of anonymous customer behavior, and the website and mobile application traffic	Legitimate interest of the controller in order to propose products and services adapted to the needs of customers
Sending newsletters and special offers subject to the user checking the relevant box indicating his/her acceptance, when registering Services	Personal data is used to inform customers about our products and services and to customize the products offered on social networks.	Legitimate interest of the controller in order to propose products and services adapted to the needs of customers and consent (opt-in)
Analyzing website traffic and frequency, audience metrics, research, statistics, surveys (cookies)	Personal data, including cookies, is collected to understand how the Website and the mobile application are used.	Legitimate interest of the controller in order to propose products and services adapted to customer needs and consent (opt-in)

Etoe does not share any personal data for commercial purposes with third parties.

Users can edit their personal data and withdraw their consent at any time, by connecting to their customer account.

ETOE processors may have access to data collected for the purpose of:
- Preparing, shipping orders and returning products
- Improving the content of websites and mobile applications
- Technical maintenance and development of ETOE website, mobile application and internal applications, including entities that perform orders and provide web hosting, information storage, email service providers, as well as analysis services, and tag management, such as Google Analytics. For further details on these analysis services and the opposition procedures, we invite you to refer to the following websites:
 - https://support.google.com/analytics/answer/6004245
- https://support.google.com/analytics/answer/6004245?hl=fr

ETOE may also share the personal data of customers who have a customer account in its physical outlets. Their access is limited to orders placed by the customer.

In accordance with Articles 14 to 22 of Regulation 2016/679 of April 27(th), 2016, any person using Cuctos, or its mobile application, has the right to enjoy the following rights:

-right to access, rectify and erase the collected data,
-right to object to the processing of their data,
-right to the restriction of processing,
-right to the portability of the data collected the option to formulate instructions relating to the retention, erasure and transmission of his/her personal data after his/her death in accordance with Article 40-1 of Law 78-17 of January 6(th), 1978

Lastly, if ETOE detects a violation of personal data likely to create a significant risk to the rights and freedoms of its users, it undertakes to inform the relevant users in the shortest possible time.

Users may exercise all these rights by connecting to their customer account, by contacting customer service at support@etoeofficial.com

Users must enclose proof of identity with their application.
In case of non-response or unsatisfactory response, users may contact the supervisory authority of their country of residence, for France, the CNIL: https://www.cnil.fr/

Data retention period

User data will not be retained beyond the period strictly necessary for the purposes set out herein and in accordance with applicable regulations and laws. In this respect, the data used for canvassing purposes may be retained for a maximum period of three years from the termination of the user's account or the last contact with the relevant prospect. User data is deleted when the storage periods expire. Nevertheless, the data may be archived beyond the specified periods for the purposes of investigating, establishing and prosecuting criminal offences for the sole purpose of making the data available to the judicial authority, when necessary.

Archiving implies that data will be anonymized and will no longer be available online but will be extracted and stored on autonomous and secure means.

In its capacity as data controller, ETOE undertakes to take all necessary measures to preserve the security and confidentiality of the data and, in particular, to prevent it from being altered, distorted or accessed by unauthorized third parties.

When browsing our website and the mobile application, information relating to the navigation of the user's terminal (computer, tablet, smartphone, etc.) may be saved through files referred to as "Cookies".

A cookie allows tracking the browsing or analyzing user behavior, including: - Measuring the number of visitors to our website and application, as well as their content. - Saving customer account information when the user is logged in. - Saving the shopping cart for 30 minutes and customizing the display of content accessible to the user.

Users can also refuse to accept cookies on the following website: http://www.youronlinechoices.com/fr/controler-ses-cookies/.

ETOE's official Facebook and Instagram accounts can allow users to post their content. Users are informed that the content published on these social networks may be viewed by any third party, and that greater vigilance is required from users when they provide certain personal data on these sites or applications such as financial data, addresses or any sensitive data. ETOE is in no case, liable for any damage caused by third parties as a result of or resulting from the publication of their personal data by users.

ETOE website and application may provide links to websites, applications and services other than ETOE, which may be operated by third parties. ETOE is not responsible for the processing of personal data by these third-party websites. Users should consult the relevant personal data protection policies.

ETOE's data protection officer or personal data manager ensures compliance with the regulations and rules in force and must establish records of processing activities involving personal data. Users can contact ETOE’s data protection officer or personal data manager at support@etoeofficial.com

Proper collection of personal information such as credit card numbers on pages secured with SSL technology.

Our Privacy Policy is adapted to the laws of the United States.