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Privacy Policy

Last updated: September 24th, 2021.

This Privacy Policy provides information on how eTrament processes personal data. The Data controller for the processing of personal data is Andrés Salamanca Lugo, a company established and registered in France with organization number 89915127800020, address: 42 avenue d’Hauterive, 81000 Castres, France, email: privacy@etrament.com.

eTrament is established in France, and adheres to the General Data Protection Regulation (GDPR). eTrament processes personal data relating to customers and other persons who have contacted eTrament. The different types of personal data processed, as well as the purpose of the processing, legal basis and source are further described below.

Please read this privacy policy carefully. By accessing or using the company service, you acknowledge that you have read, understand, and agree to be bound by all the terms of this privacy policy and our terms of service. If you do not agree to such terms, exit this page and do not access or use the company service.

1. Your Consent

Providing us with personal data is purely consensual. You are not obligated under any laws to provide us with any personal data, but without providing such personal data, we cannot provide you with our products and services.

2. Your Rights Under Applicable Laws

2.1 Right of Access and Rectification

You have the right to know what personal data we collect about you and to ensure that such data is accurate and relevant for the purposes for which we collected it. You can receive a copy of your personal data, and to rectify such personal data if it is not accurate, complete, or updated. However, we may first ask you to provide us with certain credentials to permit us to identify you before rectifying, deleting, or reviewing.

2.2 Right to Delete Personal Data or Restrict Processing

You have the right to delete your personal data or restrict its processing by ourselves and third parties.
We may postpone or deny your request if your personal data is in current use for the purposes for which it was collected or for other legitimate purposes such as compliance with legal obligations.

2.3 Right to Withdraw Consent

You have the right to withdraw your consent to the processing of your personal data. Exercising this right will not affect the lawfulness of processing your personal data based on your consent before its withdrawal.

2.4 Right of Data Portability

Where technically feasible, you have the right to ask to transfer your personal data in accordance with your right to data portability.

2.5 The Right to Lodge a Complaint

You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your personal data.

2.6 Your California Privacy Rights

Based on our understanding of the term “sell” under the CCPA, we do not “sell” you personal information and have not sold it to third parties for a business or commercial purpose in the 12 months preceding the CCPA’s entry into force.

3. Type and uses of personal data we collect

We collect information in four different ways: when you visit or use our website, when you purchase a product on our website, when you subscribe to our mailing list, and when you contact us.

3.1 When visiting/using our website

We collect information relating to how you use our website such as the pages you viewed, the links you clicked, the websites that referred you to us, approximate geolocation, your device type, screen resolution, operating system, and browser. This data are processed for the purposes of analyzing the use of the website and understanding how we can improve it.  We also collect aggregated data from third parties, such as social media sites, to send you targeted/interest-based ads.The legal basis for this processing is based on your consent by accepting our cookies policy.

We collect information you fill when you leave a review on our products, including IP address and email address, for the only purpose of monitoring it and displaying it on the website. The legal basis for this processing is based on your consent by leaving a review, which is voluntary to submit.

3.2 When purchasing a product on our website

eTrament processes “transactional data” for the purpose of providing our customers with the products and services they have ordered, including placing a purchase, processing payment and delivering the product. Transactional data includes:

  • Contact and payment information: Name, e-mail address, phone number, billing and shipping addresses, credit card information or other payment information.
  • Cart details

Our customers have the possibility to create a personal account on our website before placing an order. If they choose to do so, eTrament processes “account data” for the purpose of giving customers access to their order details and history, such as:

  • Personal account username and password

After a purchase, eTrament store your transactional and account data to ensure that we can provide you with the rights you are granted in our terms and conditions.

The legal basis for the processing is fulfilling an agreement to which the customer is party. 

If a customer does not wish to provide the necessary contact and payment information, the customer will be unable to purchase eTrament’s products.

3.3 When subscribing to our mailing list

eTrament processes the following personal data for the purpose of providing subscribers with the newsletters the subscriptions comprise:

  • Contact information: E-mail address

The legal basis for the processing is consent from the data subject, which is voluntary to submit. The data is provided to eTrament by the subscriber. The subscriber can at any time choose the “unsubscribe” option included in our newsletter should the subscriber no longer wish to be a recipient of the newsletter.

3.4 When contacting us

Customers/Users can send us emails if they have questions about our products, both before and after purchase. eTrament processes the following information for the purpose of answering any question or inquiry received by eTrament’s support service:

  • Contact information: e-mail address
  • Any other requested and unrequested information sent to eTrament in the inquiry

The legal basis for the processing is fulfilling an agreement as requested by the inquirer. The data is provided to eTrament by customer/sender.

4. Who Do We Share Personal Data With?

4.1 Third-Parties

We use third-party service providers that may have access to your personal data:

  • Ohwo and Gmail to send promotional and support communications to our users. 
  • Google Analytics for web and marketing analytic purposes.
  • Payplug and, PayPal for our payment processing and accounting.
  • Facebook Ads to reach our target audience with relevant ads. We use the data to track sales and other business goals, all the data is being masked, and the company can’t identify any action from a specific customer or user.

We require the foregoing parties to process such information in compliance with this Privacy Policy and subject to security and other appropriate confidentiality safeguards.

eTrament does not disclose your personal data to unauthorized third parties. Any transfer of personal data is in accordance with law.

4.2 International Transfer

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer of your personal data to various countries around the world that may have different levels of privacy protection than your country and may be transferred outside of the European Economic Area.

If there is a transfer of your personal data outside the EEA we will, in the absence of an EC Adequacy decision relevant to the destination country or the transfer, seek to rely on appropriate safeguards such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient): https://www.privacyshield.gov/welcome), or enter into appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm). 

4.3 Legal Compliance

We may share information in accordance with a written legal request by a valid legal authority. We will do our best to object to such request if we believe that it is baseless.

4.5 Merger or Reorganization

We may transfer data if we become involved in a reorganization, merger, consolidation, acquisition, or any form of sale of some or all of our assets, with any type of entity, whether public, private, foreign or local.

5. How long is the data stored?

We delete or irreversibly anonymize data as soon as the purpose of the processing is fulfilled or we are no longer required by law to store your data:

eTrament’s customer and users:
Name, contact information, order details and inquiry details are deleted when they are no longer necessary to fulfill the purpose of processing, and when they are no longer necessary to process in order to fulfill legal obligations or for eTrament to be able to handle claims and complaints.

Subscribers to eTrament’s newsletter:
The personal data is deleted when the subscriber unsubscribes to eTrament’s newsletter or when the newsletter is discontinued.

5. Use Of Cookies, Trackers, and Remarketing Beacons

5.1 What are cookies and why do we use them?

In order to collect the data described herein, we may use temporary cookies that remain on your browser for a limited period of time. We may also use persistent cookies that remain on your browser for the duration we provide the services. 

A cookie is a small piece of information which is sent to and stored on your browser. Cookies by themselves cannot be used to discover your identity. Cookies do not damage your browser.

Cookies are used to distinguish users, determine which browser is used, locate users to help us implementing a relevant shipping policy, identify which site led to our website, determine the number of visits to our website, when visits to our website occur, error logging, and how users navigate the website. We use cookies from Google Analytics and Facebook Pixel on etrament.com. 

We may also use web beacons via the Services to collect information. Web beacons or “gifs,” are electronic images that may be used in our Services or in our emails. We use Web beacons to deliver cookies, count visits, and to tell if an email has been opened and acted upon.

We also use third-party technologies, such as cookies and web beacons and various third-party providers (e.g., Google, Facebook, etc.) to process and analyze your personal data, profile end-user activities and provide targeted ads, including without limitation tracking your use of the Services and third-party services and sites.

5.2 How to disable cookies

Cookies once placed can be deleted again at any time. Take note that completely disabling cookies may lead to less functionality of the websites you visit and, in this case, hinder you from buying the products and services provided on etrament.com.

Cookies can be disabled in the settings of your internet browser (e.g. Chrome, Safari, Firefox, Internet Explorer). Consult your browser’s Help page to disable cookies.

You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not).

5.3 Note on Google Analytics

etrament.com uses Google Analytics, a web analysis service of Google LLC (hereinafter: “Google”). Google Analytics uses “cookies” to evaluate your use of the website, in order to compile reports on the website activities

We ensure the anonymization of your IP address when navigating on our website. This means that your IP-Address will be shortened by Google, however, within the Member States of the European Union or in other States party to the Agreement on the European Economic Area. Only in exceptions will your full IP address be transferred to a server of Google in the USA and abbreviated there. The IP address submitted by your browser in the scope of Google Analytics will not be combined with any other Data of Google.

For more detailed information on usage conditions and data protection, see
http://www.google.com/intl/de/analytics/learn/privacy.html or https://www.google.de/intl/de/policies/.

6. Children

We will not knowingly contact or engage with children under the age of 16. If you have reason to believe that a child under the age of 16 has provided us with their personal data, please contact us at privacy@etrament.com, and we will take steps to remove such information and terminate the child’s account

7. Public Areas

We may provide areas on our website where you can publicly post information about yourself or can communicate with others such as comment section and review section. This information may be accessible by other users and companies, and therefore this information could be read, collected, and used by others. We have no control over who reads your postings or what other users may do with the information you voluntarily post, so please use caution when posting any content or providing anything that could be deemed personal information.

8. Security Standards

We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of personal data. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

9. Complaints

If you are dissatisfied with eTrament’s processing of personal data or have questions or inquiries concerning eTrament’s processing of personal data, please write to us at 42 avenue d’Hauterive, 81100 Castres, France, or email us at privacy@etrament.com. We are happy to assist.

Data subjects may also file a complaint by contacting the Data Protection Authority in France (CNIL) or, if the customer is resident elsewhere in Europe, their local data protection authority.

10. Changes to This Privacy Policy

We continually strive to find new ways to enhance your experience with eTrament and we may modify this Privacy Policy from time to time to reflect changes in our privacy practices.  You are encouraged to review this Privacy Policy periodically and to check the “Last Updated” date at the top of the Privacy Policy for the most recent version.

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