Privacy Policy

Adena is committed to respecting privacy and protecting the personal data of users on its website. In the interest of transparency, Adena has adopted a "Privacy Policy" regarding the personal data of its users collected by Adena on the website it publishes: adenaofficial.com.

Adena has updated its Privacy Policy in accordance with applicable regulations, particularly Regulation (EU) 2016/679 of April 27, 2016 ("GDPR") and Law No. 78-17 of January 6, 1978, as amended, relating to data processing, files, and freedoms ("LIL") and its implementing decree.

Users of the Site acknowledge that they have read and accepted this Privacy Policy, along with the General Terms of Use. If users disagree with the provisions of this Privacy Policy, they are free not to use the Site or provide any personal data.

Definitions

  • "Supervisory Authority": The National Commission for Informatics and Liberties (CNIL).
  • "Consent": The data subject's freely given, specific, informed, and unambiguous expression of will, by which they agree, through a statement or a clear affirmative action, to the processing of their personal data.
  • "Recipient": Any natural or legal person, public authority, department, or other body receiving personal data, whether a third party or not.
  • "Personal data": Any information related to an identified or identifiable natural person (hereinafter referred to as the "data subject").
  • "Identifiable natural person": Refers to a natural person who can be identified, directly or indirectly, especially by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more specific factors related to their physical, physiological, genetic, mental, economic, cultural, or social identity.
  • "Purpose": Refers to the objective pursued by the processing (e.g., order management, newsletter subscription, etc.).
  • "Processing limitation": Refers to marking stored personal data to limit its future processing.
  • "Data controller": Refers to the natural or legal person, public authority, department, or other body which, alone or jointly with others, determines the purposes and means of the processing.
  • "Site": Refers to the website adenaofficial.com where Adena offers its products and services to users.
  • "Processor": Refers to the natural or legal person, public authority, service, or other body that processes personal data on behalf of the data controller.
  • "Third party": Refers to a natural or legal person, public authority, service, or body other than the data subject, the data controller, the processor, and those persons who, under the direct authority of the data controller or the processor, are authorized to process personal data.
  • "Processing": Refers to any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, communication by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
  • "User": Refers to any internet user who visits the Site and/or benefits from the Products and/or Services offered on the Site, whose personal data may be processed by Adena under the conditions set forth below. One or more users may be referred to as Data Subject(s).

Who is the Data Controller?

The Data Controller is

Adena France
A simplified joint-stock company with a sole shareholder (SASU)
Registered in the Paris Trade and Companies Register under number 891 973 851
With a VAT number (TIN)
Whose registered office is located at (ADDRESS)

If you have any questions regarding the processing of your data, you may contact the data controller via email at the following address: adenacontacto@gmail.com.

What data is collected?

As a User, when you browse the Site and/or use the services offered on the Site, Adena may collect the following personal data about you:

  • Identification data: last name, first name, copies of identity card and/or passport, IP address, real or presumed personal interests and/or needs, data related to the device used, etc.
  • Contact data: email address, postal address (for delivery and billing), phone number.
  • Payment and billing data: payment method used, banking information, billing details.
  • Data related to interactions between the User and Adena: content of the contact message sent to Adena through the Site.
  • Data related to the management of commercial relationships and order tracking: information requests between the User and Adena, exchange history with Adena's services, order details and tracking, subscription to Adena newsletters, validation or abandonment of the shopping cart, etc.

Adena informs its Users that it may collect their Personal Data in particular:

  • During their visit to the Site;
  • When creating a User account (optional);
  • When purchasing a product on the Site;
  • When subscribing to Adena's newsletters;
  • When requesting contact with Adena using the form provided on the Site;
  • During any interaction with Adena through the Site and/or the contact email address adenacontacto@gmail.com.

Regardless of the collection method, Adena commits to informing its Users of:

  • The purposes of the processing;
  • Whether the information requested is mandatory or optional, and the possible consequences of not responding;
  • The recipients of the data;
  • The existence and modalities of exercising their rights (in particular, rights of access, rectification, and opposition to the processing of their Personal Data).

For what purposes and on what basis are these data processed?

Adena collects your Personal Data directly from you when you browse the Site, use the various services offered on the Site, request to contact Adena using the form provided on the Site, or during any interaction with Adena through the Site and/or the contact email address adenacontacto@gmail.com.

Adena collects and processes your Personal Data for the following explicit, legitimate, and specific purposes:

  • To manage the proper functioning and continuous improvement of the Site, services, and features offered;
  • To manage and track your product orders placed on the Site;
  • To manage and track your subscriptions to Adena newsletters;
  • To offer commercial prospecting services and targeted advertising;
  • To respond to all your requests and engage in dialogue with you when you contact us via the form provided on the Site or the contact email address adenacontacto@gmail.com;
  • To respond to your requests for the exercise of rights of access, rectification, opposition, deletion, limitation, portability, digital death rights, and the right to file a complaint with the CNIL;
  • To comply with legal or administrative obligations imposed by the legislator.

Adena commits to informing its Users if their Personal Data is processed for purposes other than those specified above.

Adena collects and processes your Personal Data based on the following grounds:

  • Management of the proper functioning and continuous improvement of the Site: legitimate interest;
  • Management and tracking of orders: performance of the contract between the User and Adena;
  • Management and tracking of subscriptions to Adena newsletters: User's consent;
  • Sending commercial prospecting and targeted advertising: User's consent;
  • Management of User requests sent via the Site's contact form or via the email address: legitimate interest;
  • Management of User requests to exercise their rights: legal obligation.

How long is data retained?

Only the individuals authorized by Adena mentioned below will have access to your Personal Data:

  • Authorized personnel from Adena's various departments (authorized personnel from the communication, administrative, logistics, and IT departments responsible for managing customer relations and oversight);
  • Subcontractors of Adena acting on behalf of Adena, including, in particular, the hosting of the Site, the service provider responsible for handling Adena's customer service, the provider responsible for sending newsletters and commercial prospecting emails, the provider responsible for sending commercial prospecting SMS, and the provider responsible for processing payments, order tracking, and billing;
  • Relevant courts, mediators, lawyers, legal officers, etc.;
  • Third-party social networks. Adena informs the User that the Site may use social plugins provided and managed by third-party companies, such as the Facebook, Instagram, Pinterest, or YouTube buttons. By clicking on these buttons, the User can share the information viewed on a page of the Site with these third parties. However, Adena informs the User that if they are not logged into the account they opened with the third party in question, that party will not be able to know the User's identity. Conversely, if the User is logged into the account they opened with the third party, the third party may link the User's interactions with the Site to the account the User opened with that third party. Adena refers the User to review the privacy policies of each third party to learn about their practices regarding the processing of Personal Data.

As part of its customer service, Adena uses a service provider. This is Stripe Payments Europe Ltd., whose registered office is located at Block 4, Harcourt Center, Harcourt Road, Dublin 2, Ireland. This service provider processes Personal Data on behalf of Adena to carry out payment operations and billing for orders placed on the Site. In this regard, Adena informs Users that identification, contact, and payment data are transmitted directly to Stripe Payments Europe Ltd. from the User's browser when the order is placed. Personal data is used exclusively by Stripe Payments Europe Ltd. for executing and completing payments and is securely transmitted using the "SSL" encryption method. Stripe Payments Europe Ltd. is PCI DSS certified.

Users can access additional information on the personal data protection policy of Stripe Payments Europe Ltd. by visiting the following link: https://stripe.com/legal.

Are data transferred outside the European Union?

To carry out certain Personal Data processing activities, Adena transfers data to service providers or other Adena group entities (Adena LLC, Adena Inc, Adena EU, Cubert Inc.) located outside the European Union or the European Economic Area, whose list is provided below. As part of these transfers, Adena ensures that its service providers and Adena group entities maintain high and sufficient security standards for Personal Data protection in accordance with the level of protection required by the GDPR, the French Data Protection Act, and its implementing decree.

Additionally, Adena has signed standard contractual clauses with each of its service providers and Adena group entities located outside the European Union to ensure a high and adequate level of protection for Personal Data. Adena informs its Users that these contractual clauses are based on the European Commission's standard contractual clauses (Decision of February 5, 2010, on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and Council, and Decision of December 27, 2004, amending Decision 2001/497/EC with respect to the introduction of an alternative set of standard contractual clauses for the transfer of personal data to third countries).

Order tracking and billing

Adena uses the Shopify system to track its orders and invoices. The company in question is Shopify Inc., headquartered at 150 Elgin Street, Suite 800, Ottawa, ON K2P 1L4, Canada. This service provider handles order tracking and invoicing for Users on behalf of Adena. In this respect, Adena informs its Users that when an order is placed on the Site, Shopify Inc. may collect and process the following Personal Data:

  • User identification data;
  • Billing data.

Users can access more information on Shopify Inc.'s personal data protection policy by visiting Shopify Inc.'s privacy policy at: https://www.shopify.com/legal/privacy. If Users have any questions, they can also directly contact Shopify Inc.'s Data Protection Officer by email at the following address: privacy@shopify.com.

Newsletter, commercial prospecting, and advertising

Adena uses a service provider’s email marketing platform for sending newsletters, commercial emails, and advertising. This is Klaviyo, headquartered at 225 Franklin St, Floor 10, Boston, MA 02110, USA. This service provider manages Adena's email marketing campaigns (sending newsletters, commercial prospecting, and advertising) for Users.

In this regard, Adena informs its Users that by subscribing to Adena's newsletters or agreeing to receive Adena's commercial and advertising offers, Adena may transfer the following personal data to Klaviyo:

  • User identification data;
  • Contact details;
  • Data relating to the device used: time zone, screen resolution, browser and operating system information, location, and language used.

Adena reminds Users that these transfers of Personal Data are necessary for the following processing activities:

  • Managing and monitoring subscriptions to Adena's newsletters;
  • Sending commercial prospecting and targeted advertising.

This processing is based on the User's consent. Thus, if the User no longer wishes Adena to carry out such transfers, they can withdraw their consent at any time by clicking on the unsubscribe link in each email containing newsletters, commercial offers, or advertisements from Adena, or by informing Adena via email at adenacontacto@gmail.com (see Article 8 of the Privacy Policy).

Sending SMS for commercial prospecting

Adena uses a service provider to send commercial prospecting SMS messages when Site Users do not finalize their shopping carts. This provider is SMSBump Inc., headquartered at 7 Fulkerson Street, Cambridge MA, 02141, USA. This provider manages the sending of commercial SMS messages on behalf of Adena when a Site User chooses not to validate their shopping cart on the Site.

In this regard, Adena informs its Users that by accepting Adena's SMSBump service, Adena may transfer the following Personal Data to SMSBump:

  • User identification data;
  • Contact details;
  • Data relating to the tracking of the business relationship.

Adena reminds Users that these transfers of Personal Data are necessary for the following processing:

  • Sending commercial prospecting messages.

This processing is based on the User's consent. Therefore, if the User no longer wishes Adena to carry out such transfers, they can withdraw their consent at any time by clicking on the unsubscribe link in each SMS sent by SMSBump, or by informing Adena via email at adenacontacto@gmail.com (see Article 8 of the Privacy Policy).

Google Tag Manager

Adena informs its Users that it uses the Google Tag Manager tool. This tool allows Adena to manage the tags on its Site (Site code). These tags facilitate the management and development of the products and services offered on the Site and reduce the loading time of the Site. Google Tag Manager only implements the Site code. Google Tag Manager does not create cookies and does not collect personal data. The tool only integrates the Site code and facilitates code management without accessing Personal Data processed by the code. However, Adena wishes to inform its Users of the presence of the tags included in this Privacy Policy. Users can find more information about Google Tag Manager and its terms of use on Google's pages.

What are your rights as a User?

As a User, you have the right to access, rectify, transfer, limit, object to, and delete your Personal Data. Furthermore, Adena informs you that you may define instructions regarding the storage, deletion, and communication of your Personal Data after your death.

In addition, concerning processing activities requiring your consent, Adena informs you that you may withdraw your consent for the processing and use of the data you previously consented to, at any time, with future effect.

If you have any questions about this or wish to exercise the aforementioned rights, you can contact Adena via email: adenacontacto@gmail.com.

Adena informs you that if you wish to exercise your rights, you must provide Adena with your contact details (surname, first name, address, and a signed copy of an identity document), as well as a legitimate reason when required by law (especially in the case of objecting to the processing). When you provide a copy of an identity document to verify your identity, Adena will keep it for the calendar year of the request plus five (5) years, especially when this communication is made in the context of exercising a right to object.

Adena informs you that you have the right to file a complaint with a supervisory authority. In France, this supervisory authority is the Commission Nationale de l'Informatique et des Libertés (CNIL), whose contact details are as follows:

Adena informs you that its products and services available on the Site are intended exclusively for adults and minors over the age of 16. In this regard, Adena does not process personal data of minors under the age of 16 without the prior consent of their legal representatives.

Adena reminds all internet users visiting its Site that if they are under 16, they should not send any information about themselves, especially Personal Data, without prior consent from their legal representatives.

Does the Site use cookies?

Adena informs its Users that Cookies consist of a series of information, a small text file, that the Site installs on the User's device when the User consults it.

Adena informs its Users that the cookies installed by the Site do not contain any identifying personal data

Personal Data is retained in accordance with legal provisions for a period not exceeding that necessary for the purposes for which it is collected and processed by Adena. However, Personal Data may be retained to provide proof of a right or contract, comply with legal obligations, or be archived according to applicable laws and regulations.

Are data transmitted to third parties?

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