PRIVACY POLICY
1. INTRODUCTION
1.1 The purpose of this privacy policy (the “Privacy Policy”) is to set out how your personal data (the “Personal Data”) is collected, processed and used by Christian Alan Pearson, trading under the name Pearson Christian, SUMO!, a German citizen born on December 9, 1976 in Rustington, United Kingdom and residing at 104, rue de Noertzange, L-3670 Kayl, registered with the Luxembourg Trade and Commerce Register under number A38905 (“SUMO”) during the use of the website available at the following address:f http://www.sumo.lu and https://www.sumoartwork.com of its online shop.
1.2 SUMO is committed to handling personal data in compliance with the applicable laws to the processing of personal data and, in particular, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the “General Data Protection Regulation" or the “GDPR”) and national relevant legislations, in particular, the Luxembourg law of 1 August 2018 on the organization of the Commission Nationale pour la Protection des Données (the “CNPD”) and on the general system of data protection as well as all other national laws or regulations implementing the GDPR that may be applicable, as the case may be (the “Data Protection Laws”).
2. SCOPE
2.1 This Privacy Policy applies whenever you make use of the present Website. SUMO is committed to safeguard the privacy of visitors to its Website. In this regard, please read the following Privacy Policy to understand how your information will be processed. This Privacy Policy may vary from time to time so please check it regularly. Any significant changes to this Privacy Policy will be clearly indicated on our home page.
2.2 The Privacy Policy applies to:
- all visitors of the Website available at the following address: http://www.sumo.lu - https://www.sumoartwork.com/;
- all persons fulfilling the contact form available on the Website at the following address: http://www.sumo.lu/contact - https://www.sumoartwork.com/contact;
- all persons using the online shop available at the following address: https://www.sumoartwork.com/art-shop;
(together referred to as the “User(s)”);
2.3 SUMO is the data controller for all the processing of personal data described hereunder.
3. EXCLUSION AND LINKS TO THIRD-PARTY WEBSITES
3.1 This Privacy Policy does not apply to websites owned by third-parties or associated websites available through a link mentioned on the Website.
3.2 Links or pointers to third party web sites on the Website are provided solely as a convenience to the Users. If Users use these links, Users will leave the Website.
3.3 SUMO has not reviewed these third party web sites, does not control them and is not responsible for any of these websites or their content.
4. CHARACTERISTICS OF THE MAIN PROCESSING OF PERSONAL DATA
4.1 Personal data are processed for the following purposes:
- for analytical purposes so that we can optimize our Website ;[A1]
- for processing and answering messages that you send us via the contact form ;
- for processing the orders made through the online shop of the Website.
4.2 For each of the above-mentioned purposes, the personal data collected are the following:
A) Personal Data related to the processing for analytical purposes:
· IP Address ;
· Data on the usage of the Website, traffic data ;
· Cookies, data entered in web forms or submitted as URL parameters, URLs and content of unprotected browsing activity, time of Users’ connections;
· User’s web browser information i.e. operating system and device.[A2]
Such processing is based on the legitimate interest of SUMO to optimize his Website. For these purposes, data shall be processed for a duration of […]
B) Personal Data related to the processing and answering of messages:
· First Name / Last Name;
· Contact details (such as email address);
· Content of the message.;[A3]
Such processing is based on the legitimate interest of SUMO to know who is contacting him and to answer him. For these purposes, data shall be processed for a duration of […]. SUMO may not take into consideration messages that are sent without the sender identifying herself/himself
C) Personal Data related to the processing of the orders made through the online shops :
· First Name / Last Name;
· Contact details;
· Address of Delivery;
· Means of Payment;
· Content of the order.[A4]
Such processing is necessary for the performance of a contract to which the User is a party. For these purposes, data will be processed for the duration of the order process and for a period equivalent to the legal prescription period (10 years). SUMO may not process an order where such information are not provided.
5. INFORMATION NECESSARY FOR THE OPERATION OF THE SITE
5.1 SUMO will also collect and process your Personal Data to the extent of what is necessary to deliver the content of the Site correctly. Thus, it is based on the legitimate interests of SUMO to provide Users with a correct-functioning Site.
5.2 For such Personal Data processing, the following Personal Data may be processed:
· […] and other relevant data.
5.3 Such Personal Data will be kept for, at the maximum, the duration of the Users’ visit on the Site.
6. USE OF COOKIES
6.1 Cookies are pieces of data stored on a User’s hard drive that contains data about a User. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognize a User’s device.
6.2 Cookies may be placed on the User’s computer or other electronic device to collect both anonymous data and Personal Data about the User.
· Strictly necessary cookies - Some of the cookies on the Site are technically essential in order to enable the Users to move around the Site and use its features. They do not identify the User as an individual and do not require the User’s consent.[A5]
· Performance cookies - Some of the cookies on the Site collect information about how Users use the Site, for instance which pages Users go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a User. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Site works. These cookies are automatically deleted at the end of the User’ session and do not require the User’s consent.[A6]
· Functionality cookies - These cookies aim at improving the navigational experience by keeping record of certain data (this avoids the User having to reintroduce such data at each connection and at tailoring the content of the Site to the User’s preferences. They allow the Site to remember choices made by the User and provide enhanced, more personal features. Users have the option at any time to delete or block cookies in their browser parameters. However, some functionalities of the Site requiring the use of such cookies may no longer be available to the Users.[A7]
6.3 Users’ prior consent is required at the first connection [A8] on the Site, through a banner available on the Website.
6.4 Cookies will be deleted after a retention period of maximum 13 months[A9] .
7. RIGHTS OF USERS
7.1 Every User has the rights to access to his/her Personal Data collected and processed by SUMO. In addition, every User has the right to rectification of any inaccurate Personal Data and the right to have incomplete Personal Data completed.
7.2 Every User may also request his/her Personal Data to be deleted, if the requirements of the Data Protection Laws are met.
7.3 Every User may also object to the processing, request it to be limited and request the portability of his/her Personal Data in accordance with the Data Protection Laws.
7.4 In case of Personal Data processing based on Users’ consent, Users have the right to withdraw, at any time, the given consent.
7.5 Users have also the right to lodge a complaint with a supervisory authority, in particular the supervisory authority of his/her habitual residence, place of work or place of alleged infringement, if the data subject considers that the processing of Personal Data relating to him/her infringes the Data Protection Laws. In Luxembourg, the relevant supervisory authority is the CNPD.
7.6 To exercise these rights, please send a written and signed request to SUMO at the address referred below.
8. SECURITY
SUMO has implemented all adequate technical and organizational measures with a view to protecting Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. All SUMO’s employees, service providers and any third parties are subject to confidentiality commitments.
9. TRANSFER OF PERSONAL DATA
SUMO does not transfer Users’ Personal Data to any third-party or to a country outside of the European Union or European Economic Area.
10. QUESTIONS, CONCERNS AND ENQUIRIES
If questions arise concerning the processing of Personal Data carried out by SUMO, this Privacy Policy or if there is any concern that Personal Data are not processed in compliance with this Privacy Policy or the Data Protection Laws, the question/concern may be referred to the SUMO at the following address: […], without prejudice for the User of his/her right to lodge a complaint to the relevant supervisory authority (i.e. the CNPD in Luxembourg).
SUMO
104, rue de Noertzange
L-3670 Kayl
Phone : +352 661 465 615
Email : info@sumo.lu