Privacy policy (EN)

WAVO - Privacy policy

Applicable from 15th of June, 2023

We respect your privacy and the protection of the personal data you provide to us, and comply with current legislation on the protection of privacy and personal data.

We have established this privacy policy (here after referred to as the "Policy") in order to (i) enable you to communicate your personal information in complete confidence and confidentiality, (ii) inform you of the way in which your personal data is processed by our company and (iii) guide you in your rights with regard to personal data.

1. Who are we?

Your personal data is processed by FINKICKS, a simplified joint stock company with share capital of €15,000.00, whose registered office is located at 129 rue Servient, 69003 LYON, registered in the Lyon Trade and Companies Register under number 921 951 232 (hereinafter referred to as "WAVO").

2. Definition of personal data

Personal data is concrete or personal information relating to a specific or identifiable individual (for example your name, telephone number or address).

Non-private data ("pseudonyms") is information relating to a specific person or account that is not sufficient to identify that person.

3. When do we collect personal data?

When you contact WAVO by any means, in particular :

• when you visit the site www.discord.com (the "Site") and use the discussion community published by WAVO (hereinafter referred to as the "Server"),
• When you use the services offered by WAVO (hereinafter "WAVO Services"),
• When, as part of the WAVO Services, you access your dashboard (hereinafter "Dashboard") accessible via the web-application published by WAVO (hereinafter "Application"),
  you may be asked to provide a certain amount of personal data about yourself, i.e. information that directly or indirectly enables you to be identified.

You will be asked to provide personal data in order to :

• Browsing the Site Server ;
• Send WAVO a request to purchase Sneakers you own;
• Create your personal account ;
• Purchase and benefit from WAVO Services under the conditions set out in the general conditions of use of WAVO Services (hereinafter "GCU"), and in particular in order to:
  • Sell Sneakers to WAVO, have them delivered and collect the corresponding immediate purchase price;
  • Log in to your Dashboard ;
  • Exercise your right to cancel the contract for the sale of Sneakers concluded with WAVO ;
  • Have WAVO deliver sneakers that you have sold to third parties and, if applicable, collect your share of the price;
  • Collect and have delivered to you by WAVO sneakers for which you have exercised your right to cancel the sales contract concluded with WAVO;
• Contact us using our contact form, by e-mail, by telephone or by any other electronic means;
• subscribe to our newsletter,
• receive information about WAVO services,
• To report a problem or request assistance, contact Customer Service ;

Some of the personal data you may be asked to provide is compulsory. The compulsory nature of the data collected is indicated by an asterisk; other data is optional. Failure to provide compulsory personal data may result in the impossibility of accessing WAVO Services.

Following the placing of an order and subject to your express consent, you may receive information and commercial offers from WAVO by electronic communication (newsletters, email, sms, etc.). These emailings enable you to be kept informed of WAVO news and of the advantages you can enjoy thanks to WAVO Services. We measure the opening rate of our electronic mailings in order to adapt them to your needs.
If you no longer wish to receive promotional messages, you can unsubscribe at any time in the "My account" section of the dashboard or by clicking on the unsubscribe link at the foot of each promotional e-mail or in each promotional SMS. Unsubscribing from promotional messages will not stop communications relating to WAVO Services (status of a Sneakers sale, etc.).
WAVO Services are not intended for minors.

4. What types of personal data do we collect?

Where appropriate and necessary for the purposes described in this Policy, WAVO collects the following personal data from you:

When you exercise your right to cancel the contract for the sale of Sneakers concluded with WAVO in order to resell the Sneakers to a customer that you have found directly under the conditions set out in article 7.4.6 of the GCU, you instruct WAVO to deliver the Sneakers to this customer. To do so, you provide WAVO with the identification data (surname, first name and address) of the said customer. In this context, you are considered to be responsible for processing the personal data relating to the purchaser of the Sneakers, WAVO being a processing subcontractor within the meaning of the applicable regulations.

You undertake to take the appropriate measures to ensure the protection and confidentiality of the personal information that you hold, that you process and that you communicate to WAVO in compliance with the applicable legal and regulatory provisions.

5. For what purposes do we collect this personal data? How long do we keep your data?

Once the purposes for which personal data was collected have been fulfilled, it will be deleted.

6. Who do we send your personal data to?

Information collected by WAVO is not sold to third parties.

We may share personal data collected with other entities, namely :

• The authorised members of WAVO in the context of carrying out the tasks resulting from the purposes identified above;
• Service providers and subcontractors who perform certain support functions on our behalf, namely :
  • Our telephone operator: Orange SA
  • Our hosting provider: Hubspot, Firebase (EU Server)
  • Our online payment service provider: STRIPE
  • Our service provider for sending user account creation emails: Hubspot EU and Firebase
  • Our email marketing service provider: Hubspot EU
  • Our logistics provider: GTL international,
  • Our transport service providers: Chronospot France
• Our legal advisers, court officers, government departments, courts and administrative authorities when necessary for the establishment, exercise and defence of legal proceedings.

We reserve the right to disclose your personal data to other parties where required or permitted to do so by law, regulation, court order or regulation, or where such disclosure is necessary in connection with an investigation or proceeding at home or abroad.

We may share your data with third parties where you consent to or request such sharing.

In addition to the assumptions listed above, we may disclose non-personal information to third parties, such as aggregated statistical data.

Finally, your data may be communicated to persons involved in any takeover, acquisition, merger, absorption or transfer of WAVO to third parties.

7. Will my data be transferred outside the European Union?

As a matter of principle, the personal data collected is not intended to be transferred outside the European Union. This personal data is hosted on a server located in the European Union.

If, exceptionally, personal data should be transferred outside the European Union, the transfers will be subject to appropriate safeguards to ensure an adequate level of data protection (standard contractual clauses, BCR, etc.).

WAVO will therefore, prior to the said transfer, take all necessary measures and guarantees to secure such transfers and undertakes to ensure that the transfer is covered by either :

• an adequacy decision from the European Commission in accordance with Article 45 of the European Data Protection Regulation,
• standard contractual clauses issued by the European Commission or a Supervisory Authority in accordance with Article 46 of the European Data Protection Regulation,
• binding corporate rules approved by a competent supervisory authority pursuant to Article 47 of the European Data Protection Regulation.

If a transfer of data to countries not recognised by the European Commission as having an adequate level of protection is envisaged, WAVO will inform you.

8. How are my personal details protected?

WAVO is committed to ensuring the security of the data you transmit. In order to prevent any unauthorised access, use, modification, destruction, loss, damage or disclosure, appropriate technical and organisational measures have been taken to protect the data collected.
In particular, the security of your data is guaranteed:

• thanks to login and password protection;
• thanks to the use of the industry standard TLS to ensure secure exchanges,
• by limiting access to your data to authorised persons only (for example, only WAVO members or their employees who need access for the purposes indicated above will have access);
• thanks to the antivirus protection of our information system.

Unfortunately, the transmission of information via the Internet is not completely secure. Although WAVO is committed to doing everything in its power to protect your personal data, WAVO cannot fully guarantee the security of the data you transmit.

In the event of a breach of your personal data presenting a risk to the rights and freedoms of the persons concerned, please be aware that WAVO is obliged to notify the competent supervisory authority and to inform you, as soon as possible, of any breach of personal data likely to give rise to a high risk to your rights and freedoms, to enable you to take the appropriate measures.

9. What are your rights?

You have the right to access your personal data, to amend it, to erase it, to be forgotten by WAVO, to restrict the processing of your data, to receive personal data about you provided to WAVO in a structured, frequently used and machine-readable format and, for a legitimate reason, to object to the processing of personal data. Where processing is based on your consent, you also have the right to withdraw it.

You also have the right to object, on grounds relating to your particular situation, to the processing of your data and to request that the processing of your data be restricted.
You also have the right to lodge a complaint with the CNIL or a data protection authority in a Member State of the European Union and to define post-mortem directives.

These rights may be exercised at any time:

• Or by sending an email to the following address: hello@wavo-app.com
• Or by using the contact form on your Dashboard
• Or by post to Wavo support

To enable WAVO to respond quickly, please provide your surname, first name, e-mail and address.
Certain requests to exercise your rights (right of access) must be accompanied by a photocopy of an identity document bearing your signature in order to verify your identity and specify the address to which the reply should be sent.
A reply will then be sent to you, except in special cases, within one (1) month of receipt of the request.

10. Changes to the Policy

We may revise or supplement this Policy, in particular to take account of new purposes or changes in legislation. Such changes will be effective from the date of their publication. Any substantial modification will be indicated on the Dashboard and/or, where applicable, by email. To keep abreast of changes, please check this page regularly.

11. Contact WAVO

If you have any comments or questions about this document, please write to us at : hello@wavo-app.com