Privacy policy

In the course of its activity and for the purposes of providing the Services (as defined in our General Terms of Use), Filumena is required to collect and process the personal data of its users (hereafter referred to as the “Users”).

This privacy policy, implemented by Filumena, is intended to provide the Users with a summary and overview of the processing of personal data carried out by Filumena.

Filumena attaches particular importance to the respect for the privacy of the Users and of the confidentiality of their personal data, and is thus committed to processing the data in compliance with the applicable laws and regulations, and in particular Law No. 78-17 of 6 January 1978 relating to Information Technology, Data Files and Civil Liberties (hereafter referred to as the “Data Protection Act”), and 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 (hereafter referred to as the “GDPR”).

Definitions

Personal data: any information relating to an identified or identifiable natural person, that is, a person who can be identified, directly or indirectly, by reference to an identification number or to one or more elements specific to that person.

Processing of personal data: any operation or any set of operations relating to personal data, whatever the process used, and in particular the collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, as well as locking, erasure, or destruction.

Cookie: a cookie is a piece of information placed on the hard drive of Internet users by the server of the site they visit. It contains several pieces of data: the name of the server which installed it, an identifier in the form of a unique number, and possibly an expiry date. This information is sometimes stored on the computer in a simple text file that a server accesses to read and save pieces of information.

Data Controller

The data controller for the processing of the personal data referred to herein is Filumena, a simplified joint stock company with a share capital of 5000 Euros, registered with the Melun Trade and Companies Register under number 902505445 and whose registered office is located at 2 rue du Haut Changis, 77210 Avon, France.

Data collected

Following consultation of this site and/or voluntary registration on it, the relevant personal data will be processed. To this end, the Data Controller informs the data subject that the personal data provided will be processed in accordance with the provisions of the GDPR and the revised Privacy Code and concern:

  • Navigation Data;
  • Personal Data not falling within the special categories of personal data as listed in Article 9 GDPR (identification and contact data, payment data, IP address, purchases);
  • Data falling under the special categories of personal data as listed in Art. 9 GDPR (data also indirectly related to religious belief, purchase "religious articles", "liturgy accessories", "special occasions");

The mandatory or optional nature of the data provided (in order to complete the Users’ registration and to render the Services) is indicated at the time of collection by an asterisk.

In addition, certain data is collected automatically as a result of the User’s actions on the site (see the paragraph on cookies).

Purposes

The personal data collected by Filumena during the provision of the Services is necessary for the performance of the contracts concluded with the Users, or to allow Filumena to pursue its legitimate interests while respecting the rights of the Users. Certain data may also be processed based on the Users’ consent.

The purposes for which Filumena processes data are the following:

  • commercial and accounting management of the contract;
  • management of customer acquisition and marketing activities;
  • detection of malicious behaviour (fraud, phishing, spam, etc.);
  • improvement of the Users path on the site;
  • social applications, interaction with social networks and external platforms, advertising, statistics, managing addresses and sending email messages, business affiliation, managing RSS feeds, contacting the user, managing payments, monitoring infrastructure, displaying content from external platforms and commenting on content;
  • more generally, any purpose referred to in Article 2 of Deliberation No. 2012-209 of 21 June 2012 creating a simplified standard for the automated processing of personal data relating to the management of users and prospects.

Recipients of the data

The personal data collected is intended for Filumena’s commercial and accounting services. It may be transmitted to Filumena’s subsidiaries, or to third-party data processors which Filumena is authorized to use within the context of the performance of its Services.

In this context, personal data may be transferred to an EU or non-EU country (see Detailed information on the processing of Personal Data). Filumena implements guarantees ensuring the protection and security of this data, in compliance with applicable rules and regulations.

Filumena does not transfer or rent personal data to third parties for marketing purposes without the express consent of the Users of Filumena.

In addition, personal data may only be disclosed to third parties for purposes other than marketing in the following cases:

  • with their authorisation;
  • at the request of the competent legal authorities, upon judicial request, or in the context of a legal dispute.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  • Plausible Analytics

    Plausible is lightweight and open source web analytics which requires no cookies and fully compliant with GDPR. Plausible utilizes the Data collected to track and examine the use of Filumena, to prepare reports on its activities. Filumena self-hosts a Plausible instance at a dedicated server.

    Personal Data processed: Usage Data.

    Place of processing: See the section "Hosting and backend infrastructure" below.

  • Mautic

    Mautic is lightweight and open source web analytics to analyze the usage of websites. Mautic utilizes the Data collected to track and examine the use of Filumena, to prepare reports on its activities. Filumena self-hosts a Mautic instance at a dedicated server.

    Personal Data processed: Usage Data.

    Place of processing: See the section "Hosting and backend infrastructure" below.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  • Sendinblue

    Sendinblue is an email address management and message sending service provided by Sendinblue – 7 rue de Madrid, 75008 Paris, France

    Personal Data processed: App Notifications; email address; phone number.

    Place of processing: France – Privacy Policy.

  • Mailjet

    Mailjet is an email address management and message sending service provided by Mailjet – 4 rue Jules Lefebvre, 75009 Paris, France

    Personal Data processed: App Notifications; email address; phone number.

    Place of processing: France – Privacy Policy.

Handling payments

Payment processing services enable Filumena to process payments by credit card, bank transfer or other means. To ensure greater security, Filumena shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  • PayPal (PayPal Inc.)

    PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: See the PayPal privacy policy.

  • Braintree (Braintree Inc.)

    Braintree is a payment service provided by Braintree Inc., which allows Users to make online payments.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: See the Braintree privacy policy.

  • Stripe (Stripe Inc.)

    Stripe is a payment service provided by Stripe Inc., which allows Users to make online payments.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: See the Stripe privacy policy.

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable Filumena to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Filumena.

  • Hertzner

    Hertzner is a hosting service provided by Hertzner Online GmbH – Industriestr. 25, 91710 Gunzenhausen, Deutschland.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: Germany – Privacy policy

  • Hostinger

    Hostinger is a hosting service provided by Hostinger – UAB, Jonavos g. 60C, 44192 Lithuania.

    Personal Data processed: various types of Data as specified in the privacy policy of the service.

    Place of processing: Netherlands – Privacy policy

Direct Email Marketing (DEM) (Filumena)

Filumena uses the User Data to propose services and products provided by subsidiary entities of Filumena.

Personal Data processed: email address and name.

Mailing list or newsletter (Filumena)

By registering for the mailing list or newsletter, the User’s email address is automatically included in a list of contacts to which email messages may be sent containing information, including commercial and promotional information, relating to Filumena and the products marketed on the platform. The User’s email address may also be added to this list as a result of Filumena’s registration or after making a purchase. Personal Data collected: Last name, first name and email address.

Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Filumena depends on the payment system used.

Data retention period

Personal data will be kept as long as necessary to pursue the purposes for which it was acquired. The period of data retention depends on the purposes for which they are processed and therefore may vary, i.e. throughout the period during which the data subject is a customer and thereafter for 5 years unless explicit consent is requested to extend data retention. Personal data functional to the fulfilment of civil and tax obligations will also be retained afterwards, in compliance with the retention periods envisaged by the regulations applicable from time to time and for the eventual defence of the Data Controller in court.

Rights of Users

In accordance with applicable rules, the Users have the right to access and rectify their personal data, which enables them to rectify, complete, update, or delete data that is inaccurate, incomplete, ambiguous, or outdated, or whose collection, use, communication, or storage is prohibited.

The Users also have the right to request the limitation of the processing, and to oppose on legitimate grounds the processing of their personal data. The User may also communicate instructions on the fate of their personal data in the event of their death.

Where applicable, the User may request the portability of their personal data or, where the legal basis for the processing is consent, withdraw their consent at any time.

The Users may exercise their rights by sending an email to privacy@filumena.net or a letter to:

Filumena SAS – Privacy policy
2 rue du Haut Changis, 77210 Avon, France

These requests shall be processed within a maximum period of 30 days.

The Users may also at any time modify the data pertaining to them by by contacting the customer relations department at support@filumena.net

The Users may unsubscribe from the Filumena newsletter or marketing emails by following the unsubscribe links in each of these emails.

In the event of a dispute, the Users may file a complaint with the CNIL, for which contact details may be found at the website of CNIL.

The Users may access detailed information on the use of their personal data, in particular concerning the purposes of the processing, the legal bases enabling Filumena to process the data, its storage period, its recipients, and, where applicable, its transfer to a country outside the European Union as well as the related compliance guarantees put in place for such transfers. To do so, the User can send their request by email to privacy@filumena.net.

Cookies

For more information about how Filumena handles cookies, please visit our cookie policy page.

Security

Filumena has taken useful precautions to preserve the security of personal data and, in particular, to prevent it from being accessed by unauthorized third parties, distorted, or damaged.

These measures include the following:

  • Multi-level firewall;
  • Proven solutions for anti-virus protection and detection and blocking of intrusion attempts;
  • Encrypted data transmission using SSL/https/VPN technology;
  • Tier 3 and PCI DSS certified data centres.

In addition, access to processing data on behalf of Filumena by the receiving third-party services requires authentication of the persons accessing the data, by means of an individual access code and password, that is sufficiently robust and regularly renewed.

Data transmitted over unsecured communication channels is subject to technical measures designed to make such data incomprehensible to any unauthorised person.

Any questions about the security of the Filumena website can be directed to support@filumena.net.

Modification of the Privacy Policy

Filumena reserves the right to change this Privacy Policy to comply with changes in the applicable laws and regulations.

The Users shall be notified of any changes made to this policy via our website or by email at least thirty days prior, when possible, to their entry into force.

Contact

Any questions about Filumena’s Privacy Policy can be directed by email to privacy@filumena.net or by mail to:

Filumena SAS – Privacy policy
2 rue du Haut Changis, 77210 Avon, France

Last updated date: 19/02/2023

Effective date: 15/08/2023

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