Personal data protection policy

Last update: March 2021

HOSPINOV is concerned about the protection of personal data. It implements a process of continuous improvement of its compliance with the General Data Protection Regulation (GDPR), the “Privacy and Electronic Communications” directive, to ensure the best level of protection of your personal data. 

Who is responsible for processing my personal data?

The data controller is the company that defines the purpose and the methods of use of your personal data. 

The personal data collected on the HOSPINOV website or mobile application are processed by STRAXIO LLC, domiciled at 21800 Oxnard St Woodland Hills California 

Hereinafter referred to together as “HOSPINOV”.

Why does HOSPINOV collect my personal data?

HOSPINOV uses your personal data mainly for the following purposes

– Management of orders and customer relations

We need information about you to manage and follow up your orders (for example, deliveries, invoices, accounting and in particular the management of customer accounts, management of customer relations such as satisfaction surveys, management of complaints and after-sales service, selection of customers for studies, surveys and product tests.

– Payment of your orders or subscriptions

When you pay on our website and our application, your payments are secure. HOSPINOV does not collect your payment data but only a payment identifier and part of your credit card numbers in order to allow you to recognize the card used for the last payment. All your bank details are only collected by our PCI-DSS (banking security standard) certified payment service provider in order to guarantee payment security.

– Payment at the time of purchase 

When you pay for an order, the card information used for payment is kept for the time necessary to complete the transaction and then for a period of 15 months from the date of payment to ensure proof of the transaction.

o Register your credit card for future purchases 

If you have accepted the registration of your credit card to facilitate your future purchases, your card is registered on your HOSPINOV account and kept for this purpose for the duration of the validity of the credit card, unless you decide to delete this data. You can delete your credit card data at any time by informing us.

– Personalizing our services and messages to you

Your information allows us to improve and personalize the services we provide and the communications we send you. For example, we may send you personalized e-mails based on the products you have viewed on our site or your purchases. As you browse our site, we may also recommend products that are similar to those you have already purchased or viewed and that match your interests.

– Third Party Marketing

Your contact data may be passed on to agencies or business partners for marketing purposes.

– E-mail and SMS: prospecting e-mails and sms sent by partners are not carried out without your consent.

o Telephone and mail: regarding postal or telephone canvassing by partners, you may object at any time by informing us.

– Personalization of online advertisements (advertising profiling for the benefit of third parties, which consists of analyzing or predicting elements concerning, in particular, the personal preferences, interests, situation, behavior, location or movements of a natural person).

HOSPINOV has an advertising network activity. As part of this business, we provide advertising services to brands by enabling them to serve their advertisements – on our site or on third-party sites – to customer profiles (audiences) targeted by HOSPINOV or that HOSPINOV has helped to create based on browsing information and declarative or purchase information available to us. HOSPINOV enables brands to identify segments of HOSPINOV’s customers in order to deliver their offers and advertisements to the targeted individuals who are the most relevant audience.

HOSPINOV does not transmit any data that could directly identify you. Only technical identifiers and socio-demographic data may be shared as part of audience identification. Your profile includes only the areas of interest from which ads will be served on behalf of advertising partners.

Ad profiles are based on two types of data: browsing data collected through cookies and information collected when you create your account or make purchases.

To opt out of ad targeting for advertising partners, you must decline advertising cookies. For more information and to manage your advertising cookies, visit the “Cookies” page of the site.

You can also opt out of having your account information and order data used for profiling purposes by notifying us at any time.

The legal basis for the use of browsing data for advertising profiling purposes is consent (consent to cookies).

The legal basis for the use of account and purchase data for advertising profiling purposes is legitimate interest (you can object to this as soon as you create an account and then at any time thereafter by notifying us).

– Fight against fraud

Personal data collected on the site are also processed to secure payments and deliveries and thus ensure optimal quality of service. HOSPINOV determines the level of fraud risk associated with each order by using a fraud detection system based on both an algorithm (automated decision) and human analysis. The analysis algorithm takes into account different parameters such as the amount of the purchase, the product category or the existence of a previous incident. As part of this analysis, HOSPINOV may question its service providers specialized in risk prevention in order to refine its analysis. Some of these providers may become the recipients of the result of the analysis carried out and may use it in their own name to feed their own incident file. 

HOSPINOV may, depending on the results of the control carried out on the orders, take security measures, in particular by requesting additional proof or by proposing an alternative delivery method (for example, delivery to a store). These measures will have the effect of suspending the execution of the order or, if the result of the analysis does not guarantee the security of the order, of cancelling it. Fraudulent use of a means of payment or fraudulent delivery will result in the order data being recorded in HOSPINOV’s alert file, which may lead HOSPINOV to carry out additional checks on subsequent orders. You may at any time submit your observations to our anti-fraud services (see the section “Exercising your rights”).

– Security of our site

We collect certain browsing data to enable us to ensure the security of our services and to detect, prevent or trace any attempt at malicious or computer-related intrusion or any violation of the terms of use of our services.

– Customer insight and site statistics and performance

We may use data to better understand our customers or for statistical purposes to analyze site activity and improve the services we offer. We analyze customer journeys, perform audience measurement, we measure, for example, the number of page views, the number of visits to the site, as well as the activity of visitors on the site and their frequency of return.

What personal data is collected about me?

What data?

In particular, we collect and process your name, first name, address, e-mail address, password, telephone number, IP address, connection and navigation data, order history, preferences and interests, products consulted, delivery incidents, complaints. In some cases, we may collect location data, for example to tell you which store is closest to you. 

The mandatory nature of the data is indicated at the time of collection by an asterisk. Some data are collected automatically following your actions on the site, other information may be transmitted by partners.

When do we collect it?

We collect the information you provide to us when:

– you create your customer account on our sites and applications

– you place an order on our sites and applications

– you browse our sites and applications and consult the products

– you participate in a game or contest

– you contact our customer service

– you write a comment or leave a review about our products or stores

– when you complete a satisfaction survey

– you see our ads

What communications may I receive?

Information and newsletters

– Service Emails 

Following an order or as part of the follow-up of a contract, you will receive an e-mail in order to allow you to follow your order or the execution of your contract (order confirmation, information on the delivery of your parcel, information on the expiration of your subscription…). These service messages are necessary for the proper execution of the orders and services you have requested. The legal basis for this processing is the contract. The receipt of this information is not linked to the choices you express for the receipt of newsletters and commercial offers.

– HOSPINOV newsletters 

Following the creation of your account, if you have not objected, you may receive information and commercial offers from HOSPINOV by e-mail or by sms (electronic communications). These newsletters allow you to keep up to date with HOSPINOV news and the advantages that you can benefit from on products or services similar to those you have already ordered or consulted. The legal basis for this processing is the legitimate interest of HOSPINOV. We measure the opening rate of our electronic mailings in order to adapt them to your needs. You can manage your choices at any time by notifying us of your intention.

– Satisfaction surveys or requests for advice on products

Following a purchase on our site, we may ask you for your opinion by e-mail or by mail through questionnaires. These satisfaction surveys or requests for advice may be requested by approved partners. The legal basis for this processing is the legitimate interest of HOSPINOV. You may object to these surveys or requests for advice directly in the e-mails sent to you or by informing us.

– Newsletters from “partners 

If you have agreed to receive offers from HOSPINOV and our “partners”, you may receive offers by electronic communication (e-mail, sms…) as well as offers from selected commercial partners. The legal basis for this processing is consent. You can withdraw your consent at any time.

– Postal mail 

If you have not objected, you may receive offers and information by mail from the companies of the group and business partners. The legal basis for this processing is the legitimate interest of HOSPINOV.

– Telephone contact 

If you do not object (except for automated prospecting, which will be subject to your express consent), you may be contacted by our operators or partners to propose offers and services related to those you have purchased. The legal basis for this processing is the legitimate interest of HOSPINOV.

Product or artist alerts

We may offer you alerts in order to be informed by e-mail of an availability or a news that interests you. These alerts allow you, depending on the case :

– to be informed punctually of the next availability of the product which interests you.

– to get recurrent information on the news of an author, an artist, a musical group…

You can subscribe to the alert by clicking on the “Alert” button. The alerts to which you are subscribed are listed in your account. Alerts are different from newsletters. To stop sending alerts, you must unsubscribe in the ” ” section.

On what legal basis and for how long is my personal data processed?

The processing of your personal data is justified on different grounds (legal basis) depending on how we use the personal data. Below you will find the legal bases and retention periods we apply to our main processing operations.

Legal basis for processing

Among the applicable legal bases:

– Contract: the processing of personal data is necessary for the performance of the contract to which you have consented.

– Consent: you agree to the processing of your personal data by explicit consent (check the box, click …). You can withdraw this consent at any time.

– Legitimate interest: HOSPINOV has a business interest in processing your data that is justified, balanced and does not infringe your privacy. Except in exceptional cases, you may object to processing based on a legitimate interest at any time by notifying HOSPINOV.

– The law: the processing of your personal data is required by law.

Duration of data storage

Most data (e.g., customer account information and order history) is stored for as long as you are an “active” customer and for a period of 5 years after your last activity (e.g., purchase, login to your account or expiration of a contract or warranty). Your data is then archived with restricted access for an additional period of time for limited purposes permitted by law (payment, warranty, disputes …). After this period, it is deleted.

Who are the recipients of my data?

Transmission of data to subcontractors

The data we collect may be passed on to service providers (subcontractors) – which HOSPINOV uses to perform its services for the purposes mentioned above, for example for the management, execution, processing and payment of your orders, as well as for marketing operations.

Sharing of data within the HOSPINOV group

Your data may also be passed on to other subsidiaries of the HOSPINOV group for research and customer knowledge purposes.

To obtain an updated list of the group’s entities likely to receive your data, you can request it.

Sharing of data with third parties

For advertising targeting

– As part of our governance activity 

We inform you that we may share some of your non-identifiable data with partners, such as customer profiles (socio-demographic data and purchase profile), cookies or technical identifiers without it being possible for them to identify you personally for the purpose of targeted advertising on our site or on third party sites (see also the section on cookies and targeted advertising).

– On social networks 

We inform you that we may share some of your non-identifiable data in order to contact you and send you personalized advertisements on social networks (more information in the social networks section).

For commercial prospecting by third parties

– Email and SMS prospecting 

Your email and SMS data may only be passed on to partners for electronic commercial prospecting campaigns if you have given your consent. You can withdraw your consent at any time and/or request disclosure of the list of commercial partners at any time by writing to vieprivee@HOSPINOV.com.

– Telephone and postal prospecting 

Your postal and telephone data may be passed on to third-party advertisers via partners (marketing agencies) in the context of postal and telephone prospecting campaigns. You can object to this at any time by notifying our services (see “my choices”) and/or by registering on the Bloctel list on the website http://www.bloctel.gouv.fr/.

To improve the knowledge of our customers

To enable us to connect your different terminals (computers, cell phones …) and provide you with a harmonized experience on the different devices you use. To learn more about the reconciliation feature or to opt out, you can visit http://www.criteo.com/fr/privacy/. 

You can also set your cookie preferences to directly manage cookies related to ad targeting from the cookie information page.

For making sales in the marketplace 

If you purchase products on the Marketplace, your data may be transmitted to Marketplace sellers in order to execute your order.

How can I express my choices about the use of my data?

We are actively working to improve our choice manager in your account to give you more control over how your data is used.

You can withdraw your consent at any time when processing is performed on this basis or object to the use of your data as described above:

– when creating your account via the dedicated checkboxes or links in the account creation page

– at any time thereafter

o by sending us an email to vieprivee@hospinov.com

If you proceed by e-mail or post 

You must indicate your name, first name, e-mail and address and mention the reason for your request, the sign in question and/or the right you wish to exercise. 

In order for us to fully understand your request, you may, for example, specify one or more of the following reasons

– Stop commercial prospecting: 

“Stop HOSPINOV email.” 

“Stop email Partners.”

– To stop telephone solicitation 

With HOSPINOV ” Stop phone solicitation 

With Bloctel: see https://conso.bloctel.fr/index.php/inscription.php

– For the cessation of postal prospecting 

“Stop door-to-door canvassing at the post office.”

– For an end to data sharing for customer knowledge purposes within the HOSPINOV group 

“Opposition shares HOSPINOV Group.

– For objecting to the personalization of our services 

“Opposition to personalization of services”

– To stop advertising targeting 

“Opposition shared with third parties for targeted advertising”. 

You can also manage your cookies by going to the cookie manager located on the cookie information page or on the websites below: 

http://www.networkadvertising.org/choices/

http://www.youronlinechoices.com/

– To delete your customer account 

“Delete my account”

What are my rights regarding the use of personal data?

In accordance with the regulations on the protection of personal data, you can exercise your rights (access, rectification, deletion, opposition, limitation and portability if necessary) and define the fate of your personal data “post mortem” HOSPINOV by e-mail: privacy@hospinov.com or by mail: HOSPINOV 21800 Oxnard St Woodland Hills California.

In order to enable us to respond quickly, we would be grateful if you could provide us with your surname, first name, e-mail, address and, if possible, your customer reference number, and specify the address to which you wish to receive a reply. We may carry out identity checks to ensure the confidentiality and security of your data. In some cases, you may be asked to provide a copy of an identity document bearing your signature. A response will be sent to you within one month of receipt of the request.

At any time during the risk analysis carried out by HOSPINOV in the context of fraud prevention, you will be able to submit your observations. 

You also have the right to file a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), in particular on its website www.cnil.fr. 

HOSPINOV has a personal data protection officer (DPO) responsible for ensuring the protection of personal data. You can contact HOSPINOV’s Data Protection Officer at dpo@Hospinov.com (except for the exercise of your rights which is mainly done at vieprivee@hospinov.com).

Is my data transferred outside the European Union?

You are informed that your data may be transferred for the purposes mentioned above to companies located in countries outside the European Union that have a lower level of data protection than the European Union. Prior to transfers outside the European Union, HOSPINOV will take all necessary measures and guarantees to secure such transfers. 

Transfers outside the European Union may be carried out in particular in the context of our following activities: IT services, fraud prevention, data exploitation in relation to social networks (to the United States).

What about the personal data of minors?

HOSPINOV’s services are not intended for minors and, therefore, HOSPINOV does not process data specifically concerning minors. For example, we do not create business profiles related to minors. 

It is up to parents and any person exercising parental authority to decide whether their minor child is authorized to use HOSPINOV services.

What is the use of data in relation to social networks?

We inform you that the information related to your navigation is captured by the social networks for the purpose of advertising targeting on their own behalf via the cookies that are deposited during your navigation on our site. The data transmitted are browsing data (pages visited, product viewed, category of product viewed, etc.) and purchase data (products purchased or categories of products purchased, type of membership, etc.). 

The legal basis for this processing is the consent you give when you accept cookies. You can withdraw your consent by setting your choices in your browser or in our cookie manager.

We also share certain data (contact information) with our partners (e.g. Facebook, Google, Linkedin, etc.) in order to send you personalized HOSPINOV advertising on social networks. The data we send punctually (name, first name, e-mail, postal code, phone number…) are encrypted. They do not allow you to be identified directly and are only used to establish a match to recognize you as a HOSPINOV customer in order to send you personalized HOSPINOV advertising on the advertising inventory offered by the social networks. The legal basis for this data processing is the legitimate interest of HOSPINOV. You have the possibility to refuse these targeted ads by notifying us (see my choices) or from your social network user account.

We also collect on our own behalf certain information and personal data in connection with your activity on HOSPINOV social network pages or on HOSPINOV sites and applications that use social network services. This data is used for statistical analysis (use of our pages and applications) as well as for advertising purposes to improve our business relationship and advertising to you in order to provide a personalized and social experience.

The information collected by HOSPINOV on its own behalf within the framework of social networks is governed by the present general conditions and the specific conditions of the HOSPINOV applications. On the other hand, HOSPINOV is not responsible for the subsequent use of your data by the social networks on their own behalf.

We invite you to consult the personal data protection policies of our various partners (e.g. Facebook, Google, Instagram, Linkedin,…) to know exactly what information is collected by these third parties. You will also be able to set up access and privacy of your data directly on social networks.

“Plug-ins and social modules

Our site uses “plug-ins” or social modules. These include small “like” and “share” buttons on third-party social networks such as Facebook, Twitter, Google+ … that you can find on our sites and applications. They allow you to “like” and share information from our sites and applications with your friends on social networks. When you visit a page of our HOSPINOV sites (web or mobile) containing plug-ins or social modules, a connection is established with the servers of the social networks (Facebook, Twitter, etc.) which are then informed that you have accessed the corresponding page of the visited HOSPINOV site, even if you do not have a Facebook or Twitter user account, and even if you are not connected to your Facebook or Twitter account. For example: If you are connected to a social network while browsing www.HOSPINOV.com, the social networks to which you are connected may mention your visit in your social network account. If you use plug-ins (for example), your actions may be recorded and published on your social network accounts depending on your social network account settings. If you do not want social networks to publish your actions from the plug-ins in your social network accounts, you must log out of your social networks before visiting our site.

Social Connect

The “Social Connect” feature allows you to connect to our site with your social network accounts (e.g. Facebook, Google…) to facilitate your purchases and access to our services. When you connect to our site with these third-party accounts, HOSPINOV may access certain information in order to provide you with a personalized and social experience. HOSPINOV may request information in addition to that already in your corporate accounts for the purposes described above. Information collected by HOSPINOV on our sites and applications is not shared with social networks without your consent. It is up to you to manage your privacy settings on social networks when you wish to log in to HOSPINOV services with your social network credentials. 

What cookies are used for ad targeting?

We use tracking technologies such as cookies to tailor advertising to your needs and interests on our sites or those of our partners. Please see the Cookies section for detailed information about the use of cookies and other similar technologies and to see what choices you have.

What data is collected by mobile applications

Use of your data in connection with the HOSPINOV app:

If you use the HOSPINOV mobile app, certain personal data may be collected by the publishers of the operating systems used in your cell phone. We invite you to read the privacy policies of the operating system editors (iOS, Android, Windows…) in order to know what use is made of your data by the operating system editors as data controllers.

Geolocation

The HOSPINOV application includes a geolocation function that allows us to know how many people visit our stores anonymously and, if you have given your consent, to send you personalized information and commercial offers based on the store you are in and your customer profile. 

By authorizing the HOSPINOV mobile application to access your location data and send you notifications, you may receive information about our offers, products or services related to the store where you are located via text message, push notification or email. Please note that you may receive location-related notifications even when your HOSPINOV application is in sleep or cache mode. 

In order to optimize the location functions in the store, it may also be necessary to activate the wifi, bluetooth or microphone functions of your cell phone. You will find information in the store on the technical means adapted to the optimization of the geolocation information in the store and the modalities of opposition according to the technology concerned. 

When you visit HOSPINOV points of sale equipped with in-store tracking equipment, the presence of your smartphone may be detected if the search for Wi-Fi, Bluetooth or micro networks is activated. 

You can choose not to allow geolocation by refusing it when you download or first use the HOSPINOV application. However, some operating systems (Android) do not allow the download of applications with geolocation if access to location data has not been authorized. Downloading the application constitutes an agreement on your part. You can also disable access to your location data in your cell phone settings at any time by referring to the technical documentation of your device.

Notifications

By authorizing the HOSPINOV mobile application to send you notifications, you will be able to receive commercial offers and information related to your profile or your journey in your store if you have also accepted geolocation. The “Notifications” function of your application is intended solely for the purpose of sending information and personalized commercial offers by HOSPINOV. You can choose not to receive notifications by declining them when you download or use the HOSPINOV application for the first time. 

You can disable notifications at any time in the settings of your cell phone by referring to the technical documentation of your device as well as in the application by going to “my account” in the section “my settings”.

Cookies in relation to the HOSPINOV application

HOSPINOV uses cookies and similar tracking technologies in connection with the use of the HOSPINOV application and your terminals (mobile or computer) in particular in order to better identify you and personalize our services. When you install the HOSPINOV application, we collect information about your use of the application or your phone. We use this information to understand and improve our business relationships (including services, suggestions and advertising). As is the case on the web, we may use these technologies to store an identifier or other information on your device. Depending on your operating system, you may be able to disable these cookies by going to your phone’s settings where you can manage applications.

HOSPINOV Assistant on Google Assistant

Within the framework of the Google HOSPINOV Assistant service, your personal data are processed by STRAXIO LLC 21800 Oxnard St Woodland Hills California. HOSPINOV collects your data (first and last name, contact details, purchases, etc., and if you have accepted them when registering for the Service, your geolocation) to process your requests for assistance (advice, help, purchases, etc.), and keeps them for the time necessary to process your request, and then archives or deletes them. If you are already a HOSPINOV customer, the advisor may have access to your data already available in our databases.

You have the right to access, rectify, delete and oppose your personal data. You may also object for a legitimate reason to the use of your data, or without having to justify a reason when your right to object aims to stop any prospecting by HOSPINOV. Finally, you can set guidelines for the storage, deletion and disclosure of your data after your death. To exercise your rights, you may contact the HOSPINOV Data Protection Officer by email: vieprivee@hospinov.com , or send a letter to HOSPINOV, Customer Service 21800 Oxnard St Woodland Hills California, indicating your surname, first name, email address and, if possible, your customer reference. In accordance with the regulations in force, any request to exercise your rights must be signed and accompanied by a photocopy of an identity document bearing your signature and specifying the address to which the reply should be sent. A response will be sent to you within 2 months of receipt of the request.

Google is also the recipient of some of the data collected as part of the Google HOSPINOV Wizard service. To find out how Google processes your data and what your rights are, please read the terms and conditions here : 

https://privacy.google.com/intl/fr/your-data.html
https://support.google.com/googlehome/answer/7072285?hl=fr

You may exercise your rights (access, rectification, deletion, opposition, limitation and portability if necessary) and define the fate of your personal data “post mortem” by e-mail: vieprivee@hospinov.com or by post: HOSPINOV 21800 Oxnard St Woodland Hills California. 

You can also contact the HOSPINOV data protection officer at dpo@Hospinov.com. 

You also have the right to file a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL), in particular on its website www.cnil.fr.

HOSPINOV account data will be kept for a period of 5 years from your last activity (e.g. purchase or expiry of your contracts), then archived with restricted access for a further 5 years for strictly limited purposes authorized by law (payment, warranty, disputes, etc.). Geolocation data is retained for a limited period if the store where the purchase is made needs to be located. 

As part of the management of your HOSPINOV account, you are informed that your data may be transmitted for the purposes mentioned above to companies located outside the European Union, in particular for customer service activities, IT services and data processing in connection with social networks. Any necessary procedures to secure the data will be implemented prior to such transfers. 

When you pay through the Service, your payments are secure. HOSPINOV does not collect your payment data but only a payment identifier and some of your card numbers in order to allow you to recognize the card used for the payment. Your bank details are only collected by our PCI-DSS certified payment service provider to ensure the security of payments.

In order to secure payments within the framework of the Service, HOSPINOV implements fraud detection processes and determines the level of fraud risk associated with each order within the framework of the Service. 

Depending on the results of the control carried out, your order may be refused within the framework of the Service and another method of payment may be offered to you (payment at the cash desk). Fraudulent use of a means of payment may result in the recording of data relating to the order in the HOSPINOV alert file, which may lead HOSPINOV to carry out additional checks on future orders. If your order is not accepted, you may submit your comments.

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