PRIVACY POLICY
(GDPR)

Date of last update: June 1, 2025

This Privacy Policy (the "Privacy Policy") aims to formalise our commitment to respecting the privacy of users of the website onyvora.com (the "Site") operated by AGENCE ROBIN.

The Privacy Policy and the General Terms and Conditions of Sale of the Site form a single contractual set. All capitalised terms not defined in this Privacy Policy are defined in the General Terms and Conditions of Sale.

As part of making our Site available, we process your personal data in compliance with General Data Protection Regulation 2016/679 of 27 April 2016 ("GDPR") and under the conditions set out below.

Personal data means any information relating to an identified or identifiable natural person. We collect and process personal data solely in the context of providing our Services or communicating about these Services, in strict compliance with the GDPR.

We collect only personal data that is adequate, relevant and limited to what is necessary for the purposes for which it is processed. Accordingly, you will never be asked to provide personal data considered "sensitive", such as your racial or ethnic origin, your political, philosophical or religious opinions.

By registering on the Site, you authorise us to process your personal data in accordance with the Privacy Policy. If you refuse the terms of this Privacy Policy, please refrain from using the Site and the Services.

1. In what cases do we collect your personal data and what data is collected?

We may collect and store your personal data in the following cases:

• Browsing the Site;
• Account creation, online payment, placing an order, newsletter subscription;
• Getting in touch (customer service).

We use your personal data to enable the implementation and management of the Site's Services and to respond to your specific requests. We also use your personal data for the purpose of operating and improving our Services, our Site and our approach. This information is used solely by us and enables us to better adapt our Services to your expectations.

If you have decided to receive emails and messages from us when creating your Account, you will then receive electronic and alphanumeric messages regarding our products and promotions. We will use the personal data you provided at the time of your registration. You may unsubscribe from these communications at any time.

1.1 Browsing the Site

Connection data. Each time you connect to our Site, we collect personal data such as, in particular, your IP address and the MAC address of your computer, the date and time of connection, as well as information about the browser you use.

Browsing data. We also collect information to identify how you access the Site, which pages are viewed and for how long. In this context, we may use Cookies.

1.2 Account Creation

Access to certain of our Services may require the prior creation of an Account. In this case, you will be asked to provide a number of items of personal data when creating your Account, in particular your surname and first name, your postal address, your email address and your telephone number.

1.3 Payment

Some of the available Services may be chargeable. To this end, you agree that we may use external service providers who may collect personal data for the purpose of enabling the smooth operation of credit card payment processing services or any other means of payment and, where applicable, the delivery of products or services.

To pay for your purchase, you must provide your billing details as well as your payment details, including in particular your bank card number, expiry date, security code and cardholder's name in the event of payment by bank card.

You may also be asked to provide the name of your telecom operator, the model of your mobile phone and a valid mobile number in order to be able to provide purchase instructions directly through your mobile phone.

We retain the details of your payments, as well as the details of your purchases. Transaction details are retained either in our systems or with the external provider. This retention is carried out for internal purposes, including accounting, compliance and legal purposes, in accordance with paragraph 5 of this Privacy Policy.

1.4 Newsletter subscription

When creating your Account, you may give your prior consent to receive our newsletters regarding news, new products, services and promotions, within the framework of the Services.

You may also consent directly to receiving our newsletters by entering your email address in the spaces provided for this purpose on the Site.

In any event, you have the right to withdraw your consent to receive such newsletters at any time and at no cost.

1.5 Contacts

In order to follow up on requests you may make to our Customer Service and to confirm information about you, we may use your surname, first name, email address and telephone number.

2. How do we protect your personal data?

We have implemented technical and organisational security measures to guarantee the security, integrity and confidentiality of all your personal data, in order to prevent it from being distorted, damaged or accessed by unauthorised third parties. We ensure an appropriate level of security, taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risks and their probability.

However, it is specified that since no security measure is infallible, we are not in a position to guarantee absolute security of your personal data.

Furthermore, it is your responsibility to ensure the confidentiality of the password enabling you to access your Account. Do not share this information with anyone. If you share your computer, remember to log out before leaving a Service.

3. In what cases do we share your personal data?

3.1 Sharing your personal data with third-party companies

While browsing the Site, your personal data may be transmitted to external service providers. These third parties provide a service on our behalf and in our name for the purpose of enabling the smooth operation of credit card payments and other Services.

Personal data may be transferred to countries outside the European Union for the purpose of fulfilling your order.

In accordance with the GDPR, all transfers of personal data to a country outside the European Union and/or not offering a level of protection considered adequate by the European Commission have been subject to cross-border flow agreements complying with the standard contractual clauses issued by the European Commission.

Other transfers of personal data may be made to the United States and are governed by the E.U. – U.S. PRIVACY SHIELD: click here for more information.

Except where a third party asks you to accept a Privacy Policy and terms of use of their own, third-party companies that have received your personal data have undertaken to process your personal data solely for the implementation of our Services.

We will never, without having obtained your prior consent, share your personal data with third-party companies for marketing and/or commercial purposes.

3.2 Sharing with authorities

We may be required to disclose your personal data to administrative or judicial authorities where such disclosure is necessary for the identification, apprehension or prosecution of any individual likely to harm our rights, those of any other user or a third party. We may finally be legally required to disclose your personal data and cannot in this case oppose such disclosure.

4. How long do we retain your personal data?

We will retain your personal data for a period of 5 years. This period enables us to have time to process your order and handle return or refund requests beyond the period of the legal guarantee of conformity.

The legal basis justifying the processing is the user's consent or the performance of the sales contract.

5. Cookies: how do we use them?

5.1 What is a cookie?

A cookie is a text file that may be stored on a device when consulting an online service using browsing software. A cookie file enables its issuer, during its period of validity, to recognise the relevant device each time that device accesses digital content containing cookies from the same issuer.

In any event, cookies placed on your browsing device with your consent are destroyed 13 months after being placed on your device.

5.2 What are the cookies issued on our Site used for?

The cookies we issue enable us to:

• Compile statistics and volumes on the attendance and use of the various elements making up our Site (sections and content visited, browsing paths), enabling us to improve the interest and user-friendliness of the Site and, where applicable, our products and services;
• Adapt the presentation of our Site to your device's display preferences (language used, display resolution, operating system used, etc.) during your visits to our Site, depending on the hardware and viewing or reading software your device contains;
• Store information relating to a form you have filled in on our Site (registration or access to your account) or to products, services or information you have chosen on our Site (subscribed service, contents of a shopping basket, etc.);
• Enable you to access reserved and personal areas of our Site, such as your Account, using identifiers or data you may have previously entrusted to us and to implement security measures, for example when you are asked to log in again to content or a service after a certain period of time.

While browsing the Site, social network cookies may be generated in particular through sharing buttons which collect personal data.

On your first visit to the Site, a cookie banner will appear on the home page. A clickable link provides further information about the purpose and operation of cookies and redirects to this Privacy Policy. Continuing to browse another page of the site or selecting an element of the Site (in particular: image, text, link, etc.) constitutes your acceptance of the placement of the cookies referred to on your computer.

5.3 How can you control the cookies used?

You may at any time configure your browsing software so that cookies are stored on your device or, conversely, that they are rejected (either systematically or depending on their issuer). You may also configure your browsing software so that you are offered the option to accept or refuse cookies on an occasional basis, before a cookie can be stored on your device.

Please note: any settings change may modify your browsing on the Internet and your conditions of access to certain services requiring the use of cookies. We disclaim all liability regarding the consequences relating to the degraded operation of our services resulting from the impossibility of recording or consulting the cookies necessary for their operation which you have refused or deleted. This would be the case if you attempted to access our content or services which require you to identify yourself. This would also be the case when we (or our service providers) are unable to recognise, for technical compatibility purposes, the type of browser used by your device, its language and display settings or the country from which your device appears to be connected to the Internet.

5.4 How do you configure your browsing software?

For cookie management and your choices, the configuration of each browser is different. It is described in your browser's help menu, which will enable you to find out how to modify your preferences regarding cookies. Below you will find information regarding the main browsers.

Internet Explorer / Edge
In Internet Explorer, click on the Tools button, then on Internet Options. On the General tab, under Browsing history, click on Settings. Click on the View files button.

Firefox

• Go to the browser's Tools tab and select the Options menu
• In the window that appears, choose Privacy and click on Show cookies

Safari

• Access Settings via the browser menu (Safari > Preferences)
• Click on Privacy.

Google Chrome

• Access Settings via the button to the right of the URL bar or via the browser menu (Chrome > Preferences).
• Select Advanced Settings
• Click on Content Settings then on Cookies.

For more information about cookies, you can consult the CNIL website.

6. What are your rights?

You alone have communicated to us the data in our possession, through the Site. You have rights over your personal data. In accordance with personal data protection regulations, in particular Articles 15 to 22 of the GDPR, and after having proved your identity, you have the right to ask us for access to your personal data, its rectification or erasure.

Furthermore, within the limits set by law, you also have the right to object to processing, to restrict it, to decide the post-mortem fate of your data, to withdraw your consent at any time and the right to portability of the personal data provided.

You may contact our Data Protection Officer to exercise your rights at the following email address: contact@onyvora.com or at the following postal address: AGENCE ROBIN, 49 rue de Ponthieu, 75008 PARIS.

7. Can we modify the Privacy Policy?

We reserve the right to modify the Privacy Policy at any time. You are therefore advised to consult it regularly. In the event of modification, we will publish these changes on this page and in the places we deem appropriate depending on the subject and importance of the changes made.

Your use of the Site after any modification signifies your acceptance of those modifications. If you do not accept certain material changes made to this Privacy Policy, you must stop using the Site.

We remind you that you may contact the CNIL directly on the CNIL website or by post at the following address: Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy - TSA 80715, 75334 PARIS CEDEX 07.