Confidentiality Charter

Who are we?

The TROPHY company, registered with the Versailles Trade and Companies Register under number 538 081 860, having its registered office at 1, Avenue Eiffel, 78420 Carrières-sur-Seine, is responsible for processing your personal data for the purposes listed in the table below.

TROPHY has appointed a Data Protection Officer (the law firm Ernst & Young) who can be contacted by email dpo@trophy-group.com or by post at the following address: SHARK HELMETS - DPO, 110, Route de la Valentine, 13011 Marseille.

Purposes & Legal basis

1. Purposes: Contact request management
   Legal basis: Our legitimate interest (responding to your requests and getting to know you better)
2. Purposes: User account access management (secure access)
   Legal basis: Our legitimate interest (ensure the security of the E-Protect-Air website and application)
3. Purposes: Management of INFINITY Offers, REFLEX Offers.
   Legal basis: The performance of the contract between us or our legitimate interest (providing adequate customer service) for data that would exceed what is strictly necessary for the performance of contractual obligations
4. Purposes: Management of connected airbag Service and the E-Protect Application
   Legal basis: The performance of the contract between us or our legitimate interest (providing adequate customer service) for data that would exceed what is strictly necessary for the performance of contractual obligations
5. Purposes: Management of the Stop & Go option
   Legal basis: The performance of the contract between us
6. Purposes: Airbag Gilet inspection
   Legal basis: The performance of the contract between us
7. Purposes: Management of withdrawals
   Legal basis: Compliance with regulatory obligations
8. Purposes: Geolocation
   Legal basis: Your consent. If you do not consent to this processing, we will not be able to provide the connected airbag service.
9. Purposes: Management of legal warranties of conformity and hidden defects
   Legal basis: Compliance with regulatory obligations
10. Purposes: Management of after-sales service and complaints
    Legal basis: The performance of the contract between us or our legitimate interest (improving our offers and customer experience) for data that would exceed what is strictly necessary for the performance of contractual obligations
11. Purposes: Measuring traffic on the online sales site
    Legal basis: Our legitimate interest (to manage and boost visits to our site) or your consent if required by law (depending on the type of cookie)
12. Purposes: Follow up on areas of interest via cookies
    Legal basis: Your consent
13. Purposes: Sales prospecting activities
    Legal basis: Our legitimate interest (to promote our offers) or your consent if required by law
14. Purposes: Management of a loyalty program and promotional operations (promotional games)
    Legal basis: The performance of the contract between us or our legitimate interest (promote our offers) for data that would exceed what is strictly necessary for the performance of contractual obligations
15. Purposes: Statistical data processing
    Legal basis: Our legitimate interest (improve our offers)
16. Purposes: Management of customer reviews and satisfaction surveys
    Legal basis: Our legitimate interest (promote and improve our offers)

What data do we process?

TROPHY processes the following categories of personal data: identification data (airbag Gilet serial number, surname, first name, contact details, telephone number, etc.), data relating to the condition of the airbag Gilet (batteries, cartridge, etc.), data relating to your interests, as well as data relating to contracts and payments.

TROPHY collects information that is essential for the purposes described above. This information is marked with an asterisk on the form. If you do not fill in these mandatory fields, TROPHY will not be able to provide you with the relevant Service.

Personal data is collected directly by TROPHY from the persons concerned, or may have been transmitted to us by our commercial partners.

Who can access your personal data?

Your personal data is mainly communicated/accessible to TROPHY personnel in charge of sales and marketing, information systems security and the Heads of Finance and Legal affairs.

Outside TROPHY, your data will be shared with:

• TROPHY's IT service providers (in charge of maintenance and IT hosting)
  
• Sub-contractors involved in payment management
• Companies who are part of the same group as TROPHY (2-RIDE Group)
• Auditors involved in certification and/or labeling processes

Subcontractors acting on TROPHY's instructions will be required to implement appropriate protection measures.

If any of TROPHY's partners are located outside of the European Union, we will ensure that transfers are carried out in accordance with French regulatory requirements (e.g. implementation of contractual clauses adopted by the European Commission). You can contact TROPHY's Data Protection Officer to obtain further information on these subjects and a copy of the relevant documents.

How long do we keep your private data?

Personal data processed by TROPHY is stored in accordance with data protection regulations and for the legally prescribed periods. For example, data relating to prospective customers is kept for 3 years from the last commercial contact;

What are your rights?

• You have the right to request access to your personal data.
• You have the right to ask for your personal data to be corrected.
• You have the right to request that we restrict the processing of your personal data, (i) if you dispute the accuracy of your data for the period of time necessary for us to verify its accuracy, (ii) if you consider that we are processing your data unlawfully and you request that we restrict its use rather than delete it, (iii) if we no longer need your data for the purposes mentioned above, but it is still required for the establishment, exercise or defense of your legal rights, (iv) if you exercise your right to object to our processing of your data, for the duration of the verification as to whether the legitimate reasons we are pursuing prevail over yours.
• You have the right to ask us to delete your personal data.
• You have the right to exercise your right to object to the processing of your personal data for reasons relating to your personal situation.
• You have the right to object, at any time and without justification, to commercial prospecting.
• You have the right not to be subject to a decision based exclusively on automated processing that has produced legal effects concerning you or significantly affecting you.
• You have the right to exercise your right to data portability, which gives you the right to obtain a copy of your data or transfer it to a third party in a structured and commonly used machine-readable format.
• You have the right to withdraw your consent at any time where the processing of your data is based on that consent.
• You also have the right to formulate directives concerning the conservation, deletion and disclosure of your personal data after your death.

These rights may be exercised at any time by sending an e-mail to dpo@trophy-group.com or by post to the following address: SHARK HELMETS - DPO, 110, Route de la Valentine, 13011 Marseille.
You may also - if you wish - lodge a complaint with the French Data Protection Authority – la Commission Nationale de l'Informatique et des Libertés (CNIL). Further information is available on its website www.cnil.fr.