Privacy Policy

Definitions

• The “Publisher” : means the legal entity that publishes the Pacomail service, here Leikir Web.
• “Sites”: refers to the Internet site accessible at the address www.pacomail.io, for the Web Application from the address app.pacomail.io, as well as all of their sub-domains, all of its elements and content (graphic charter, frames, banners, images, web and video animations, source code, etc).
• “Solution” means all the technology developed and Services offered by Pacomail via the Web Application.
• “User”: means any person using the Website and the Solution.

Type of data collected

In the course of using the Sites, the Publisher may collect the following categories of data about its Users:

• Identification data: name, first name, e-mail address, etc.
• Billing and/or payment data: bank details, means of payment, invoices, etc.
• Usage data: services subscribed to, products used, consumption, communications, etc.
• User relationship monitoring data: support requests, correspondence with the User, etc.

Use of collected data

The Publisher uses the data for the purpose of performing and managing the contract. This includes the management of the User’s account and contractual relationship, installation, maintenance, provision and management of the subscribed service, provision of assistance, processing of requests, billing of the service, management of claims and disputes and collection procedures. Data may also be transferred to third party service providers who provide services or assistance and advice to the Publisher. The subcontractors and partners of the Editor may be located outside the European Union. Where such processor or partner is located in a country that has not been recognized as providing an adequate level of protection, the Publisher shall require such processor or partner to comply with its security and confidentiality requirements for personal data and to process such data only for the purposes it has determined. Such subcontractors and partners will have previously signed the European Commission’s Standard Contractual Clauses.

Upon request, data may also be transferred to persons and authorities whose right of access to personal data is recognized by law, regulations or provisions emanating from authorities empowered by law.

The Publisher may also use the data where it has a legitimate interest. The data will be used to evaluate and improve its services and to develop new ones, as well as to carry out loyalty, prospecting, survey and promotion actions. With the express agreement of the User, the Editor may communicate by email commercial information for services complementary to those already provided.
This data will be kept for the time necessary to achieve these purposes and for a maximum period of three years from the end of the contractual relationship concerning direct marketing.

Cookies

In accordance with the recommendations of the CNIL, the maximum duration of conservation of cookies is 13 months after their first deposit in the terminal of the User, as well as the duration of the validity of the consent of the User to the use of these cookies. The lifetime of cookies is not extended with each visit. The User’s consent must therefore be renewed at the end of this period.

Cookies may be used for statistical purposes, in particular to optimize the services rendered to the User, based on the processing of information concerning the frequency of access, the personalization of the pages as well as the operations performed and the information consulted.
The Editor may place cookies on the User’s terminal. The cookie records information relating to the navigation on the service (the pages consulted, the date and time of the consultation…) that the Editor will be able to read during subsequent visits.

Right to access and rectify personal data

The User may at any time access his data, rectify them, request their deletion, oppose their processing for legitimate reasons due to a particular situation by sending an email to the following address: dpo@pacomail.io. By sending an email to the same address, the User can also define directives concerning the fate of personal data after his/her death. Depending on the nature of the request, proof of identity may be required.
Data that Pacomail needs for the purpose for which it was collected, that is necessary to comply with a legal obligation and/or to establish, exercise or defend legal claims may not be deleted.

The User may contact the Data Protection Officer for questions relating to the protection of personal data at the following address: dpo@pacomail.io. In case of complaint to which the Editor would not have given a satisfactory answer, the User can contact the Commission Nationale de l’Informatique et des Libertés (CNIL) in charge of the respect of the obligations as regards personal data.

Technical data retention

The technical data are kept for the time strictly necessary to achieve the purposes mentioned above.

Retention period for personal data and anonymization

Means of data purging are put in place in order to provide for the effective deletion of data as soon as the period of conservation or archiving necessary for the achievement of the determined or imposed purposes is reached. In accordance with the law n°78-17 of January 6, 1978 relating to data processing, files and freedoms, the User also has a right of deletion on his data that he can exercise at any time by contacting the Editor.
For security reasons, if the User is not authenticated on the Sites for a period of three years, the User will receive an e-mail inviting him to log in as soon as possible, otherwise the data will be deleted from the databases.
User may delete his or her Account at any time by simply requesting the Publisher to do so or by using the Account deletion menu in the Account settings, if applicable.
In the event of a breach of any provision(s) of the T&C or any other document incorporated herein by reference, the Publisher reserves the right to terminate or restrict, without prior notice and at its sole discretion, the offending User’s use and access to the Services.

Data security

The Editor implements the necessary actions to protect the personal data it processes and rigorously selects its partners and service providers who may have access to the data. Data is processed electronically and/or manually and in any case in such a way that its security, protection and confidentiality are ensured with regard to its level of sensitivity, through administrative, technical and physical measures to prevent loss, theft, unauthorized use, disclosure or modification.

Indications in case of a security breach detected by the Editor

The Editor undertakes to implement all appropriate technical and organizational measures to ensure a level of security appropriate to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of personal data. In the event that the Editor would have knowledge of an illegal access to the personal data concerning the User stored on its servers or those of its providers, or of an unauthorized access resulting in the realization of the risks identified above, the Editor undertakes to :

Notify the incident to the impacted Users as soon as possible.
Examine the causes of the incident and inform the impacted Users.
Take reasonable steps to mitigate any adverse effects and damages that may result from such incident.

Under no circumstances may the commitments defined in the above point concerning notification in the event of a security breach be assimilated to any recognition of fault or responsibility for the occurrence of the incident in question.

Changes to the privacy policy

In the event that this Privacy Policy is modified, the Publisher undertakes not to lower the level of privacy substantially without prior notice to Users.