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CUSTOMER PRIVACY POLICY

EFFECTIVE DATE: JANUARY 01, 2024

 

1. WHAT DOES THIS POLICY COVER? DO OTHER POLICIES APPLY TO YOU?

 

Our privacy policy (the “Privacy Policy”) has been established and is maintained by the company EJE DESIGN, (“EJE DESIGN” or “We”) SAS with capital of 10000€ registered with the RCS of Romans under number 934 424 763, whose registered office is located at 53 Grande Rue, 26000-Valence and whose intra-community VAT number is FR00000. It covers the situations in which We collect, access, process, use, store, communicate and transfer your personal data (the “Personal Data”). E

This Privacy Policy does not cover products or services you may use that are provided by other companies acting on their own behalf.

The Privacy Policy does not apply to services provided by other companies acting on their own behalf, such as franchisees or licensees, nor when You share information through the various social networks or on other online platforms owned and managed by companies other than EJE DESIGN. These companies have their own privacy policies.

 

2. WHAT SPECIAL CONDITIONS APPLY TO YOU DEPENDING ON YOUR COUNTRY OF RESIDENCE?

The collection, use and protection of your Personal Data is essential for the proper functioning of the site and to offer you a personalized experience and quality service. This approach is carried out in accordance with the applicable European data protection regulations and is also in accordance with consumer law where you have your country of habitual residence. This respect therefore allows us to better meet your expectations.

If you reside in a country outside the European Union, we invite you to consult our appendix 1 to find information specific to your country.

3. WHO COLLECTS AND USES YOUR PERSONAL DATA?

We act as Data Controller, which determines why and how your Personal Data is collected, used and protected.

In order to be able to offer our products and services, We need to collect Personal Data about You and share it if necessary with selected partners who act as our subcontractors. All our partners, just like Us, are required to implement appropriate security measures to protect the personal data in their possession. They are also bound by a confidentiality agreement which sets out how and when they are authorized to use your personal data on our behalf.

Some of our partners in the course of their work may also determine why and how your Personal Data is collected and used. They then have their own privacy policies and cookie policies. The Personal Data that you give them will be subject to their rules and not to these.

4. WHY DO WE COLLECT YOUR PERSONAL DATA?

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We will collect, record, hold, organize, store, adapt, interconnect, use, consult, perform statistical analyses, transfer and share the Personal Data collected for the purposes described below. Your Personal Data will not be used further for purposes incompatible with those for which it was collected. All processing of your Personal Data will be carried out in accordance with the privacy legislation applicable to You and will be based on the legal bases set out in this article.

  • Provide you with the products and services that you have purchased or requested

The Eje-Design.com Website (the “Website”) uses Personal Data to manage our relationship with You and to fulfill our obligations under the contract you enter into with Us when You purchase, or otherwise request, products or services from Us. This use may include, but is not limited to, processing your payment, delivering your ordered product, invoicing, internal company accounting, producing your personalized product, managing returns, etc. In order to provide You with the products or services you have ordered, XXX will collect, process, store, share and transfer your Personal Data. We inform You that some of the operations mentioned below, in particular the delivery or payment of your order, may be carried out by our partners. Your Personal Data may then be communicated to them and used by them so that they can carry out the task assigned to them.

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Purpose(s): Legal Basis: To provide you with the products and services that you have ordered, on our Website, and all the acts necessary for the execution of our obligations under the contract that You have concluded with Us, namely, without this list being exhaustive, the processing of your payment, the production of the said product or service, the delivery of the product or service, etc.) Execution of a contract

  • TO MANAGE YOUR PROFILE

You have the possibility to create and manage a customer account on the Website. To do this, a certain amount of Personal Data concerning You will be requested and will be collected by EJE Design. Once You have created your customer account, your Personal Data will be linked to it. This may be Personal Data that we have obtained from You, but also that we have obtained from other sources such as our distribution partners, our payment partners or our delivery partners and this in accordance with the applicable legislation. Data relating to Your orders and the tracking of their delivery will also be collected in your customer account. Your Personal Data is also necessary for Us to order products or services on our Website, to offer You a personalized and tailor-made experience, journey or products and in certain cases are necessary to access certain Products and Services. We draw your attention to the fact that we will use personal identification data such as your email address or telephone number to link an interaction or purchase to your customer account. Please note that we will use your date of birth to determine if you are old enough to use our services.

In order to keep your personal data accurate and up to date, you have the possibility to rectify them at any time via your customer area or please indicate to us by email at support@eje-design.com which of your data needs to be updated or corrected. Please be aware that this action may require us to correct typographical errors or inconsistent personal data.

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Purpose(s): Legal Basis: Creation, management and administration of your customer account. Performance of a contract and legitimate interest

 

  • TO PROVIDE YOU WITH PERSONALIZED CUSTOMER SERVICE AND SUPPORT.

In order to have a unified experience and regardless of the way we communicate with You, physical relationship in our stores or those of our partners or via the Website, by Chat, telephone or Video, EJE Design wants its customer service offered to You to be personalized and the most adapted to Your expectations. To this end, We will collect, process, analyze, use, store, communicate and transfer Your Personal Data in order to be able to identify You and thus provide You with the assistance You request or share relevant information with You. Please note that when You contact us, we keep the Personal Data that You shared with Us, the topics covered and the solutions that have been provided to You. This Personal Data will then be attached to your customer account if you have one or to a temporary file otherwise.

In order to improve the quality of Our services and products and to offer You the most appropriate response, we will collect, process, analyze, use, store, communicate and transfer Your Personal Data based on Your consent or rely on Our legitimate interest. In order to respond to Your requests when You contact Us, and this by whatever means, We will use Your Personal Data. Thus, We may ask You for Personal Data in order to Identify You in order to access Your customer account or Your temporary file to know the interactions We have had with You in the past and to provide You with an appropriate response to Your request. In the event that We are unable to identify You, please note that We may create a temporary file concerning You with the Personal Data that You share with Us in order to offer You the same purchasing experience. In the event that You do not wish to be in contact with Us, simply close the navigation window of the Chat on our Website.

 

Your Personal Data from your customer account or temporary file may be used by our employees to contact You directly about products that You have ordered or that You request in another way, or to share with You other information that You have requested from Us. Please be aware that the interactions that You have with Us may be subject to control in order to allow Us to improve the quality and security of our services.

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Legal Basis: Creation, management and administration of your customer account. Performance of a contract and legitimate interest Creation, management and administration of your temporary file Performance of pre-contractual measures or legitimate interest Inbound interaction with You in relation to products, services or information following Your request Performance of a contract, performance of pre-contractual measures Outbound interaction with You in relation to products, services or information following Your request Performance of a contract, performance of pre-contractual measures or legitimate interest Real-time interaction with You in relation to products, services or information following Your request Performance of a contract, performance of pre-contractual measures or legitimate interest Monitoring Our interactions with You to enable an improvement in the quality of our services Performance of a contract, performance of pre-contractual measures or legitimate interest Monitoring Our interactions with You in order to enable Us to provide You with the most appropriate response to Your request Performance of a contract, performance of pre-contractual measures pre-contractual or legitimate interest

  • TO SEND YOU NON-MARKETING COMMUNICATIONS.

We may send You Non-marketing communications at Your request or important in the context of Your Order or for the security of your personal data. Please be aware that even if You unsubscribe from our marketing communications or do not register, You will receive this information. These are sent for the proper performance of Our Contract or in order to comply with certain of our legal obligations. Non-marketing communications include, but are not limited to: When creating a customer account, sending an email to verify your identity; When forgetting your username or password to access your customer account, sending an email to reset your username or password; When ordering a product, all information emails relating to the order and its delivery; In the event that a service is suspended for maintenance; In the event of an upgrade, correction, or incident affecting our services that could involve your data; …

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Please note that we will never contact you to ask for your password or credit card number.

 

Purpose(s): Legal Basis: Management and administration of your customer account Execution of a contract Information on the stages of your order Execution of a contract Information on the life of your data Execution of a contract and compliance with a legal obligation

              

  • TO ENABLE YOU TO RECEIVE RELEVANT INFORMATION AND PERSONALIZED MARKETING CONTENT.

With your prior consent, we will send you information about us and news about our products, our services, our offers or events that we organize or participate in. This information may be local or international. Please note that to enable us to provide you with the most appropriate communication possible, we will use a portion of profiling based on your personal data, on the orders or requests that you have made, on the interactions that we have had with you and any other personal data that you have communicated to us and that are linked to your customer account or your temporary file. These communications may be made by mail, SMS, email or telephone.

Please note that You have the possibility to withdraw Your consent to receive our promotional communications at any time by going to your customer area or by sending us an email to the following address xxx@xxx.com. In order to enrich Your Personal Data, please note that We may use Cookies and/or other online advertising technologies. Thanks to these technologies, We will collect Personal Data related to Your activity on our Website or on other Internet Sites. Thus, We will be able to know for example if after having received a newsletter or a promotional offer, You visited our Website. The use of cookies or other online advertising technologies may be contextual, meaning that they are displayed based on the web page you are visiting, or behavioral, meaning that the advertising that appears is based on your interests that we have deduced from the Personal Data that You have shared with Us. Please note that We may use these technologies to display to You, if You consent, Products or Services that are most relevant to You. In the event that You no longer wish to see personalized advertising, You can change your cookie preferences or delete them from your browser.

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Purpose(s): Legal Basis: Sending and presenting personalized communications in the context of ordering a Product. Execution of a contract Sending and presenting personalized communications of promotional offers of Products or Services Legitimate interest Updating Your Personal Data Execution of a contract or Compliance with a legal obligation Presentation of contextual or behavioral advertising Consent

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  • TO CARRY OUT OUR BUSINESS SAFELY AND PROTECT OUR ACTIVITIES AND OUR STAFF.

As part of our anti-fraud process, we implement a set of procedures, as part of the execution of the contract and in order to comply with some of our legal obligations, in order to deliver Our Products to you safely, and to protect Our legitimate interests. Thus, We may be required in particular to implement review and evaluation measures in order to ensure that You comply with our General Conditions. These measures may lead Us to take note of a proven or suspected non-compliance with Our General Conditions or fraud and therefore cancel an order placed.

We also implement administrative and technical measures to protect Our Website, Our computer systems, Our networks, transactions and any other means to protect the Personal Data that We collect, use or store. Thus, We may be required to verify your identity in order not to share Your Personal Data with an unauthorized third party. FOR EXAMPLE, WHEN YOU PURCHASE A PRODUCT, YOUR PERSONAL DATA IS ASSOCIATED WITH A UNIQUE CODE, PLACED IN AND/OR PRINTED ON THIS PRODUCT, SO THAT, BY READING THIS UNIQUE CODE, WE CAN RECOGNIZE THE ORDER AS YOURS, WHICH WILL ALLOW US TO EVALUATE YOUR COMPLIANCE WITH OUR GENERAL CONDITIONS OR TO DETECT A POSSIBLE FRAUD ON YOUR PART AND TO TAKE COERCIVE AND/OR DISCIPLINARY MEASURES AGAINST YOU IN THE EVENT OF NON-COMPLIANCE OR FRAUD, SUSPECTED OR PROVEN, ON YOUR PART.

Please be aware that in order to defend Our Rights and Property, Our employees, or even Our business partners, We could implement certain measures in compliance with laws and regulations. Thus, please be aware that We have set up a procedure to combat malicious calls so that any inappropriate behavior, harassment, insult or threat systematically results in the sending of a warning to the user concerned and their registration on a provisional monitoring list. In the event of a repeat offense, the user will receive a second warning which will prohibit them from calling Us and making any order or request for 6 months. Only contact by email will then be authorized with said user in order to preserve their rights.

 

Purpose(s): Legal Basis: Delivery of orders Execution of a contract or Compliance with a legal obligation Implement cybersecurity and physical security measures Execution of a contract or Compliance with a legal obligation Implement fraud prevention, detection and investigation measures Execution of a contract or Compliance with a legal obligation Implement activities related to business compliance Compliance with a legal obligation or Legitimate interest Implement related to the protection of intellectual property and litigation management Compliance with a legal obligation or Legitimate interest

  • TO EVALUATE AND BETTER UNDERSTAND OUR ACTIVITY.

In order to fulfill our legal obligations and our contract with You, We may be required to access and use some of Your Personal Data for legal, financial or management purposes related to business analysis or market research. Thus, for example, as part of the analysis of the characteristics of our customers, we could access and use our invoices issued in connection with Your purchases and Your other Personal Data such as your age, your geographical location, your gender, etc. Similarly, Your Personal Data may be involved in some of our internal procedures such as accounting, inventory management, internal or external audit, financial control.

Please note that We may also be required, on the basis of a customer satisfaction survey or questionnaire, to access Your existing Personal Data or to obtain new Personal Data concerning You as part of a market study, analysis of Our activity or the impact of Our marketing or communication campaigns.

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Purpose(s): Legal Basis: Performance of activities related to the contract Performance of a contract or Compliance with a legal obligation Performance of market research and analysis activities related to our business Performance of a contract or Legitimate Interest Share the necessary information with our auditors, lawyers, service providers. Compliance with a legal obligation or Legitimate Interest

              

  • TO OPTIMIZE AND MANAGE OUR WEBSITE AND OTHER MEANS OF COMMUNICATION.

In order to administer, optimize, secure or improve Our means of communication of Our mobile application, or Our Website, We may be required to take certain measures involving Your Personal Data. Please be aware that in the case of use of cookies or other online advertising technologies, We systematically ensure that We have obtained Your prior consent before collecting, accessing or using all or part of Your Personal Data. We may also use this personal data to correct operational problems with our Website or our application. For this, We may be required to use cookies or other online advertising technologies.

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Purpose(s): Legal Basis: Analysis and correction of technical problems of the Website or the application Execution of a contract or Consent and Legitimate Interest Analysis of the use of our means of communication Execution of a contract or Consent and Legitimate Interest

5. WHAT PERSONAL DATA DO WE COLLECT?

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Foreword: If you reside in California, We invite You to consult Appendix 1 of this document. Please be aware that We strive to collect and use only the data necessary to properly carry out the processing purposes stated. The lists below are provided to You in order to give You an overview of the type of data concerned.

  • CUSTOMER ACCOUNT IDENTIFIERS & INFORMATION

We inform you that the creation of Your customer account is mandatory to place orders on Our Website. The information collected in this context allows Us to identify You, to administer your customer account, to allow the proper execution of the contract and to provide You with customer service related to Your orders or requests. This Personal Data includes, Your title, Your Name, Your First name, Your Pseudonym, Your email address, Your login ID, Your IP address, Your date and place of birth, Your postal address, Your Country of residence, Your telephone number, Your customer number, Your lifestyle.

Please note that in some countries, certain Personal Data may be considered sensitive under applicable legislation. We will only collect and use this data when there is no other possible option but always in compliance with applicable legislation.

  • TRANSACTION DATA & BUSINESS INFORMATION

The information collected in this context allows Us to provide You with the products and services You have requested from Us, to manage Your customer account, to execute the contract binding Us, to provide You with customer service, to secure Our communications and to better understand Our business. This Personal Data includes data on the Products You have ordered or requested, their price, sizes and characteristics, on the time at which the Product was ordered, if a return has taken place when possible, on the comments You have made on the Product or customer service, Your purchase history, Your Customer History, the interactions We have had with You. Some data will be linked to your transaction and become Personal Data. This is the case, for example, of the reference number of the Product ordered, the certificate of authenticity number, or the delivery number of the Product. This information allows Us to fight against fraud and to provide You with information that You may request on the product.

  • INFORMATION AND DEDUCTIONS ON PERSONAL LIFE

In order to offer You an optimal set of services, We may use a set of data from Your profile of Your customer account. The collection or use of this data is however not systematic. This Personal Data includes the people to whom You send invitations, your lifestyle habits, the use of Our Website, Your responses to Our satisfaction surveys and any other data that We may collect on You directly or indirectly, by deduction or from the data above.

  • USER GENERATED CONTENT

The information collected in this context allows Us to better understand your opinion or satisfaction following an order or the performance of a service. This Personal Data includes the opinions and comments that You may send Us, and the nature and type of interactions that We have had with You.

  • TECHNICAL, ELECTRONIC AND LOCATION INFORMATION

The information collected in this context allows Us to carry out the requested service, provide a personalized offer, carry out appropriate communication, enable the security of Our activity, evaluate and deepen the knowledge of Our activity and manage and improve Our Website or Our various means of communication. This Personal Data includes knowledge of the means of communication that You use to contact Us or the use that You make of our various means of communication. Thus, certain data is automatically shared with Us by the device or service provider that You use. Please note that some of this data is collected using cookies or other online advertising technologies. This Personal Data includes Your IP address, the type of device that You use, the geographic location of Your connection, Your browsing history, search history for interaction with other websites or any other technical personal data shared by the service provider.

6. WHEN DO WE COLLECT YOUR PERSONAL DATA?

In addition to the collection of Your Personal Data set out in point 5 of this document, We also collect Personal Data when You interact with Us. This is the case when You subscribe to Our newsletter, request advice via Our Website, by telephone or from our business partners.

7. WHAT ARE OUR THIRD PARTY SOURCES?

We obtain Your Personal Data primarily directly from You and this directly from Us or from third parties such as our business partners. Indirectly, We may obtain Personal Data about You through Our partners in the organization of an event, Our service providers who provide a service on Our behalf, Our technology partners and suppliers, public authorities and government entities.

8. DO YOU ALWAYS HAVE TO SHARE ALL YOUR PERSONAL DATA WITH US?

Mandatory Personal Data is clearly identified as such on our Website. If You do not wish to provide Us with certain other Personal Data, You may simply not provide it to Us. Please be aware, however, that if You choose to do so, You may not be able to benefit from certain services.

In the case of certain legal requirements, We may be required to ask You to provide Us with additional Personal Data. In this case, We will specify whether this data is mandatory for the continuation of Your Order or Our relationship or not.

9. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?

In accordance with current legislation, We only keep Your Personal Data for the necessary time, i.e. concerning your customer account or temporary file, 5 years from the last interaction that You initiated with Us and traceable in Our systems.

Please note that before proceeding with the deletion of Your Personal Data linked to Your Customer Account or Your temporary file, We will contact You by email to inform You of said deletion. You will then have the possibility to ask Us to keep Your Personal Data. In the event that You do not respond, the deletion of all Your Personal Data that We are not required to keep for longer in order to comply with Our legal, tax or accounting obligations, will be carried out. We will destroy them in such a way that it is no longer possible to read, restore or recover them.

10. HOW DO WE PROTECT YOUR PERSONAL DATA?

Aware of the importance of Your Personal Data to You and Us, We have implemented a system to ensure their confidentiality as best as possible. We have implemented specific technical and organizational measures in accordance with the legislation applicable in this case, in order to protect Your data against any destruction, loss or illicit or accidental alteration, unauthorized access or disclosure. Thus, for example, We implement the secure http protocol ("HTTPS") to protect Your connection to Our Website, We ensure that Your data is encrypted between your device and Our servers by implementing the Secure Sockets Layer ("SSL") protocol and/or other security methods and all the personal data that we collect is stored on secure servers. We have also set up training for Our employees to mobilize them on the importance of protecting personal data, contractual obligations towards our partners and subcontractors and an organization that strictly controls the scope of the authorization of those of Our employees or partners who have access to the personal data that we collect and process. Thus, We only give access to Your Personal Data or communicate them to those of our employees and partners who strictly need to know them.

Please be aware that to maintain the security of Your Personal Data, We may occasionally need to reset your password.

Please be aware, however, that no service can be 100% secure. In order for Your Personal Data to be protected as best as possible, it is important that You are aware of the essential role You play by protecting, for example, your devices with anti-virus, firewalls or anti-spam software. Thus, You accept the security consequences inherent in interactions on the Internet and You will not hold Us or our partners responsible in the event of a security incident or breach of personal data unless said incident or breach is due to Our negligence.

11. WHERE DO WE TRANSFER AND STORE YOUR PERSONAL DATA?

Due to Our international presence, We may transfer Your Personal Data worldwide. Please be aware, however, that Our servers are located in Europe.

Please be aware that when We use, share or transfer personal data outside the country in which the data was collected or stored, We will put in place appropriate measures to make the transfer legitimate under applicable data protection legislation, such as obtaining Your consent or implementing contractual guarantees.

12. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

  • RETAILERS (INCLUDING ONLINE), RESELLERS, FRANCHISEES, LICENSEES, DELIVERY SERVICE PROVIDERS, FULFILMENT COMPANIES AND TRANSACTION PARTNERS

These are the partners who allow Us to offer You the products and services that You request, such as allowing You to make the payment for Your order or allowing Us to deliver the Product(s) ordered on our Website to You. Please note that our privacy policy does not apply to the processing activities carried out by these partners because they act on their own behalf for the provision of their service. In the case of retailers for example or franchisees, they may also intervene in the creation or management of your customer account by collecting Your Personal Data and your consent from You when You make a purchase from them.

  • APPROVED PARTNERS ACTING AS SERVICE PROVIDERS

All of Our approved partners are subject to appropriate security obligations in order to protect confidential information, including potentially Your Personal Data, and contractual guidelines specifying when and how they are authorized to collect and/or use Your Personal Data.

  • MARKETING SERVICE PROVIDERS, ADVERTISING PROVIDERS, COMMUNICATION SERVICE PROVIDERS (E-MAIL, SMS, MMS)

Intervening in the management of Your customer profile, these service providers help Us to provide You with relevant and personalized content. This may involve non-marketing communications linked to Your order or request, or marketing communications based for example on Your previous purchases or on Your requests.

  • IT SERVICE PROVIDERS

Intervening throughout the process in the management of Your customer account, Your order or Your request, these service providers allow Us to:

  • To optimize, manage and maintain operational and available Our Website;

  • To collect, use and store Your Personal Data when creating Your customer account and/or Your orders;

  • To allow you to interact with Us for any request;

  • To send you relevant information related to your Order or marketing;

  • To allow you to make purchases securely;

  • To allow us to track the processing of your order or request;

  • To best assess Our activity;

  • etc..

  • LAW ENFORCEMENT AUTHORITY, REGULATORY BODY, GOVERNMENT AGENCY, COURT, LAWYERS

In order to comply with current regulations or to enforce Our rights, We may be required to communicate Your Personal Data.

13. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

Subject to certain conditions, you may exercise your rights under applicable data protection legislation as follows:

  • If you wish to access, rectify, update or request deletion of your personal information. You can object to the processing of your personal information when such processing is based on legitimate interests, ask us to limit the processing of your personal information or request the portability of your personal information.

  • If we have collected and processed your personal information with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on a legal basis other than consent.

We respond to all requests we receive from users in accordance with applicable data protection laws. We may ask you to provide proof of identity before we can respond to the above requests. In some cases, we may reject requests for certain reasons (for example, if the request is unlawful or if it may infringe on trade secrets or another person's intellectual property or privacy).

To exercise rights on behalf of a deceased person, We will ask You to provide Us with proof that You are a close family member or executor of the deceased person's will.

You have the right to lodge a complaint with your local supervisory authority if you consider that the processing of your personal data does not comply with the regulations in force.

14. WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE?

Please see our Cookie Policy for more information on the cookies we use, why we use them, and how you can better control their use through your browser and other tools.

15. CAN THE PRIVACY POLICY BE MODIFIED?

We reserve the right to amend this notice from time to time. If we make any changes, the updated notice will be posted with a revised effective date.

We may also inform you if there are any significant changes. If required by law, we may at that time ask you for consent to these changes.

16. HOW TO CONTACT US?

For any questions regarding our data protection policy or to exercise your rights, you can contact us by email at the following address support.rgpd@eje-design.com.

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