Welcome Originals: Privacy Policy

Version dated April 30, 2020

We invite you to read this document carefully (hereinafter, the “Privacy Policy”). For any question concerning this document and, in general, about the collection and processing of your personal data by the company Coruscant, do not hesitate to contact us by e-mail: privacy@wttj.co

1. Preamble and scope

Coruscant is concerned with protection and the confidentiality of your personal data and attaches great importance to the protection of the privacy of the users of its services.

The purpose of this Privacy Policy is to define the rules applicable to the collection and processing of your personal data (hereinafter one or “Personal Data (s)”) via the WELCOME ORIGINALS application and/or the dedicated website www.welcomeoriginals.com (hereinafter together the “WELCOME ORIGINALS Platform”).

A Personal Data is defined as any information relating to a natural person who can be identified, directly or indirectly, such as the names, first names, email and postal addresses of a natural person, his image on a photograph or a video, an IP address, a geolocation data, etc.

The Privacy Policy details the Personal Data that we collect and process within the framework of the WELCOME ORIGINALS Platform, the reasons for the processing of your Personal Data, the way in which we use it and the features offered to allow you to access and update your Personal Data.

The Privacy Policy is an integral part of the General Terms of Use and Sale of the WELCOME ORIGINALS application. It applies to all Users of the WELCOME ORIGINALS application and of the website www.welcomeoriginals.com

Our Privacy Policy does not apply to services, pages and content edited, disseminated and/or made available on the WELCOME ORIGINALS Platform by third-party companies, and in particular the APPLE or GOOGLE PLAY payment solutions that may be chosen by the User to access to paid contents or subscribe. CORUSCANT is not responsible for the processing of Personal Data that may result from the use of such third-party’s services; we invite you to contact the publisher of these services, pages and contents to find out the rules applicable to the processing of your Personal Data and, if necessary, exercise your rights in this respect. For APPLE: here; for GOOGLE: here

2. Acceptance and updating of the Privacy Policy

By checking online the box "I have read and accept the Privacy Policy of Welcome Originals", you (as a User) confirm that you have read and accept without restriction or reservation these Privacy Policy. If you disagree with any of its terms, you are free not to or no longer use our services (if the terms of the Policy are changed).

The Privacy Policy may be subject to change, it being specified that any reduction in your rights cannot be applied without your consent. Also, we will publish the new versions of the Privacy Policy on the WELCOME ORIGINALS Platform, and we will alert you by means of an email offering you the possibility of consulting them as well as by an in-app message.

In general, the Privacy Policy is always easily accessible on the WELCOME ORIGINALS Platform.

3. Data controller

The processing of Personal Data of Users of the WELCOME ORIGINALS Platform is subject to French law, in particular to Law No. 78-17 of January 6, 1978 relating to data processing, files and freedoms, as amended (“French Data Protection Act”), and to the EU General Regulation No. 2016/479 on the protection of personal data (“GDPR”).

The “data controller” of the Personal Data collected and processed by or through the WELCOME ORIGINALS Platform, within the meaning of the French Data Protection Act and the GDPR, is the French company Coruscant (registered with the trade registry of Paris under n°802 162 628) and located: 24 rue du mail - 75002 Paris - France.

In this capacity, we undertake, within the framework of our activities and for the processes which are carried out by us, to respect the provisions of the French Data Protection Act and the GDPR, and to carry out lawful, fair and transparent processing of your Personal Data, and in particular to: carry out data processing for specific, explicit and legitimate purposes, without being further processed in a manner incompatible with these purposes, for a period which does not exceed the duration necessary for the purposes for which they are collected and processed.

4. Categories of Personal Data collected and processed by Coruscant via the WELCOME ORIGINALS Platform

a) Personal data that you communicate to Coruscant

We collect the Personal Data of Users using the WELCOME ORIGINALS Platform to give them access to the services, pages and content of the WELCOME ORIGINALS application and/or website, and to allow them to use said services, pages and content, where applicable for a paid subscription.

Access and use of the WELCOME ORIGINALS application involves the collection and processing of your last name, first name, e-mail addresses, and connection data (IP address) and information relating to your mobile device (model and operating system version).

In the context of the use of the WELCOME ORIGINALS Platform, Users are also required to communicate other information such as the pages and contents they view.

b) Cookies

A “cookie” (or “tracer”) is an electronic connection device which designates a text file likely to be saved in a dedicated space on the hard drive of your terminal (computer, tablet or smartphone), when consulting an online service or page. A cookie allows its issuer to identify the terminal in which it is registered, during the period of validity or registration of the cookie. The cookie therefore does not identify you as such; it is used to record your browsing information on the WELCOME ORIGINALS website.

5. Conditions of Use of Personal Data

a) Purposes of collecting and processing your Personal Data

Personal Data of Users is collected and processed for defined and precise purposes, such as: (i) Providing and managing access to the WELCOME ORIGINALS Platform and its functionalities and services; (ii) Communicate with Users and improve the quality of our services, namely answering your questions and keeping you informed of our new contents and services; (iii) Fight against online fraud; and (iv) Resolve any possible dispute or resolve any problem in connection with the use of our services.

b) Retention period of your Personal Data

We undertake to keep your Personal Data only for the period strictly necessary for the processing (s) declared for the aforementioned purposes, and therefore for the entire period during which you are a User of the WELCOME ORIGINALS Platform and an additional period of 12 (twelve) months in order to meet our legal, accounting and tax obligations and in particular, to prevent possible unlawful behavior after the deletion of your personal account (reuse of your old account by a third party) and to respond to possible judicial requisitions. In this case, your data will be deactivated and will no longer be accessible online.

In any event, we undertake to erase your Personal Data from our databases at the end of these periods.

6. Sharing informations with third parties

a) Lack of communication to the third party

We undertake not to disclose, nor to assign or sell to third parties the information and Personal Data that you communicate to us, with the exception of communications necessary for the use of our services, and in particular for the payment of the contents made available. available for a fee on the WELCOME ORIGINALS Application.

b) Communication for external treatment needs

Your information and Personal Data may, if necessary, be transmitted to third-party subcontractors involved in the provision of our services (technical and hosting providers, customer follow-up and satisfaction surveys, management of security incidents or fraudulent activity , statistics, etc.).

The company Coruscant undertakes to communicate your information and Personal Data only to authorized and trusted service providers, who process it on our behalf, according to our instructions and in accordance with these Confidentiality Rules and in compliance with any other appropriate measure. security and privacy.

c) Communication legal reasons

In addition, your information and Personal Data may be disclosed to a third party if Coruscant is required to do so by law, regulatory provision, or court order, or if this disclosure is made necessary for the purposes of an investigation, injunction or legal proceedings, on national territory or abroad.

Similarly, we may be required to share your information and Personal Data with companies, advisers or third parties in order to:

  • Enforce the Privacy Policy and the General Conditions of Sale and Use of the WELCOME ORIGINALS application in force, including to note any breaches thereof, obtain payment or combat counterfeiting;
  • Guard against any infringement of the rights, property or security of the Coruscant company and its users, in application and in compliance with the law.

7. Security of Personal Data

We implement all the necessary security measures to protect your Personal Data against any unauthorized access and any unauthorized disclosure, modification, damage or destruction of the data that we hold.

To this end, Coruscant and its technical and hosting providers have deployed appropriate measures to ensure the integrity, confidentiality and security of your Personal Data. However, we cannot guarantee that your communications and other Personal Data will not be intercepted or disclosed by a third party.

Finally, we inform you that your Personal Data is stored by AMAZON WEB SERVICES on servers located in the European Union.

8**. Respect for the rights of Users of the WELCOME ORIGINALS Platform**

You have a right of access (ex: check the data concerning you that we keep), a right of rectification (update or correct your data), and a right of deletion (ex: closure of your personal account) of your Personal Data, as well as a right of opposition to the collection and processing of all or part thereof for the purposes of commercial prospecting, including profiling insofar as it is linked to such prospecting.

In addition, it should be noted that these rights offer you the possibility of modifying your notification preferences at any time, by accepting or refusing that your Personal Data be used within the framework of our marketing or promotional actions.

You also have a right to the portability of your Personal Data.

You can exercise these rights at any time:

  • By writing to the address mentioned in section 3 above,
  • By sending an email to: privacy@wttj.co

If you exercise these rights, we endeavor to respond to your requests within 30 days, if necessary renewable.

You can also obtain information on your rights on the CNIL (FRench Data Protection Authority) website: www.cnil.fr