The information and personal data collected through the website http://www.seven-hugs.com/ and/or through the use of the products and/or services provided by 7HUGS LABS aim at (i) allowing orders to be placed, processed and delivered, (ii) providing the products and/or services in accordance with their purpose, and (iii) improving the quality of 7HUGS LABS’ products and/or services in order to better meet Users’ expectations.
In accordance with the Data Privacy Act of January 6, 1978 (as modified in 2004), the automated processing of personal data has been declared by 7HUGS LABS to the “Commission Nationale Informatique et Liberté (CNIL)” and recorded under number 1899230.
1. Information and personal data collected
The processing of orders by 7HUGS LABS and the use of 7HUGS LABS’ website and/or products and/or services may result in the collection by 7HUGS LABS of the following information and personal data:
- User’s first and last names, age or date of birth and picture;
- First and last names, age or date of birth and picture of members of User’s family/home;
- User’s residence and email addresses (and billing address, if different from residence address);
- Password and other information enabling 7HUGS LABS to check User’s identity when using the products and/or services.
- Presence/absence of members of User’s family/home in a room;
- Phases of sleep of members of User’s family/home.
Home environment information:
- Temperature and humidity in User’s home;
- Air quality in User’s home.
- Technical information about User’s mobile device or computer system (including mobile device ID, IP address, device type, device identifiers, browser types, browser language, etc.);
- Technical data sent from 7HUGS LABS products;
- Usage statistics about website browsing (including referring and exit pages, URLs, platform type, number of clicks, domain names, landing pages, pages viewed, amount of time spent on particular pages, etc.);
- Usage statistics about User’s interactions with the products and/or services.
Payment details, including credit card number and expiration date.
Correspondence between User and 7HUGS LABS, including assistance required from 7HUGS LABS’ customer support department and feedback provided by User about the products and/or services.
Users may “opt out” of providing any of the above data, but they recognize that doing so may prevent 7HUGS LABS from processing their order or providing the products and/or services in accordance with their purpose.
2. Means of collection of information and personal data
7HUGS LABS may collect the above-listed information and personal data in one or several of the following ways:
Use of 7HUGS LABS’ website: Some information and personal data may be collected without purchase of and/or subscription to 7HUGS LABS’ products and/or services, through website browsing or posting of comments on 7HUGS LABS’ website.
Processing of orders: 7HUGS LABS collects the information and personal data provided during the purchase of and/or subscription to 7HUGS LABS’ products and/or services on its website.
Creation of User account: After purchasing and/or subscribing to 7HUGS LABS’ products and/or services on its website, Users will be required to activate their product/service and create a User account in order to be able to use such products and/or services. 7HUGS LABS collects and stores the synchronization and login data generated/provided by Users to this end.
Use of the products and/or services: 7HUGS LABS collects and stores (i) information and personal data provided by Users themselves when using the products and/or services, and (ii) data collected by 7HUGS LABS’ hardware and software which form part of 7HUGS LABS’ products and/or services.
Use of “cookies” and passive collection of personal data: Subject to prior provision of information and collection of Users’ consent as concerns cookies which are not exempted from such prior information and consent, 7HUGS LABS may use tracking technologies in order to collect and analyze certain types of technical information (including cookies, which are small bites of information that are stored by the browser on the hard drive of a computer). Users can set their web browser to limit the type of cookies that they allow. Disablement of cookies may disable some of the features and functionalities of the products and/or services.
3. Storage of information and personal data
The information and personal data collected by 7HUGS LABS is stored and processed on 7HUGS LABS’ servers which are hosted in Ireland by Amazon.
Users’ payment details such as credit card number and expiration date will not be stored without prior “opt-in” by Users. The security code will never be stored.
Unless for specific information and personal data for which duration of storage is provided for by law, other information and personal data will be stored by 7HUGS LABS for a period of time which will not exceed the purposes of the processing of such data. Users’ personal data will not be kept after Users have closed their User account.
4. Use of information and personal data
7HUGS LABS makes use of Users’ information and personal data to provide Users with an efficient and customized experience when using 7HUGS LABS’ products and/or services.
7HUGS LABS may also make use of anonymized data in order to perform statistics for internal purposes (in particular improvement of its products and/or services). Such data will be compiled into a statistical aggregate and will not include any personally identifying information.
5. Promotional Communications
Subject to prior “opt-in” by Users, 7HUGS LABS may also use the personal data collected to send Users commercial solicitations for 7HUGS LABS’ products and/or services by email.
Users will be given the opportunity to stop receiving such commercial solicitations from 7HUGS LABS by clicking on the "unsubscribe" link in any such e-mail.
Such “opting-out” of commercial solicitations will not prevent 7HUGS LABS from communicating with Users as necessary for the provision of the products and/or services purchased/subscribed by Users as well as for other legitimate non-marketing reasons.
6. Sharing of information and personal data
7HUGS LABS will not trade, sell, rent or otherwise share Users’ information and personal data to any third party without Users’ consent, except in the following situations:
Payment processing: 7HUGS LABS may have to share Users’ payment details to allow payment processing by a third party service provider, which will be instructed to use the personal data transmitted exclusively for the purpose of processing payment on 7HUGS LABS’ behalf and in accordance with the confidentiality agreement entered into between such third party service provider and 7HUGS LABS.
Legal reasons: 7HUGS LABS may have to release information concerning Users’ use of its website and/or products and/or services as required by law and when 7HUGS LABS is ordered to do so through a written request from a judicial or administrative authority entitled to receive said data and stating the reasons of said request.
Sale or merger: If 7HUGS LABS undergoes a business transition, such as a merger, acquisition by another company or sale of all or a portion of its assets, 7HUGS LABS may have to transfer all Users’ information and personal data to the successor organization in such transition. In such an event, Users will receive notification of such business transition involving transfer of their information and personal data.
Although 7HUGS LABS’ products and/or services are intended to enhance the well-being of all members of a family/home, such products and/or services shall not be used directly by children under the age of 18.
Users must be above the age of 18 to create a User account and they acknowledge that they may only use 7HUGS LABS’ products and/or services with children of whom they are the legal guardian.
Personal data of children under the age of 18 collected without their legal guardian’s approval will be immediately deleted upon 7HUGS LABS becoming aware of such situation.
7HUGS LABS is committed to the security of the data which is collected and has implemented reasonable technical and organizational measures to prevent unauthorized access to that data. These measures include policies, procedures and technical elements relating to data access controls (among which anonymization and encryption of the data, firewalls, physical lock and key, internal restrictions, password protection, security protocols, etc.). Such measures are reasonably designed to help protect Users’ personal data from loss, unauthorized access, disclosure, alteration or destruction.
Users nevertheless acknowledge that no website or Internet transmission is completely secure, and 7HUGS LABS cannot guarantee that no unauthorized access, hacking, data loss or other breaches will ever occur.
In the event that any User’s personal data is accessed, or is reasonably believed to have been accessed, by an unauthorized person, 7HUGS LABS will give prompt notice to the relevant User and take the measures necessary to determine the scope of the breach and restore the integrity of the data system.
Users must protect and maintain the security of their personal data and their User account, and they shall immediately notify 7HUGS LABS of any unauthorized use thereof.
9. User access to personal data
In accordance with the Data Privacy Act of January 6, 1978 (as modified in 2004), all Users have a right to access to, modify, complement and delete the personal data which relate to them. They can also oppose, for legitimate reasons, to the processing of their personal data.
Users have direct access to their personal data via their User account in the application, where they may modify themselves some of their information and personal data.
In addition, Users may exercise all rights above by sending a request, together with a proof of identity, to the following address: email@example.com.
10. Third parties websites and advertisements
7HUGS LABS – 21 bis rue des Citeaux – 92130 Issy les Moulineaux