CUSUAKA PRIVACY POLICY

This privacy policy (hereinafter referred to as the "Privacy Policy") defines the legal framework for the collection, use and processing by the Company of the personal data of users browsing and/or making use of the services offered via the web platform developed by CUSUAKA (hereinafter referred to as the "Users"), accessible at http://www.cusuaka.com/ designed and operated by the Company (hereinafter referred to as the "Platform").
The personal data collected in the context of this Privacy Policy is mandatory. This information is necessary for the processing and provision of the services offered by the Company via the Platform (hereinafter referred to as the "Services"). Failure to provide this information will prevent the proper functioning of the Services offered online.
The Company undertakes to comply with the applicable regulations on the protection of personal data (hereinafter referred to as the "Personal Data"), and in particular the obligations arising from European Regulation No. 2016/679 on the protection of personal data (RGPD).
The Company collects Personal Data only in compliance with the terms of this Privacy Policy and any legal and reasonable instructions given by the User at any time.
Where the Company becomes aware of a breach of rights in connection with the processing of personal data, such breach will be notified to the CNIL within a period not exceeding seventy-two (72) hours of becoming aware of it.
Any violation relating to the processing of the User's personal data will be notified to the User concerned by e-mail, within one (1) month.

ARTICLE 1: INFORMATION COLLECTED

1.1 Throughout the use of the Platform and Services, the Company may collect any information, directly or indirectly identifying the User, required to create an account on the Platform and necessary for the proper operation of the Platform (hereinafter referred to as "Personal Data").
When logging in for the first time, the User expressly consents to the processing of his/her Personal Data within the limits of processing strictly necessary for the proper operation of the Platform.
All personal information collected is mandatory. This information is necessary for the processing and provision of the Services. Failure to provide this information will prevent the proper functioning of the Services offered online. This includes in particular
§ Personal Data relating to the User's identity, including title, surname, first name, e-mail address, telephone number, postal address and zip code;
§ Personal Data relating to browsing, collected automatically by the Company and in particular the anonymized IP address, the browser used, the browsing time, the operating system used, the language and the pages viewed;
§ Data relating to statistics on visits to the Platform by Users, in particular traffic data and other data or communication resources used by the User to access the Platform;

1.2 Personal Data may be collected directly when the User communicates them to the Company by means of the forms for creating a User account, requesting contact, making a quotation, subscribing to the newsletter available on the Platform and reporting illicit content.
The Company grants itself the right to review, scan or analyze communications exchanged between the Company and Users via the Platform for the purposes of fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and User support.
The Personal Data collected for these purposes is mandatory and strictly necessary for the proper operation of the Platform. Failing this, the Services cannot be provided.

ARTICLE 2: USE OF PERSONAL DATA COLLECTED

The Company uses, stores and processes Personal Data in order to supply, understand, improve and develop the Platform, to create and maintain an environment of trust with Users and to comply with its legal obligations, and in particular in order to :

2.1 Development of the Platform
§ Enable Users to access/use the Platform;
§ Enable Users to communicate with the Company's staff;
§ To manage, protect, improve and optimize the Platform through statistics, analyses and studies;
§ Provide customer service tailored to Users' needs;
§ To send Users support messages or messages relating to the Services, updates, security alerts and notifications;
§ as part of fraud detection and prevention measures;

2.2 Creating and maintaining an environment of trust for Users
§ Detecting and preventing fraud, spam, abuse, security incidents and other damaging activities;
§ Conduct security investigations and risk assessments;
§ verify or authenticate information or identifications transmitted by Users;
§ Comply with the Company's legal obligations;
§ Resolve any disputes with Users;

2.3 To provide, customize, evaluate and improve our Advertising and Marketing Services
§ To send promotional messages, commercial and advertising information;
§ To personalize, evaluate and improve the advertising of the Services;

ARTICLE 3: SHARING AND SEPARATION OF PERSONAL DATA

3.1 The Company may disclose Users' Personal Data to courts, governmental or law enforcement authorities or authorized third parties, if required or permitted by law, or if such disclosure is reasonably deemed necessary: (i) to comply with the Company's legal obligations, (ii) to comply with the judicial process and to pursue claims against the Company, (iii) to respond to verified requests in connection with a judicial investigation or alleged or suspected illegal activity or any other activity that may expose the Company or the User to legal liability.

3.2 The Company is entitled to subcontract all or part of the performance of the Services in compliance with applicable legal provisions.
The Company may also subcontract Personal Data hosting services on condition that the Personal Data is processed by a hosting platform located exclusively within the territory of the European Union. The subcontractor will be authorized́ to process on behalf of the Company the Personal Data necessary to provide the Services.

3.3 Personal Data may be transmitted to technical service providers, for the sole purpose of the proper performance of the Services, or to its various suppliers such as payment solution providers.

ARTICLE 4: PROTECTION OF PERSONAL DATA - USERS' RIGHTS

4.1 Personal Data communicated by the User will be destroyed no later than six (6) months after the User ceases to use the Services. The Company reserves the right to retain certain data in order to justify, where applicable, the full performance of its contractual or legal obligations. Data retained in this way will be limited to what is strictly necessary.

4.2 In all cases, Users have the right to access, rectify, modify, oppose, port and delete their Personal Data by writing to the following address - hola@cusuaka.com
The company has not appointed a Data Protection Officer.
In accordance with current regulations, all requests must be signed and accompanied by a photocopy of an identity document bearing the User's signature.
The User may retrieve his or her Personal Data in an open and readable format. The right to portability is limited to the data provided by the User concerned. It applies on the basis of the User's prior consent. The Company undertakes to transfer, on request, within a period of one (1) month, any Personal Data collection document to the User in order to be able to implement the right to portability. The cost of recovering the data shall be borne by the User making the request.

ARTICLE 5: USE OF COOKIES

In accordance with CNIL deliberation no. 2013-378 of December 5, 2013, the Company further informs that cookies record certain information that is stored in the memory of the User's hard disk. This information is used to generate audience statistics.
A warning message, in the form of a banner, asks the User to accept cookies beforehand.
Users visiting the home page or another page of the Platform directly from a search engine will be informed :
§ the precise purpose of the cookies used
§ of the possibility of objecting to these cookies and changing the settings by clicking on a link in the banner;
§ that continued browsing implies consent to the deposit of cookies on the user's terminal.
In order to guarantee Users' free, informed and unequivocal consent to the Platform, the banner will not disappear until Users continue browsing.
Unless prior consent has been obtained, cookies will not be deposited or read.

ARTICLE 6. NEWSLETTER

Depending on the choices made by the User, he/she may receive the newsletter.
By checking the box provided for this purpose or by expressly agreeing to this, the User accepts that the Company may send him/her a newsletter which may contain information about new activities offered by the Company's Partners. Users may unsubscribe from the newsletter by clicking on the appropriate link in each newsletter.