Policy
confidentiality

Nordigital.net LTD, whose registered office is at Unit 126, 5 Spur Road, Isleworth, Middlesex, United Kingdom, TW7 5BD

Registration number : 07009113

VAT number : GB455167677

Last update: 10 November 2023

Access to the Site and its functions requires the collection and processing of Users' personal data. It was therefore necessary to establish a policy for the protection of personal data in order to comply with the recommendations for the processing of personal data as laid down by the applicable laws and regulations.

The Site's Data Protection Policy has been drawn up in accordance with the recommendations of the Commission Nationale de l'Informatique et des Libertés (CNIL). Its purpose is to inform Users of the Site of the way in which their personal data is processed and of the commitments and measures we have taken to ensure that the personal data of Users of the Site is respected.

It has been drawn up in accordance with the provisions of :

The Data Protection Act of 6 January 1978;

The European Regulation on Personal Data (known as the "GDPR") of 23 May 2018;

The Law transposing the European Regulation on the Protection of Personal Data (R.G.P.D.) of 20 June 2018.

The version currently published on the Site is the current version of this policy. The Vendor reserves the right to modify it at any time in order to comply with current legal obligations. Any changes made to the Privacy Policy will be communicated to Users in order to obtain their consent to the new policy.

By browsing our Site, Users acknowledge that they have read, understood and accept this data protection policy. Any questions relating to this policy may be sent to the following address: contact.talkto1@gmail.com .

1.1 Technical terms relating to the protection of personal data

On our Site, the terms below have the meaning ascribed to them in the R.G.P.D. (art.4):

Consent: "any freely given, specific, informed and unambiguous indication of the data subject's wishes by which the data subject signifies his agreement, either by a declaration or by a clear and positive act, to personal data relating to him being processed";

Controller: "the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing operation; where the purposes and means of such processing are determined by Union law or by the law of a Member State, the controller may be designated or specific criteria for such designation may be laid down in Union law or in the law of a Member State";

Processor: "the natural or legal person, public authority, department or other body which processes personal data on behalf of the controller";

Processing: "any operation or set of operations which is performed upon personal data or sets of data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction";

Personal data breach: "a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to personal data transmitted, stored or otherwise processed".

1.2 Other terms used herein

"Customer": in accordance with the provisions of the introductory article of the French Consumer Code, means any natural person who is acting for purposes that do not fall within the scope of his or her commercial, industrial, craft, liberal or agricultural activity, and who has placed an order on the Site;

"Site": refers to the http://talk4to.com/ Site operated by the Seller and made available to the User;

"User": refers to any individual using our Site and having access to its content.

Personal data" refers to any information that can directly or indirectly identify a natural person (surname, first name, e-mail address, telephone number, postal address, etc.).

As such, the GDPR defines personal data as: "any information relating to an identified or identifiable natural person (hereinafter referred to as 'data subject'); an 'identifiable natural person' is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity;".

In accordance with the provisions of Article 8 of European Regulation 2016/679 and the French Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data.

Users under the age of fifteen (15) are invited to seek the consent of a legal representative - required by the Seller - in order for their personal data to be collected and in order to be able to use the Site's services.

The Vendor may not be held liable in the event of any user providing personal data concerning a minor under the age of fifteen (15).

Personal data" refers to any information that can directly or indirectly identify a natural person (surname, first name, e-mail address, telephone number, postal address, etc.).

As such, the GDPR defines personal data as: "any information relating to an identified or identifiable natural person (hereinafter referred to as 'data subject'); an 'identifiable natural person' is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity;".

We collect your consent.

When browsing the Site, Users will be asked on several occasions to provide some of their personal data (for the purposes indicated in article 5).

By providing his/her data, the User therefore consents to the collection and processing of the personal data provided by the Seller for the exclusive purposes detailed in article 5 of the Policy. This consent, together with other reasons, serves as the legal basis for the processing of the data collected.

The Seller collects and processes data that is strictly necessary for the purposes for which it is processed. We undertake to our Users not to process data for purposes other than those mentioned below. If we were to offer a new service on the Site, or any other feature of the Site, requiring the collection and processing of data, we undertake to collect the Users' consent once again before offering the new service in question.

Whenever the Site processes personal data, the Seller takes all reasonable steps to ensure that the personal data is accurate and relevant to the purposes for which it is processed.

We collect data from Users solely for the following purposes:

5.1 Creating an account (optional)

Customers and Users may create an account on the Site. To do so, they must fill in the following details: surname, first name, e-mail address.

User data is used for the purposes of :

Confirm the creation of your account;

Create your customer account ;

Communicating with the Customer/User ;

Provide after-sales support.

The legal basis is the performance of a Contract, as a result of the placing of an order, with the latter accepting these provisions.

5.2 Placing an order

To place an order on the Site, Customers must provide the following information: surname, first name, e-mail address and billing address.

User and communication data is used solely for the purposes of :

Confirm the customer's order;

Processing the customer's order;

Provide the services ordered;

Providing after-sales service.

Customers are also informed that by placing an order, they will receive transactional communications from the Vendor (invoices, password changes, English test results). They may unsubscribe at any time by using the functions provided for this purpose in the communication emails sent by the Vendor.

The legal basis is the Performance of a Contract as a result of the placing of an order, with the latter accepting these provisions.

5.4 Payment for services

Payment for orders via the Site is made via our HIPAY payment service provider, which acts as the data controller for Customer payment data. The Seller does not have access to Customer payment data.

5.5 Subscription

By placing an order on the Site, the Customer automatically benefits from a subscription to the Vendor's Subscription (see the General Terms and Conditions of Sale). If the Customer has not cancelled their subscription within 24 hours, it is automatically extended for a period of one month, renewable by tacit agreement.

The data used to conclude the subscription is the data provided by the Customer when placing the order and is used for the purposes of :

Providing subscription services

Manage subscriptions (billing, termination, renewal)

Providing after-sales service

5.6 Contact form

A contact form is available on the Site. To respond to their request, Users must provide their surname, first name, e-mail address and telephone number.

User and communication data is used solely for the purposes of :

Process the User's request;

Respond to the User's request.

The legal basis is the User's Consent.

5.7 Analysis of navigation information

When browsing the Site, Users may be asked to enter their personal connection data (cookies, tracers).

Connection data and browsing information are used solely for statistical studies (analysis of site traffic and user experience) and other purposes mentioned in the cookies policy.

The legal basis is as follows: The processing is necessary for the purposes of the legitimate interests pursued by the Seller, in particular to offer Users a smooth and improved browsing experience.

Connection data is also used to prevent and combat computer fraud.

The legal basis is the response to a legal obligation.

We do not exceed the legal data retention periods and User data is only retained for as long as is necessary for the purposes for which it was collected.

The retention periods are as follows:

Data relating to the identity of the User who is not a customer (surname, first name): this is deleted or made anonymous three (3) years after the last contact from the User, unless the User has previously exercised a right (in application of the RGPD) resulting in the deletion of his/her data;

Non-customer communication data (e-mail, telephone number, postal address): this is deleted or anonymised three (3) years after the last contact from the User, unless the User has previously exercised a right (in application of the RGPD) resulting in the deletion of his/her data;

Data relating to Customers who have placed an order : this data is deleted five (5) years after the end of the commercial relationship with the Customer, unless the Customer has previously exercised a right (pursuant to the RGPD) resulting in the deletion of the data;

Connection data -: in accordance with the Cookies policy, this is kept for a maximum period of 13 months (except for the exceptions indicated in article 13).

In establishing our data processing policy, we have drawn up a reference grid for data retention periods, based on the recommendations of the CNIL. In addition, the Seller may retain certain personal data in order to fulfil its legal or regulatory obligations, to enable users to exercise their rights, or for statistical purposes. At the end of the retention period, personal data will be deleted or made anonymous.

The data collected via the Site is intended exclusively for the following recipients.

7.1 Site hosting

The Site is hosted by Kinsta, 8605 Santa Monica Blvd #92581 West Hollywood, CA 90069 - United States. https://kinsta.com/fr/

The host has access to the data within the limits of its respective remits, for the purposes of hosting the Site. It has limited access to User data as part of the performance of these services and has a contractual obligation to use it in accordance with the provisions of the applicable regulations on the protection of personal data.

To find out more, consult Kinsta's policy.

7.2 Third-party service providers

The Site and the Seller rely on certain third-party services to provide certain functions. These third parties have limited access to User data for the purposes of providing these services and are contractually obliged to use it in accordance with the provisions of the applicable regulations on the protection of personal data.

Users' statistical data (cookies) are used to improve the user experience and enhance the Site's functionalities. Users are invited to refer to the site's cookies policy.

7.3 Legal obligations

Data may also be transmitted by the Vendor to third parties and competent authorities in order to comply with legal, judicial, fiscal or regulatory obligations. The Vendor guarantees Users that no personal data will be transferred to an unauthorised third party without the prior, voluntary, informed, express and written consent of the User.

The Seller shall not process, host or transfer Information collected from its users to a country outside the European Union or recognised as "non-adequate" by the European Commission without first informing the owner of the data and obtaining its consent.

The Seller has taken all useful and necessary precautions, with regard to the state of the art in the field, to protect your information in a secure environment in order to avoid any destruction, loss, alteration, distribution or unauthorised access. Despite our best efforts, no method of transmission over the Internet and no method of electronic storage is completely secure. Consequently, we cannot guarantee absolute security. If we become aware of a breach of security, we will notify the users concerned so that they can take appropriate action. Our incident notification procedures take account of our legal obligations, whether at national or European level.

In the event that the integrity and confidentiality of your data are compromised, the data controller undertakes to comply with the procedures put in place under the French Data Protection Act of 6 January 1978 and the European Data Protection Regulation ("RGPD").

The Seller does not resell or outsource User data.

In accordance with the French Data Protection Act of 6 January 1978 and the European Data Protection Regulation ("E.D.P.R."), Users of the Site have the following rights:

9.1 Right of access, rectification and deletion

Users may find out about, update, modify or request the deletion of data concerning them by sending an e-mail to the person responsible for processing personal data, specifying the subject of their request and using the contact e-mail address contact.talkto1@gmail.com .

9.2 Right to portability

The User has the right to request the portability of his/her personal data, held by the Site or by the Seller, to another site, by making a request for the portability of his/her personal data to the data controller, by sending an e-mail to the address provided above.

9.3 Right to limit and object to data processing

The User has the right to request the limitation of or to oppose the processing of his/her data by the Vendor, without the Vendor being able to refuse, unless he/she can demonstrate the existence of legitimate and overriding reasons, which may override the interests and rights and freedoms of the User.

The User must make a request to the data controller to restrict the processing of his/her personal data, by sending an e-mail to the above address.

9.4 Right not to be subject to a decision based exclusively on an automated process 

In accordance with the provisions of Regulation 2016/679, the User has the right not to be subject to a decision based exclusively on an automated process if the decision produces legal effects concerning him or her, or significantly affects him or her in a similar way.

9.5 Right to determine the fate of data

Users are reminded that they may organise what is to become of their data collected and processed if they die, in accordance with law no. 2016-1321 of 7 October 2016.

10.1 How to exercise your rights

To exercise any of your rights, simply :

Write to the Seller at the address of its registered office;

Or send an e-mail to contact.talkto1@gmail.com .

Enter your full name and address and enclose proof of identity.

The data controller is Mr Carlo El contact.talkto1@gmail.com .

Requests will be processed within one month, unless there are compelling reasons put forward and justified by the Seller to extend the deadline.

10.2 Referral to the CNIL

If the Vendor does not satisfy the User's request, the User is entitled to refer the matter to the CNIL (Commission Nationale de l'Informatique et des Libertés, https://www.cnil.fr) in order to assert his/her rights.

11.1 What is a Cookie?

The User is informed that a cookie is a small file deposited on the terminal of any user (computer, tablet or mobile device), by our Site, during its consultation. It does not contain any personal information, but enables a link to be made between the User's device and their preferences for use and experience on our Site (e.g. location, language, font size).

11.2 User consent

For the use of "cookie" files involving the storage and analysis of personal data, the User's consent is always requested. This consent is valid for a period of thirteen (13) months, with one or more exceptions (see table Art.13), at the end of which the User will be asked for a new authorisation.

In accordance with CNIL deliberation no. 2013-378 of 5 December 2013, the Seller informs Users of the Site that cookies record certain information that is stored in the memory of their hard disk. This information is used to generate Site audience statistics and to offer services according to the information they have already selected during their previous visits.

An alert message, in the form of a banner, asks each User visiting the Site whether they wish to accept cookies beforehand. In order to guarantee the free, informed and unequivocal consent of the User visiting the Site, the banner will not disappear until the User has continued browsing and configured his/her choices.

Unless the User has given their prior consent, cookies will not be deposited or read:

If any person who visits the Site (home page or directly on another page of the Site from a search engine, for example) does not continue browsing: a simple absence of action cannot be assimilated to an expression of will;

Or if they click on the link in the banner allowing them to set their cookie parameters and, where applicable, refuse to accept cookies.

We use and collect cookies in order to :

To process statistics and information on traffic on our site and to optimise it as much as possible;

To offer our users a fluid browsing experience by adapting the presentation of our Site to the display preferences of the user's terminal;

To store information provided on the Site by the User.

The list of cookies present on the Site is as follows:

All Users may refuse to accept cookies by configuring their browser in the following way(s):

Open a private browser window ;

Configuration of cookies via the "Cookies" Widget available on the home page of our Site;

Configure your computer so that a message appears asking you to accept, personalise or refuse cookies on each site or systematically;

Or any other means available to the user.

Users may at any time choose to express and modify their wishes with regard to cookies. The Vendor declines all responsibility for the consequences of the operation of the Site and any services offered resulting from :

Refusal of cookies by the user ;

And/or of the impossibility for the site to record or consult the cookies necessary for their operation as a result of the user's choice.

Users can configure their browser software in such a way as to configure their choices regarding the use of cookies:

For Microsoft EdgeTM: https://support.microsoft.com/en-us/microsoft-edge

For SafariTM: http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html

For ChromeTM: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

Pour FirefoxTM : http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

For OperaTM: http://help.opera.com/Windows/10.20/fr/cookies.html

Users may also configure their browser to accept or refuse cookies on a case-by-case basis before they are installed, or delete cookies from their terminal. The User is informed that by setting his/her browser to refuse cookies, certain functions of our Site may not be accessible and the Vendor or the host may not be held liable in this respect.

The Seller reserves the right to modify this Policy at any time. If a change is made to this Policy, the new version will be published immediately on the Site. If the User does not agree with the terms of the new version of the Policy, he/she may no longer use the Site's Services and no longer browse the Site.

By browsing the Site, the User confirms that he/she has read and understood this privacy policy and accepts its terms, particularly with regard to the collection and processing of his/her personal data and the use of cookies.