Last updated: April 29, 2020
Your privacy is important to Sunna Design SA (“Sunna Design”) and its subsidiaries. This Statement explains how Sunna Design collects, uses, discloses, retains and deletes personal information, including information collected through Sunna Design’s website (currently, www.sunna-design.com and www.solarlighting.com), or directly by Sunna Design representatives.
Sunna Design welcomes questions and comments on this Privacy Statement and feedback on its management of personal information. Any questions, concerns, requests for access or changes to personal information, withdrawals or variations of consent, complaints, or inquiries regarding our privacy policies and practices, including questions about the collection, use, disclosure or storage of personal information by our approved suppliers, distributors or service providers outside of France, may be directed to Sunna Design’s Privacy Officer at 17 rue du Commandant Charcot, 33290 Blanquefort.
1. Your Consent
Sunna Design will only collect, use and disclose personal information for the purposes for which it was provided, unless you consent to a new purpose, or if permitted or required by law. Except where limited exceptions apply, Sunna Design will make a reasonable effort to advise you in advance of the purposes for which your personal information is being collected, used, and disclosed.
When you provide or submit your personal information to Sunna Design, we consider that you have consented to the collection, use, and disclosure of your personal information for the purposes for which it was provided or submitted. We will handle that personal information in accordance with this Privacy Statement, or as otherwise permitted by applicable law.
Subject to legal or contractual restrictions, on reasonable notice, you may withdraw or vary your consent to Sunna Design’s collection, use and disclosure of your personal information by submitting a written request to Sunna Design’s Privacy Officer using the contact information above. If you withdraw or vary your consent, there may be products and services that Sunna Design can no longer supply to you.
In this Privacy Statement, “personal information” means information about an identifiable individual.
2. How Sunna Design Collects Personal Information
(a) Direct Collection:
Although Sunna Design collects personal information primarily from the individual involved, Sunna Design may also collect personal information from other authorized sources.
You may be asked to provide or submit your personal information to Sunna Design when you contact Sunna Design to discuss our products or services, place an order for our products and services, register to create a Sunna Design account, subscribe for Sunna Design services including our newsletter, respond to a survey, fill out a form, submit an inquiry, or when you are otherwise in contact with Sunna Design, or its representatives. In those circumstances, you can choose not to provide or submit your personal information, but then we might not be able to fully respond to you.
(b) Automatic Collection:
Sunna Design’s website may automatically collect certain information regarding your use of the website, such as the dates and times you access Sunna Design’s website and the browsers, operating systems and devices you use to access the website. Sunna Design may use that information for various purposes, including to administer and improve Sunna Design’s website.
Sunna Design’s website and email messages may also use “cookies” and other similar technologies, such as web beacons, pixel or gif tags, and action tags. Those technologies collect information that assists Sunna Design to improve Sunna Design services, advertising and customer communications. Sunna Design may use information collected through cookies and similar technologies to recognize you as a user of Sunna Design’s website, determine your general location, track your use of Sunna Design’s website, offer personalized online content, information and advertisements, and otherwise facilitate and improve your use of Sunna Design’s website. Sunna Design may use web beacons, pixel or gif tags, and action tags to confirm that email messages have been delivered to and opened by you.
You may choose to decline or disable cookies if your web browser permits, but doing so may affect your ability to access or use certain features of Sunna Design’s website. You may opt-out of receiving emails in accordance with this Privacy Statement.
When you contact Sunna Design service or sale representatives by telephone, those calls may be monitored or recorded for quality assurance purposes. If Sunna Design wishes to use personal information you have provided during the course of those calls for quality assurance purposes, Sunna Design will contact you to seek your consent.
(c) Location-Based Services:
Sunna Design may provide location-based services, including marketing and promotions specific to your location and the calculation of prices in local currency. To do so, Sunna Design may collect and use information regarding the geographic location of your computer or mobile device. If the location data contains your personal information, then Sunna Design will treat the location data as personal information in accordance with this Privacy Statement. If the location data is collected anonymously in a form that does not personally identify you, then Sunna Design will treat the location data as non-personal information in accordance with this Privacy Statement. You may configure your computer or mobile device to either transmit or not transmit location data to Sunna Design.
3. How Sunna Design Uses Personal Information
Sunna Design uses your personal information:
(a) to provide you with products and services that you have registered or purchased to receive from Sunna Design;
(b) to facilitate transactions and process your purchases for Sunna Design products;
(c) to process and respond to your specific suggestions, comments, inquiries and requests (including your feedback to Sunna Design about Sunna Design’s products), and to otherwise administer Sunna Design’s relationship with you;
(d) to create and manage your Sunna Design account;
(e) if necessary, to facilitate the return of products for servicing or repairs; and
(f) for those purposes required or permitted by law.
Sunna Design may combine your personal information collected through various sources, including information collected through Sunna Design’s website, and develop a customer profile for you which will be used for the purposes above.
If you have provided your consent for Sunna Design to use your personal information for marketing and promotional purposes, we may also use your personal information to:
(g) to administer and facilitate your participation in contests and promotions related to Sunna Design’s products;
(h) to develop, deliver, and improve Sunna Design’s products and advertising; and
(i) to send you information regarding Sunna Design’s announcements, news, and updates that may be of interest to you.
Sunna Design may use personal information to create non-personal information which may then be used, disclosed, transferred and retained for other purposes such as analyzing statistics, assessing our client usage of our networks and facilities, quality assurance, and to help us plan our business activities.
4. How Sunna Design Discloses Personal Information
(a) Suppliers, Distributors and Service Providers:
Sunna Design may disclose or transfer your personal information to its approved suppliers, distributors, and service providers to assist Sunna Design in the provision of products and services to you, to provide products and services to Sunna Design, to perform work on behalf of Sunna Design using your personal information, or as otherwise permitted by applicable law.
Sunna Design requires its approved suppliers, distributors, and service providers to agree to use your personal information only for the purposes for which the information is provided to them, and to protect the privacy of your personal information in a manner that is consistent with this Privacy Statement. Regardless of the steps taken by Sunna Design to protect personal information in the custody of third parties, personal information that is used, processed, or stored in a foreign country may be accessible to law enforcement, courts, regulatory agencies and national security authorities of that jurisdiction.
(b) Sunna Design Business Transactions:
Sunna Design may disclose your personal information in connection with a proposed or actual business transaction in which Sunna Design is involved (such as a corporate reorganization, merger or acquisition, or the sale of some or all of Sunna Design’s business or assets), but Sunna Design will require that the information recipient agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Statement and applicable law.
(c) Law Enforcement/Legal Disclosures:
Your personal information may be subject to collection by and disclosure to law enforcement agencies in accordance with applicable law. Sunna Design may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order, or litigation disclosure obligations. Sunna Design may disclose your personal information to law enforcement authorities or other organizations if Sunna Design reasonably believes the disclosure is necessary or appropriate to protect and enforce Sunna Design’s legal rights, interests and remedies or to protect the business, operations or customers of Sunna Design or other persons. Sunna Design has no control over, or responsibility or liability for, the use, disclosure, retention and deletion of your personal information by the agencies, organizations or other persons to whom Sunna Design discloses the information in the foregoing circumstances, and the use, disclosure, retention and deletion of the disclosed information by those agencies, organizations or other persons is not subject to this Privacy Statement.
5. Location of Personal Information
Sunna Design may process, store and use your personal information at facilities in various countries, including Canada and the United States of America. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information. By providing Sunna Design with your personal information, you consent to the transfer of your personal information to facilities located in other countries and the processing and storage of your personal information at those facilities.
6. Retention and Protection of Personal Information
Sunna Design retains your personal information for the period reasonably necessary for the purposes described in this Privacy Statement or a longer period required or permitted by applicable law. Sunna Design will delete or dispose of your personal information when Sunna Design is no longer reasonably required to keep the information for the purposes described in this Privacy Statement.
Sunna Design employs reasonable safeguards – including administrative, physical and technical security and safeguarding measures and solutions – appropriate to the sensitivity of the personal information in Sunna Design’s possession or under Sunna Design’s control in order to protect the information from unauthorized access, collection, use, disclosure, disposal or similar risks. To process transactions from our website, we use Secure Socket Layer (SSL) technology and encryption.
Nevertheless, security risks cannot be eliminated and Sunna Design cannot guarantee that your personal information will not be used or disclosed in ways not otherwise described in this Privacy Statement.
7. Accuracy and Access to Personal Information
Sunna Design will rely on you to ensure that your personal information is as accurate, complete and up to date as necessary for the purposes of the products and services that Sunna Design provides to you. You will promptly notify Sunna Design of any relevant changes to your personal information using the procedures provided on Sunna Design ’s website or by contacting a Sunna Design representative.
You may request access to your personal information and information about Sunna Design’s collection, use, disclosure, retention and deletion of your personal information by submitting a written request to Sunna Design’s Privacy Officer using the contact information above. Subject to applicable exceptions and limitations prescribed by applicable law, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and to have it amended as appropriate. You may be required to pay a reasonable fee for access to your personal information.
8. Non-Personal Information
Sunna Design creates or collects non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise anonymized so that it no longer relates to an identifiable individual. Sunna Design may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever.
If non-personal information is combined with personal information, then the non-personal information will be treated as personal information for the purposes of this Privacy Statement.
9. Other Matters
(a) Business Contact Information: To the extent permitted by applicable law, the provisions of this Privacy Statement concerning personal information do not apply to information (such as your name, position or title, business address, business telephone number, business fax number and business email address) that enables you to be contacted at a place of business.
(b) Website Terms and Conditions: The Terms and Conditions that you accept when you register for a Sunna Design account contain important provisions, including provisions disclaiming, limiting or excluding Sunna Design’s liability and provisions determining the applicable law and exclusive jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those terms and conditions applies to any dispute that may arise in relation to this Privacy Statement or Sunna Design’s collection, use, disclosure, retention and deletion of your personal information, and are of the same force and effect as if they had been reproduced directly in this Privacy Statement.
(d) Former Users: If you cease using the Sunna Design website, Sunna Design may continue to use and disclose your personal information in accordance with this Privacy Statement, as amended from time to time.
(e) Unsubscribing to Newsletters and Messages: You may unsubscribe from Sunna Design’s commercial electronic messages by using the applicable unsubscribe procedure included in those messages or by contacting Sunna Design at [email protected]
(f) English Language: You and Sunna Design have each expressly requested and required that this Privacy Statement and all other related documents be drawn up in the English language. Les parties conviennent et exigent expressement que ce Politique et tous les documents qui s’y rapportent soient rédigés en anglais.
(g) Changes to this Statement: Privacy laws are subject to change and Sunna Design may change this Privacy Statement at its discretion from time to time, without any prior notice or liability to any person, by posting a new version of this Privacy Statement on Sunna Design’s website. Sunna Design’s collection, use, disclosure, retention and deletion of your personal information will be governed by the version of this Privacy Statement in effect at that time. Your continued dealings with Sunna Design subsequent to any change to this Privacy Statement will signify your consent to the collection, use, disclosure, retention and deletion of your personal information in accordance with the changed Privacy Statement. Accordingly, you should check the “Last Updated” date of this Privacy Statement (at the top of this Statement) and review any changes since the last version.