Resell Help

Privacy Policy

CompaRecycle is committed to protecting personal data. It implements a continuous improvement approach to comply with the General Data Protection Regulation (GDPR) No. 2016/679 of April 27, 2016 and the French Data Protection Act No. 78-17 of January 6, 1978.

For any information about personal data protection, you can also visit the French Data Protection Authority (CNIL) website www.cnil.fr.

To preserve your privacy and protect your personal data and comply with regulations, a Data Protection Officer has been appointed within CompaRecycle (Data Protection Officer – DPO). They ensure compliance with personal data protection rules. As such, they are your primary contact when you are concerned with any collection or processing of personal data. It is through them that you can exercise your rights.

1. Definitions from GDPR

The following definitions are those from the General Data Protection Regulation No. 2016/679 of April 27, 2016 (GDPR) and the French Data Protection Act No. 78-17 of January 6, 1978.

 

Personal Data

Personal data means any information relating to an identified or identifiable natural person. This person can be identified directly (e.g., name and surname) or indirectly (e.g., by telephone number or registration plate number, an identifier such as social security number, postal address or email, but also voice or image), through a single piece of data or by cross-referencing several pieces (e.g., a woman living at such address, born on such day and member of such association).

 

File

A file is a data processing system organized in a stable and structured set of data. The data in a file is accessible according to determined criteria.

 

Recipient

The natural or legal person, public authority, agency or other body authorized to receive communication of data recorded in a file or processing due to their functions.

 

Data Controller

The data controller is the legal entity (company, municipality, etc.) or natural person who determines the purposes and means of processing, i.e., the objective and how to achieve it. In practice and generally, it is the legal entity represented by its legal representative.

 

Processing

Processing of personal data means any operation, or set of operations, performed on personal data, regardless of the process used (collection, recording, organization, storage, adaptation, modification, extraction, consultation, use, communication by transmission or dissemination or any other form of making available, alignment or combination). Personal data processing is not necessarily computerized: paper files are also concerned and must be protected under the same conditions. Processing of data must have an objective, a purpose determined prior to data collection and their exploitation.

 

Processor

The processor is the natural or legal person (company or public body) who processes data on behalf of another organization (the "data controller"), as part of a service or provision.

2. Methods of data collection and types of data collected

The Personal Data we process on the website https://obe-en.comparecycle.com is strictly necessary for the purposes for which it was collected. We strive to minimize the data collected, keep it up to date by facilitating the exercise of data subjects' rights. We ensure the updating of personal data we process while respecting the purposes listed below. We do not collect Personal Data without the knowledge of the persons concerned and apply and respect the principle of data minimization and relevance. Similarly, we do not intentionally collect or solicit Personal Data concerning persons under 18 years of age. Personal Data may be collected when:

 

We collect and process in particular your name, surname, postal address, email addresses, password, phone number, product IMEI, IP address, connection data, navigation data, trade-in history. During your calls to the Hotline, your data may also be recorded. If you do not wish for them to be recorded, you can indicate this during your call.

3. Who is responsible for personal data processing carried out through the site?

This is CompaRecycle, a Simplified Joint Stock Company with a capital of 2,000 euros, located at 56 avenue Jean Jaurès, 91430 Igny, registered with the Evry Trade and Companies Register under number 533 616 983 represented by Mr. Gaël Brouard as Chief Executive Officer duly authorized.

Whenever CompaRecycle determines the purposes of processing your personal data as well as the means of processing used, it will be qualified as a data controller and will assume all obligations that the Regulations place on it.

4. Why does CompaRecycle collect my personal data?

CompaRecycle uses your personal data mainly for the following purposes and legal bases. They are also stored for a well-defined period presented below:

 

We need your information for processing your device trade-ins, creating the transfer document, and creating the transport document. This information is then transmitted to carriers for sending your used products to our recycling partners. This personal information is also processed by these same recycling partners.

The legal basis is the execution of a contract.

This data is kept for 3 years from the last activity and then archived for ten years for legal reasons (Police book), accounting, and litigation.

To track your trade-in, you can visit the trade-in site https://obe-en.comparecycle.com. For any additional information, you can also contact CompaRecycle customer service by email or phone. For this, we ask for personal information such as name, surname, trade-in number to quickly find all information concerning your trade-in and thus respond to your expectations as best and as quickly as possible.

The legal basis is the execution of a contract.

This data is kept for 3 years from the last activity then anonymized.

To pay for your trade-in, CompaRecycle asks you to provide your bank details. For this, only the IBAN and BIC codes will be requested. Other banking information, such as bank card number, expiry date, or security code will never be requested.

The legal basis is the execution of a contract.

Bank details for a one-time trade-in are kept for 13 months.

 

Furthermore, if you have accepted the storage of your bank details (IBAN and BIC codes) to facilitate your future trade-ins, these are stored and kept for this use for the validity period of the bank card, unless you decide to delete this data in the dedicated space. Indeed, you can decide at any time to cancel your consent to this storage of your bank details to facilitate the payment of your future trade-ins by going to your account.

The legal basis is consent.

The retention of consent related to the storage of bank details for future trade-ins lasts until consent is withdrawn.

Like all professionals practicing second-hand buying and selling, CompaRecycle is legally required to maintain a police register. The police register or register of movable objects (ROM) is a control register that any trader carrying out the purchase and sale of second-hand movable objects, precious metals, or second-hand vehicles must keep. Mandatory in many sectors of activity, the police register allows tracing second-hand objects and precious metals to fight against handling stolen goods and tax fraud.

The police register must therefore clearly identify the product's origin, purchase price, and destination. The police register must be kept up to date by professionals and reflect the physical stock status of the establishment. During an inspection, it must be able to be provided to the inspector.

 

The legal basis is legal obligation

 

This police register is kept in digital form. The legal retention period, according to Article 3 of Decree No. 2013-287 of April 4, 2013 relating to the register kept by persons whose professional activity includes the sale or exchange of certain movable objects, is ten years from their registration in the processing.

 

We may use data to better understand our customers or for statistical purposes to analyze our site's activity and improve the services we offer. We analyze customer journeys, measure audience, we measure for example the number of page views, number of site visits, as well as visitor activity on the site and their frequency of return.

The legal basis is legitimate interest

Personal data related to this processing is kept for 3 years then archived for ten years for legal reasons and litigation.

5. What communications am I likely to receive?

Following the creation of your account, password reset, or when validating your device trade-in, you will receive an email that will let you know about the validation of your account, confirmation of proper consideration of your password, or that your package has been delivered to our recycling partners. These service emails are in no way newsletters or commercial offer proposals but are necessary for the proper execution of the trade-ins and services you have requested by registering on the site https://obe-en.comparecycle.com.

6. Who are the recipients of my data?

Data transmission:

The data we collect may be transmitted to our affiliated partner, Orange Belgium company, to our recycling partners, as well as to our processors. Here is the list of our processors:

 

Internally, your personal data is processed by CompaRecycle employees. In all cases, only data strictly necessary for the intended processing is transmitted to authorized employees who need to know it due to their functions. All persons likely to have access to your personal data are bound by contract to a confidentiality obligation.

7. Is your data processed outside the EU?

Your data is processed and stored throughout the processing duration on OVH company's servers, located in the European Union.

As part of the tools we use (see article about recipients concerning our processors), your data may be subject to transfers outside the European Union. In this context, the transfer of your data is secured using the following tools:

8. Security Measures

We place particular importance on the security of your personal data.

To this end, we implement all technical and organizational means to ensure a level of data security, depending particularly on the purposes of processing and associated risks.

We therefore limit access to your data to only employees, processors, and other third parties who need access for performing their duties. They are subject to a confidentiality obligation.

We implement protections to reduce risks of loss, alteration, misuse, unauthorized access, disclosure, modification, or destruction of data.

Furthermore, we require our processors to implement appropriate technical and organizational security measures to ensure the confidentiality of personal data and a level appropriate to the risk.

9. What are your rights?

You have the right to obtain from CompaRecycle confirmation whether personal data concerning you is being processed or not. In the event that data is processed, you have a right of access to this data and the following information:

- The purposes of processing;

- The categories of personal data concerned;

- The recipients or categories of recipients to whom the data has been or will be disclosed;

- The planned retention period of the data if possible, or when not possible, the criteria used to determine this duration;

- The right to request from CompaRecycle rectification or erasure of data concerning you, restriction of processing or the right to object to processing;

- The right to lodge a complaint with the CNIL;

- When personal data is not collected directly from you, any available information about its source;

- The existence of automated decision-making, including profiling, and, at least in such cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.

You have the right to request CompaRecycle to rectify your data that would be inaccurate, without delay. You also have the right to have incomplete personal data completed, including by providing a supplementary statement.

 

You have the right to erasure of your personal data without undue delay where one of the following grounds applies:

You are informed that the right to erasure may not apply if processing is necessary:

You have the right to obtain restriction of processing of your personal data where one of the following applies:

a) A verification of your data is necessary following your contestation of the accuracy of your personal data;

b) The processing is unlawful and you oppose the erasure of your personal data and request the restriction of their use instead;

c) CompaRecycle no longer needs the personal data for the purposes of processing, but they are required by you for the establishment, exercise, or defense of legal claims;

d) You have objected to processing and CompaRecycle verifies whether its legitimate grounds override your legitimate grounds.

You have the right to receive the personal data you have provided to CompaRecycle in a structured, commonly used and machine-readable format when, cumulatively:

a) The processing is based on consent or on a contract;

b) The processing is carried out by automated means.

In exercising this right, you have the right to have your personal data transmitted directly by CompaRecycle to another controller where technically feasible.

The right to data portability must not adversely affect the rights and freedoms of others.

Under the right to object, you have the right to object at any time, on grounds relating to your particular situation, to processing of your personal data based on CompaRecycle's legitimate interests.

CompaRecycle will no longer process your personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

You have the right to object at any time to the processing of your personal data for direct marketing purposes. To do so, you can do it completely free of charge.

According to law, you have the right to define guidelines regarding the retention, erasure and communication of your personal data after your death.

You can communicate your instructions to us or register them with a certified digital trusted third party. You can designate the person of your choice who will be responsible for executing your instructions. In the absence of designation, it will be your heirs.

10. How to exercise your rights?

If you wish to exercise any of your rights and/or obtain communication of information concerning you, you must contact CompaRecycle by indicating your name(s), surname(s) and contact details electronically at the following address: rgpd@comparecycle.com.

 

Any request to exercise your rights must be accompanied by elements proving your identity. An identity document may be requested in case of reasonable doubt about your identity. You will receive an acknowledgment of receipt after sending your request.

 

CompaRecycle has one (1) month to respond to you from the receipt of your request. This period may be extended by two months due to the complexity of your request and the number of requests made to it. In such case, you will be informed no later than within one (1) month following your request.

 

If your exchanges with CompaRecycle have not been satisfactory, you have the possibility to lodge a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the supervisory authority in charge of compliance with personal data protection obligations in France. (www.cnil.fr)

11. Cookies

A "cookie" is a string of information, generally small in size and identified by a name, which may be transmitted to your browser by a website you connect to. Your web browser will retain it for a certain period and will send it back to the web server each time you reconnect to it. Cookies have multiple uses: they can be used to remember your client ID on a merchant site, the current content of your shopping cart, an identifier to track your browsing for statistical or advertising purposes, etc.

 

Cookies can be of several types:

When browsing our site, CompaRecycle may deposit, subject to your consent where applicable:

Cookies necessary for the site's functioning: these cookies are exempt from obtaining your consent as they are mandatory for the site's operation

Audience measurement cookies: these cookies are used to measure the site's audience. CompaRecycle uses Google Analytics cookie: obtaining your consent is necessary for the deposit of this cookie.

In accordance with Directive 2002/58/EC of July 12, 2002, CompaRecycle obtains your prior consent for cookie placement. You can, at any time, express your choice or modify it:

Through your browser settings

Internet Explorer: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

Safari: https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=fr_FR

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

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

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

Via the tarteaucitron.js tool offered by CompaRecycle: you are informed of the collection of this information thanks to the cookies banner that appears during your 1st navigation on the site.

The maximum retention period for cookies is 13 months maximum after their first deposit on the browsing terminal.

12. Modification of the Privacy Policy

We reserve the right to occasionally modify this privacy policy. If we do so, we will inform you by modifying the date located at the bottom of this policy. We encourage you to regularly consult our personal data protection policy to stay informed of our practices in this area and to know the means at your disposal to control the use of your personal data and protect your privacy.

Date of update of this privacy policy: July 2023