Article 1. General provisions

1.1. The present GTC apply to all commercial transactions carried out through the Platform by the User for the benefit of Supermiro.

1.2. Supermiro reserves the right to modify the present GTC at any time by publishing a new version on the website https://supermiro.club/eng/gtc (hereinafter the "Website"). The present GTC applicable at that time are those in force at the date of acceptance of the present GTC when using the Platform and ordering Products/Services (i.e. the date of registration of the User on the Platform or the date of order by the User through the Platform).

1.3. These GTC are available for consultation on the Website. Supermiro also makes sure that their acceptance is clear and without reserve from the User. 

1.4.The User acknowledges having read all of these GTCs before ticking them and having accepted them without restriction or reservation. 

1.5.The User acknowledges that he/she has received the necessary advice and information to ensure that the offer is suitable for his/her needs when using the Platform and ordering the Products/Services.

1.6.The User declares that he/she is legally capable of entering into a contract under the laws of Luxembourg or that he/she can validly represent the natural person for whom he/she is entering into a contract.

1.7. Unless proven otherwise, the information recorded by Supermiro constitutes the proof of all transactions. 

Article 2. Purpose

These GTC determine the rights and obligations of the parties in the context of all the services detailed in Article 4 of these GTC.

Article 3. Price - payment - refund

3.1. The selling price of each Product is fixed by Supermiro. It is mentioned in euros before and after tax on the description sheet available on the Platform or its payment provider.

3.2. As this price is mentioned on the Platform exclusive of tax and inclusive of all taxes (in particular VAT, import VAT, packaging costs, customs duties, etc.), the User may not be asked to pay any sum other than that shown on the Product/Service description sheet.

3.3. Supermiro proceeds to the immediate invoicing of any Product/Service commercialized through the Platform upon the order by the User of any Product/Service with a cancellation option for the User at the latest 24 hours before the consumption of the Products/Services by filling in the withdrawal form at the following link.

3.4. The User accepts that, in the event of cancellation less than 24 hours before the consumption of the Product(s)/Service(s), he/she will not have any right to a refund of the sale price of the Product(s)/Service(s).

3.5. In accordance with Article L 222-9 (7) l) of the Consumer Code, orders for tickets for cultural events are not subject to a right of withdrawal for the User.

3.6. An order of Products/Services made by a User cannot be refunded even in case of loss or theft, nor can it be taken back or exchanged except in case of cancellation of the Products/Services. Supermiro reserves the right to accept the return of tickets in certain cases and at its sole discretion.

3.7. In case of cancellation or postponement of a Product/Service, Supermiro will inform the User as soon as possible by email or by phone. In case of cancellation, the Product /Service provider concerned will define the modalities of reimbursement and Supermiro's responsibility will not be considered as committed. If Supermiro is in charge of the refund, Supermiro will do it as soon as possible. Only the price of the ticket will be refunded. No expenses of any kind will be refunded or compensated by Supermiro. The refund will be made by the same means that was used to make the payment.

3.8. Payment for Products/Services purchased by Users through the Platform will be made solely through the Platform by credit card or gift card.

3.9. The Platform is subject to a security system. Supermiro uses modern and reliable technologies for the transmission, processing and recording of the payment data. Payments by credit card are made by the Digiteal system during the online transaction and the transmission of the User's data is done in a coded and secured form (https://www.digiteal.eu/).

3.10. The prices charged by Supermiro are expressed in Euros and take into account the VAT applicable on the day of the order.

Article 4. Performance and remuneration of The Products/Services

4.1. For each order of Product/Service made by the User via the Platform, Supermiro will collect from the User the sales price including VAT of the Product/Service.

4.2. Invoicing for the Products/Services will take place simultaneously with the confirmation of the order of the Products/Services by a User through the Platform.

4.3. The payment of the Products/Services by the User will result in the issuance of an invoice by Supermiro to be presented to the Partner. 

4.4. The User will be able to benefit from the Services/Product only after the effective payment and the reception of this payment by Supermiro.

4.5. The User can send all his requests to Supermiro only by email to this address.

Article 5. Access to the Platform by the User

5.1. Access to the Platform by the User is reserved for strictly personal use. 

5.2. When using the Platform and/or ordering Products/Services, the User declares that he/she is acting in a private capacity. 

5.3. In addition to accepting these GTC, access to the Platform is subject to the opening of an individual account. To do so, the User must provide data allowing him/her to be identified.

5.4. When opening this account, the User agrees to provide only accurate information, and to inform Supermiro without delay of any change affecting it by e-mail at the following address.

5.5. To access and use the Platform, the User must use the login and password created when opening an account on the Platform. The User undertakes to keep them secret and not to disclose them to any third party.

5.6. Indeed, the User will be the only one responsible for the access to the Platform thanks to his login and password, except in case of proof of fraudulent use that would not be attributable to him. In case of loss, misappropriation or fraudulent use of his login and/or password, the User commits to immediately notify Supermiro at the following address.

Article 6. Obligations of Supermiro

6.1. Supermiro commits itself to respect the applicable legislation regarding the exercise of a commercial activity (notably registration, accounting, social and fiscal obligations). 

6.2. Supermiro also commits to respect the laws and regulations that are incumbent upon it in its capacity as a professional, particularly with regard to the marketing of the Platform and the Products/Services that it sells on the Platform.

6.3. Supermiro commits itself to implement all means in order to satisfy its obligations in an optimal way by delivering a quality service to the Users.

6.4. It undertakes to reply to emails received by its customer service and its sales department within 5 working days of their receipt, in French or English.

6.5. All exchanges between Supermiro and the User are strictly confidential. Supermiro commits itself not to disclose the content of these exchanges to a third party.

Article 7. Limitation of liability

7.1. Supermiro is bound to an obligation of means in the context of the access to the Platform by the User in the context of any reservation or order of Product/Service made through the Platform by the User. Supermiro cannot be held responsible for the non-performance of the services previously agreed upon with the User due to the faulty behavior of the Partner or its staff, in case of force majeure, such as a disruption or total or partial strike, in particular, of the postal services or means of transport and/or communication. 

7.2. An order made by a User cannot be reimbursed by Supermiro in case of loss or theft by the User and fraudulent use of the invoice by a third party.

7.3. Finally, Supermiro declines any responsibility regarding the sales that the User concludes through the Platform with the Partners. Any complaint related to the descriptions, texts, comments, photos, video, etc. appearing on the description of the Products/Services will be redirected to the designated Partner, who will assume the whole and only responsibility and liability in this respect.

Article 8. Intellectual property

8.1. All texts, comments, works, illustrations, works, and images reproduced or represented on the Platform are strictly reserved under copyright law and intellectual property law for the entire duration of the protection of these rights and for the entire world. In this respect and in accordance with the provisions of the amended law of 18 April 2001 on copyright, related rights, and databases, only use for private purposes is authorized, subject to different or even more restrictive provisions provided for by law. Any reproduction or representation, in whole or in part, of the Platform or of all or part of the elements found on the Platform is strictly forbidden.

8.2. The company names, brands, and distinctive signs reproduced on the Platform are protected under trademark law. The reproduction or representation of all or part of one of the aforementioned signs is strictly forbidden and must be subject to prior written authorization from the trademark holder.

Article 9. Partial nullity

If one or more provisions of these GTC are held to be invalid or declared as such in application of law; a regulation; or a definitive decision of competent jurisdiction, the other provisions shall retain all their force and scope.

Article 10. No waiver

If during the course of the contractual relationship Supermiro does not require the performance of any of the provisions of these GTC, this shall not be construed as a waiver of the said provision, so that the User may not subsequently invoke the said total or partial non-performance of the said provision.

Article 11. Applicable law and attribution of jurisdiction

The present GTC applicable between the User and Supermiro are subject to Luxembourg law and interpreted in accordance with Luxembourg law.

Article 12. Personal Data

12.1. Supermiro is likely to collect personal data concerning the User and which are the following:

• Name and surname of the User ;
• The User's telephone number; and
• The professional and/or personal e-mail address of the User.
• The date of birth of the User

12.2. The personal information collected by Supermiro via the present GTC are registered in its customer file and mainly used for the good management of the relations with the User and the realization of the services provided by the present GTC.

12.3. The information collected is kept for a period not exceeding two years, after the end of access to the Platform by the User, unless :

• A longer retention period is permitted or required by law or regulation;
• One of the Partner's employees has exercised, under the conditions set out below, one of the rights granted to him/her by the legislation currently in force in Luxembourg.

12.4. By adhering to these general sales conditions, the User consents to the collection and use of his/her personal data for the purpose of providing the services previously agreed upon with Supermiro.

12.5. Access to personal data is strictly limited to Supermiro's employees and agents, partners and payment provider(s), who are authorized to process such data due to their functions. The information collected may be communicated to third parties linked to Supermiro by contract for the execution of subcontracted tasks necessary for the realization of the Services without the express authorization of the Customer's employees. It is specified that, within the framework of the execution of their services, the third parties have only limited access to the data and have a contractual obligation to use them in accordance with the provisions of the applicable legislation regarding the protection of personal data. Apart from the cases stated above, Supermiro commits itself not to sell, rent, transfer or give access to third parties to the data without the prior consent of the User, unless forced to do so for a legitimate reason (legal obligation, fight against fraud or abuse, exercise of the rights of defense, etc.). 

12.6. The User's personal data are collected by Supermiro in accordance with the General Data Protection Regulation of 27 April 2016 applicable as of 25 May 2018 (hereinafter "GDPR") on the protection of individuals with regard to the processing of personal data and the free movement of such data.

12.7. Supermiro is the person responsible for the processing of the personal data collected. 

12.8. By accepting these GTC, the User agrees to the collection and use of his/her personal data for the purpose of providing the services previously agreed with Supermiro.

12.9. The User has, in accordance with the RGPD, a right of access, modification, rectification, deletion, opposability and limitation of personal data concerning him. These rights can be exercised either by mail to the address given above, or by e-mail to the following address: [email protected].

12.10. The data protection policy implemented by Supermiro in order to protect the personal data of the Users within the framework of the services is available below.

12.11. The User also has the right to file a complaint with the Luxembourg supervisory authority, namely the National Commission for Data Protection or CNPD, under the following link Complaint form - Individuals - National Commission for Data Protection - Luxembourg (public.lu)

DATA PROTECTION POLICY

Date of last update: October 20th , 2021

Effective date: October 18th, 2021
 

1. Introduction

Our quick and easy to understand explanation before anything else:

At SPMO S.A. (hereinafter "Supermiro") ("we", "us" or "our"), we take privacy and confidentiality issues very seriously. We have developed this data protection policy (the "Data Protection Policy") in order to clearly define and explain how we are committed to respecting your privacy rights at all times; how we collect personal data through your use of our website (supermiro.club), our newsletters, and the services offered through Supermiro the Club (the "Club") and how we use this personal data.

Any processing of your personal data is carried out in accordance with applicable data protection laws, including but not limited to, the European General Data Protection Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

By using our Services, you acknowledge that you have been informed of this Data Protection Policy and that you understand and agree with its contents. We reserve the right to adapt this data protection statement if the operation of our website makes this necessary.

To put it simply:

• We do not work with external agencies, the information you give us access to is only used by Supermiro to improve the quality of our service.
• Supermiro is not a service or a platform that sells or resells to third parties information related to our users. We analyze and compile statistics of aggregate consultation rates to understand the interest of our users in a systematically anonymized way. The data collected will not be passed on to third parties without your express consent, unless we are legally required to do so.
• You may revoke the consent you have given at any time.
• Supermiro's goal is to create links between people for a more open and inclusive world. In short, to create a world where everyone can discover and access everything that is happening around them. We are a community built on trust... We are committed to being transparent; to answer your questions. Supermiro is a human-sized company, and we always do our best to fulfill our primary mission: to give people a good time and make users smile every day.
• One of the fundamental elements to gain this trust is to be clear about how we use your information and protect your privacy. This data protection policy explains what personal data Supermiro processes, how Supermiro processes it and for what purposes, in detail.

2. Definitions

2.1. Personal data (or Data) 
Any information which directly, indirectly, or in combination with other information - including a personal identification number - allows the identification or identifiability of a natural person. 

2.2.Use of  data 
The information collected automatically by Supermiro in the context of the provision of its services offered through its website, its mobile application, its platform dedicated to the Club (or by third party services employed), which may include the IP addresses or the domain names of the computers used by the Users who use this Service, the URI addresses (Uniform Resource Identifier), request time, the method used to submit the request to the server, File size the size of the file received in response, the numerical code indicating the status of the server response (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the User, the various time details per visit (e.g. time spent on each page in the Application) and path details in the Application with special reference to the sequence of pages visited, and other parameters relating to the User's operating system or computer environment. 

2.3.User  
The person using the services made available by Supermiro which, unless otherwise specified, corresponds to the Person concerned. 

2.4. Data Subject 
The natural person to whom the Personal Data refers. 

2.5. Sub-processor 
The natural or legal person, public authority, institution, or any other body that processes Personal Data on behalf of the Data Controller, as described in this Privacy Policy. 

2.6. Data Processing 
Any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (Article 4 of the GDPR Law).

2.7. Data Controller 
The natural or legal person, public authority, institution, or any other body that, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the services made available by Supermiro. Unless otherwise stated, the Data Controller is the Owner of the websites and mobile applications offered.

2.8. Application 
The means by which the User's Personal Data are collected and processed by Supermiro through its websites or mobile applications.

2.9. Service 
The service provided by this Service is described in the relevant terms and conditions (if any) and on this Site/Application.

2.10.European Union (or EU)
Unless otherwise indicated, all references in this document to the European Union include all current Member States of the European Union and the European Economic Area.

2.11. Cookie  
A small piece of data is stored in the User's device.

2.12. Legal information 
This privacy policy has been prepared in compliance with the provisions of several laws (General Data Protection Regulation).

3. Owner and dat controller

3.1. Owner

Name: SPMO S.A.

Email: [email protected]

Address: Supermiro, 29 boulevard Grande Duchesse Charlotte

L-1331 Luxembourg

3.2. Data Protection Officer (DPO)

Name: Christophe L.

Email: [email protected]

Address: Supermiro, 29 boulevard Grande Duchesse Charlotte

L-1331 Luxembourg

4. Personal Information Collected & Use

4.1. Data collection at Supermiro

We carry out Data Processing in accordance with the services you wish to access and we are committed to protecting your Personal Data, ensuring confidentiality and processing your Personal Data only for the following purposes

• the execution of the services you access;
• management of our relationship (including payment processing, billing, support services, etc.);
• to comply with our internal policies and procedures (including our document retention policy); and
• to comply with any Personal Data retention obligations imposed on us by law.

4.2 Cookies and similar technologies

Our website uses cookies and similar technologies to ensure that it functions properly, to enhance your experience, and to analyse and improve the impact of our content. For more information on the use of cookies on our website and the options available to you in this regard, please see our Cookie Policy. (see point 6)

4.3. Navigating our platforms

When you use our website and applications, we collect information to improve our service. The data collected includes: date and time of your visit, experiences viewed, tips viewed and tours viewed.

4.4. Your account

4.4.1.  Your Supermiro Le Club account

Thanks to your super boss, you will have the possibility to create an account on our Supermiro Le Club platform in order to access unique culinary and cultural experiences. The processing of data related to your Club account is necessary to provide you with this account and the related features on the basis of the contractual relationship concluded when you use our Club services (Article 6 (1) (b) of the GDPR Law). 

As part of creating a Club account and accepting this Privacy Policy, you may choose to access the following options/services:

• Subscription to weekly newsletters with information about the Club;
• Access to the platform and club content;
• Purchase and reservation of experiences offered through the Club

In order to use and/or browse the Club, we ask you to provide us with:

• Name, First name, Emails, Date of birth.

When you wish to book and purchase an experience through the Club, you will need to make the payment for this purchase by credit card to our payment provider and provide the following information:

• Last name, First name, Card number, CVC code.

For more information about the processing of your data by this provider, please refer directly to the data protection policies and the privacy policy available under this link

• We retain your account information for 2 years after you unsubscribe from the Services.

You can change some of your account information or delete your account directly in your account preferences.

The fields marked with an asterisk in the registration form are mandatory data. You can choose not to provide this data. Without providing this data, you cannot create an account on our website or our application and thus use the latter.

4.5 Newsletters 

We offer various services that allow you to stay informed of the latest news. 

You can subscribe to our newsletters (weekly and informative) by e-mail.

• The weekly newsletters inform you about new experiences available for Le Club. You can manage your subscription to these newsletters in the "My account" menu of the website. You can also contact us directly via our contact form, by email or by replying to these newsletters if you do not wish to receive them anymore by yourself using the unsubscribe link in the footer of each newsletter. We will then manually remove your email address from the mailing list within one week.

For the provision of these services, we process your personal data on the basis of the execution of consent (Article 6(1)(a) GDPR Law).

• We store your data for this purpose:
• Trace of the sending of a newsletter: 2 years (to ensure the functioning of the unsubscribe link)

Newsletter content: 6 months.

4.6. Contact via our forms

On the basis of your consent, if you contact us (e.g. via the contact form or directly by email), your following data will be saved to process your request: Name, First name, Email address, Company name, User type. If you are logged in with your account, your contact requests are linked to your account. In addition, in case of a booking or sale, your data will be transmitted to the partner and the data you provide in the context of this connection will also be transmitted to this partner without us having any control over the use they may make of it.

We keep the data related to our exchange for a period of 2 years.

4.7. Backups, Cleanups, Unsubscriptions, and General Maintenance

4.7.1. Logging data

We may use log data relating to visits to our site:

• To resolve problems with the functionality of our site and to correct bugs based on the performance of the contract or your consent that applies when you use our services (Article 6(1)(a) or (b) GDPR Law).
• To detect and prevent unwanted or abusive activities (e.g. phishing or spam activities) based on the legitimate interest for fraud prevention (Article 6(1)(f) GDPR Law).
• We keep the log data for a period of 6 months.

Our log file contains data that our users provide automatically when they visit our site by virtue of the communication protocols in force. The provision of this data is therefore technically necessary to access our site.

4.7.2. Content hosted on third-party servers

When you visit a page on our website that contains such content hosted on third-party servers, your HTTP request, including information about your user-agent (i.e. the device with which you access our website) and your IP address, is transmitted to the server of the third party concerned. If necessary, your request is accompanied by a referrer, which tells the target server the address of the page on which the content in question is embedded.

The transmission of your HTTP request with a referrer, if applicable, in this context is necessary for the purposes of our legitimate interest in providing our audience with a diverse and attractive website (Article 6(1)(f) GDPR Law).

We do not store your data for these purposes.

The providers from whom we integrate content on our site, i.e. the recipients of your data, may vary over time. These are typically online service providers. For the transfer of your data to recipients outside the European Economic Area, we rely either on an adequacy decision adopted by the European Commission or on standard data protection clauses adopted by the European Commission.

The provision of your HTTP request is technically necessary to access our site under current communication protocols.

4.7.3.  Data backup - backups

We may retain your data in connection with backups that we perform based on our legitimate interest in backing up data in connection with our website in order to be able to restore it in the event of loss or hardware failure (Article 6(1)(f) GDPR Law).

• We keep our database backups for 20 days.
• We keep the website files for a period of 2 years.

To make our backups, we use a solution offered by the data center that also hosts our servers. In this capacity, the data center is also the recipient of your data. You are not obliged to provide us with any data specifically so that we can make backups of it.

4.7.4. IP location

We may process your IP address to determine the country from which you access our website and, depending on your location, give you access or not to certain content based on our legitimate interest in complying with our intellectual property obligations (Article 6(1)(f) GDPR).

• We keep track of your IP address for 3 months and then anonymize it.

The provision of your IP address is technically necessary to access our site.

4.7.5. Statistical cleanup processing

At regular intervals, cleaning of the internal audience statistics is carried out in order to remove the erroneous data related to the passage of robots (indexing or malicious) in order to have an objective vision of the interest of the users for the products offered by Supermiro.

5. Users' rights

You have a legal right to obtain information to enable you to determine whether we hold your personal data, to access it and to make corrections, update, revise or delete it within reasonable limits. We will respond to your request to exercise such rights within a reasonable time (and in any event within 30 days of receipt of a request).

5.1. Accessing your Data.

Users have the right to know whether Data is being processed by the Owner, to obtain information about certain aspects of the processing and to obtain a copy of the Data being processed. Such additional information includes details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Provided that the rights and freedoms of others are not affected, we will send you a copy of your personal data.

You have the right to request access to the information we hold about you. You can do this by contacting us at [email protected] or by using the request form available in the "my account" section. To enable us to respond to your request, we may ask you to confirm your identity.

5.2.  Verify and obtain a correction.

Users have the right to verify the accuracy of their Data and to request that it be updated or corrected.

You have the right to request the rectification of any personal data concerning you that are inaccurate and, taking into account the purpose of the processing, you may request that information be added to your personal data if it is incomplete.

At any time, you can access and change your personal information in the Account Preferences for your account on our website. However, if you still feel that the information we have about you is incorrect, please contact us so that we can update it and ensure its accuracy.

If any of your personal information changes (e.g., e-mail address), please review this information in the Online Preferences, or e-mail us the changes to allow us to correct or update your personal information.

5.3. Have your Personal Information deleted or erased

Users have the right, under certain conditions, to obtain the deletion of their Data from the Owner.

If at any time you wish Supermiro to delete your information, you can do so in the Online Preferences, or you can simply contact us at this e-mail address: [email protected]. In some cases, such as when we need your data for the exercise of the right to freedom of expression and information or for the establishment, exercise, or defense of legal claims, your right to erasure may not apply.

5.4. Oppose the processing of your Data

Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are added in the relevant section below.

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your data based on legitimate interest. In this case, we will no longer process your data, unless we have compelling legitimate grounds for the processing that override your interests and rights and freedoms or we require your data for the establishment, exercise, or defense of legal claims.

You still have the right to object at any time to the processing of your data for the sole purpose of canvassing, in which case we will cease to process them for this purpose.

5.5. Withdraw your consent at any time

Users have the right to withdraw their consent if they have already given their consent to the processing of their Personal Data. Withdrawing their consent does not affect the lawfulness of the processing based on the consent prior to the withdrawal of consent.

5.6. Limiting the processing of your Data

Users have the right, under certain conditions, to limit the processing of their Data. In this case, the Owner will process their Data only for storage purposes.

You have the right to obtain the limitation of the processing of your data when:

• You dispute the accuracy of your data
• The processing is unlawful
• We no longer need your data, but you need it for the establishment, exercise, or defense of legal claims
• You have objected to the processing and we have not yet been able to verify whether we have any legitimate grounds that override yours

Where processing has been restricted, your personal data may, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or on important European Union or Member State public interest grounds.

You are informed when we lift the restriction on the processing of your Personal Data.

5.7. Retrieve your Data and transfer them to another controller

Users have the right to retrieve their Data in a structured, commonly used, and machine-readable format and, if technically possible, to transmit it to another data controller without any obstacles of any kind. This provision applies, provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract to which the User is party, or on pre-contractual obligations.

5.8. Obtaining additional information

If any information is missing from this data protection policy or if you wish to obtain clarification of any of the items mentioned here, you may contact the DPO at [email protected].

5.9. Filing a complaint

Users have the right to file a complaint with their competent data protection authority. (CNPD: 15 Boulevard du Jazz, L-4370 Belvaux).

Before lodging such a complaint, we encourage you to send us your questions and remarks concerning the processing of your personal data directly by email to [email protected]. We take the protection of your personal data seriously and will do our best to respond to any complaints you may have.

You can exercise any of these rights by contacting us at: [email protected]

You can also change some of your account information or delete your account directly in your account preferences.

To exercise your rights in relation to cookies and similar technologies used on our site, please see our Cookie Policy below.

6. Policy on Cookies and Similar Technologies

Supermiro uses cookies. This policy informs you about the use of these cookies on the website, the sub-websites of supermiro.com, the mobile applications as well as the options available to you in this respect.

6.1. What is a cookie?

Cookies are portions of code installed in the browser that help the Owner to provide the Services according to the purposes described. Some of the purposes for installing Cookies may also require the User's consent.

A cookie is a small text file that is sent to your browser when you visit a website. It can be sent either directly by the server hosting the website you are visiting or by a third-party server to which the website may have forwarded your request. By default, your browser stores the cookie and returns it each time you make a new request to the server from which it originated. A cookie can only be read by the server that set it. A cookie may, for example, contain an identification number that allows your browser to recognize you when you interact with the website in question. It may also contain a simple "yes" or "no" answer, for example, to remember your choice to accept cookies.

Alternatively, a website can use the localStorage function of your browser. LocalStorage works in essentially the same way as a cookie. Similar to a cookie, this function allows your browser to save data about a website and access it when needed. A registration by localStorage is specific to a given server. For the purposes of this policy, the term "cookie" refers to both a cookie and the localStorage function.

6.2. Who can place cookies on our website?

The cookies on our site can be issued either directly by us or by the suppliers with whom we collaborate or by the partners of these suppliers. In the case of the Club, only Supermiro issues cookies.

Where the installation of Cookies is based on consent, such consent may be freely withdrawn at any time by following the instructions provided in this document.

6.3. Cookies and their purpose

6.3.1. Technical cookies strictly necessary for the functioning of the Service

Our website uses cookies to record your user session and to carry out other activities strictly necessary for the operation of the platform, such as traffic distribution. These cookies are required to allow the visit of our sites and the use of certain parts of them. They allow to:

• Keep the choice you have expressed on the deposit of cookies
• Securely access your personal account
• Keep your personal account logged in during your visit
• Interacting with our site, for example when you fill in forms
• Navigate between the different pages of our site

The use of these cookies is based on our legitimate interest to ensure the proper functioning of our services under Article 6(1)(f) of the GDPR Law. If you object to the use of these cookies, our website will not function.

6.3.2.  Cookies for improving the user experience and for measuring the anonymous internal audience

This Application uses Cookies to save browsing preferences and optimize the User's browsing experience. Among these Cookies are, for example, those that define language and currency preferences or those for the management of internal statistics used directly by the Owner of the site. These cookies are intended to facilitate access to our website and to make its use more pleasant and personalized. They allow us to:

• Personalize our website by remembering your preferences (for example, the appearance of popup settings or advertisements)
• Keep your personal account logged in from one browser session to the next.
• Audience measurement is required for the operation of the service but without collecting personal data because it is anonymous.

We need your consent under Article 6(1)(a) of the GDPR Law for the use of these cookies. You can always withdraw your consent at a later date. If you refuse to give your consent, you will not benefit from the additional features that these cookies provide.

6.4. List of cookies

6.5.  Person responsible for the processing of cookies

We are responsible for the collection of the request made to our site and the transmission of this request to the third-party providers mentioned in the above point as well as to the partners of these providers. We are also responsible for the data processing carried out for the purposes we pursue in connection with the technical cookies strictly necessary for the functioning of our website, the cookies for improving the user experience, and for measuring the internal anonymous audience, as well as the analytical cookies.

6.6. Retention period for cookies

We generally limit the retention period of our cookies to a maximum of one year.