Privacy Policy
Privacy Policy
Date of publication: 15.12.2022
Last update date: 07.07.2025
ARTICLE 1 – PREAMBLE
1.1. In the context of the products offered for sale by the Company TISSY & CO (hereinafter “TISSY & CO”), and in particular via its Website www.roreactive.com, TISSY & CO may collect and process personal data. Any information relating to an identified or identifiable natural person (e.g., surnames, first names, username, e-mail address, etc.) is personal data.
1.2. TISSY & CO is committed to the protection of the privacy and personal data of its users. The purpose of this policy is to specify the methods of collection and processing of personal data for which TISSY & CO is the controller or joint controller with the company TISSY, depending on the processing in question, in accordance with the applicable regulations in force.
1.3. The “TSE Group” refers to the Company TISSY & CO and TISSY.
1.4. This policy therefore aims to inform users of the www.roreactive.com Website of the practices implemented by TISSY & CO for the collection, processing, use, and sharing of personal data, as well as the procedures for exercising users' rights.
1.5. TISSY & CO reserves the right to modify this policy at its discretion and at any time, without prior notice to the user, according to the technical and/or commercial development of its products, its personal data processing and transfer practices, and the evolution of the applicable regulations in force. Modifications will enter into force on the date they are posted online and are enforceable against users from the date of their first use of the Website following their publication.
ARTICLE 2 – DATA CONTROLLER
2.1. The Company TISSY & CO, a simplified joint-stock company located at 455 Promenade des Anglais, 06200 Nice, and registered with the Antibes Trade and Companies Register (RCS) under number 901 912 832, is responsible for the processing of personal data implemented via the www.roreactive.com Website concerning (1) the management and processing of orders, (2) order billing and payment management (collection), and (3) the processing of withdrawal requests, legal guarantees, and the exercise of rights.
2.2. The Company TISSY & CO is a joint controller with the company TISSY, a simplified joint-stock company located at 455 Promenade des Anglais, 06200 Nice, and registered with the Antibes Trade and Companies Register (RCS) under number 901 912 832, concerning processing implemented (1) in terms of advertising, marketing, and other solicitations or commercial actions, and (2) the processing of requests to exercise rights, where applicable.
ARTICLE 3 – COLLECTION AND PROCESSING OF YOUR DATA
3.1. Personal data concerning you may be collected directly by TISSY & CO, in particular because it is necessary for the management, execution, and monitoring of orders as well as for the commercial relations of TISSY & CO and TISSY. Certain data is also kept for security purposes, in order to comply with legal and regulatory obligations and to allow the Website to improve and personalize the products offered and to send commercial solicitations to prospects who have consented and to customers of the Website.
3.2. TISSY & CO and TISSY do not collect any personal data concerning you from third parties.
3.3. Depending on the processing concerned, different personal data about you may be collected by TISSY & CO, or jointly by TISSY & CO and TISSY. As of today, there are five main processing activities implemented by TISSY.
3.3.1. Customer account, management, and order processing
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Data Controller: SAS TISSY & CO, 950 route roumanille 06410 BIOT
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Processed data: Data necessary for creating the customer account and placing the order (account creation data, i.e., e-mail or mobile number and password) and for delivery (surname, first name optional, company name optional, address, postal code, city, telephone). |
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Retention period: 3 years from the date of order delivery. |
Your rights: You can view and rectify your personal data if it is incorrect directly on your account profile. You also have the right to the portability of your data under certain conditions. To exercise your right to portability, you can send your request by e-mail to data@trainsweateat.com. |
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Data recipients: Marketing and sales team, management of TISSY. Data necessary for the delivery of the order is communicated to the service provider in charge of delivery. Technical subcontractors in charge of data hosting and/or sending notifications and e-mails may also process your personal data. Their access is strictly regulated and their use is strictly limited to the execution of the service. |
Transfer outside the EU: Your personal data is stored on servers located in Ireland in accordance with SHOPIFY’s declarations (https://www.shopify.com/legal/privacy/https://www.shopify.com/legal/dpa). Some may be transferred to the US and Canada according to the rules applied by SHOPIFY and under their responsibility. For more information on data transfers, see Article 6. TISSY and TISSY & CO ensure that these hosting providers guarantee standards and levels of data protection equivalent to those of European regulations. These providers have granted TISSY & CO contractual guarantees:
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Legal basis for processing: The General Terms and Conditions of Sale (GTC) of the Website. |
Profiling or fully automated decision-making producing legal effects or significantly affecting you: None. |
3.3.2. Order billing and payment management (collection)
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Data Controller: SAS TISSY & CO, 950 route roumanille 06410 BIOT
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Processed data: Data necessary for managing order billing (surname, first name, billing address, e-mail, payment method used, order amount, order details). |
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Retention period: 10 years from the end of the financial year in which the order took place. |
Your rights: You can request to view and rectify your personal data if it is incorrect. You can exercise your rights directly via your account and/or by sending your request to data@trainsweateat.com. |
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Data recipients: Marketing and sales team, accountant, management of TISSY & CO. Technical subcontractors in charge of payment management (STRIPE), hosting, and/or sending notifications and e-mails may also process your personal data. Their access is strictly regulated and their use is strictly limited to billing and collection management. |
Transfer outside the EU: Your personal data is stored on servers located in Ireland in accordance with SHOPIFY’s declarations (https://www.shopify.com/legal/privacy/https://www.shopify.com/legal/dpa). Some may be transferred to the US and Canada according to the rules applied by SHOPIFY and under their responsibility. For more information on data transfers, see Article 6. TISSY and TISSY & CO ensure that these hosting providers guarantee standards and levels of data protection equivalent to those of European regulations. These providers have granted TISSY & CO contractual guarantees.
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Legal basis for processing: Legal obligation. |
Profiling or fully automated decision-making producing legal effects or significantly affecting you: None. |
3.3.3. Management of withdrawal requests and exercise of legal guarantees
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Data Controller: SAS TISSY & CO, 950 route roumanille 06410 BIOT
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Processed data: All data collected about the customer in the context of the processing identified in 3.3.1. and 3.3.2. |
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Retention period: The duration of the litigation after the exhaustion of all remedies and/or legal statute of limitations for actions regarding legal guarantees and withdrawal. |
Your rights: You can request to view and rectify your personal data if it is incorrect. You can exercise your rights directly via your account and/or by sending your request to data@trainsweateat.com. |
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Data recipients: Marketing and sales team, management of TISSY & CO. Technical subcontractors in charge of hosting, marketing, sending notifications and e-mails, as well as legal and accounting subcontractors may also process your personal data. Their access is strictly regulated and their use is strictly limited to managing withdrawal requests and legal guarantees. |
Transfer outside the EU: Your personal data is stored on servers located in Ireland in accordance with SHOPIFY’s declarations (https://www.shopify.com/legal/privacy/https://www.shopify.com/legal/dpa). Your personal data may be transmitted to technical service providers (subcontractors) located outside the EU or EEA, and whose servers may be located outside the EU or EEA. TISSY and TISSY & CO ensure that these providers guarantee standards and levels of data protection equivalent to those of European regulations. These providers have granted TISSY & CO contractual guarantees. For more information on data transfers to TISSY & CO subcontractors, see Article 6. |
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Legal basis for processing: Legitimate interest. |
Profiling or fully automated decision-making producing legal effects or significantly affecting you: None. |
3.3.4. Management of requests to exercise rights of persons
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Data Controller: SAS TISSY & CO, 950 route roumanille 06410 BIOT
Joint Data Controller: SAS TISSY, 950 route roumanille 06410 BIOT
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Processed data: All data collected in the context of the processing identified in 3.3.1., 3.3.2., 3.3.3, and 3.3.5. |
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Retention period: Five years from the end of the calendar year of the request to exercise rights. |
Your rights: You can request to view and rectify your personal data if it is incorrect. You can exercise your rights directly via your account and/or by sending your request to data@trainsweateat.com. |
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Data recipients: Marketing and sales team, management of TISSY & CO and TISSY. Technical subcontractors in charge of hosting, marketing, sending notifications and e-mails, as well as legal and accounting subcontractors may also process your personal data. Their access is strictly regulated and their use is strictly limited to managing requests to exercise rights. |
Transfer outside the EU: Your personal data is stored on servers located in Ireland in accordance with SHOPIFY’s declarations (https://www.shopify.com/legal/privacy/https://www.shopify.com/legal/dpa). Your personal data may be transmitted to technical service providers (subcontractors) located outside the EU or EEA, and whose servers may be located outside the EU or EEA and in particular in Canada. TISSY and TISSY & CO ensure that these providers guarantee standards and levels of data protection equivalent to those of European regulations. These providers have granted TISSY and TISSY & CO contractual guarantees. For more information on data transfers to TISSY and TISSY & CO subcontractors, see Article 6. |
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Legal basis for processing: Legitimate interest. |
Profiling or fully automated decision-making producing legal effects or significantly affecting you: None. |
3.3.5. Advertising, marketing, and commercial solicitations
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Data Controller: SAS TISSY & CO, 950 route roumanille 06410 BIOT
Joint Data Controller: SAS TISSY, 950 route roumanille 06410 BIOT
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Processed data: Client and prospect data necessary for managing and optimizing marketing, as well as sending commercial solicitations (newsletters, promotional operations, email marketing, push notifications), namely: surname, first name optional, email, time zone, device information, IP address, postal address, age, date of birth, location and language used, order history and details, browsing history. |
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Retention period: 3 years from the end of the client's commercial relationship, and 3 years from the last contact from the prospect.
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Your rights: You may request to view, rectify, or even delete your personal data via your Account. You also have a right to object to profiling and a right to data portability under certain conditions. You can withdraw your consent at any time by clicking on the "unsubscribe" button present in each newsletter. To verify the conditions for exercising your rights, you can consult the CNIL website. You may also exercise all your rights by sending your request to data@trainsweateat.com. |
Data recipient: Marketing and sales team, management of TISSY & CO and TISSY. Technical subcontractors in charge of hosting, marketing, sending notifications and emails may also process your personal data, namely in particular GOOGLE TAG MANAGER, AXEPTIO, KLAVIYO, IMGIX, SHOPIFY, GOOGLE ANALYTICS, FACEBOOK SDK, GOOGLE HOSTED LIBRARIES, INSTAGRAM. These technical providers are identified in particular in Article 6. Their access is strictly regulated by TISSY and TISSY & CO and their use is strictly limited to carrying out marketing operations on behalf of TISSY and TISSY & CO. |
Transfer outside the EU: Your personal data is stored on servers located in Ireland in accordance with SHOPIFY's declarations (https://www.shopify.com/legal/privacy /https://www.shopify.com/legal/dpa). Your personal data may be transmitted to technical providers (subcontractors) located outside the EU or the EEA, and in particular in Canada. TISSY and TISSY & CO ensure that these providers guarantee standards and levels of data protection equivalent to those of European regulations. These providers have granted TISSY and TISSY & CO contractual guarantees. For more information on data transfers to TISSY and TISSY & CO's subcontractors, see Article 6. |
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Legal basis for processing concerning prospects: Consent via a checkbox. Legal basis for processing concerning clients: The Site's general terms and conditions of sale |
Profiling or fully automated decision-making producing legal effects or significantly affecting you: None. |
ARTICLE 4 – COOKIES
4.1. TISSY and TISSY & CO use cookies on the Site www.roreactive.com
A cookie is a small text file left on your computer during your first visit to a Site. Your web browser will keep it for a certain period and send it back to the web server each time you reconnect.
4.2. Several types of cookies are used:
Cookies related to operations concerning personalized advertising, intended to ensure advertising tracking and enable the implementation of email and push notification campaigns.
Audience measurement cookies ("analytics"), allowing TISSY and TISSY & CO to better understand the User's use of the Site, with the goal of improving them. There are several types of analytics cookies, each collecting different types of data according to their purpose and use, allowing the collection of, in particular:
Information related to incidents, errors, and bugs encountered during use;
Data related to the performance of calls made and on-screen rendering;
Experimentation metrics, allowing two different types of behavior on the Site to be compared by two different Users, and to measure which of the two is the best behavior (in other words, the most appropriate);
Data on the opening of deep links;
Data allowing product development and improvement, such as data intended to collect information related to visited pages and screens, visit duration, categories, and products viewed;
Data allowing the creation of a profile on the user and their interests, to optimize and select personalized content that may interest them;
Data allowing market research to be exploited in order to generate audience data;
Data allowing the measurement of content performance and the correct display of products and photos;
Data related to marketing campaign tracking;
Data related to opening "Push Notifications" or "In-App" messages;
Cookies, user terminal identifiers, or other user terminal information.
Sharing cookies, allowing content from the Site to be shared on social networks. These are likely to be deposited on the Site by third-party sites, through sharing buttons in particular (Meta, including Instagram and Facebook, and YouTube).
Functionality cookies, intended to ensure internal redirects (internal cookie), enable User authentication, access to fonts, and access to and playback of photographs, images, and other multimedia resources.
Security cookies, intended to ensure the prevention of payment fraud (Stripe, Scalapay).
4.3. Audience measurement cookies are kept for a maximum of thirteen months from the user's first visit to the Site. The data collected via these cookies may be kept for a maximum of twenty-five (25) months.
4.4. For each third-party cookie, the User can find all information relating, in particular, to the purposes of cookie usage and the data controller at the following addresses:
Google Tag Manager: https://www.google.com/analytics/terms/tag-manager/
Axeptio: https://www.axeptio.eu/fr
Klaviyo: https://www.klaviyo.com/legal
Imgix: https://imgix.com/privacy
Google Analytics: https://marketingplatform.google.com/about/analytics/terms/us/
Facebook SDK: https://opensource.fb.com/legal/privacy/
Google Hosted Libraries: https://developers.google.com/speed/libraries/terms?hl=fr
4.5. During your first visit to the Site, a banner informs you of the presence of cookies on the Site and invites you to manage (accept or refuse) their use by accepting or refusing their installation. You can manage the Site's cookies by visiting the page - TO BE COMPLETED WITH THE LINK]. To learn more about cookies, you can also consult the CNIL website: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser.
4.6. Functionality, security, and certain audience measurement cookies are necessary for the proper use of the various services of the Site and do not require the User's consent. You can always object to their placement. In this case, your user experience may be degraded, and certain Site features may be unavailable, preventing access to certain services of the Site.
4.7. Sharing cookies, cookies related to operations concerning personalized advertising and personalization, and certain audience measurement cookies require prior information and your prior consent. They will not be placed until you have expressly consented to them.
ARTICLE 5 – YOUR RIGHTS
5.1. In accordance with applicable regulations (Act No. 78-17 of 6 January 1978, as amended, known as "Informatique et Libertés" and Regulation (EU) No. 2016/679 of 27 April 2016 on the protection of personal data), you have the right to access, rectify, object to, erase, and limit data, as well as the right to portability.
5.2. Your right of access allows you to know what data concerning you is processed by the Site, to obtain communication of it, and to verify its accuracy.
5.3. Your right to rectification allows you to request the correction of inaccurate data concerning you.
5.4. Your right to object allows you to object to your data being used by the Site for a specific objective, under the conditions set by the applicable regulations in force. This right may be exercised for prospecting, profiling, or to request the deletion of personal information, provided that the legitimate interest on which the processing of the data concerned is based is not compelling for the Site.
5.5. TISSY & CO, in its capacity as controller and joint controller of processing, only keeps your personal data for the time necessary for the various processing operations implemented. Upon expiration of the retention period indicated for each processing operation, the data is deleted. When the legitimate basis for processing your data is based on your consent or legitimate interest, you may exercise your right to erasure, provided that this does not conflict with the exercise of the right to freedom of expression and information, compliance with a legal obligation, their use for statistical purposes, or the establishment, exercise, or defense of legal claims.
5.6. You also have a right to the limitation of your data that you can exercise in the four cases provided for in Article 18 of the GDPR (a, b, c, or d)).
5.7. You also have a right to data portability, which allows you, subject to satisfying its legal conditions for exercise, to obtain a copy of the data held by TISSY & CO based on either consent or the performance of the contract, and potentially to transmit them to another controller. For more information on the conditions for exercising this right, you can consult the CNIL website: https://www.cnil.fr/fr/le-droit-la-portabilite-obtenir-et-reutiliser-une-copie-de-vos-donnees.
5.8. You can exercise your rights by contacting TISSY & CO:
By email to data@trainsweateat.com;
By mail to Société TISSY & CO – Personal Data Protection – 950 route roumanille 06410 BIOT
5.9. To facilitate the processing of your request, it is advisable to:
Indicate to us the processing operations concerned by your request;
Indicate to us the rights you intend to exercise;
Provide us with a copy of your identity document if requested, to allow us to ensure your identity in case of legitimate doubt.
5.10. If, however, you are not satisfied with the processing of your request to exercise your rights, you always have the possibility to refer the matter to the CNIL, Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.
ARTICLE 6 – DATA TRANSFER
6.1. Personal data collected and processed by TISSY & CO and co-processed by TISSY may be transmitted to commercial and technical subcontractor providers of TISSY & CO and TISSY in charge of ensuring the management of certain services (technical, marketing, and/or commercial) on their behalf.
6.2. The subcontractors of TISSY & CO are as follows:
For hosting: SHOPIFY
For PSPs: STRIPE
For cookies: Google Tag Manager, Axeptio, Klaviyo, Imgix, Shopify, Google Analytics, Facebook SDK, Google Hosted Libraries
For carrying out advertising and marketing services: Facebook and Instagram.
6.3. These service providers may be located in Europe, in the European Economic Area, or sometimes even outside the European Union. In the latter case, service providers located outside the European Union have access to users' personal data exclusively for the purposes of performing the services entrusted to them by TISSY & CO and/or TISSY, and under conditions that ensure a sufficient and appropriate level of data protection. In any event, such transfers are governed by commitments and declarations.
6.4. The company SCALAPAY, a simplified joint-stock company (SAS) with share capital of 1,000 Euros, registered with the Paris Trade and Companies Register under number 887 683 118, located at 33 rue Layette, 75009 Paris, is the data controller for processing related to payment for orders in three installments, payment monitoring, and debt collection management, where applicable. Bank details entered by the customer in order to proceed with payment in three installments are neither collected nor stored by TISSY & CO. TISSY & CO is the data controller for processing related to the collection of sums due for orders, which processing is subcontracted to SCALAPAY.