Privacy policy

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This policy describes how Hard-Core Riders (“Kite Attitude / Foil Attitude”) collects and processes your personal data, in accordance with Regulation (EU) 2016/679 (GDPR) and the French Data Protection Act.

1. Data Controller

Hard-Core Riders, a simplified joint-stock company (SASU) with capital of 30,000 euros, headquartered at 33 rue des Voûtes, 76130 Mont Saint Aignan, registered with the Rouen Trade and Companies Register under number 823 982 418 00027. Publisher: Donatien Roger. Contact: contact@kiteattitude.com — +33 6 49 15 07 37. Data Protection Officer (DPO): [to be specified, if applicable].

2. Data Collected

Identity and contact information (last name, first name, email, phone number, shipping and billing addresses);

Order and billing data (products, amounts, history);

Payment data (processed by our payment service provider; not stored by us);

3. Purposes and Legal Bases

Kite Attitude collects and uses the personal data of its customers and users for specific, explicit, and legitimate purposes. The data collected is limited to what is necessary for the operation of the website, the processing of orders, customer relationship management, the security of our services, and, where applicable, the sending of marketing communications. All processing of personal data is based on a legal basis provided for by applicable regulations, in particular the General Data Protection Regulation (GDPR).

3.1. Management of Customer Accounts and Orders

When you create a customer account or place an order on the Kite Attitude website, we use the data necessary to create and manage your account, as well as to process your order. The data in question may include, in particular, your first and last name, your billing address and, if applicable, your shipping address, your email address, your phone number, information regarding the products ordered, and your order history. This data is used, in particular, to: * create and manage your customer account; * record and process your orders; * send you order confirmations; * ensure the preparation and delivery of your purchases; * inform you of the status of your order; * manage returns, refunds, warranties, and requests submitted to our customer service department; * monitor customer relations and maintain a record of your purchases. The legal basis for this processing is **the performance of the contract**, in accordance with Article 6(1)(b) of the GDPR, when the processing of data is necessary for the fulfillment of your order or the provision of the requested services.

3.2. Payment for Orders

Payment for orders can be made, in particular, via **PayPal**. When you choose PayPal as your payment method, certain information necessary for processing and securing the transaction may be transmitted to the relevant payment service provider. Your bank details or full PayPal account credentials, when payment is made directly through PayPal, are processed by that service provider and are not intended to be retained by Kite Attitude. Kite Attitude may, however, retain transaction-related information necessary for order tracking, billing, managing refunds, and handling any disputes. The legal basis for the processing necessary for payment and order fulfillment is **contract performance**. Processing carried out directly by PayPal is also subject to PayPal’s own terms and conditions and privacy policy.

3.3. Billing and Accounting Obligations

Certain data related to orders and transactions is used to issue invoices, maintain accounting records of business activity, and comply with the legal and tax obligations applicable to Kite Attitude. This data may include, in particular, the customer’s contact information, order details, the products involved, invoiced amounts, transaction dates, and information necessary for issuing and retaining invoices. The legal basis for this processing is **a legal obligation**, when the retention or use of the data is required by applicable regulations. The data is retained for the periods required by applicable legal and regulatory provisions, particularly with regard to accounting and tax matters.

3.4. Newsletters and Marketing Communications

Kite Attitude may offer users who wish to do so the opportunity to receive its newsletter and marketing communications. When you subscribe to our newsletter, your email address and the information necessary to manage your subscription are used to send you, in particular: * news about Kite Attitude; * information about our products; * new releases; * sales offers and promotions; * information about our events or activities; * content that may interest you related to kitesurfing, wing surfing, and related sports. These communications are sent through our technical service provider, **Brevo**. When your consent is required, it is obtained through an affirmative action on your part. You may withdraw your consent at any time, free of charge, including by using the unsubscribe link included in each newsletter. If you are already a Kite Attitude customer, certain marketing communications regarding products or services similar to those you have already purchased may—subject to compliance with the conditions set forth in applicable regulations—be sent without prior consent. You will be informed of this possibility when your email address is collected and will have a simple and free way to opt out of receiving these communications. The legal basis for this processing is **your consent**, when required, or, when the conditions of the exception applicable to existing customers are met, Kite Attitude’s **legitimate interest** in developing and maintaining its business relationship with its customers.

3.5. Important Information Regarding Safety and the Practice of Kiteboarding and Wing Surfing

Regardless of whether you subscribe to the marketing newsletter, Kite Attitude may send its customers electronic communications whose primary purpose is to provide important information regarding the safety, use, or practice of the products and equipment offered by Kite Attitude. These communications may include, in particular: * important recommendations or reminders regarding the safety of kitesurfing or wing surfing; * information regarding the use, maintenance, or safety of equipment; * warnings concerning a product or category of products; * information regarding a potential recall, defect, or safety issue affecting a product; * significant changes to safety recommendations or terms of use; * advice intended to assist practitioners in the safe and proper use of their equipment. The primary purpose of these communications is **to inform users and contribute to their safety when using Kite Attitude’s products and services**, not to conduct commercial marketing activities. They may therefore be sent to the relevant customers when necessary for providing information and managing the customer relationship, even if those individuals are not subscribed to the commercial newsletter. The legal basis for these communications may be **the performance of the contract**, when they are directly necessary for the service provided or the use of a product, or **Kite Attitude’s legitimate interest**, when these communications are necessary for managing the relationship with its customers and ensuring the safe use of products. Kite Attitude ensures that these com

munications are limited to information that is relevant and necessary for their intended purpose. They do not constitute a means of circumventing the rules applicable to commercial solicitation. When a message primarily serves a promotional or commercial purpose, the rules applicable to commercial solicitation apply.

3.6. Communications Regarding Orders and Customer Relations

Certain electronic communications are necessary for processing your order or managing your relationship with Kite Attitude and do not constitute commercial communications. These may include:

* order confirmations;

* payment confirmations;

* delivery information;

* information regarding a return or refund;

* responses to your inquiries sent to customer service;

* important information regarding your account;

* information necessary for the use or safety of a purchased product.

These communications are necessary for fulfilling the order or managing the contractual relationship. The legal basis for this processing is **the performance of the contract** or, where applicable, Kite Attitude’s **legitimate interest** in managing its relationship with its customers.

3.7. Website Security and Fraud Prevention

Kite Attitude may process certain data to ensure the security of its website and services, protect customer accounts, and prevent fraudulent or abusive behavior. In particular, this processing may be intended to: * detect and prevent fraud attempts; * secure customer accounts; * detect abnormal logins or behavior; * to protect the website against misuse; * to ensure the security of transactions; * to identify and resolve technical and security incidents. The legal basis for this processing may be Kite Attitude’s **legitimate interest** in ensuring the security of its website, systems, and business operations, provided that this interest does not disproportionately infringe upon the rights and freedoms of the data subjects.

3.8. Improvement of the Website and Services Kite Attitude may use certain technical information and data related to the website’s operation to improve its functionality, usability, and the services offered. In particular, this processing may help identify navigation difficulties, technical errors, or features requiring improvement. To date, **Kite Attitude does not use Google Analytics to compile audience statistics**. If new analytics, audience measurement, or tracking tools are implemented in the future, their use will be subject to the information disclosures and, where necessary, the collection of consent required by applicable regulations.

3.9. Principle of Purpose Limitation The personal data collected by Kite Attitude is used solely for the purposes described in this privacy policy or for purposes compatible with them. Kite Attitude ensures that it collects only the data necessary to fulfill these purposes and does not retain personal data for an excessive period of time. Retention periods are determined based on the purpose of the processing and, where required by law, applicable legal obligations.

4. Recipients and Processors

Your data is shared only with service providers necessary for the performance of the service: carriers and Boxtal (shipping), PayPal (payment), our transactional email service (Resend), and our web host. Each acts under a Data Processing Agreement (DPA). We do not sell your data to third parties.

5. Transfers Outside the European Union

Certain service providers (notably PayPal and Resend) may process data outside the EU. These transfers are governed by appropriate safeguards (standard contractual clauses, Data Privacy Framework).

6. Retention Periods

Customer account: until deleted, then archived; an inactive account is deleted/anonymized after 3 years;

Orders and invoices: 10 years (legal accounting requirement);

Marketing data: 3 years from the last contact.

7. Your Rights

You have the rights to access, correct, delete, object to, restrict, and transfer your data. You can exercise these rights through your account (under “My Personal Data”) or by writing to contact@kiteattitude.com. You may also file a complaint with the CNIL (www.cnil.fr).

8. Cookies

The website uses only cookies that are strictly necessary for its operation (session cookies, shopping cart cookies), which do not require your consent. No audience measurement or advertising cookies are set. Fonts are hosted locally (no third-party services are used). Should audience measurement tools be added in the future, a consent banner will be implemented.

9. Security

The site is accessible via HTTPS, passwords are encrypted (bcrypt), and technical and organizational measures protect your data.

10. Contact

For any questions regarding your data: contact@kiteattitude.com.