Privacy Policy

Privacy Policy _
1- Introduction
HOLDHAM, a public limited company under French law, with share capital of 6160000 euros, registered with the Caen RCS under number 352998827 , located 1 rue du Campus14200HérouvilleHolyClearFrance ( “HOLDHAM” , “we” , “our” ) is the data controller. This means that we decide how we store and use the personal data we collect.

This Privacy Policy describes the way in which we collect and use personal data relating to users of “.MY-UNILUX” (“you”, “your”, “yours”) in accordance with the General Regulations on the Protection of Personal Data of the April 27, 2016 (“GDPR”) and applicable national laws.

It also describes the legal bases on which we process personal data, who we share it with and how it is stored.

It is important that you read this Privacy Policy , as well as any other notices of information we may provide on specific occasions when we collect or process your personal data, so that you know how and why we use this data .

By using “.MY-UNILUX”, you agree to the terms set out in this Privacy Policy. If you disagree with certain terms appearing in the Privacy Policy, we invite you not to use “.MY-UNILUX”

2- How is your personal data collected?
We collect personal data in different ways, as described below.

Data collected when creating a “.MY-UNILUX” account
To use “.MY-UNILUX” you must open an account by entering your email address. You will then receive an email containing an activation code allowing you to activate your account.

If you do not provide us with your email address, you will not be able to create an account and access the services offered by “.MY-UNILUX”.

Please note : in the event of “closure of the email address” (for example in the event of departure from a company, if you used a professional email address), you will no longer be able to have access to your account and your data.

When installing the “.MY-UNILUX” Application , we also collect the language and country of use by querying the IPStack service. We collect this information to be able to determine the language to display in “.MY-UNILUX”, the language we will use to communicate with you and also the location of your data in our nearest data centers.

Data collected during your use of the “.MY-UNILUX” site
We collect personal data directly from you when you shop on “.MY-UNILUX” as detailed below.

We collect information when establishing your order and your delivery note: name, first name, delivery address. We do not collect your banking details when you pay online. These are collected securely by our payment partner that we have chosen for its confidentiality and security guarantees.
We collect personal data from you when you contact us via the contact form.
We also collect data in order to study traffic and user journeys using analytical tools integrated into the “.MY-UNILUX” site. However, please note that this data is processed completely anonymously. This means that the link between the data and the user has been broken and under no circumstances can we trace the user back from the data.
Furthermore , please note that we use cookies on the “.MY-UNILUX” Site through which we collect some of your browsing data. If you would like to know more about the use of cookies on the “.MY-UNILUX” Site, please read the cookies policy.

3- For what purposes are your personal data collected?
We use your personal data for the purposes described below.

Purpose of processing

Legal basis for processing

Process the order and allow delivery of the chosen products to the address provided.

Performance of a contract we enter into with you ( ConditionsGeneral sales)

Enable the proper functioning of “.MY-UNILUX”,

including to process your comments/opinions, to manage your requests relating to your rights, to improve “.MY-UNILUX” and the services we offer, to enable the resolution of disputes, to handle complaints and to correct operating problems

Our legitimate interest: management and development of “.MY-UNILUX”

Performance of a contract we have entered into with you ( conditionsgeneralof use ) _

Contact you about “.MY-UNILUX”

Performance of a contract we have entered into with you ( conditionsgeneralof use ) _

Ensuring the security of “.MY-UNILUX” and preventing illicit activities on “.MY-UNILUX”

Our legitimate interest: management of “.MY-UNILUX” and compliance with the legal obligations to which we are subject

Send reminders in the event of a basket awaiting validation.

Our legitimate interest: management of “.MY-UNILUX” and compliance with the legal obligations to which we are subject

Send commercial information via the newsletter

Based on your prior consent

Carry out statistical analyzes and studies on your use of the SiteWeb “.MY-UNILUX”

Our legitimate interest within the meaning of the GDPR

Organize competitions upon registration

Execution of the competition contract

We believe that the risk associated with personal data that we process on the basis of our legitimate interests is not excessive or overly intrusive. In particular, we have put in place measures to protect your rights by applying appropriate retention periods and ensuring appropriate security controls.

No profiling will be carried out and more generally no automated decisions will be taken on the basis of the data collected.

4- Commercial communications and opt-out
You may receive administrative emails from us (emails concerning changes in the operation of “.MY-UNILUX”, the privacy policy, etc.).

Furthermore , if you have consented, you can receive the newsletter via emails containing offers and information concerning “.MY-UNILUX” compatible products.

You can withdraw your consent and request to no longer receive commercial emails by using the unsubscribe link in the message received or by sending us a request at this address: .

5- Duration of retention of your personal data
We keep your personal data on an active basis for the duration that your user account is active. Then , 36 months after your last authentication to your “.MY-UNILUX” account, we keep your data in archive databases for the time legally necessary.

6- Recipients of personal data
We will share your personal data with third parties when required to do so by law, when necessary to manage the contractual relationship we have with you or when we have another legitimate interest in doing so. We will share your personal data with the following categories of third parties:

the daughter company of HOLDHAM which ensures processing and delivery
the HOLDHAM company which supports the order management and delivery activity
the company that provides us with the Shopify hosting provider platform
our other service providers who support our business such as IT and logistics providers.
Our banking partner who ensures online order payment.
Please note that your personal data will never be sold. We will never rent or sell your personal data.

We may also disclose your personal data to third parties:

if we sell or buy a business or assets, we may disclose your personal data to the prospective seller or buyer of that business or assets; And
if HOLDHAM or any part of its assets are acquired by a third party, in which case personal data held by HOLDHAM will be one of the transferred assets.

7- Data transfers outside the European Economic Area
We may transfer your personal data outside the SpaceEconomicEuropean (“ EEA ”) in the following cases:

As part of the management of our customer base, we may share your contact data with a company that has joined the “ Privacy” program.Shield ” established by the United States Department of Commerce ; located in the United States .
As part of our use of the Google cookieAnalytics , we may share your connection data with the Google company which has joined the “ Privacy” program.Shield ” established by the United States Department of Commerce .

Please note that we take necessary precautions to ensure that these service providers implement adequate guarantees and respect strict conditions regarding confidentiality, use and protection of data.

8- Public authority
We may disclose your personal data to legally authorized bodies and authorities as part of an investigation into illegal activities that may result in our liability, your liability or the liability of another user of “.MY-UNILUX”.

9- Your rights
As a data subject, you have certain rights with regard to your personal data. These rights are not absolute and each of these rights is subject to certain conditions in accordance with the GDPR and applicable national laws.

The right of access: you have the right to obtain from us confirmation whether or not your personal data is processed by us, as well as certain other information ( similarhasthoseprovidedIntherepresentPolicyofConfidentiality ) on how they are used. You also have the right to access all of your personal data via an email sent to the address:
The right to rectification: you can rectify or correct certain personal data in “.MY-UNILUX” if they are inaccurate or incomplete via “my account”.
However , please note that your account is inherently linked to your email address. We are unable to change the email address that is linked to your account.

The right to erasure: also known as the "right to be forgotten " , this right allows you to erase or request the erasure or deletion of your personal data when, for example, there is no there is no compelling reason for us to continue using them or their use is illegal. However, this is not a general right to erasure and there are some exceptions, for example where we need to use the information to defend a legal claim or to be able to comply with a legal obligation.
You can decide to permanently and irrevocably delete your account and your personal data at any time. To do this, you must send your request by email to the address: When deleting your account and all data stored on it, you will receive an email confirming the deletion of your account.

The right to restrict processing: You have the right to ' block ' or prevent further use of your personal data when we are assessing a request for rectification or as an alternative to erasure. Where processing is restricted, we may still retain your personal data, but we cannot use it further.
The right to data portability: you have the right to obtain and reuse certain personal data for your own purposes across different companies (which are separate data controllers). This only applies to personal data that you have provided to us, which we process with your consent and for the purposes of contract performance, which are processed by automated means. In this case, we will provide you with a copy of your text data in a structured, commonly used and machine-readable format.
The right to object: you have the right to object to certain types of processing, for reasons relating to your particular situation, at any time, to the extent that this processing takes place for the purposes of legitimate interests pursued by HOLDHAM. We will be allowed to continue processing personal data if we can demonstrate that the processing is justified by compelling legitimate reasons which override your interests, rights and freedoms or if we need it for the establishment, the exercise or defense of legal actions. If you object to the processing of your personal data for direct marketing purposes, you can unsubscribe from email communications by using the " unsubscribe " button at the bottom of each communication.
The right to withdraw your consent: Where we process your personal data based on your consent, you have the right to withdraw your consent at any time. However, such withdrawal does not affect the lawfulness of the processing which took place before such withdrawal. You can unsubscribe from the email newsletter by using the " unsubscribe " button at the bottom of each email or by sending your request by email to the following address:
The right to provide us with instructions on the use of your personal data after your death: you have the right to provide us with instructions on the management (for example, retention, erasure and disclosure) of your data after your death. death. You can change or revoke your instructions at any time.
If you would like further information about your rights, wish to exercise any of them or have a complaint, please contact us at:

If you are not satisfied with our response to your complaint or you believe that the processing of your personal data does not comply with applicable data protection laws, you can lodge a complaint with a supervisory authority regarding data protection. If you reside in the European Union, you may file this complaint with the supervisory authority of the country in which you reside. If you do not reside within the European Union, you can file your complaint with the Commission Informatique et Libertés (CNIL) which is the data protection authority in France.

We will review all such requests and provide our response within the time limits required by applicable law. Please note, however, that some personal data may be exempt from such requests in certain circumstances, including if we need to continue to process your personal data for its legitimate interests or to comply with a legal obligation.

You will not have to pay any fees to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. We may also refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access that information (or exercise your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to anyone who does not have the right to receive it.

10- Security
We and our service providers have adopted physical, electronic and administrative security measures to protect your personal data, including the use of threat and attack monitoring, passwords and encryption techniques. allowing you to secure access to your personal data.

11- Contact of the data protection officer
We have appointed Ms. Virginie Ori as data protection delegate to monitor compliance with this Privacy Policy. If you have any questions about this Privacy Policy, how we process your personal data or if you wish to exercise any of your rights, you can contact our Data Protection Officer


Address: Holdham, for the attention of the Data Protection Officer, 1 rue du Campus, 14200 Hérouville-Saint-Clair, France.

12- Modifications to this Privacy Policy
We reserve the right to update this Privacy Policy at any time. Please check this Privacy Policy regularly to be informed of any changes. We may also notify you by any means, from time to time, of any changes in the processing of your personal data.

We kindly ask you to also read the General Conditions of Use of the Application and the “.MY-UNILUX” Website.

Cookies Policy of the “.MY-UNILUX” Website
When consulting the “.MY-UNILUX” Website, cookies are placed on your computer, tablet or smartphone. This page allows you to better understand how cookies work and how to use current tools to configure them.

1- What is a cookie?
A cookie is a small text file in alphanumeric format that is sent to your browser and stored on your computer's hard drive. A cookie file allows its issuer to identify the terminal in which it is recorded, during the validity or recording period of said cookie.

2- What cookies do we use?
On the “.MY-UNILUX” Website, we use the following types of cookies:

Technical cookies: these cookies have the exclusive purpose of enabling and facilitating navigation on a website, as well as access to different products and services. Technical cookies make it possible in particular to recognize the Internet user, to indicate their passage on a particular page and thus to improve their browsing comfort.

These cookies we use include: (

User-centric security cookies to detect authentication abuses for a limited persistent duration, such as failed login attempts. These cookies are set for the specific task of improving the security of the service.
Multimedia content playback session cookies (flash cookies) are used for the duration of a session to record technical data necessary for playing video or audio content (for example: image quality, speed of network link, and caching settings).
Load balancing session cookies are used for the duration of the session to identify the same server in the pool to allow the load balancer to redirect user requests appropriately.
Persistent user interface personalization cookies are used to store a user's preference for a service across multiple pages.

Audience measurement cookies: these cookies are intended to obtain information on Internet users' navigation on a website in order to produce audience statistics and measurements.

According to the Shopify website:

User experience is fundamental and we use many tools to help us improve our website. To this end, we use performance cookies to collect information about how and how often you use our website. These cookies only collect information for statistical purposes and do not collect any information that could identify you personally. However, because these cookies are not strictly necessary for the use of our website, we need your consent to use them. The performance cookies we use include:

Proprietary analytics cookies - We use these cookies to estimate the number of unique visitors, to improve our website and to detect the most searched words in search engines leading to a web page. These cookies are not used to target you with online marketing. We use these cookies to learn how our website performs and to make relevant improvements to improve your browsing experience.
We also use Google Analytics and other third-party analytics providers to help us measure how users interact with content on our website. These cookies “remember” our users’ actions on previous pages and how they interact with the website. For more information about Google Analytics, visit the Google information page. For instructions on how to opt out of Google Analytics, see below.

Targeting cookies are used on our website to personalize marketing to you and your interests and to provide you with a more personalized service in the future. These cookies remember your previous visit to our website and we may share this information with third parties, such as advertisers. Although these cookies may track your visits to our website and other sites, they generally cannot identify you personally. Without these cookies, the advertisements you see may be less relevant and less interesting to you. We do not use third-party advertising cookies.

Finally, social plugin tracking cookies are used by many social networks that have “social plugin modules”. We integrate these modules into our platform to offer services that can be considered “explicitly requested” by our users. However, your consent is required because some third-party social plugin tracking cookies are used for purposes such as behavioral advertising, analytics and/or market research.

3- How to control cookies?
You have the following options to reject/delete statistical cookies.

Configuring your browser:

Most browsers accept cookies by default. However, you can decide to block these cookies or ask your browser to notify you when a site tries to implement a cookie on your device.

For cookie management and user choices, the configuration of each browser is different. It is described in the help menu of the browser used, it allows you to know how to modify your cookie preferences. For exemple :

Firefox Click the menu button and select " Options ." Select the “ Privacy panel . Set the " Retention Rules " menu to " Use custom settings for history". Uncheck the “Accept cookies” box. Any changes you made will be automatically saved.

Google Chrome Select the Chrome menu icon . Select"Settings" . At the bottom of the page, select "Show advanced settings" . In the "Privacy" section , select "Content Settings" . Select"Ban all sites from storing data" . Select OK.

InternetExploreClick the Tools button , then click "Internet Options" . Click the "Privacy" tab , then press the "Advanced" button to bring up the Advanced Privacy Settings window . Then check the box"Ignore automatic cookie management" , then select "Refuse" in the "Third-party cookies" column .

SafariClick on “Settings” > “Safari” > “Security. In the “ Accept cookies ” area, check the box of your choice.

Please note: configuring your browser in this way may result in the deletion of all cookies, including those allowing good navigation on the “.MY-UNILUX” Site. If you wish to delete only the audience measurement cookie " GoogleAnalytics ", please refer to the option described below.

Downloading a browser add-on for opting out of Google Analytics:

If you do not wish to transmit information to Google Analytics, you can download and install the module accessible by following the following link This module is compatible with Chrome, Internet Explorer 11, Safari, Firefox and Opera.

4- More information on cookies
For more information on cookies, you can go to the website of the Commission Informatique et Libertés, at this address: