Cotélac attaches great importance to protection and respect of your personal data in the following context and in the context of any other contact that we may have. As it is acutely aware of the importance to ensure the confidentiality of data, Cotélac commits to protect personal data in accordance with the applicable regulations regarding personal data protection in Europe and in France.
This confidentiality policy applies to all natural persons of legal age. Its purpose is to inform you regarding our commitments and our practices in the collection, use and sharing of information you may be led to give us when you consult or purchase our products displayed and offered for sale under the « Cotélac », « acoté » and « Cotélac Homme » brands on our Websites on the following URLs: www.cotelac.fr and www.acoté.com / (hereinafter referred to as the « Websites »); and when you visit the shops we operate directly through COTELAC, SAS, a simplified stock corporation with capital of € 1 360 800, Rue du Professeur Luc Montagnier, ZA en Pragnat Nord – 01500 AMBERIEU en BUGEY, registered in the Bourg Registry of Trade & Companies under number 378 239 974 ( hereinafter referred to as « Cotélac »), or operate indirectly through our subsidiaries or commercial partners (hereinafter referred to as the « Shops »).
We may change or complete our confidentiality policy at any time, particularly for compliance with any changes in the legislation, regulations, case law or technology. In that event, the updating date will be clearly indicated at the head of this policy. Hence, it is up to you to regularly read this policy in order to be acquainted with the evolution of its content.
With respect to the legal and regulatory provisions, Cotélac is authorized to use personal data only in the following cases:
- - for execution of the contract,
- - for performance of a legal obligation,
- - with your consent,
- - in Cotélac’s legitimate interest.
In using our Websites and our services, or in interacting in any other way with us, our Shops and/or our Websites, you acknowledge that you have read this confidentiality policy and understand it, and consent to our collection, use, storage, processing and transmission of the personal data that we collect through our Websites and Shops in accordance with this confidentiality policy.
If you do not agree with this confidentiality policy, please do not visit these Websites, do not create a user account and do not use or submit your personal data to these Websites or our Shops in any manner.
ROCESSING OF YOUR PERSONAL DATA
The term « Personal Data » within the meaning of this confidentiality policy designates any information that enables direct or indirect identification of a natural person (e.g. surname, given name, registration number, telephone number, photograph, date of birth, address, digital fingerprint, etc.) that you choose to communicate to, or share with, us when you use the Websites or visit one of our Shops.
Cotélac commits to process your personal data in accordance with the 2016/679 European General Data Protection Regulation of the European Parliament and Council of 27 April 2016, as well as the laws applicable in the country in which your personal data are collected. We reserve the right to process additional data if such is required by law or in the context of a criminal case, investigation or proceeding.
PERSONAL DATA THAT WE COLLECT
1. Source of personal data
You will be asked to transmit personal data in the following situations:
Our Websites distributing our products: When you place an order on our Websites; when you fill out forms; when you create or modify a user account; when you create a list of favourites; and when you participate in promotional offers.
Our shops: When you visit our shops, fill out the customer card request and/or the customer sheet, interact with us, or purchase our products.
Events: When you participate in our events, surveys or market studies, competitions and other promotional events, including online, for example, through third party sites or networks such as Facebook, Twitter and Instagram
Our customer service: When you contact us by telephone, email or any other means of communication.
Letters, emails, SMS and other electronic messages.
If you provide us with personal data of third parties (for example: your family members, our customers or prospects), you must verify that such third parties are informed thereof and have authorized the use of their personal data as described in this confidentiality policy.
2. Type of personal data
We may collect and use the following various types of personal data according to the specific purpose intended:
- - Personal data, such as given name, surname, sex, age, date of birth, billing address and delivery address.
- - Contact data, such as address, email, land telephone number, cellular phone number, and fax number if such exists;
- - Banking data, such as means of payment (credit card, debit card and cheque), a copy of your two-sided identity card if such is required for antifraud purposes or by virtue of legal provisions applicable to money laundering.
- - Information regarding purchases that have been made, such as the date, products or services, place of purchase, complaints, returns and reimbursements.
- - Habits and profiles, such as data regarding your purchases; information regarding the activity or offers linked to the management of customer relations, purchasing habits, and preferences with respect to interests and recreation.
THE WAYS IN WHICH WE USE YOUR PERSONAL DATA
We may use your personal data for the following purposes:
- - The management of online purchases on our Websites or in our Shops, such as those on the customer’s account, or the management of basket and orders (as identified in the general terms and conditions of sale).
- - The management of sale and after-sale services and complaints (payments, invoices, returns, warranties, taxation, antifraud, management of delivery of purchased merchandise).
- - The sharing of information with commercial partners.
- - Compliance with the obligations imposed by law, the regulations or the European laws, and for establishment or protection of our rights in the context of a proceeding.
- - Provide you with the service you request (for example, proceed with the creation of your user account, manage the authentication on the Websites, manage your accounts, provide you with assistance, manage your lists of favourites, respond to your questions or contact requests that you submit to us, including through the after-sale service).
- - The Management of Customer Relations (hereinafter « CRM »): Offer you promotions and other personalized services, send you newsletters and other advertising messages regarding our products and services, invitations to events related to our brands (which we or our partners organize), surveys and market studies, and invitations to participate in competitions and lotteries, as well as other offers.
- - Analyze for the purposes of profiling and personalization your contacts with us, your areas of interest, your preferences and purchasing habits, and create individualized or aggregate profiles based on this information in order to determine how we can offer you a better service, and also to provide you with a personalized purchasing experience in our Shops.
It is necessary that you transmit your personal data for the purposes indicated above. If you refuse, you will not be able to make purchases on our Websites or enter in our CRM system and benefit from our personalized programmes and services.
The transmission of your personal data for your inclusion in the CRM system is optional and free charge, but only if you provide those data for the purpose of marketing as well as for profiling/personalization or for one or the other. You may at any time unsubscribe or decide to no longer participate by deleting our cookies and/or contacting us.
THE WAYS IN WHICH WE SHARE YOUR PERSONAL DATA
We share your personal data with our subsidiaries and franchisees, including those located in other countries, as well as with other companies that provide services in our name (as described hereinafter), whether under our management or that of a third party. We provide said companies and entities only with personal data that are necessary for execution of the services offered, and we prohibit them from using your personal data for any other purposes.
1. Sharing with subcontractors
On our Websites, your personal data may be shared with third parties that
- - provide services to the seller (preparation and delivery of orders, management of payments by credit or debit cards, antifraud controls, relations with the customs department for sales abroad, the web agency and the company hosting the site).
- - monitor and analyse the Website’s activity; provide technical and organizational services for the reasons specified above and below:
- - Maintenance of our customer database; maintenance and development of the Sites, provision of assistance in advertising and marketing; and management of emails, market studies, surveys, competitions, lotteries and promotions.
In our subsidiaries and shops and at our commercial partners, your personal data may be shared with third parties as subcontractors for the CRM and upon our instructions.
Such third parties may access, store and process your personal data to provide you with these services on our behalf, in your country or abroad. Our service providers are not authorized to use your personal data for a purpose other than to provide the services that are specified in contracts between us and them.
2. Sharing with other third parties
In the event of a transfer of assets or any other similar transaction (e.g. a merger, acquisition, reorganization or liquidation), the customers’ data will constitute one of the transferred assets, and we can share them with one of our legal successors, to the extent that such is allowed by law and according to our legitimate interest. Unless otherwise agreed, your personal data will remain subject to our pre-existing confidentiality policy.
We may also disclose your personal data to third parties pursuant to a law of the EU or a Member State in the context of legal proceedings, in response to a public authority for a legitimate reason, or to protect our rights, our security, our property, or the public.
PROTECTON OF CHILDREN’S PRIVACY
Our Websites are designed and intended for the general public. Our services are for persons who are at least 18 years of age. We do not intentionally request or collect, whether online or in our shops, personal data of persons under 18 years of age. If we are told or we see that we have collected a child’s personal data, we will delete them as soon as possible. We may use your personal data to verify the age and compliance with our rules with respect to age.
If you are not 18 years of age, please do not create a user account or make a purchase online and ask your legal representative to take the necessary steps.
STORAGE, ACCESSIBILITY AND TRANSFER OF PERSONAL DATA BY COTELAC
Personal data collected via the Websites are processed mainly through electronic means, including web analysis services hosted by the servers of service providers that we select both in and outside of the European Union. In our Shops, personal data may also be processed on paper. In both cases, personal data are recorded in our centralized database, secured and managed by our Customer Service and our sales and marketing department, for the purposes specified in the foregoing paragraph without prejudice to the provisions of the article related to the sharing of personal data.
Only our employees and sales agents may access personal data in order to carry out their assignments. Our employees and sales agents are subject to confidentiality obligations in accordance with the provisions of law applicable in such matters. If you consent to the processing of your personal data for the CRM, your personal data may be read, modified and updated by our employees in our Shops and/or online (in particular, the sales and marketing personnel).
If we must transfer your personal data to a foreign country in order to attain any of the purposes described herein -- including in countries in which the legislation regarding data protection differs from that which is in effect in your country -- we will take all necessary measures to ensure that any such transfers comply with the European data protection regulation, or any other standards of the country where we collect the data, so that your personal data remain secured and confidential.
ECURITY AND CONFIDENTIALITY OF YOUR PERSONAL DATA
We have established reasonable measures to guarantee the security of your personal data and avoid any accidental loss, as well as any undue access, use and disclosure thereof:
- - We use the Secure Socket Layer (SSL) technology – i.e. an encrypting tool that secures information when you transmit it via the internet.
- - We also use firewalls, password systems and other technologies and guarantees for proper functioning of our Website and for protection of our databases.
- - We also use surveillance systems to guarantee the security of our buildings.
The access to your personal data is limited in order to avoid any unauthorized access, modification or abusive use, and is authorized only for our employees and agents who need them to carry out their assignments and for our subcontractors and third parties as indicated hereinabove.
If we see, or have good reason to believe, that the security of your personal data in our possession or in our sphere of control has, or might have, been compromised, we will inform you of the matter in conformity with the legal prescriptions and according to the methods specified by law.
YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA – WHO DO YOU CONTACT?
Pursuant to articles 14 to 22 of the General Data Protection Regulation, any person who uses our services has the right to access, rectify, delete, oppose the use of -- particularly in the context of an automated processing -- or limit the processing of, his personal data, as well as the right to the portability of his data.
Consequently, you may at any time:
- - Ask us not to contact you in the future by letter, via our newsletters or by SMS
- - Ask us for a copy of your personal data that we possess
- - Ask us to correct, update or delete your personal data in our databases
- - Report to us any abusive use of your personal data
- - Ask us for the portability of your personal data
To that end, you may contact us by email at email@example.com or by post to Cotélac ZA en Pragnat Nord, Rue du professeur Luc Montagnier, 01500 Ambérieu-en-Bugey.
The requests for deletion of your personal data are subject to compliance with the legal obligations regarding the retention of documents that are incumbent on us.
When you contact us to exercise your rights, make sure you give us your name, email address, postal address and/or your telephone number in order for us to verify your identification and process your request within thirty (30) days.
If you no longer want to participate in one of the CRM programmes, you may unsubscribe at any time from our newsletters or SMS via the unsubscribing links and tools at the bottom of each newsletter, and in your account, and/or by contacting us.
RETENTION OF PERSONAL DATA
Your personal data may be retained for the duration of the business relationship and as long as necessary for the purposes described in this confidentiality policy. At the end of each period, your personal data will be retained only for compliance with our obligations specified by law and the regulations, or to enable us to retain proof with respect to our respective rights and obligations.
Prospects’ data are retained for a period of three (3) years, commencing to run as of the date of the last contact. Customers’ data are retained for a period of five (5) years, commencing to run as of the date of the last purchase. Your bank card data are not retained after the payment for your purchase/order.
The personal data regarding the details of your purchases that are processed for profiling and marketing purposes are retained for a limited period in accordance with the maximum duration authorized by law. Upon expiration of that period, the personal data will be permanently deleted or rendered anonymous.
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