PRIVACY POLICY AND PROTECTION OF PERSONAL DATA



Last update: 29/08/2019

We intend to offer the highest level of protection for your personal data, in accordance with the rules, practices, recommendations and best practices referred to in the applicable legal and regulatory provisions, whether from European or local sources, and in particular Regulation (EU) 2016/679 of the European Parliament and of the Council on the Protection of Personal Data (the "GDPR") of 26 April 2016, which came into effect on 25 May 2018.

This "Privacy and Data Protection Policy", hereinafter "Personal Data Policy", describes our commitments to the protection of personal data and informs you of the methods of processing them, the precautions taken to protect them and reminds you of your rights, and how you can exercise them.



  1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

The controller of your data is:

RYCHAL DE CARNE, a simplified joint-stock company with a single shareholder and a capital of 10,000 euros, registered with the Paris Trade and Companies Register since 08/06/2016 under number 820 815 660. Registered office: 30 rue de la Trémoille 75008 PARIS.

Hereinafter referred to as "RYCHAL DE CARNE" or "Us".



  1. WHAT PERSONAL INFORMATION DO WE COLLECT?

The personal data collected concern both personal and non-personal data, but also electronic identification data relating to the computer terminal used to access the Site www.rychaldecarne.com (hereinafter referred to as "the Website").

We collect the data you provide us when you create a customer account, place an order, interact with our customer service, participate in a contest or subscribe to our newsletter.

We may, therefore, collect your surname, first name, e-mail address, postal address, and if applicable, telephone number, date of birth, measurements/sizes as well as your taste and clothing preferences or your banking data (this list is not exhaustive and depends on your relationship with RYCHAL DE CARNE).

The mandatory or optional nature of the information to be provided is indicated by an asterisk at the time of collection.

To ensure complete rigor in the management of the Data concerning you, you are requested to provide us only with complete, accurate and up-to-date information that does not prejudice the interests or rights of third parties.

Certain data are also collected automatically as a result of the activity of users of the Website (hereinafter referred to as Users) on the Website, in particular by "Cookies", the existence and disposal of which is indicated below in the section entitled "Use of Cookies" and in the document dedicated to them on this Website.

This data identifies the connection terminal, which is used to access this Website. It is specified that these data alone are generally not sufficient to identify a User by name.



  1. FOR WHAT PURPOSES ARE YOUR PERSONAL DATA USED?

Personal data that may be collected by RYCHAL DE CARNE are treated confidentially. They are operated solely for purposes relating to the facilitation of our relationship with you, the implementation of RYCHAL DE CARNE's promotional and commercial activity and the proper administration of our management systems and processes.

The possible processing purposes are summarized in the following table:

Purposes

Shelf life

Learn more

Customer relationship management (creation and use of a user account, exchanges with our customer service, sending transactional emails and notifications)

3 years after last contact

We process the data necessary to create your user account and to inform you following contact with our Customer Service or in the event of a complaint.

Your data is also used to inform you by SMS and/or e-mail of the progress of your order and to notify you of the confirmation of a return request and, if necessary, to refund the returned products or in the event of cancellation of the order.

Purchase /Management of orders, deliveries and returns

Bank details are kept for the duration of the payment transaction.

We use the personal information collected to manage the payment of products according to the payment method used, ensure the preparation and delivery of products ordered online.

Subscribe to our newsletter and email commercial offers

3 years after last contact

If you have subscribed to our newsletter, we may send you newsletters to inform you about new products and promotions.

You may also receive email or SMS from us following the purchase of our products to offer you products similar to those you have purchased (Article L.34-5 of the French Post and Electronic Communications Code).

You may object at any time to the sending of such messages from us by following the instructions specified in each of our messages.

Analysis of buying behaviors and Targeted Advertising

3 years after last contact

Except cookies and other tracking devices: 13 months

Some of your browsing information, such as the products you have seen or added to the shopping cart, the sections of the site visited or your purchase history can be collected, in order to determine your preferences in order to offer you commercial communications tailored to your profile, i.e. personalized according to your interests or previous purchases.

Site navigation and user experience optimization

The duration of the session and a maximum of 13 months

Through the use of cookies and similar technologies, we collect data during your online browsing allowing us to ensure the proper functioning of our site and offer you an optimized experience of our services such as the creation and storage of a shopping cart until the confirmation of your order or the security of your connection.

Some cookies also allow us to know the use and performance of the Site to improve the usability of our services.

For more information see our Cookies Policy

Fraud Prevention

3 years after incident or report

We are required to activate the necessary mechanisms to prevent possible fraud attempts and ensure the security of payments during transactions.

Organization of contests

3 years after the end of the contest, unless we are legally required to keep them longer

The processing of your personal data allows us to manage the draws, communicate with the candidates and send the prizes to the winners.



  1. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR DATA?

We rely on the legal bases set out below to be able to process personal data:

  • The execution of the contract:

The processing of the User's data is necessary for the execution of the sales contract and, if necessary, to provide the subscribed services. If the user wishes to purchase our products and does not provide this data, it will not be possible to make the sale. The User is therefore under obligation to provide the data necessary for the execution of the sales contract.

  • Legal obligations:

For the invoicing of online purchases, the management of the exercise of the right of withdrawal and the refund of returned products, the processing of the customer's data is based on RYCHAL DE CARNE's legal obligations in the context of its relationship with the said customers.

  • Consent:

For the following actions: the creation of customer accounts, the sending of newsletters and customized commercial offers to customers, the analysis of the Site's performance and purchasing behavior, the organization of contests, the processing of Personal Data is based on consent.

  • Legitimate interest:

For the prevention of fraud, the detection of bugs and the optimization of online browsing as well as the sending of offers concerning products similar to those you have purchased, the processing of Personal Data is based on RYCHAL DE CARNE's legitimate interest.



  1. PERSONAL DATA POLICY FOR VULNERABLE PERSONS

Some of our services may be used by minors, without us being aware of it. If information is collected from a minor or a legally unauthorized person, the minor's or person's legal representative will always have the opportunity to contact RYCHAL DE CARNE to have the personal data concerned immediately deleted, rectified or modified under the conditions described in Article 8 of the Personal Data Policy.



  1. WITH WHOM DO WE SHARE YOUR DATA?

Your data may be transmitted to the following categories of recipients:

  • RYCHAL DE CARNE's internal services in charge of the execution of the subscribed services, in particular, IT, accounting and marketing logistics services.



  • Technical and operational service providers, external to RYCHAL DE CARNE, who have support and tool management functions such as our online payment, delivery, or hosting service providers.

Most of them have the status of "subcontractors" within the meaning of the GDPR. They are bound to RYCHAL DE CARNE by agreements that determine the methods of managing Personal Data and guarantee that all appropriate measures for their security have been taken. The entire processing chain is therefore controlled and supervised.



  • The judicial or administrative authorities empowered by law, which would be required to request disclosure, following the laws and regulations in force.



  • For specific purposes, your data may be shared with some of RYCHAL DE CARNE's business partners with whom it participates in joint business operations. In this regard, it is specified that these operations only take place, where applicable, in cases expressly authorized by law, and with your prior consent, in particular for purposes naturally arising from the relationship you have with RYCHAL DE CARNE. If other types of treatment are considered, be assured that they can only be used after you have been informed in advance, after allowing yourself to express your choice clearly and indisputably, and if necessary, by obtaining your formal consent.



  • To collect information to analyze the website's audience and improve its content, your data may be transmitted and stored by Google on its servers when using the Google Analytics tool.

Google may also transfer this information to third parties if required to do so by law or if they have a partnership agreement.

You can disable the use of this tool by selecting the appropriate settings in your browser. Such deactivation may prevent the use of certain features. By using this website, and unless you deactivate its analysis tool, you expressly consent to the processing of some of your data by Google.

For more information on Google Analytics privacy policies, and also if you want to disable this tool by installing the Google add-on module, click on the following link: https://policies.google.com/technologies/partner-sites?hl=en



  1. STORAGE AND SECURITY OF PERSONAL DATA



Your data are kept for the time necessary for their processing, and, unless otherwise expressly or legally permitted, for a maximum of three (3) years from the day of their collection or our last contact with you. Electronic identification data are kept for thirteen (13) months from the date of collection.

Under the aforementioned legal exceptions, your data may be stored for evidentiary purposes, following the legal and regulatory provisions in force (in particular those provided for by the Civil Code and the Consumer Code).

RYCHAL DE CARNE is extremely vigilant and has taken the appropriate technical measures, in particular, those recommended by the CNIL, regarding the risks of a security incident involving personal data and their consequences for individuals. These consequences can range from the simple inconvenience caused to you, to cases of diversion, intrusion, disclosure, and alteration, which may cause serious harm. RYCHAL DE CARNE has therefore set up various measures to prevent these risks, including technical tools following the rules of the art, to ensure information security. Information on these techniques may be communicated to our correspondents and contacts who may have a legitimate interest in ensuring this, subject of course to the usual rules of confidentiality and security. Among the mechanisms envisaged are various information partitioning devices, firewalls, access control procedures, the use of cryptography mechanisms, etc. RYCHAL DE CARNE guarantees that at least restrictions and controls on access to the Data are applied, only to persons authorized to know or access it under their functions and who have been specially trained in data protection issues. Where the processing is likely to present risks, additional security measures shall be implemented.

However, the User acknowledges and accepts that RYCHAL DE CARNE, although equipped with the aforementioned devices and the expertise of professionals in these techniques, is not in a position to control all the risks associated with the operation on the Internet, including malicious attacks directed against it by particularly well-equipped entities. RYCHAL DE CARNE is therefore obliged to draw your attention to the existence of possible risks, which may arise, in extreme cases and despite the precautions taken, in terms of occasional loss or breach of confidentiality of data passing through the networks.

RYCHAL DE CARNE has set up a specialized monitoring team, composed of its technicians, representatives of internal services, likely to be potentially exposed to these risks and qualified external consultants. This team is kept up to date, in particular with the recommendations regularly issued on these subjects by the CNIL, the recent European Committee for the Protection of Personal Data and the National Agency for the Security of Information Systems. RYCHAL DE CARNE also has a Crisis Management Committee, structured so that, within the short deadlines prescribed by law, all the technical, legal and notification measures legally prescribed are taken very quickly, for the best protection of the interests of the persons concerned.



  1. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?



By the Privacy Policy, you have the following specific rights:

Right of access (Art. 15 of the GDPR): you have the right to access your Personal Data, which has been collected by RYCHAL DE CARNE and to check in particular:

  • That the processing carried out on it is following the purposes set out in this RYCHAL DE CARNE Data Policy,

  • That the categories of Personal Data concerned by the processing are limited to those expressly covered by the Personal Data Policy,

  • That the recipients to whom the Data are communicated are those provided for in the Personal Data Policy.

Right of rectification (Art. 16 GDPR): you have the right to obtain from RYCHAL DE CARNE as soon as possible, the rectification of any inaccurate Personal Data and the completion of any incomplete ones.

Right of erasure (Art. 17 of the DGPS): you may request that your data be erased if they are inaccurate, incomplete, ambiguous, outdated, or if their collection, use, communication or storage is not necessary or even unlawful.

Right to limitation of processing: (Art. 18 of the GPDR): you may request RYCHAL DE CARNE to limit the processing of personal data in the cases provided for by the applicable texts.

Right to portability (Art. 20 of the GPDR): you have the right to receive your data in a structured, commonly used and machine-readable format, and to transmit them to another controller when the latter is based on consent or a contract and is carried out by automated processes.

Right of opposition (Art. 21 of the GPDR): you have the right to object to the processing of personal data concerning you if they are processed for prospecting purposes.

Automated individual decisions (Art. 22 of the GPDR): you have the right not to be the subject of a decision based exclusively on automated processing affecting you (induced legal effects) and may to this end lodge a complaint with the competent supervisory authorities (the CNIL for France, knowing that you may also act before the authority of the Member State in which your habitual residence is located, your workplace or the place where the violation was allegedly committed).

You may exercise at any time with RYCHAL DE CARNE all the rights and prerogatives provided for by the above-mentioned texts by sending an e-mail to the e-mail address [email protected] or by sending a letter to RYCHAL DE CARNE 30 rue de la Trémoille 75008 PARIS -- FRANCE, indicating your full name, e-mail address, and if possible your customer reference.

We remind you that your rights are strictly individual and can only be exercised by the person concerned about his or her information. Following the regulations in force, your request must specify the address to which the reply must be sent and be accompanied by a photocopy of documents to verify your identity.



  1. USE OF COOKIES

WEBSITE COOKIES

All web pages on this Website uses so-called "cookies". These systems, which are now universally used by sites, allow companies to collect certain information, mainly of a technical nature and to identify site users. Cookies are generally described as cookies, which are files generated by the site and sent to your browser to record your activities while you are browsing. Most market tool cookies remember the name of the cookie's domain of origin, its lifetime and a unique number created randomly.

RYCHAL DE CARNE uses cookies, which are generated as standard by its web tools when a user accesses the Website.

You are then informed that, during your visit, a cookie may be automatically installed on your browser. It is stored on the hard disk of your computer terminal. This file may be accessible through the tool on our websites during your subsequent visits. The maximum period of storage of this information by RYCHAL DE CARNE in the User's terminals, by the recommendations of the CNIL, is 13 months.

You can refuse the presence of Cookies by activating a setting on your browser. All details on the implementation of your refusal are available on the CNIL website: www.cnil.fr/fr/Cookies-les-outils-pour-les-maîtriser.

We draw your attention to the fact that, if the browser is configured to refuse all Cookies, you may experience technical difficulties and be blocked in your navigation. You may not be able to perform all the operations proposed, including having access to certain functions designed to facilitate your navigation on our Site.

You will find all the necessary information on our use of Cookies in a specific document to which we expressly refer, accessible at the corresponding tab entitled "Cookies Policy". This cookie information notice is also accessible directly with the hyperlink inserted in our "cookie banner", i. e. the warning that appears on your screen during your visits, until you have clicked on the said link and indicated your acknowledgment and acceptance of our Cookies Policy.

AUDIENCE ANALYSIS TOOLS

We also inform you that we use Google's audience analysis tool systems that also use Cookies, also described in the above Cookies Policy.



  1. MODIFICATION OF THE PERSONAL DATA POLICY AND ADDITIONAL INFORMATIONS



RYCHAL DE CARNE reserves the right to modify this Personal Data Policy at any time.

Any changes to the Personal Data Policy will be effective immediately upon posting and will be posted at the top of the page.

In the event of a significant change in our Personal Data Policy, such as a change in the purposes of collection, the renewal of the User's consent to our Personal Data Policy will be reiterated.

Consequently, the User is invited to regularly consult the Personal Data Policy to be informed of any changes that may have occurred.

If you have any questions about this privacy and data protection policy, you may contact us at any time by sending an e-mail to [email protected] or by sending a letter to the following address: RYCHAL DE CARNE 30 rue de la Trémoille 75008 PARIS - France.

If you wish to obtain additional information on the protection of Personal Data in general, you can consult the website of the Commission Nationale de l'Informatique et des Libertés (CNIL) at the following link: www.cnil.fr