Security and protection of personal data
DEFINITIONS:
The Publisher: The person, natural or legal, who publishes communication services to the public online.
The Site: All the sites, Internet pages and online services offered by the Publisher.
The User: The person using the Site and the services.
NATURE OF DATA COLLECTED
In the context of the use of the Sites, the Publisher is likely to collect the following categories of data concerning its Users:
Civil status, identity, identification data …
Data relating to personal life (lifestyle, family situation, excluding sensitive or dangerous data)
Data relating to professional life (CV, education, professional training, distinctions …)
Economic and financial information (income, financial situation, tax situation …)
Connection data (IP addresses, event logs …)
Location data (movements, GPS data, GSM …)
COMMUNICATION OF PERSONAL DATA TO THIRD PARTIES
Communication to authorities on the basis of legal obligations
On the basis of legal obligations, your personal data may be disclosed in application of a law, a regulation or by virtue of a decision of a competent regulatory or judicial authority. In general, we agree to comply with all legal rules which could prevent, limit or regulate the dissemination of information or data and in particular to comply with Law No. 78-
17 of January 6, 1978 relating to data processing, files and freedoms.
Communication to third party partners
We may make certain personal data available to strategic partners working with us, for the provision of products and services or helping us to market our products to customers.
Communication to third parties with recipient restrictions
The personal data that you communicate to us during your order are transmitted to our suppliers and subsidiaries for processing thereof. This information is considered by our suppliers and subsidiaries to be strictly confidential.
VIRALITY OF THE CONDITIONS OF REUSE OF PERSONAL DATA
No commitment on the virality of the conditions of re-use
If your personal data is communicated to a third party, the third party’s confidentiality conditions apply.
PRIOR INFORMATION FOR THE COMMUNICATION OF PERSONAL DATA TO THIRD PARTIES IN THE EVENT OF MERGER / ABSORPTION
Prior information and possibility of opt-out before and after the merger / acquisition
In the event that we take part in a merger, acquisition or any other form of disposal of assets, we are committed to ensuring the confidentiality of your personal data and to inform you before they are transferred. Or subject to new privacy rules.
PURPOSE OF REUSE OF COLLECTED PERSONAL DATA
Perform operations relating to customer management concerning
- the contracts ; the orders ; the deliveries ; the bills ; accounting and in particular customer account management
a loyalty program within one or more legal entities; - monitoring customer relations such as conducting satisfaction surveys, managing complaints and after-sales service
- the selection of customers to carry out studies, surveys and product tests (except with the consent of the persons concerned collected under the conditions provided for in article 6, these operations must not lead to the establishment of profiles likely to reveal sensitive data – racial or ethnic origins, philosophical, political, trade union, religious opinions, sex life or people’s health)
Perform prospecting operations
- management of technical prospecting operations (which includes technical operations such as standardization, enrichment and deduplication)
- the selection of people to carry out loyalty, prospecting, survey, product test and promotion actions. Unless the consent of the persons concerned is obtained under the conditions provided for in article 6, these operations must not lead to the establishment of profiles likely to reveal sensitive data (racial or ethnic origins, philosophical, political, trade union, religious, sex life or people’s health)
- carrying out solicitation operations
Development of trade statistics
The transfer, rental or exchange of its customer files and its prospect files.
Updating of its prospecting files by the organization in charge of managing the telephone canvassing opposition list, in application of the provisions of the consumer code.
Management of requests for the right of access, rectification and opposition.
DATA AGGREGATION
Aggregation with non-personal data
We may publish, disclose and use aggregated information (information relating to all of our Users or to specific groups or categories of Users that we combine so that an individual User can no longer be identified or mentioned) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising, and other business purposes.
Aggregation with personal data available on the User’s social accounts
If you connect your account to an account of another service in order to cross-send, that service may communicate your profile and connection information to us, as well as any other information for which you have authorized disclosure. We may aggregate information relating to all of our others.
Users, groups, accounts, to personal data available on the User.
COLLECTION OF IDENTITY DATA
Free consultation
Consultation of the Site does not require registration or prior identification. It can be carried out without your communicating any personal data concerning you (surname, first name, address, etc.). We do not record any personal data for the simple consultation of the Site.
COLLECTION OF IDENTIFICATION DATA
Use of the user identifier for connection proposal and commercial offers
We use your electronic identifiers to search for relationships present by connection, by email address or by services. We may use your contact information to allow others to find your account, including through third-party services and client applications. You can download your address book so that we can help you find knowledge on our network or to allow other Users of our network to find you. We can offer suggestions to you and other Network Users from contacts imported from your address book. We are likely to work in partnership with companies that offer incentive offers. To support this type of promotion and incentive offer, we may share your electronic identifier.
GEOLOCATION
Geolocation for the purpose of providing the service
We collect and process your geolocation data in order to provide you with our services. We may need to use personal data in order to determine your geographic position in real time. In accordance with your right of opposition provided for by law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, to deactivate the functions relating to geolocation.
Geolocation for crossover purposes
We collect and process your geolocation data in order to allow our services to identify crossing points in time and space with other users of the service in order to present you the profile of cross-users. In accordance with your right of opposition provided for by law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, to deactivate the functions relating to geolocation. You acknowledge that the service will no longer be able to present you with a profile of other Users.
Geolocation with provision of partners for referencing and aggregation (with opt-in)
We can collect and process your geolocation data with our partners. We are committed to anonymizing the data used. In accordance with your right of opposition provided for by law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms, you have the possibility, at any time, to deactivate the functions relating to geolocation.
TERMINAL DATA COLLECTION
Collection of profiling data and technical data for the purpose of providing the service
Some of the technical data of your device is collected automatically by the Site. This information includes your IP address, Internet service provider, hardware configuration, software configuration, type and language of the browser, etc. The collection of this data is necessary for the provision of services.
Technical data collection for advertising, commercial and statistical purposes
The technical data of your device are automatically collected and recorded by the Site, for advertising, commercial and statistical purposes. This information helps us to personalize and continually improve your experience on our Site. We do not collect or store any personal data (surname, first name, address …) possibly attached to technical data. The data collected may be sold to third parties.
COOKIES
Storage period of cookies
In accordance with the recommendations of the CNIL, the maximum duration of storage of cookies is a maximum of 13 months after their first deposit in the User’s terminal, as is the duration of the validity of the User’s consent to the use of these cookies. The lifetime of cookies is not extended with each visit. The User’s consent must therefore be renewed at the end of this period.
Purpose cookies
Cookies can be used for statistical purposes, in particular to optimize the services rendered to the User, from the processing of information concerning the frequency of access, the personalization of the pages as well as the operations carried out and the information consulted.
You are informed that the Publisher may place cookies on your terminal. The cookie records information relating to navigation on the service (the pages you have consulted, the date and time of the consultation, etc.) that we will be able to read during your subsequent visits.
User right to refuse cookies
You acknowledge having been informed that the Publisher may use cookies. If you do not want cookies to be used on your device, most browsers allow you to disable cookies through the setting options.
CONSERVATION OF TECHNICAL DATA
Technical data retention period
The technical data are kept for the time strictly necessary to achieve the purposes referred to above.
PERIOD OF RETENTION OF PERSONAL DATA AND OF ANONYMIZATION
Data retention for the duration of the contractual relationship
In accordance with article 6-5 ° of the law n ° 78-17 of January 6, 1978 relating to data processing, the files and freedoms, the personal data being treated are not preserved beyond the time necessary for the performance of the obligations defined at the conclusion of the contract or the predefined duration of the contractual relationship.
Retention of anonymized data beyond the contractual relationship / after deletion of the account
We keep personal data for the time strictly necessary to achieve the purposes described in these Terms. Beyond this period, they will be anonymized and kept for exclusively statistical purposes and will not give rise to any exploitation of any kind whatsoever.
Data deletion after account deletion
Data purging means are put in place to provide for their effective deletion as soon as the retention or archiving period necessary for the accomplishment of the determined or imposed purposes is reached. In accordance with law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms, you also have the right to delete your data which you can exercise at any time by contacting the Editor.
Data deletion after 3 years of inactivity
For security reasons, if you have not authenticated yourself on the Site for a period of three years, you will receive an e-mail inviting you to connect as soon as possible, otherwise your data will be deleted from our databases. data.
Account deletion on demand
The User has the possibility of deleting his Account at any time, by simple request to the Publisher OR through the Account deletion menu present in the Account settings if necessary.
Account deletion in case of violation of the T & Cs
In the event of violation of one or more provisions of the CGU or of any other document incorporated herein by reference, the Publisher reserves the right to end or restrict your use and access without any prior warning and at its sole discretion services, your account and all Sites.
INFORMATION IN THE EVENT OF A SECURITY FAILURE DETECTED BY THE PUBLISHER
User information in the event of a security breach
We are committed to implementing all appropriate technical and organizational measures in order to guarantee a level of security adapted to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of personal data about you.
In the event that we become aware of illegal access to personal data concerning you stored on our servers or those of our service providers, or unauthorized access resulting in the realization of the risks identified above, we undertake at :
- Notify you of the incident as soon as possible;
Examine the causes of the incident and find out about them;
Take the necessary measures within the limits of reasonableness in order to lessen the negative effects and damages that could result from the said incident
Limitation of Liability
In no case shall the commitments defined in the point above relating to the notification in the event of a security breach be assimilated to any acknowledgment of fault or responsibility for the occurrence of the incident in question.
TRANSFER OF PERSONAL DATA ABROAD
No transfer outside the European Union
The Publisher undertakes not to transfer the personal data of its Users outside the European Union.
MODIFICATION OF THE TOS AND PRIVACY POLICY
In case of modification of these Terms, commitment not to lower the level of confidentiality substantially without the prior information of the persons concerned
We undertake to inform you in the event of a substantial modification of these T & Cs, and not to lower the level of confidentiality of your data substantially without notifying you and obtaining your consent.
APPLICABLE LAW AND REMEDIES
Arbitration clause
You expressly agree that any dispute that may arise from these TOS, including its interpretation or execution, will be subject to arbitration proceedings subject to the rules of the arbitration platform chosen by mutual agreement, to which you unreservedly adhere.
DATA PORTABILITY
Data portability
The Publisher undertakes to offer you the possibility of having all your personal data sent to you on request. The User is thus assured of a better control of his data, and retains the possibility of reusing them. These data must be provided in an open and easily reusable format.
Request to be made at this address: smile@smileywines.com