Data protection

Introduction

 

This Privacy Policy allows users to clearly and accurately indicate what personal data may be collected when browsing the Website, www.densmore.mc.

We are committed to respecting the privacy of Users. We also set out below the conditions in which the Users’ personal data are likely to be processed when browsing the Website.

 

1. Définitions

 

Data: any information relating to an identified or identifiable natural person (as defined by the GDPR);

GDPR: refers to the European General Data Protection Regulation No. 2016/679 of 27 April 2016;

“DC” or “we”: refers to the Havea Group (including all its subsidiaries), data controller (DC), whose head office is located at Parc d’Activité Sud Loire – BOUFFÉRÉ – 85 612 MONTAIGU Cedex, registered in the RCS de La Roche sur Yon under No. 823 334 578;

Website: refers to the Website accessible from the URL www.densmore.mc(including subdomain https://services.densmore.mc);

Processing: means “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction” (definition given by the GDPR);

“Users” or “you”: means all natural persons who browse the Website and access its features and content (i.e. customers, prospects and Internet users).

 

2. Data collection

1. Time of data collection

 

This Privacy Policy applies to all data that you provide to us or that we collect, directly or indirectly, including:

 

• Browsing the website;
• Making orders, purchases, subscriptions;
• Creating a customer account on the Website;
• Subscribing to the newsletter; Contacting After-Sales Service and/or Customer Service;
• Participating in a contest;
• Consulting our sales promotions and/or our advertisements; Answering our questionnaires; Requesting any information including via the contact form of the Website.

 

When specific data collection is required for the associated processing, we mark the required fields with an asterisk.

Your data may also be collected from third parties provided they have obtained your consent in advance.

 

2. Details of data processing

 

The table below allows you to get an overview of the data processed by the DC, the purposes of data processing and the legal basis for such processing.

 

Treatment Data collected Purpose of data processing Legal basis for data processing
Customer account and preference management Gender
First name
Name
Email
Date of birth
Password,
Full postal address
Telephone No.
Order history
Personal preferences
This data will enable us:
– to manage your customer account and preferences (including orders, purchases, subscriptions, etc.) ;
– to carry out audience statistics and measurements;
– to control our site and improve its content, particularly according to your preferences.
Contractual performance

User consent

Legitimate interest

Management of orders, purchases, subscriptions Gender
First name
Name
Email
Password
Full postal addressTelephone No.
Order history

Any information transmitted about you (including health data)

This data will enable us:
– to manage your orders, purchases, subscriptions, etc. (including their processing, tracking, delivery, invoicing, claims management and after-sales service);
– to interact with you according to your requests/needs for any order following orders, subscriptions, purchases made, and in the event of missing information, for the purpose of finalising your orders, purchases, subscriptions;
– to contact you in case of unavailability of one of our products. 

 

Contractual performance
Managing payments and collections Payment data
Name
First name
Full postal address
Order history
This data will enable us:
– To process and track the payment made via the chosen method of payment;
– To collect payments in the event of unpaid balances.Regarding the storage of your payment data:
– either these are kept by the DC at the time of the transaction, which will then be deleted,
– or the DC does not collect them (e.g. bank card data entered on the Website is not fully collected. Only a payment ID (token) and a portion of your credit/bank card numbers are collected. All payment data is collected by our PCI-DSS certified payment provider to ensure secure payments).
Contractual performance
Business communications management (including newsletters) Email
Name
First name
Full postal address 
This data will enable us:
– To send you promotional communications concerning our products by email and/or by mail;
– To carry out targeted advertising in connection with advertising or other partners (Facebook, Google, etc.);
– To carry out audience statistics and measurements.
User consent
Legitimate interest
Managing customer knowledge, statistics and Website performance Connection data
Navigation data
Name
First name
Email 
This data will enable us:
– to evaluate your satisfaction with orders and purchases made;
– to carry out satisfaction surveys;
– to enrich your customer profile (preferences);– to analyse the activity of our Website and improve the services offered;– to carry out customer experience, audience measurement, and statistical analyses.
Legitimate interest

User consent

Managing promotional operations (such as games, contests, etc.) Gender
Name
First name
Full postal address
Telephone
Email
Date of birth
This data will allow us to enrol you in our participation programme for proposed promotional activities. User consent
Managing all types of requests Civility

Name

First name

Full postal address
Email

This data will enable us:
– to provide a personalised response to your request;
– to carry out statistics, satisfaction surveys;
– to process your request as part of our vigilance approach (prevention and surveillance of adverse reactions to products – follow-up corrective actions taken if applicable)
User consent

Legal obligation

Legitimate interest

Managing customer reviews Name
First name
This data will allow us to post your reviews for products that you have purchased. User consent
Managing browsing online Connection data
Navigation data
This data will enable us to:
– ensure the proper functioning of our Website;
– perform statistics;
– proceed with the dissemination of targeted advertising online on our website and on other sites (e.g. on social media)
User consent

Legitimate interest

 

In addition, we may use certain techniques known as “profiling”, namely, any form of automated processing of personal data that uses the collected data to analyse and evaluate certain personal aspects of a natural person, such as analysing and/or deducing, by means of dynamic segmentation, development of scenarios, hearings, certain elements and/or behaviours relating to personal preferences, interests, purchasing habits, and orders. Based on these analyses and deductions, we send and/or post communications and/or content (possibly related to the HAVEA GROUP and its subsidiaries) tailored to your interests/needs that we will have identified. Automated decisions may also be made from profiling, including the use of this type of process to determine whether or not it is relevant to send you certain communications. You have the right, under certain circumstances, to object to the use of your data for “profiling” purposes. In this case, reference should be made to point 7 below.

 

3. Data destination

 

The data being processed are intended for internal teams of the DC (and its subsidiaries) and possibly for the service providers to which the DC may make use of, particularly in the processing of orders, purchases, subscriptions, management of customer reviews, statistics, audience measures, etc. (Subcontractors within the meaning of the GDPR). These service providers will be able to contact you in order to send you promotional offers and satisfaction surveys in order to assess the quality of their service. If you no longer wish to receive them, we invite you to contact these service providers directly regarding these possible mailings.

The data may also be transmitted to third party service providers to whom we entrust your data for sales or marketing purposes on our behalf (including web analytics, advertising networks in connection with marketing and promotional campaigns).

In addition, the data may also be transmitted to any police, judicial or administrative authorities (within the framework of a legal obligation or the legitimate interest of the DC).

 

4. Data of minors

 

The Website is accessible to any natural person, adult or minor. However, and in principle, this Website is intended for persons who are adults and able to make contractual obligations.

 

5. Data retention

 

Your data is kept for a period of time in accordance with legal requirements or proportionate to the purposes for which it was processed. Some storage periods respond to the legitimate interest of the DC.

 

Retention periods vary depending on whether we have a contractual relationship in progress (active customer), whether we have had a contractual relationship with you in the past (inactive customer), or whether we have never had such a relationship with you (prospect). The data related to your browsing on the Website and collected by the cookies, which you have authorized, have a specific retention period as set out below.

 

As an example:

 

• all data relating to prospects is retained for 3 years from the collection or last contact from the prospect;
• all data relating to an active customer is retained for the length of the contractual relationship;
• all data relating to an inactive customer is retained for 5 years from the end of the contractual relationship or the last contact from the inactive customer;
• browsing data is retained for a maximum of 13 months.

 

Archiving on an intermediate basis is also possible for administrative reasons, particularly in litigation, commercial, civil and even tax matters, in the context of compliance with a legal obligation.

In any event, where their retention is no longer justified by legal, commercial, or marketing requirement or by legitimate interests of the DC or if the User has made use of a right of modification or deletion or opposition (except in the case of retention for the purpose of complying with a legal obligation), we will anonymise or delete them securely.

 

6. Transfer of your data

 

We keep your data within the European Union. However, the data may be transferred to subcontractors and/or commercial partners located in other countries, particularly outside the European Union. In case of transfer of this type, we ensure that the processing is carried out in accordance with this Privacy Policy and that it is framed by the European Commission’s standard contractual clauses which ensure an adequate level of data protection and allow for the respect of privacy and fundamental rights of persons.

 

7. Methods for exercising Users’ rights

 

In accordance with the regulations on the protection of personal data (and in particular the GDPR), you have a right of access, rectification, deletion, opposition, limitation and portability of your data.You also have the opportunity to formulate guidelines concerning what happens to your data after your death.

To exercise these rights, it is sufficient to submit a complete formal written request accompanied by any item allowing for your identification (identification document, customer number, etc.) depending on the following reception methods:

 

• By email: contact@havea.com
• Via the contact form (if existing)
• By mail: HAVEA GROUP – Consumer Service – Densmore – Parc d’activité Sud Loire, 85612 Montaigu Cedex

 

The precise terms and conditions for the exercise of your rights are mentioned in the regulations on the protection of personal data (and in particular the GDPR) and also on the CNIL website.

 

Before responding to any request, we may verify your identity and/or ask you to provide us with more information to respond to your request.

 

From the receipt of any complete written request, we undertake to respond to any request within one (1) month, which may be extended by two months in the event of a complex request.

 

In the event that we have not responded satisfactorily to your request, a complaint can be submitted to the the French Data Protection Agency (Commission Nationale de l’Informatique et des Libertés, CNIL) via its websitehttps://www.cnil.fr/fr/.

 

8. Data security

 

As a DC, we implement appropriate technical and organisational measures in accordance with applicable legal provisions to protect your data from alteration, accidental or unlawful loss, unauthorised use, disclosure or access.

 

9. Modifications to the Privacy Policy

 

We may occasionally change this Privacy Policy (including for reasons of legislative or regulatory change). Users are therefore advised to check this page regularly for any changes or updates to this Privacy Policy.

 

  • Cookies and other trackers

 

1. What is a cookie?

 

A cookie is a small text file in alphanumeric format that is deposited on your device’s hard drive when visiting a site, viewing an advertisement, etc. All (or almost all) websites use cookies to function properly and optimise their ergonomics and functionality.

 

2. Why do we use cookies?

 

We use cookies in order to optimise Users’ visits to the Website. They also use cookies, including third-party cookies, to present advertisements that are appropriate for Users.

 

3. Types of cookies and other trackers used

 

When visiting our Website, various information may be stored in “Cookies” files installed on their device.

Depending on their function and purpose of use, cookies are classified into the categories described below:

 

Essential or technical cookies

 

They are strictly necessary for the proper functioning of the Website and cannot be disabled. They make it possible to retain the choice of Users to move and use basic features (for example, connecting to the customer space). These cookies only store anonymised data. These cookies are essential for the use of the Website and cannot be disabled.

 

Statistical cookies

 

They allow us to determine traffic statistics and volumes and the use of various elements of our Website (headings and content visited, experiences, etc.), enabling us to improve the interest and ergonomics of our services.

 

Advertising cookies

 

The purpose of these services is to identify the interests of Users through the products consulted on the Website and to collect navigation data in order to customise the advertising offer addressed to Users outside of the Website or to meet specific objectives.

 

Social media cookies

 

Cookies may also be stored via the Website on the User’s device by social networks when using network buttons (“Facebook”, “Pinterest”, “Instagram”, “Google +”, etc.). For more information about these cookies and your data, we invite you to refer to their privacy policy on their respective websites.

 

4. Management of cookies

There are several ways to manage cookies. Any settings that the User makes will likely change their browsing on the Internet and the conditions of access to certain services requiring the use of cookies (essential/technical cookies).

The User may make the choice at any time to express and modify their wishes with regard to cookies, by using the methods described below.

The User may configure their browser software so that cookies are stored on their device or, otherwise, rejected, either systematically or according to their issuer. Their browser software may also be configured so that the acceptance or refusal of cookies is occasionally proposed, before a cookie is likely to be stored on their device.

If the User agrees to save cookies on their device in their browser software, cookies embedded in the pages and content they have viewed may be temporarily stored in a dedicated space on their device. They will only be readable by their issuer.

If the User refuses to save the cookies that we issue on their device, or deletes cookies that we have saved on it, they will no longer be able to benefit from a number of features that are nevertheless necessary to navigate certain areas of our Website. This would be the case when we cannot recognise, for technical compatibility purposes, the type of browser used by their device, their language and display settings, or the country from which their device appears to be connected to the Internet. Where applicable, we disclaim all responsibility for the consequences related to the degraded operation of our services resulting from our inability to save or consult the cookies required for their operation and that the User may have refused or deleted.

For the management of cookies and choices, the configuration of each browser is different. It is described in the help menu of the User’s browser, which will allow you to know how to modify your wishes in terms of cookies.

 

With the Internet Explorer browser: follow the procedurehttps://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies.

 

With the Mozilla browser, follow the procedure https://support.mozilla.org/fr/kb/autoriser-bloquer-cookies-preferences-sites?redirectlocale=fr&redirectslug=Activer+et+d%C3%A9sactiver+les+cookies

 

With the Chrome browser, follow the procedure https://support.google.com/chrome/answer/95647?hl=fr&hlrm=en.

 

With the Safari browser, follow the procedure https://support.apple.com/safari

 

With the Opera browser, follow the procedure https://www.accepterlescookies.com/comment-accepter-les-cookies-sur-opera.html

 

In addition, the User can log on to the Youronlinechoices website, offered by digital advertising professionals grouped within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France.

 

The User may thus be able to find out the companies registered to this platform and that offer the possibility to refuse or accept the cookies used by these companies to adapt the advertisements that may be displayed on their device to their browsing information: http://www.youronlinechoices.com/fr/controler-ses-cookies/.

 

This European platform is shared by hundreds of Internet advertising professionals and provides a centralised interface for expressing their refusal or acceptance of cookies that may be used to adapt the advertisements likely to be displayed there to the browsing of their device.

 

 

5. Storage of cookies

 

Cookies installed by the DC will be limited to a duration of thirteen (13) months on the User’s device from the time the User will have given consent to the application of the cookie. Beyond that period, the User must give their consent again.

 

3. APPLICABLE LAW AND ATTRIBUTION OF COMPETENCE

 

This Privacy Policy is governed by French law.

 

In the event of a dispute and in the absence of an amicable agreement, the User may avail themselves of either one of the territorially competent courts under the Code of Civil Procedure, or the jurisdiction of the place where the User remained at the time of the conclusion of the agreement or the occurrence of the harmful event.