PERSONAL DATA POLICY

Preamble

This personal data policy applies to the website accessible through the following url: www.directchateaux.com proposed by the company Béret Noir. It aims to inform you about :

How we may collect and process your personal data where appropriate;

The rights you have regarding your own data;

The identity of the controller of your data;

The transfer of your data to third parties;

Our policy regarding the management of "cookies".

This privacy policy complements the Legal Notice and General Terms and Conditions of Sale that you can consult on our Site.

We undertake to process all data collected in a manner consistent with :

The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ;

To the law n°78-17 of January 6, 1978, known as the "Informatique et Libertés" law, as amended by the law n° 2018-493 of June 20, 2018 on the protection of personal data.

The data subject whose personal data are processed by the company Béret Noir agrees that they are processed in accordance with this policy.

Article 1: The data controller

The identity and contact details of the Data Controller are as follows

Béret Noir, a simplified joint stock company with a capital of 5,000 euros, registered in the Bordeaux Trade and Companies Register under number 893 952 309, whose registered office is located at 16 rue du 8 mai 1945 - 33150 Cenon, whose legal representative is Guillaume Saillan in his capacity as Managing Director.

Requests relating to personal data should be sent by post to the following address Béret Noir - Le Forum, 16 rue du 8 mai 1945, 33150 Cenon, France

Or via the email address contact@agence-beret-noir.fr

Article 2: Personal data collected and processed

Within the framework of the exploitation of our Website www.directchateaux.com, we collect personal data relating to the users.

2.1 General data are collected for the website www.directchateaux.com 

During your connection: your IP address as well as navigation data, subject to your agreement and the settings of your terminal;

During exchanges with us via the contact form: your surname(s) and first name(s), the name of your company, your address (street, postal code, town), your telephone number, as well as your e-mail address. These data are essential to answer the messages you send us via the contact form.

When you browse our Site and you have authorized the collection of your data through cookies.

When you place an order for a product;

When you consult and use the features offered on our Site;

When you participate in our direct marketing and promotional offers, such as entering a contest;

When it is necessary with regard to the applicable regulations, we undertake to collect the express, specific and prior consent of the users of the Site and/or to allow them to object to the use of their data for certain purposes. All users have the right to withdraw their consent at any time.

2.2 We may process the following personal data in accordance with the purposes described in Article 3 of this Charter:

2.2.1 With regard to the management of our Site when you place an Order and/or use the various features of the site, the data collected are as follows:

Transactional information about the Product(s) Order

Browsing information including consultation history, IP addresses, browser settings.

2.2.2 With respect to interaction with our Site, certain data is automatically collected from your device or web browser. Information on these practices is specified in Article 8 "Cookies" below. This data includes IP address and cookies.

Article 3: The purposes of the processing

We collect and/or process your personal data in compliance with European and French data protection laws, if necessary:

To identify persons using our Site;

To carry out statistics relating to the use of the site and to improve its operation;

To carry out maintenance operations and to search for errors;

To respond to messages you send us via the contact form;

To process your Order(s);

To comply with applicable law or other legal requirements;

To protect the security of systems, to detect and prevent fraud, or to ensure our legitimate interests, without disregarding your interests or your fundamental rights and freedoms requiring greater protection of your personal data.

You have the right to withdraw your consent at any time, or to object to any processing of your personal data collected.

The collection and processing of data thus meet the following purposes:

Accessing our Site, placing and processing an Order

When you access our Site, we collect and use the personal information you provide to enable you to place an Order and to enable us to process it.

Prospecting and/or sending information to Users

This processing aims at sending by email to Users notifications of events concerning our activity and those of our partners.

To operate, maintain and improve the functionalities of our Site, in particular for the placing of Orders

The personal data you provide is used for accounting and internal audit purposes. It is also used to detect technical or order processing problems and to administer our Site. Personal data about how you use our Site is used to understand User behavior and preferences and to develop statistics to improve our services/online store and to develop new features.

To improve our offering of Products on our Site

Personal information about how you use our Site to place Orders is used to understand User behavior and preferences and to develop statistics to improve our offering of Products on our Site and to offer new Products;

To provide personalized content and navigation

To make the Products on our Site more relevant to the interests of Users, provided that we have obtained the User's explicit and prior consent;

To comply with legal obligations, to prevent or detect fraud, abuse, unlawful use, violations of the Terms and Conditions of Sale, and to comply with court orders and government requests.

Article 4: Consent

When placing an Order or a contact request, you are required to fill in forms and communicate personal data in order to place an Order.

We undertake, when required by applicable regulations, to obtain your explicit, specific and prior consent, and/or to allow you to object to the use of your personal data for certain purposes, and/or to access and/or rectify information concerning it.

Article 5: Transmission of personal data to third parties

The personal data collected will be accessible :

To authorized personnel of the company Béret Noir, the company Pélican Air Services and the company Horizon, ensuring the management and maintenance of the site;

It may however be communicated to third parties in application of legal or regulatory provisions, court decisions or if necessary for the protection or defense of our rights.

The personal data that we have collected may be transmitted to third-party companies within the framework of subcontracting agreements signed with us exclusively for the purposes indicated in Article 3. Prior to transfers, we will take all necessary measures and guarantees to secure such transfers.

Transfers can thus be carried out within the framework of the following activities and events: emailing management, event organization, IT services, research and statistics.

We do not transfer any personal data to partners for commercial operations or for any other purpose that would not meet the needs of the purposes indicated in article 3. In the event that we consider modifying our data transfer policy with a view to transferring data to partners, particularly commercial partners, this can only be done subject to having obtained your explicit and prior consent.

Article 6: Hosting and transfer of personal data

The personal data collected and processed are hosted by any service provider hosting our servers in France or any other European territory.

The User is informed that we may, if necessary, transfer your personal data to a third country or to an international organization that is subject to an adequacy decision issued by the European Commission, it being specified that, in the case of a transfer to a country or an international organization that is not subject to an adequacy decision, this may only be done on the condition that appropriate safeguards are put in place and that the users concerned have enforceable rights and effective means of recourse, under the conditions of the Regulations in force.

Article 7: Data retention

Personal data are kept for the time strictly necessary to achieve the purposes for which they are processed and according to the recommendations of the CNIL and is based on the simplified standard No. NS-048 on the automated processing of personal data relating to the management of customers and prospects.

They can then be archived with restricted access for an additional period of time for limited reasons and authorized by law (payment, guarantee, disputes ...).

Article 8 : Cookies

When you visit our Site, cookies are deposited on your computer, your mobile or your tablet.

A cookie is a small text file stored in the browser of your terminal (computer, mobile, tablet) when visiting a site or viewing an advertisement. It is intended to collect information about your browsing or to send you services tailored to your terminal. Cookies are managed by your Internet browser.

8.1 Cookies used and their purpose

Our Site uses :

Operating cookies (mandatory) guaranteeing the proper functioning of our Site and allowing its optimization. Our Site cannot function properly without these cookies.

Analytics cookies to obtain anonymous statistics on the number of visitors to our Site in order to optimize its ergonomics, navigation and content. By deactivating these cookies, we will not be able to analyze the traffic on our Site.

These cookies allow our services to function optimally. They are essential to navigate and access our Site. They are therefore always active. The cookies collected are not transferred to third parties or used for any other purpose than those stated above.

8.2 Configuration of cookies

You have different ways of managing cookies.

You have the possibility below to manage the configuration of your cookies at any time via a dedicated interface or via your browser and thus oppose the recording of cookies by configuring your browser. The configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to modify your wishes regarding cookies.

8.3 Consent

By browsing our Site, you agree to the use of the above-mentioned cookies.

During your first navigation, we informed you of the presence of the aforementioned cookies and of the possibility of opposing them by accessing the present Charter for the use of personal data.

We inform you that refusing cookies :

May lead to problems with the functioning of our Site

The impossibility of carrying out an analysis of the traffic of our Site

In order to manage cookies in the best way possible, we invite you to set your browser parameters taking into account the purpose of the cookies.

8.4 Rights of access, deletion, opposition

As for other personal data, you have the same rights as specified in article 10 below.

8.5 Retention period

We keep the cookies collected for a period of :

13 months for operating cookies

13 months for Analytics cookies

This period is not automatically extended when you visit the site again. After this period, the data is either deleted or rendered anonymous if it is not.

Article 9 : Data security

To ensure the security of personal data, in particular to prevent them from being distorted, damaged or accessed by unauthorized third parties, we take all necessary precautions in view of the nature of the data and the risks presented by the processing.

Article 10: Users' rights

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and Law No. 78-17 of 6 January 1978 on data processing, data files and individual liberties, you have the following rights which you may exercise at any time by contacting the company Béret Noir at the following email address contact@agence-beret-noir.fr, or by post to: Béret Noir - Le Forum, 16 rue du 8 mai 1945, 33150 Cenon

Right of access to your personal data;

Right to rectify and obtain the modification of the data which would be inaccurate or incomplete;

Right to request the deletion of your personal data, except if we have legal or legitimate reasons to keep them;

Right to object to the processing of your personal data and to have it limited, unless we have a legitimate interest in doing so;

Right to the portability of your personal data to the extent applicable;

Right to organize the fate of your personal data after your death;

Right to withdraw, at any time, your consent to the processing of his or her personal data (without prejudice to the lawfulness of the Processing based on the consent made prior to the withdrawal thereof).

Any request must specify the right you wish to exercise, be accompanied by a photocopy of your valid national identity card (or passport) and mention the contact details (address, telephone number, e-mail) where we can contact you. This information will only be kept for the time necessary to process your request.

It is however specified that the exercise of your right to the deletion of your personal data and/or the exercise of your right to object to the processing of your personal data and/or the exercise of your right to limit the processing of your personal data and/or your right to withdraw your consent at any time to the processing of your personal data is likely to result in the impossibility for the User to use the site and/or to place an Order.

In addition, you are informed of your right to file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL) either by post at 3 Place de Fontenoy - TSA 80715 - 75334 Paris 07 or by filing a complaint online at www.cnil.fr.

Article 11: Information on the contractual nature of the provision of personal data

With regard to the regulatory or contractual nature of the collection, the fact that it is a condition for the conclusion of a contract, the obligation to provide personal data, as well as the possible consequences of not providing such data, the user is informed of the following:

the request to provide personal data has a contractual character (in the context of the relationship that the User wishes to establish with the company Béret Noir by using our Site to make an Order of Product(s)),

the provision of this data, insofar as it is necessary for the processing of the Order, is a condition for the conclusion of this contractual relationship,

Therefore, the User is required to provide his/her personal data if he/she wishes to place an Order on our Site,

Failure to provide such personal data shall not allow the User to place an Order on our Site.

Article 12. Automated decision making

It is hereby stated that the personal data collected does not lead to automated decision-making within the meaning of the current regulations.

Article 13. Possible further processing of personal data

In the event that personal data are further processed for purposes other than those for which the personal data were collected and as identified above, the Data Controller shall provide the data subject with prior information about such other purpose and any other relevant legal information required.

Article 14. Age of the person who can provide personal data

The collection of personal data can only concern persons aged at least 18 years for France, and abroad the legal age for the purchase and consumption of alcohol. Users of our Site must be of legal age in their country of residence to access it and, if applicable, to place an Order, so that by placing an Order via our Site and/or by communicating personal data to us, you represent and warrant to the company Béret Noir that you are of legal age in your country. This stipulation is without prejudice to the commitment made by the User to the company Béret Noir according to which he declares and guarantees to the company Béret Noir that he has the legal capacity to use our Site and, if necessary to place an Order.

Article 15: Links to other sites

Our Site may contain links to other sites, over which we have no control. We are not responsible for the data protection policies or practices of other sites that you choose to visit from our Site. We encourage you to read the privacy policies of those other sites to understand how they collect, use and share your information.

Article 16: Changes

We reserve the right to modify or update at any time the present Charter of use of personal data. These modifications will be published in this section. You are invited to regularly consult the Charter of use of the personal data and to check if modifications were made.

More information

You will find more information on the protection of personal data on the website of the Commission Nationale Informatique et Libertés (www.cnil.fr)