Privacy Policy | gaya by garnazelle

PREAMBLE:

The company GARNAZELLE, a limited liability company with share capital of €788,000, registered with the Paris Trade and Companies Register under number 438147761, with its registered office at 3 rue du Marché Saint-Honoré, 75001 Paris (hereinafter "GARNAZELLE SARL") undertakes to comply with the legislation in force in France (Law No. 78-17 of 6 January 1978 "Informatique et Libertés") and in Europe (Regulation 2016/679 of 27 April 2016 "GDPR"), to ensure the protection, confidentiality and security of personal data, and to ensure respect for the privacy of its customers and all visitors to its website.

This Privacy Policy (hereinafter "the Policy") describes how GARNAZELLE SARL collects and processes the Personal Data of persons browsing its website or placing an order with it. The Policy also specifies the legal bases on which GARNAZELLE SARL relies to process Personal Data and sets out their retention periods.

In any event, GARNAZELLE SARL undertakes to respect the following principles:

Your data is used solely for explicit, legitimate and specified purposes related to the various features offered on the site, for ordering products listed therein;
Only the Personal Data that is necessary for these purposes is collected and processed by GARNAZELLE SARL.
You are informed in a clear and transparent manner about the purpose for which your Personal Data is collected and about your rights regarding data protection.

Article 1: Definitions

This article defines the essential terms contained in the Privacy Policy.

Terms whose first letter appears in upper case shall have the meaning assigned to them in this article, whether singular or plural:

"Customer": refers to any person placing an order for products through the Site;

"Cookies": refers to trackers that allow access to information stored in the terminal equipment of the Site Visitor;

"Order": refers to any order placed by the Customer through the Site;

"Recipient": refers to the natural or legal person who receives Personal Data, whether or not they are a third party;

"Personal Data": refers to any information relating to an identified or identifiable natural person, either directly (e.g. by name) or indirectly (e.g. by reference to an identifier);

"Data Subject" / "You": refers to the identified or identifiable natural person whose Personal Data is processed by GARNAZELLE SARL, whether as a Site Visitor or as a Customer;

"Data Controller": refers to the natural or legal person who, alone or jointly, determines the purposes and means of Personal Data processing. In this case, GARNAZELLE SARL is the Data Controller;

"Site": refers to the website published by GARNAZELLE SARL, accessible at the following URL: https://www.gaya-joaillerie.com/;

"Processor": refers to the natural or legal person who processes Personal Data on behalf of the Data Controller;

"Processing": refers to any operation or set of operations performed or not by automated means and applied to data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, alignment or combination, restriction, erasure or destruction;

"Third Party": refers to any natural or legal person, public authority, agency or body other than the data subject, the data controller, the processor and persons who, under the direct authority of the data controller or the processor, are authorised to process Personal Data;

"Visitor": refers to any person browsing the website, whether or not a customer of GARNAZELLE SARL;

"Personal Data Breach": refers to a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

Article 2: When is your data collected ?

Your Personal Data, as a Site Visitor or Customer of GARNAZELLE SARL, may be collected in the following circumstances:

When visiting and browsing the Site;
When creating a personal account on the Site;
When placing an Order (purchasing a product);
During exchanges relating to the delivery of a product;
When contacting the after-sales service;
When subscribing to the newsletter;
During exchanges and/or contact between you and GARNAZELLE SARL.

Article 3: For what purposes is your data processed ?

The processing of your Personal Data by GARNAZELLE SARL is carried out for the following purposes:

Creating a personal account on the Site;
Placing and managing an order;
Payment for the order;
Delivery of the order;
Monitoring the contractual relationship with customers;
After-sales service;
Tracking statistics and measuring audience on the Site;
Improving navigation on the Site.

Article 4: On what legal bases is your data collected? How long is it retained?

GARNAZELLE SARL collects and processes your Personal Data only for specified purposes, in accordance with the applicable legal bases. Data is retained for a limited period, proportionate to the purposes for which it was collected, as well as to the legal obligations to which GARNAZELLE SARL is subject.

Management of prospects, development and management of communication and prospecting operations (including the newsletter) Data collected: contact details such as name, first name and email address. Legal basis: your consent. Retention period: up to 3 years from the last contact with the data subject.

Creation of a customer account Data collected: name, first name, address and telephone number. Legal basis: your consent. Retention period: up to 3 years from the last contact with the data subject or in the event of account inactivity.

Management of product orders and their delivery Data collected: identification data and contact details — name, first name, email address, postal address and telephone number. Legal basis: performance of a contract. Retention period: for the duration necessary for managing the contractual relationship and for the applicable limitation periods.

Remote payment by bank card Data collected: bank card number and expiry date. Legal basis: performance of a contract. Retention period: until full payment is made, plus the withdrawal period applicable to the sale of products.

Management of after-sales service Data collected: contact details and billing data. Legal basis: compliance with legal obligations. Retention period: for the duration necessary to process the request and for the applicable limitation periods.

Analysis of interactions and audience measurement Data collected: content viewed, establishments visited and pages consulted. Legal basis: your consent. Retention period: 6 months.

Regarding retention periods, it is specified that GARNAZELLE SARL retains your Personal Data only for as long as is strictly necessary to achieve the purposes for which it was collected, including in order to comply with any applicable legal, regulatory or accounting obligation.

Article 5: Who are the recipients of your data?

Your Personal Data may be processed by the following persons:

Authorised members of the GARNAZELLE SARL team;
Service providers authorised by GARNAZELLE SARL to carry out product deliveries;
Providers of IT systems and support for GARNAZELLE SARL's operations (e.g. IT, hosting and maintenance service providers, secure payment solution providers).

Your Data will not be communicated to other persons without your consent.

The third parties with whom GARNAZELLE SARL shares your Data are limited (by law and by contract) in their ability to use your Personal Data for the specific purposes identified by GARNAZELLE SARL.

In any event, GARNAZELLE SARL makes its best efforts to ensure that recipients of your Personal Data are subject to confidentiality and security obligations consistent with this Privacy Policy, applicable laws and in particular the GDPR and the "Informatique et Libertés" Act in its latest version in force.

Finally, you are informed that GARNAZELLE SARL may share your Personal Data in order to comply with legal obligations (for example, transmission of data to public authorities).

Article 6: Is your data transferred outside the European Union?

In principle, all your Data is stored within the territory of the European Union and is not transferred outside this territory.

However, if the processing of your Personal Data were to involve a transfer outside the European Union, such transfers would be made subject to appropriate guarantees in terms of security and confidentiality, in compliance with applicable regulations (in particular standard contractual clauses, in accordance with clause models validated by the European Commission).

Article 7: What are your rights?

As a Data Subject whose Personal Data is processed, you have various rights.

These rights are not, however, absolute and are subject to certain conditions, in accordance with the GDPR and other applicable texts, in particular Law No. 78-17 of 6 January 1978 known as the "Informatique et Libertés" Act.

7.1 The right of access

You have the right to obtain from GARNAZELLE SARL confirmation as to whether or not your Personal Data is being processed by GARNAZELLE SARL, as well as information on how it is processed. You also have the right to obtain a copy of your Personal Data processed by GARNAZELLE SARL.

7.2 The right to rectification

You may request that GARNAZELLE SARL take steps to correct your Personal Data if it is inaccurate or incomplete. For example, if GARNAZELLE SARL holds the wrong name or address for delivering the products you have ordered.

7.3 The right to erasure ("right to be forgotten")

You may request the erasure or deletion of your Personal Data, for example when there is no (longer any) compelling reason for GARNAZELLE SARL to continue using it.

7.4 The right to restriction of processing

You have the right to request the restriction of Personal Data processing or to prevent further use of your Personal Data.

7.5 The right to data portability

You have the right to retrieve and reuse certain Personal Data relating to you. This right applies only to Personal Data that you have provided to GARNAZELLE SARL, which it processes with your consent, for the purposes of performing a contract, and which is processed by automated means. Where applicable, GARNAZELLE SARL will provide you with a copy of your Personal Data in a structured, commonly used and machine-readable format (where technically possible). GARNAZELLE SARL may also, if you wish, transmit (where possible) such Personal Data directly to another data controller.

7.6 The right to object

You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time, insofar as the processing has taken place for the purposes of legitimate interests pursued by GARNAZELLE SARL. In any event, GARNAZELLE SARL will be authorised to continue processing your Personal Data if it is able to demonstrate that the processing is justified by freedoms, or if such Personal Data is necessary for the establishment, exercise or defence of legal claims.

7.7 The right to withdraw your consent

Where GARNAZELLE SARL processes your Personal Data on the legal basis of your consent, you have the ability to withdraw your consent at any time. However, you are hereby informed that withdrawal does not in any way affect the lawfulness of the processing that took place prior to exercising this right of withdrawal.

7.8 The right to provide instructions regarding the use of your personal data after your death

You have the right to provide GARNAZELLE SARL with instructions regarding the management (e.g. retention, erasure and disclosure) of your Personal Data after your death. You may amend or revoke your instructions at any time.

7.9 Right to lodge a complaint with the CNIL

In the event that you are not satisfied with GARNAZELLE SARL's response to your complaint, or if you believe that the processing of your Personal Data does not comply with applicable data protection regulations, you may lodge a complaint with the competent data protection supervisory authority. The Commission Informatique et Libertés (CNIL) is the data protection authority in France.

Article 8: How can you exercise your rights?

If you wish to exercise any of your rights, you may contact us at the following email address: boutique@garnazelle.com

To learn more about your rights, you may visit the CNIL website (www.cnil.fr/fr/comprendre-vos-droits). When submitting a request to exercise your rights, proof of identity may be requested if necessary, in particular to preserve the security of the processing that is the subject of the request.

A response will be sent to you, depending on the complexity of your request, within the time limits set out in Article 12.3 of the GDPR.

Article 9: How is your personal data protected?

GARNAZELLE SARL ensures that Personal Data is processed with full security and confidentiality, including when certain operations are carried out by Processors.

To this end, GARNAZELLE SARL implements appropriate technical and organisational measures to prevent the loss, misuse, alteration and deletion of your Personal Data.

These measures are adapted according to the level of sensitivity of the Personal Data processed and the level of risk presented by the processing of such data or its implementation.

If a Personal Data breach affecting you occurs, GARNAZELLE SARL will inform you within the time limits and in accordance with the procedures set out in applicable laws and regulations.

Article 10: Can this Policy be amended?

GARNAZELLE SARL reserves the right to modify this Privacy Policy.

If the modifications are formal in nature, the new policy will apply immediately.

If the modifications or updates are substantial (for example, the addition of a new purpose), the Data Subjects will be notified.

If consent were required again, GARNAZELLE SARL would of course proceed to collect consent anew.

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