PERSONAL DATA PROCESSING AND COOKIE MANAGEMENT POLICY
Preamble
Guinot SAS thanks you for visiting its website www.masterscolors.com (hereinafter the ‘Site’).
Guinot SAS undertakes to process your personal data in accordance with the General Data Protection Regulation (‘RGPD’) and the French Data Protection Act.
This processing of personal data is governed, in particular and without limitation, by the following standards:
- The European Data Protection Regulation (EU Regulation 2016/679 of the European Parliament and of the Council or ‘RGPD’) applicable since 25 May 2018 ;
- and Law no. 78-17 of 6 January 1978 relating to information technology, files and freedoms (known as the ‘Data Protection Law’) amended by the Health Law of January 2016, the Law for a Digital Republic of October 2016 and LAW no. 2018-493 of 20 June 2018 relating to the protection of personal data posit as a principle the protection of human identity, human rights, privacy and individual or public freedoms.
This policy (‘Policy’) informs any natural person concerned (customer, prospect, visitor to the Site) of the way in which Guinot SAS processes personal data as well as the rights that this person has and how to exercise them.
1- What is personal data?
Personal data (hereinafter referred to as ‘Data’ or ‘Personal Data’) means any information relating to an identified or identifiable natural person, directly or indirectly, by reference to an identification number or to one or more factors specific to that person. Example: surname, first name, telephone number, email address, etc..
2 - Who collects your Data?
The Data Controller is Guinot SAS, represented by its legal representative.
This Personal Data Processing Policy details the policy of Guinot SAS, a simplified joint stock company (SAS) with a capital of 10,200,000 euros (€), whose registered office is located at 120, avenue Charles de Gaulle, 92200 Neuilly sur Seine, registered in the NANTERRE Trade and Companies Register under no. 632 041 877, with regard to Personal Data.
This Policy applies to all Personal Data and information that you transmit to Guinot SAS, in particular when browsing the Site, subscribing to newsletters or placing an order via the Guinot SAS e-commerce site.
Your rights may be exercised by writing to us at : Guinot SAS - DPO - 120, Avenue Charles De Gaulle - 92200 Neuilly sur Seine or by email to: dpo@guinot.com.
3 - What Data is collected?
When you register on our Site, when you connect to your account, make requests, and/or when you disconnect, we collect the following categories of Personal Data, in particular:
- Your identity (title, surname, first names) ;
- Your contact details (postal and/or e-mail address, telephone numbers, comments);
- Your professional data when you submit job applications (CV, covering letter);
- Your browsing data: we receive and record information from your computer and browser, including your IP address, your software and hardware, and the page you request. To find out more, please consult our cookies policy set out in paragraph 14 of this Policy;
- Your reference institute ;
- Your order data (products ordered, quantity);
- Your order history;
- Your location data.
This data is subject to automated processing and is recorded in the Guinot SAS information system and database.
You may not send any form to Guinot SAS without first reading this Policy.
In the event that you provide the contact details and personal data of a third party in the context of placing an order for a product, for example, you guarantee that this third party is informed that you have communicated data concerning them to Guinot SAS and that they have accepted such communication.
4 – Is it compulsory to provide Personal Data?
The Personal Data requested in the forms is strictly necessary for our services to process your request, whether it be, for example, a request to contact you or to create your customer area, and must therefore be provided.
If you do not fill in these fields, your request will not be processed.
As far as cookies are concerned, you have the option of accepting or refusing them, with the exception of certain cookies that are strictly necessary for the operation of the website. In this respect, we invite you to consult our cookies policy set out in paragraph 14 of this Policy.
5 - Why do we collect your Data?
We collect your Data in order to better manage our services and your requests.
- Processing is based on the performance of pre-contractual and contractual measures when the purpose of the collection is to :
. Create and manage customer and prospective customer accounts so that your requests can be taken into account ;
. Manage your requests for rights ;
. Personalising and meeting your individual needs;
. Monitoring prospect customer relations, in particular managing your complaints and requests;
- The processing is based on your consent when the purpose of the collection is to :
. Providing personalised advertising content ;
. Send you newsletters, information bulletins and promotional offers;
- The processing is based on our legitimate interest, namely the improvement of our services and the security of our Site and computer network when the purpose of the collection is to :
. Improving our website ;
. Improve customer service/prospecting and your requests ;
. Administering promotions, surveys, competitions ;
. To analyse your comments and opinions left on our website and our social network pages.
On this last point, by leaving opinions and comments on our sites or by sharing information on our social networking pages about our offers, products and events, you are likely to communicate content and Personal Data to us. This information enables us to better meet your expectations in order to improve the quality of our products and services.
It may be reproduced and represented in particular on our sites for information purposes, and used to draw up anonymous statistical studies providing us with information about your habits and behaviour with regard to our products.
It may not be collected or used for any other purpose.
- - The processing is based on e-commerce :
- Creating your account on our Site
- Managing orders (processing and tracking orders, deliveries, invoices, payments, accounting)
- Managing customer contacts and sending notifications relating to the creation of an account on the Site and/or the status of the order
- Delivering orders placed
- Management of the relationship with the reference institute
- Management of remote complaints and after-sales service (SAV)
- Management of the loyalty programme
- Management of Internet users' opinions on products and services
- Commercial canvassing, i.e. to enable the sending of information, in particular commercial information from Guinot SAS, such as newsletters, new offers or current events
- Management of the location of your IP address for access to the Site's services
- The management of cookies as presented below, namely :
o Management of personalised web display and Customer preferences;
o Management of abandoned basket recovery
o Management of the payment module
o Statistical analysis of products ordered
6 - Confidentiality
Your Personal Data will not be sold, exchanged, transferred, or given to any other company for any reason, without your consent, other than what is necessary to respond to a request and/or transaction in the context of the Purposes set out above.
7 – Who receives the Data?
We do not sell, trade or transfer your Personal Information to third parties. This does not include trusted third parties or co-contractors/partners who assist us in operating our Website or conducting our business, so long as those parties agree to keep this information confidential.
The Site is hosted by NAITWAYS (NAITWAYS SAS), a company whose registered office is located at 131 bis Rue de Billancourt, 92100 Boulogne-Billancourt- FRANCE, registered in the Nantes Métropole Trade and Companies Register under number 508 823 614.
As part of the management and dispatch of your order, your data may also be transferred to our service providers such as :
- Our carrier for delivery,
- Our payment service provider for online payments made from our Site
- Our emailing service provider
- For the management of our franchise network, the reference institute designated by the Customer.
As part of the management of our Site, your data may also be transferred to our cookie service providers, as presented in our cookie policy set out in paragraph 14 of this Policy.
In certain situations, we are under a legal, regulatory and/or judicial obligation to share information as part of investigations, preventive measures and/or decisions concerning illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, breaches of our terms of use, or when we are required to do so by law.
8- What guarantees are there in the event of a transfer outside the European Union?
We guarantee, in the event of transfer of your Data abroad and particularly outside the European Union, to implement all appropriate measures to guarantee a sufficient level of protection for your Data, such as:
- Moving to countries recognised as adequate by the European Commission, i.e. offering protection equivalent to that guaranteed by the European Union;
- Obtaining guarantees of security and confidentiality from subcontractors by imposing strict contractual clauses and reserving the right to monitor them regularly, for example by carrying out audits.
9 – How long is your Data kept?
Your Personal Data is stored at the site host (NAITWAYS SAS) and is kept for a period not exceeding twenty-four (24) months following the last update made by the subscriber (CNIL recommendation No. 02-017 of 21 March 2002), unless anonymisation is required or there is a legal obligation to keep certain data for a longer period.
Your Data is kept for a limited period corresponding to the purposes for which it was collected, with regard to the regulations in force and in compliance with legal, contractual, fiscal and social obligations and for the defence of the legitimate interests of Guinot SAS, namely five (5) years from the end of the contractual relationship, this period corresponding to the duration of the applicable legal statute of limitations, in the event of litigation.
Your data is also kept within the framework of e_commerce for a period which does not exceed the time required for the following purposes, namely :
- Concerning customer relationship management, remote complaints and after-sales service: for the period strictly necessary to process the order, complaint and after-sales service, plus three (3) years from the end of the commercial relationship. In addition, data may be kept in order to comply with a legal obligation for as long as is necessary to meet this obligation.
- Concerning the delivery of products: from the time the order is placed until delivery and payment, and for as long as there are outstanding items (unpaid invoices, disputes, litigation, etc.).
- Concerning Customer reviews of products and services: for as long as the product is on the market;
- Concerning the management of the loyalty programme: for the duration of your membership of the programme.
- Concerning commercial prospecting: three (3) years after your last response to a solicitation.
- - Concerning the management of cookies: thirteen (13) months from your initial express consent.
You acknowledge that the data you provide to us and which is stored in our information systems is accurate and constitutes proof of your identity.
10 – What rights do you have over your Data?
En application des articles 14 à 22 du RGPD, toute personne physique utilisant notre Site a la faculté d’exercer les droits suivants :
- Right of access: you may request a copy of your personal data;
- Right of rectification: you may request the modification of any data concerning you that is inaccurate;
- Right to object: you may object to us processing your data; if your request to object does not concern canvassing, we may, depending on the case, justify a refusal on the grounds that there are compelling legitimate grounds for processing the Data or that the Data is necessary for the establishment, exercise or defence of legal claims, or that you have given your consent - you must then withdraw that consent and not object, or that a contract is binding on us, or that a legal obligation requires us to process your data in particular;
- Right to erasure: you can ask us to erase your data;
- Right to limitation of processing: you have the right to request that the processing of your Data be blocked for a certain period of time, for example while we examine a dispute on your part regarding the use of your Data or a request to exercise your rights.
- Right to portability: you have the right to request that the Data collected in a form with your consent or as part of a contract be communicated to you in an easily reusable format and transmitted to the third party of your choice, subject to technical feasibility.
Furthermore, when a person gives their consent to the processing of their Personal Data, they have the right to withdraw it at any time.
Finally, when a breach of Personal Data likely to give rise to a high risk for your rights and freedoms is detected, you will be informed of this breach as soon as possible.
You may formulate directives relating to the conservation, deletion and communication of your Personal Data after your death, in accordance with article 40-1 of law 78-17 of 6 January 1978.
These rights and these directives may be exercised by writing to us at : Guinot SAS - DPO - 120 Avenue Charles De Gaulle - 92200 Neuilly Sur Seine or by email to: dpo@guinot.com
In order to enable us to identify you quickly and respond to your request, you must attach to your request any element that can be used to prove your identity (in particular a request made via your customer account or your email). A reply will be sent to you within 1 month of receipt of the request. In certain cases, due to the complexity of the request or the number of requests, this period may be extended by 2 months.
You may also contact the Commission Nationale de l'Informatique et des Libertés (CNIL), the regulatory authority responsible for ensuring compliance with regulations on the protection of personal data in France, by internet https://www.cnil.fr/fr/agir or by post at the following address Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy - TSA 80715, 75334 PARIS CEDEX, France.
11 – What safety measures have been implemented?
Guinot SAS has taken all necessary technical and organisational measures to ensure the security and confidentiality of the personal data processed and to prevent it from being distorted, damaged, destroyed or accessed by unauthorised third parties. All the security measures put in place comply with the state of the art, particularly as regards information systems.
These measures include the following:
- Identification of cyber risks
- Controlling access and authorisation
- Data encryption
- A secure IT environment
Insofar as Guinot SAS does not control all the risks associated with the operation of the Internet, it draws your attention to the existence of possible risks inherent in its use and operation.
Guinot SAS will notify, within the legal deadlines, all personal data breaches to the competent supervisory authority for the protection of personal data and will notify you if these are likely to give rise to a high risk for the rights and freedoms of individuals.
12 - Create an account on www.masterscolors.com
By creating an account on the www.masterscolors.com website, you consent to us collecting, using and disclosing your Personal Data for purposes related to your request. The information collected is processed electronically in order to facilitate contact between you and Guinot SAS.
By posting your contact details and your message on your account, you undertake to write objectively and never excessively. Not to enter information relating to sensitive data (health, racial or ethnic origin, sexual orientation, political opinions, etc.). Particular attention must be paid to sensitive data covered by Article 8 of the French Data Protection Act.
Guinot SAS reserves the right to withdraw a contact form for reasons of non-compliance with the French Data Protection Act and reserves the right to lodge a complaint against any person who does not comply with these commitments.
13- How do I unsubscribe?
We use the email address you provide to send you information and updates relating to your enquiries, contact requests, product information, etc. If at any time you wish to unsubscribe and no longer receive emails, please send us an email to desabonnement@guinot.com with ‘unsubscribe’ in the subject line.
14- Which cookies are used?
A cookie is a small computer file, a tracker, which makes it possible to analyse the behaviour of users when they visit a website, read an e-mail or install or use software or a mobile application.
The cookies we use are listed below. These are text files stored and used to record personal and non-personal information about your browsing on the Website.
Guinot SAS may use them or other technologies that may collect or store Personal Data in order to improve the services provided to you.
You will be warned the first time you receive a cookie by the display of a banner at the bottom of the consultation page and you can choose to accept or refuse cookies on a case-by-case basis or refuse them systematically at any time.
You can choose to deactivate cookies by configuring your browser or using the cookie manager.
Please note that some cookies, which are necessary for the operation of the Website, cannot be refused.
|
Publisher |
Type de Cookies |
Objectives |
Function, addressee and retention period |
They can be deactivated |
|
|
Google Analytics |
Analysis of user behaviour on the Site |
Google statistical analysis 3 years |
Yes |
|
|
Google Maps |
Search for points of sale |
Display a Google map No conservation |
Yes |
|
|
Google Ads |
Enables us to track users who have clicked on targeted advertisements |
Delivery of advertising to consumers 3 years |
Yes |
|
|
Pixel Facebook |
Communication with Facebook |
Sharing content via social networks Facebook privacy rules : http://www.facebook.com/policy.php |
Yes |
Guinot SAS reminds you that setting these parameters may modify your conditions of access to its content and services requiring the use of cookies.
Your prior consent to the insertion of cookies and tracers is valid for a maximum of six (6) months, in accordance with the recommendations of the Commission Nationale Informatique et Libertés (CNIL). You will therefore be invited once again to express your consent or to refuse the deposit of these cookies when this period has elapsed.
As a reminder, the cookies exempt from consent according to the CNIL (guidelines September 2020):
- Tracers preserving the choice expressed by users on the deposit of tracers
- Tracers intended for authentication to a service, including those intended to ensure the security of the authentication mechanism, for example by limiting robotic or unexpected access attempts.
- Tracers designed to store the contents of a shopping basket on a merchant site or to invoice the user for the product(s) and/or service(s) purchased.
- Tracers for personalising the user interface (for example, for choosing the language or presentation of a service), when such personalisation constitutes an intrinsic and expected element of the service
- Plotters used to balance the load of equipment providing a communication service
-Tracers enabling pay sites to limit free access to a sample of content requested by users (predefined quantity and/or over a limited period)
For more information, you can contact Guinot SAS by the following means:
- By post : Guinot SAS, Délégué à la Protection des Données Personnelles (DPO)
120 Avenue Charles de Gaulle, 92200 Neuilly sur Seine
- By email to the following address: dpo@guinot.com
13- Updating the Policy
This Policy may be modified at any time by Guinot SAS, particularly in order to comply with any changes in French and European legislation and regulations. Updates are put online without notifying the user and are deemed to be accepted without reservation when you access the Site or log in to your user account.