GENERAL INFORMATION

In accordance with the General Data Protection Regulation, the processing referred to in this Confidentiality and Privacy Policy is underpinned by a specific legal framework.

The body in charge of data processing is the VERLET company.
You may refer any questions about or observations on this declaration or concerning data protection in general to the VERLET company referred to as follows:

VERLET
256 Rue St Honoré
75001 PARIS
France
email: infos @ verlet.fr

WHY DO WE USE YOUR PERSONAL DATA?

In order to use the Site and make use of the Services, you have accepted the General Terms and Conditions of Sale. This document sets out a contractual tie between yourself and VERLET serving in particular as a legal basis for VERLET’s collection and processing of your Personal Data.

This Data is needed to carry out a number of processes related to the performance of our contractual tie. We use your data, among others, to manage your registration and also manage your purchases, answer your questions or send you information about our products.

Your Personal Data is needed to enable you to access and use our Services, to allow us to improve them and to allow us:
- To carry out operations concerning our commercial tie, meaning your registration, Orders, deliveries, invoices, accounting, refunds, Order returns, exercising your right to a cooling-off period, etc.
- To bring you offers close to your location, in particular via the "In-store collection" or "Paris same day" services
- To bring you loyalty, promotional and special events (tastings)
- To carry out marketing initiatives

More specifically, Personal Data collected via the Cookies that we and our Partners place on your Terminal allow us:
- To draw up statistics, record the number of visits to and use made of the various components of our Site (sections browsed and content viewed, user pathway), allowing us to improve the appeal and user friendliness of our Services
- To adapt our Site’s layout to your Terminal’s display preferences (language, display resolution, operating system used, etc.) when you browse our Site, as dictated by your Terminal’s viewers or players
- To retain information drawn from any forms that you have completed on our Site (registration or access to your account) or from Orders (options selected, Order basket contents, etc.)
- To allow you to access restricted-access or private sections of our Site, such as your account, using any usernames or Data that you may have previously given to us;
- To implement security features, for example when you are asked to log in again to view content or make use of a Service after it has timed out
- To record how many times our sales sections and/or promotions are displayed and activated, including on electronic media published by third parties and/or Partners, to identify such content and these supports and to record how many users clicked on each item of content
- To calculate any sums owed to our Partners in the advertising dissemination process (advertising space agency, site/media outlet) and to draw up statistics

WHAT DATA IS COLLECTED?

VERLET collects the Data that you volunteer via a collection form on the Site, in particular upon registering or placing an Order (your profile, i.e. your official surname, usual surname, forename and any middle name(s), sex, date of birth and delivery address, for example) with which VERLET associates a Customer reference number.

(Upon placement of an Order, our banking service providers also collect and process Personal Data concerning your payment methods (bank card number, bank card expiry date, security code - which is not retained - etc.). For our part, we process part of your bank card number (the first four (4) digits and the last two (2) digits as passed on by your bank. This payment method identifier cannot therefore be used to make transactions.)

We also collect information on the transaction carried out (transaction number, purchase details, etc.), or on the settlement of invoices issued from or via the Site (payment procedures, discounts granted, receipts, balances and outstanding invoices).

Some types of Data are required on a mandatory basis and others optional, as shown in the collection form on our Site.

VERLET collects and processes Data pertaining to the commercial tie with you: product purchased, quantity, value, delivery and/or billing address(es), telephone number, door code, as well as any other information relevant to the delivery (tracking number, shipment status, etc.) order history, correspondence and/or telephone conversations with you and our after-sales service, Customer conversations and comments, person(s) in charge of customer relations, etc..

The following are also collected and processed: Data needed to carry out loyalty promotion initiatives, sales drives and promotions, the organisation and processing of competitions, lotteries and any promotional initiatives such as the entry date, the answers to competition questions and nature of the prizes; and Data pertaining to posts by Customers reviewing products or the Site itself.

Moreover, when you access the Site and/or electronic media published by a third party containing promotional campaigns disseminated by VERLET, cookies are liable to be used and/or placed on your machine, including by our Partners. They save and/or read files on your Terminal in order to collect and process information pertaining to your interaction with us, and in particular your browsing and usage patterns in relation to the Site.

This means that VERLET collects and processes Data pertaining to your browsing and usage patterns in relation to the Site.

WITH WHOM DO WE SHARE YOUR DATA?

All Personal Data collected by VERLET is private and confidential.

VERLET will never pass on your Personal Data to a third party that is liable to use it for its own purposes, and in particular commercial and/or direct advertising purposes, without your permission.

However, VERLET may pass on your Personal Data to comply with an order from the judicial authorities.

We share your data with service providers who assist us or supply necessary support. We draw up contracts with our service providers, which means that we can be sure that your Personal Data is processed effectively.

VERLET may need to transfer some types of Personal Data to third party Partners, temporarily and safely. These are needed in particular:
- For the running, live content and maintenance of our Site
- For making sure that the emails that you have opted to receive are sent out
- For the completion of tasks necessary in order for Services to be performed, for your Order to be fulfilled, for goods to be delivered, for services to be rendered and/or for certain goods to be set aside instore
- For combatting fraud and more generally any criminal activity
- For certain aspects of the after-sales service
- For satisfaction surveys to be carried out, etc.

Our Partners who may need to gain access to your Data process them on our behalf, as per our instructions, in accordance both with this Confidentiality and Privacy Policy and with any appropriate security and confidentiality measure.

FOR HOW LONG DO WE KEEP YOUR DATA?

We keep your personal data only for as long as it takes to carry out the processing for which we hold the data, in order to meet your needs or to meet our legal obligations.

Your Personal Data concerning your Customer profile such as you stated it to be and/or completed it on the Site, and those concerning your browsing and/or your usage patterns in relation to the Site and advertisements that are disseminated to you both on the Site and on third party media by our Partners and/or the Personal Data that is passed on to us by said Partners is held, in an active database, for a period of three (3) years as from the date of your most recent activity as a Customer on the Site or on an electronic communication medium (email in particular).
Once this timeframe has elapsed, your Customer profile is considered "dormant" and will be automatically deactivated. It is therefore up to you to set up a new one for any further Orders.

Your Personal Data pertaining to an Order on the Site (surname, forename, product or service, delivery address, billing address, etc.) is kept for a period of three (3) years as from the date when the Order was placed.
It remains accessible to you and to us, in particular from your Customer account, so that both you and we can have your full Order history at your/our disposal. We can delete it at any time upon request on your part.

However, once the said timeframes have elapsed, if need be taking your deletion request into account in this, your Personal Data can be archived in order for us to meet our legal, accounting and fiscal obligations (like the obligation to keep invoices for a period of ten (10) years set forth in Article L.123-22 of the French Commercial Code [Code du commerce]) and/or at the very least for the applicable limitation period like the common law limitation period of five (5) years set forth in Article 2224 of the French Civil Code [Code civil]). This may also be done in order to prevent any unlawful activity after your Customer account has been deleted (misuse of your old account by a third party, for example) or in order to meet requests after the closure of your Customer account, including those concerning Orders, etc..

In case of legal action, including any such action solely concerning VERLET, for example in connection with the authorities, the aforementioned Personal Data and any information, documents or papers containing Personal Data that may establish the events liable to become accusations or concerning the identification of the accused, the victims, the witnesses or the court officers (official surname, usual surname, forename and any middle name(s),  sex, date and place of birth, nationality, address, telephone and fax numbers, email address) can be kept for the duration of the case, including for a period longer than those stated above.

WHAT RIGHTS DO YOU HAVE?

We respect your right to privacy. It is important for you to keep control of your personal data. To this end you have the right to access your Personal Data and to request that it be rectified or deleted. Moreover, you can object to the processing and portability of your data.

Access rights
You have the option of getting confirmation from VERLET that the Data concerning you is/is not processed, and if it is, gaining access to it.
 
Rectification rights
You have the option of having VERLET rectify without delay any Data concerning you that is inaccurate. You also have the option of having any incomplete Data supplemented, including by providing an additional declaration.

Data deletion rights
You have the option of having VERLET delete without delay Data concerning you, where one of the following reasons applies:

a) The Data is no longer needed for the purpose for which it was collected or processed by VERLET in a different way
b) You have withdrawn your permission for the processing of this Data and there is no other legal basis for its being processed
c) You are exercising your right to object under the conditions recalled below and there is no legitimate and overriding reason for its being processed
d) The Data have been processed unlawfully
e) The Data must be deleted to meet a legal obligation
f) The Data was collected from a child

Data portability right
You have the option of having VERLET send you the Data concerning you, in a structured, commonly used and machine-readable format if:

a) The processing of the Data is based on permission having been granted, or on a contract, and
b) The processing is carried out via automated processes

When exercising your portability right, you have the right to have VERLET pass the Data directly to a processing agent that you shall appoint, technology permitting.

Your right to Data portability must not impinge upon the rights and civil liberties of any other person.
 
Objection right
You have the right to object at any time, for personal reasons, to the processing of Data concerning you in VERLET’s legitimate interest. VERLET will then no longer process the Data, unless it can prove that there are legitimate and overriding reasons for the processing that override your interests, rights and civil liberties, or may keep them for such rights to be ascertained, exercised or defended in court.

Where Data is being processed for sales drive purposes, you can at any time object to the processing of this Data from the ‘Make your choice known’ paragraph.

If a Customer wishes to object to processing of their Personal Data for which VERLET has not put a button in place, they can always exercise their right to object under the conditions of paragraph III – Your rights.

HOW DO YOU EXERCISE YOUR RIGHTS?

To exercise your Specific Rights with VERLET and/or, where applicable, have this Policy read out to you, you can either send your request:
- By email sent to our Data Protection Officer at infos@verlet.fr
- By visiting the "Contact" section of the Site and selecting the relevant subsection
- By letter sent to our Data Protection Officer at the following address: VERLET / 256, Rue St Honoré / 75001 PARIS

A reply will be sent to you at the latest within one (1) month following the date when your request is received. If need be, owing to the complexity and/or number of requests, this timeframe may be extended by two months by VERLET, who will notify you of this.

Should you request that your Data de deleted and/or exercise your right to do so we can nonetheless keep them in archive form for as long as is needed to meet our legal, accounting and fiscal obligations and in particular, in order to prevent any unlawful
activity after your Customer account has been deleted (misuse of your old account by a third party).

You can also ask us at any time to stop sending advertising material or newsletters suited to your Terminal’s browsing information, by contacting us directly and free of charge, or by clicking on the unsubscribe link present in newsletter that we might send you by email. Where applicable, any advertising material that you continue to receive, unless you exercised your right to object with us, will not be able to be browsed using your Terminal.

You can at any time lodge a complaint with the competent supervisory authority (in France, the CNIL: www.cnil.fr)

COOKIES

As you browse our sites, information pertaining to your browsing session are liable to be saved in files known as "Cookies" installed on your terminal (computer, tablet, smartphone, etc.).
This section gives you more information on the origin and use made of the browsing information processed when you visit our site https://www.comptoirsrichard.fr.

1. What is a cookie?
A cookie is a small text file containing various pieces of information. It is placed on your terminal (computer, tablet, smartphone...) via your browser, by websites that you visit. Cookies can be designed for a number of purposes. Whatever the type of cookie, only the issuer is liable to read or modify the information contained within it.

2. The different types of cookie used by https://www.verlet.fr:
The site https://www.verlet.fr uses cookies. None of the cookies implemented on our sites harvest Personal Data concerning you.
The types de cookies used by https://www.verlet.fr sites are those that are strictly necessary. They are essential to the running of our site and allow you to access, in particular, secure sections such as your basket, your customer account, etc. Without these cookies, you would not be able to use our site properly.

- Analytics or performance cookies: these cookies tell us how you use our site and how it performs, and enable us to improve the way it works. In particular they record your browsing data (the most visited pages, the exit pages from which you leave our site or  the duration of your visit).

- Our affiliation programme cookies: these cookies allow us to quantify traffic athttps://www.verlet.fr. These cookies have a variable lifespan and only contain browsing information.
We have no control over the process used by social networks to collect information on your browsing sessions on our site.

If you have an account on one of these networks, we urge you to read its privacy policy to find out how the browsing information gathered by such social media buttons is intended to be used, which may include advertising purposes. The privacy policy should allow you to make choices about these social networks, in particular by adjusting your account settings on each of these networks.

3. More information on cookies:
You can find out more about the use of cookies on the CNIL site: http://www.cnil.fr/your-rights/your-traces/les-cookies/

4. Accept or reject the use of cookies:
N.B.: We remind you that your browser’s cookie settings are liable to affect your access to our services. If your browser is configured to reject all cookies you will not, for example, be able to make purchases and essential site features will no longer work.
You can configure your browser to either save cookies on your terminal or reject them, either systematically or depending on the identity of the issuer.
You can also configure your browser to accept or reject cookies one by one, before any are liable to be saved on your terminal.

To find out how to adjust your cookie preferences, simply use your browser’s help menu:
Internet Explorer™ : Online help
Safari™ : Online help
Chrome™ : Online help
Firefox™ : Online help
Opera™ : Online help