Privacy policy and protection of personal data

Last update: November 26, 2019

We intend to offer the highest level of protection for your personal data, in accordance with the rules, practices, recommendations and best practices referred to in the applicable legal and regulatory provisions, whether from European or local sources, and in particular Regulation (EU) 2016/679 of the European Parliament and of the Council on the Protection of Personal Data (the “DGPS”) of 26 April 2016, which came into force on 25 May 2018.

This “Privacy and Data Protection Policy”, here in after “Personal Data Policy”, describes our commitments to the protection of personal data and informs you of the methods of processing your data, the precautions taken to protect them and reminds you of your rights, and how you can exercise them.

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

The controller of your data is:

LACELIER FRANCE, a public limited company with a management board and a supervisory board with a capital of €10,000,000, registered in the Paris Trade and Companies Register under number 388 634 883, whose registered office is located at 4-6 rue Cesselin 75011 Paris – France.

Hereinafter referred to as “LACELIER” or “We”.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

The personal data collected concern personal and non-personal data, but also electronic identification data relating to the computer terminal used to access the Site www.lacelier.com  (hereinafter referred to as “the Website”).

We collect the data you provide us with, in particular when you use our contact form, send us your applications or subscribe to our newsletter.

We may therefore collect your surname, first name, e-mail address, telephone number, place of residence and, where applicable, date of birth, profession, level of education, professional experience, photograph (this list is not exhaustive and depends on your relationship with LACELIER).

The mandatory or optional nature of the information to be provided is indicated by an asterisk at the time of collection.

To ensure complete rigour in the management of the Data concerning you, you are asked to provide us only with complete, accurate and up-to-date information that does not harm the interests or rights of third parties.

Certain data are also collected automatically as a result of the activity of users of the Website (hereinafter referred to as Users) on the Website, in particular by “Cookies”, the existence and disposal of which is indicated below in the section entitled “Use of Cookies” and in the document dedicated to them on this Website.

This data identifies the connection terminal, which is used to access this Website. It is specified that these data alone are generally not sufficient to identify a User by name.

3. FOR WHAT PURPOSES ARE YOUR PERSONAL DATA USED?

Personal data that may be collected by LACELIER are treated confidentially. They are carried out solely for purposes relating to the facilitation of our relationship with you, the implementation of LACELIER’s promotional and commercial activity and the proper administration of our management systems and processes.

The possible processing purposes are summarized in the following table:

4. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

We rely on the legal bases set out below in order to be able to process personal data:

The consent 

For the following actions: The response to your questions and requests transmitted from the contact form, the sending of newsletters and commercial offers, the management of application files and the analysis of the performance of the Site, the processing of Personal Data is based on consent.

Legitimate interest

For the detection of bugs and the optimization of online browsing, the processing of Personal Data is based on LACELIER’s legitimate interest.

5. PERSONAL DATA POLICY FOR VULNERABLE PERSONS

Some of our services may be used by minors, without our knowledge. If information is collected about a minor or a legally unauthorised person, the minor’s or person’s legal representative will always have the opportunity to contact LACELIER in order to have the personal data concerned immediately deleted, rectified or modified under the conditions described in Article 8 of the Personal Data Policy.

6. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

Your personal data may be transmitted to the following categories of recipients:

• The internal departments of LACELIER and the LACELIER Group Companies in charge of processing your requests and executing the services subscribed, in particular IT, sales, support, HR and marketing services.
• The judicial or administrative authorities empowered by law, which would be required to request disclosure, in accordance with the laws and regulations in force.
• In order to collect information to analyse the website’s audience and improve its content, your personal data may be transmitted and stored by Google on its servers when using the Google Analytics tool.

Google may also transfer this information to third parties if required to do so by law or if they have a partnership agreement.

You can disable the use of this tool by selecting the appropriate settings in your browser. Such deactivation may prevent the use of certain features. By using this website, and unless you deactivate its analysis tool, you expressly consent to the processing of some of your personal data by Google.

For more information on privacy rules for using Google Analytics, but also if you want to disable this tool by installing the Google add-on module for this purpose, click on the following link: https://policies.google.com/technologies/partner-sites?hl=fr

7. STORAGE AND SECURITY OF PERSONAL DATA

Your personal data are kept for the time necessary for their processing, and, unless otherwise expressly or legally permitted, for a maximum of three (3) years from the day of their collection or our last contact with you. Electronic identification data are kept for a period of thirteen (13) months from the date of collection.

Under the legal exceptions, your personal data may be stored for evidentiary purposes, in accordance with the legal and regulatory provisions in force (in particular those provided for by the Civil Code and the Consumer Code).

LACELIER exercises the greatest vigilance and has taken the appropriate technical measures, in particular those recommended by the CNIL, regarding the risks of a security incident involving personal data and their consequences for individuals. These consequences can range from the simple inconvenience caused to you, to cases of embezzlement, intrusion, disclosure and alteration, which may cause serious harm. LACELIER has therefore set up various measures to prevent these risks, including technical tools in accordance with good engineering practice, to ensure information security. Information on these techniques may be communicated to our correspondents and contacts who may have a legitimate interest in ensuring this, subject of course to the usual rules of confidentiality and security. Among the mechanisms envisaged are various information partitioning devices, firewalls, access control procedures, the use of cryptography mechanisms, etc. LACELIER guarantees that at least restrictions and controls on access to the Data are applied, only to persons authorised to know or access it by virtue of their functions and who have been specially trained in data protection issues. Where the processing is likely to present risks, additional security measures shall be implemented.

However, the User acknowledges and accepts that LACELIER, although equipped with the aforementioned devices and the expertise of professionals in these techniques, is not in a position to control all the risks associated with the operation of the Internet, in particular malicious attacks directed against it by particularly well equipped pharmacies. LACELIER is therefore obliged to draw your attention to the existence of possible risks, which may arise, in extreme cases and despite the precautions taken, in terms of occasional loss or breach of confidentiality of data passing through the networks. LACELIER has set up a specialised monitoring team, composed of its technicians, representatives of internal services, likely to be potentially exposed to these risks and qualified external consultants. This team is kept up to date, in particular with the recommendations regularly issued on these subjects by the CNIL, the recent European Committee for the Protection of Personal Data (COE) and the National Agency for the Security of Information Systems (ANSSI). LACELIER also has a Crisis Management Committee, structured so that, within the short deadlines prescribed by law, all the technical, legal and notification measures legally prescribed are taken very quickly, for the best protection of the interests of the persons concerned.

8. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

In accordance with the Privacy Policy, you have the following specific rights:

Right of access (Art. 15 of the DGPS): you have the right to access the Personal Data concerning you, which has been collected by LACELIER and to check in particular:

• that the processing carried out is in accordance with the purposes of this LACELIER Data Policy,
• that the categories of Personal Data concerned by the processing are limited to those expressly covered by the Personal Data Policy,
• that the recipients to whom the Data are communicated are those provided for in the Personal Data Policy.

Right of rectification (Art. 16 RGPD): you have the right to obtain from LACELIER FRANCE. as soon as possible, the rectification of any inaccurate Personal Data and the completion of any incomplete ones.

Right to erasure (Art. 17 of the DGPS): you may request that your personal data be erased if they are inaccurate, incomplete, ambiguous, outdated, or if their collection, use, communication or storage is not necessary or even unlawful.

Right to limitation of processing: (Art. 18 of the DGPS): you may request LACELIER to limit the processing of personal data in the cases provided for by the applicable texts.

Right to portability (Art. 20 of the DGPS): you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit them to another controller when the latter is based on consent or a contract and is carried out by automated processes.

Right of opposition (Art. 21 of the DGPS): you have the right to object to the processing of personal data concerning you in the event that they are processed for the purpose of prospecting

Automated individual decisions: (Art. 22 of the DGPS): you have the right not to be the subject of a decision based exclusively on automated processing affecting you (induced legal effects) and may to this end lodge a complaint with the competent supervisory authorities (the CNIL for France, knowing that you may also act before the authority of the Member State in which your habitual residence is located, your workplace or the place where the violation was allegedly committed).

You may exercise at any time with LACELIER FRANCE all the rights and prerogatives provided for by the above-mentioned texts by sending an e-mail to privacy@lacelier.com  or by sending a letter to LACELIER FRANCE, 4-6 rue Cesselin – 75011 Paris — FRANCE, indicating your full name and e-mail address. A proof of identity may be required.

We remind you that your rights are strictly individual and can only be exercised by the person concerned with regard to his or her own information. In accordance with the regulations in force, your request must specify the address to which the reply must be sent and be accompanied by a photocopy of elements to verify your identity.

9. USE OF COOKIES

Website Cookies

All web pages on this Website use so-called “cookies”. These systems, which are now universally used by sites, allow companies to collect certain information, mainly of a technical nature and to identify site users. Cookies are generally described as cookies, which are files generated by the site and sent to your browser to record your activities while you are browsing. Most market tool cookies remember the name of the cookie’s domain of origin, its lifetime and a unique number created at random.

LACELIER uses cookies, which are generated as standard by its web tools, when a user accesses the Website.

You are then informed that, during your visit, a cookie may be automatically installed on your browser. It is stored on the hard disk of your computer terminal. This file may be accessible through the tool on our websites during your subsequent visits. The maximum period of storage of this information by LACELIER in the User’s terminals, in accordance with the recommendations of the CNIL, is 13 months.

You can refuse the presence of Cookies by activating a setting on your browser. All details on the implementation of your refusal are available on the CNIL website: www.cnil.fr/fr/Cookies-les-outils-pour-les-maîtriser

We draw your attention to the fact that, if the browser is configured to refuse all Cookies, you may experience technical difficulties and be blocked in your browsing. You may not be able to perform all the operations offered, including having access to certain functions designed to facilitate your navigation on our Site.

You will find all the necessary information on our use of Cookies in a specific document to which we expressly refer, accessible at the corresponding tab entitled “Cookies Policy”.  This cookie information notice is also accessible directly with the hyperlink inserted in our “cookie banner”, i. e. the warning that appears on your screen during your visits, until you have clicked on the said link and indicated your acknowledgement and acceptance of our Cookies Use Policy.

Audience Analysis Tool

We also inform you that we use Google’s audience analysis tool systems that also use Cookies, also described in the above Cookies Usage Policy.

10. MODIFICATION OF THE PERSONAL DATA AND ADDITIONAL INFORMATION POLICY

LACELIER reserves the right to modify this Personal Data Policy at any time.

Any changes to the Personal Data Policy will be effective immediately upon posting and will be posted at the top of the page.

In the event of a significant change in our Personal Data Policy, such as a change in the purposes of collection, the renewal of the User’s consent to our Personal Data Policy will be reiterated.

Consequently, the User is invited to regularly consult the Personal Data Policy in order to be informed of any changes that may have occurred.

If you have any questions about this privacy and data protection policy, you may contact us at any time by sending an e-mail to privacy@lacelier.com  or by sending a letter to the following address: LACELIER FRANCE, 4-6 rue Cesselin – 75011 Paris – France.

If you wish to obtain additional information on the protection of Personal Data in general, you can consult the website of the “Commission Nationale de l’Informatique et des Libertés” (CNIL) at the following link: www.cnil.fr