Privacy policy

Personal Data Protection Policy

The company ARLETTIE PARIS (referred to as “we”, “our”) shall do its utmost to respect the privacy of all the parties registered for the Services that it offers (together referred to as “you”, “yours”) so that they can benefit from the best experience possible when browsing on the Website and participating in the Events organised in the ARLETTIE spaces.

We attach the greatest importance to the trust of our users, Registered Parties and members, and in this respect, we consider the processing of your personal data to be a priority. For this reason, we would like to provide you with the most transparent information regarding the way in which we are likely to use it.

In accordance with  current regulations, this Personal Data Protection Policy (the “Policy”) applies when you browse on our Website  or participate in our Events and aims to inform you of the collection, the use and more broadly the processing of your personal data. The terms used in  both singular and plural and defined in the General Conditions and Special Conditions will have the same meaning within this Confidentiality Policy.

1. WHICH PERSONAL DATA DO WE PROCESS, AND HOW ARE THEY COLLECTED?

We only collect personal data necessary for the purpose for which it is processed. The compulsory nature of the communication of information is indicated in the collection form during your registration or the amendment of your information.

This data is the following:

  1. Your identification data, such as your first and last name, gender and date of birth;
  2. Your contact details, such as your personal and/or professional postal address, personal and/or professional telephone number and personal and/or professional e-mail address;
  3. Your personal information, namely your date of birth, all the information relating to your marital situation (spouses, children etc) and your leisure activities;
  4. Your information associated with your participation in the Events, namely all the information associated with the subscription to the Arlettie Club and/or with your participation in the Events, such as your registration, your attendance if appropriate, and your purchases, such as products purchased and information associated with your payment method;
  5. The data of persons likely to accompany you during certain Events (hereafter referred to as “the Guests”): the organisation of certain Events authorises you to be accompanied by third parties under specific conditions. In such cases, in order to be certain of the satisfactory running of the Events in question and for reasons of security, we are likely to process information relating to third parties whose personal data as described above  have previously been communicated to us by you in full or in part.

This Policy is also applicable to the processing of the personal data of Guests as forwarded by you to us, and we therefore invite you to ensure that third parties have given you authorisation for their data to be forwarded to us for this purpose and that they have read this Policy.

  • Your connection data at the time of your visit to our Website, such as the information regarding the hardware and software of your computer or mobile device. This information includes your IP address, device model, browser type, and device identification. This information is used to ensure smooth running of the Website, to maintain its quality, for the purposes of general statistics, and to meet our legal and regulatory obligations.
  • Cookies: we ask you to read the paragraph below relating to the use of cookies.

In order to gather this data, we use different collection methods and in particular:

  • Directly from you: when you fill in a registration form, register for an Event, carry out a transaction, or pass on information to us by telephone, by letter, on line, by electronic mail or any other method;
  • Indirectly: when you visit our Website (for example, by means of cookies or connection data) and following the Events at which you participate. We also gather the personal data of Guests indirectly through you within the context of the forms that you send us.

2. ARE COOKIES DEPOSITED WHEN BROWSING ON THE WEBSITE?

A “cookie” is a text file placed on your device using a navigation tool. Cookies allow its issuer, and exclusively this issuer, to identify the terminal at which it is recorded, for the duration of the validity or storage of the cookie, and cannot be used to carry out programmes or transmit viruses to your computer.

We use cookies or other similar technologies (i) to facilitate your browsing on the Website, (ii) to use the main features of the Website and secure your connection, and to directly access the personal spaces of the Website using user ID or data that you may have entrusted to us previously, (iii) to adapt the presentation of the Website to  your terminal’s display preferences during your visits, and (iv) to carry out statistical studies.

You have the option of accepting or refusing the cookies. Most browsers automatically accept cookies, but if you prefer, you can generally amend the parameters of your browser to refuse cookies. If you choose to refuse cookies, you risk not being able to  benefit from all features of the Website.

You can configure your browser so that:

  • The cookies are retained, or on the contrary rejected, either systematically, or depending on their issuer;
  • The acceptance or refusal of cookies is suggested from time to time, before a cookie is likely to be retained on your device
  • Cookies accepted on your device can be removed at any time.

For managing cookies, the configuration of each browser is different. It is described in the help menu of each browser and in particular at the following addresses communicated for information purposes:

3. ON WHAT BASIS AND FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA

The personal data that we collect is processed in accordance with  current regulations for explicit, legitimate and specific purposes, either on the basis of our General Conditions, or to fulfil a legal and/or regulatory and/or contractual obligation with our partners, in particular the Brands, or subject to your prior consent.

The aims of our processing are described below:

A. TO ENSURE PROVISION OF SERVICES

We collect and use your personal data to allow us to stage the Event that we organise and more specifically to:

  • Manage your account and, if applicable, your membership of the ARLETTIE Clubs;
  • Inform you of our Events and enable you to participate in them, while observing our obligations and commitments to our partners, in particular the Brands;
  • Manage your participation at our Events, and in particular: the terms and conditions of your access, depending on any conditions imposed by the Brands, under the conditions specified in the General Conditions and  provided they are legitimate and lawful;
  • Process the transactions made at the time of sales,  and process any incidents that occur (management of fraud, payment incidents, disputes etc);
  • Ensure the quality of our Services and improve them. In this respect, we draw up personalised statistics to allow improvement in the provision of our Services by supplying Services that may be of more specific interest to you on the basis of your purchase history and patterns and also to draw up general statistics, which  are made anonymous when processing of your personal data does not appear necessary for it to be carried out. We are also likely to contact you for surveys;
  • Provide customer service;
  • Contact us.

Your personal data are also essential for us for our interactions with you within the context of your browsing on the Website and our management of your registration for our Services, and more generally within the context of our commercial relations with you.

You are informed that in certain scenarios specified in the General Conditions, we may:

  • Contact you electronically, by text, post and/or telephone depending on the preferences you have expressed;
  • Select the Events likely to interest you in view of information that you have provided to us, or on the other hand not to contact you if no information is provided, so  that we can have a qualified service  based on your interests and/or the obligations by which we may be constrained by our partners.

B. TO MAKE THE WEBSITE SECURE

We ensure the security of your personal data and of those of third parties against any access, use or fraudulent disclosure, by putting in place data protection strengthened by the use of technical measures of appropriate physical and logical security in order to guarantee integrity of your data, as well as its confidential and secure processing.

Within the limits by which we are constrained because of the state of the technology, we shall  make every effort to  make your information completely secure. In this respect, we call on trusted and recognised partners to provide sufficient guarantees for implementation of the appropriate state of the art technical and organisational measures, so that the processing of your data meets the requirements of  current regulations and guarantees protection of your rights.

C. TO OBSERVE OUR STATUTORY AND REGULATORY OBLIGATIONS

Within the context of operation of the Website and all the services offered on it as described by the Policy, we are bound by various statutory and regulatory obligations involving the preservation of your personal data.

4. WHO ARE THE RECIPIENTS OF THE PROCESSED PERSONAL DATA?

We only process your personal data within the context of the purposes described by this Policy.

For this reason, we are likely to transfer your data under the conditions described below:

  • Within the ARLETTIE group for the exclusive purpose of allowing you to access the ARLETTIE Spaces within which ARLETTIE organises the Events in which you wish to participate;
  • To trusted partners intervening as sub-contractors, in order to provide you with all the services that we offer you on the Website and/or within the context of our Events and more specifically:

            – to host your data and to assist you within the context of the use of the Website or during participation in our Events;

            – to send you electronic mail;

            – to send you mail and letters (post sorting centre);

            – to send you texts;

            – to allow you to access the Events;

            – during a sale, to ensure payment (payment and management of bank cards),

            – to manage their logistics (spaces, logistical centre);

            – for the purposes of statistical analysis, which allows us to improve the quality of our products and services.

These third parties are contractually obliged to use the personal data that we send them only for the purposes for which they have been authorised, and they are obliged to maintain the security and confidentiality of your information with protection equal or above the protection that we provide.

5. WHEN ARE THE DATA COLLECTED AND HOW LONG ARE THEY KEPT?

We only keep your personal data for the period of time necessary for satisfactory provision of the services that we offer, unless the law requires your personal data to be kept for a different length of time.

Consequently, we keep the data from your Account for a maximum of five (5) years with effect from the closure of your account, unless the law requires certain of this data to be kept for a shorter period.

Your bank data are not kept beyond the period necessary for completion of the transaction unless you have given your prior consent thereto. By way of an exception to the above, and if you have not given us such consent, your card  number and validity date may be retained for purposes of proof in case there is a dispute over the transaction for a maximum period of thirteen (13) months following the debit date, this period may be extended to fifteen (15) months for deferred payment cards.

The cookies placed on your browser have a life expectancy of thirteen (13) months.

By exception, this data may then be archived for an additional period exclusively to manage pending complaints and disputes, to fulfil the legal and/or regulatory obligations, and/or to respond to claims by authorities authorised to make a claim.

6. ARE YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

Within the context of providing the Services, we may transfer your personal data to some of our external service providers based outside the European Economic Area (EEA), meaning that the processing of your personal data involves a transfer of data outside the EEA.

In this case, we ensure that this transfer is made under conditions that are consistent with current regulations, take all appropriate measures under the conditions, subject to the legal, technical and operational guarantees which ensure the confidentiality and security of this data, and in particular:

            – By transferring your personal data to countries considered by the European Commission to offer an adequate level of personal data protection; or

            – By making sure that the recipient entity protects your personal data under conditions approved

7. WHAT ARE YOUR RIGHTS AND HOW DO YOU EXERCISE THEM?

In accordance with the regulations in force, you have the following rights:

  • Access to your personal data, in order to receive a copy of the personal data that we hold on you and check that we are processing it in accordance with current regulations;
  • Correction of personal data that we hold about you, in order to allow you to correct any incomplete or inaccurate information that we hold on you;
  • Deletion of your personal data, allowing you to remove, or request us to remove, personal data if we do not have legitimate reasons to continue processing it. You also have the right to remove, or request us to remove, your personal data if you have exercised your right to object to the processing (see below) or if we are obliged to delete your personal data in accordance with the regulations in force. You are advised that we are not always able to respond to your request for deletion, for specific legal reasons which will be notified to you, if applicable, at the time of your request;
  • To be informed of the aim of the processing of your (or a third party’s) personal data, allowing you to specify to us when we are relying on a legitimate interest and your specific situation dictates something which incites you to object to the processing for this reason because you consider that it affects your rights and fundamental freedoms. In certain cases, we may demonstrate that we have legitimate and pressing reasons to process your personal data;
  • To request a restriction of the processing of your personal data, allowing you to request us to suspend processing of your personal data in the following cases: (a) if you would like us to establish the accuracy of the personal data; (b) if our use of the personal data is illegal, but you do not want us to delete it; (c) if you need us to keep the personal data even when we no longer need it as you need it to establish, exercise or defend legal complaints; or (d) you oppose our use of your personal data, but we must verify if we have legitimate pressing reasons to use it;
  • To request the transfer of your personal data to you or to a third party, allowing you to ask us to provide you, or a third party chosen by you, with your personal data in a structured format that is commonly used and machine-readable.  You are advised that this right applies only to the automated personal data that you initially provided for us to use or  when we have used the personal data to perform a contract with you;
  • To withdraw consent at any time when we are relying on the consent to process your personal data. However, this will not affect the legality of any processing carried out before you withdrew your consent or when we rely on a different legal basis for the processing. If you withdraw your consent, we may not be able to provide you with certain products or services. We will inform you if this is the case at the time when you withdraw you consent.

These rights may be exercised by contacting us at donneespersonnelles@arlettie.fr with proof of your identity. In addition, you are reminded that you may exercise some of these rights directly according to the configuration of your account. If you no longer wish to receive messages from us, you can click on the link at the bottom of the e-mail. For technical reasons, a reasonable period is necessary for us to meet your request and you may receive a few messages following your request while we are still taking it into account.

Exercising some of these rights may prevent us from providing you with access to the Website and/or from using all or part of the services that we are offering you and in particular informing you of forthcoming Events under optimum conditions.

You may send a complaint to the National Commission on Informatics and Liberty, the supervisory authority responsible for the observance of obligations in matters of personal data.

Finally, it is pointed out that we may be required to pass on your personal data under the conditions set out in the law, to a duly authorised judicial or administrative authority.

7. CAN THIS POLICY BE AMENDED?

We can, occasionally and at any time, amend this Policy, especially because we are developing our services and/or because the regulations in force require us to. We will inform you of this through a message on the Website or any other method.

In any event, we recommend that you regularly refer to this Policy to obtain the latest information regarding our confidentiality practices.

The most recent version of the Policy is the one bearing the date indicated at the end of this document.

Date of last update of this Policy: 5 October 2018.

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