1. Who are we?
1.1 Data controller
The following information is provided to you so that you are aware of the personal data protection commitments of Nactis Flavours SA with a Board of Directors and share capital of 7,033,070 euros, whose registered office is located at 36, rue Gutenberg, ZI La Marinière, 91070 Bondoufle, which acts as data controller for the processing of personal data referred to in this document.
2. The personal data we process
In the context of personal data processing, Nactis Flavours collects and processes the following categories of data in particular:
- The browsing data of customers and prospects (IP address, type of device, etc.);
- Customer identification data (first and last name, postal address and email address, etc.);
- The history of orders placed;
- The history of exchanges with our teams (by email or via online chat):
- Some marketing and logistical information (orders, sales, after-sales service etc.), sales reports, complaints and information requests, email campaigns.
We may collect personal data, in particular:
- through the contracts signed;
- via our website;
- through orders placed and call centres;
- through social media and brand communication channels (e.g. Facebook, Twitter);
- or when you give them to us voluntarily, in particular for our loyalty programme.
3. The purposes and legal bases of our data processing
3.1 The purposes of our processing
The processing we carry out is for the following purposes:
- the management and follow-up of requests for information made by customers or prospects and the answers given to them;
- the management and follow-up of orders:
- the management of the after-sales service;
- order tracking and statistics;
- subscription to the newsletter and prospecting, in particular sales prospecting in the event of opt-in;
- management and monitoring of product warranties;
- litigation management;
- compliance with legal obligations, particularly in terms of accounting.
3.2 The legal bases of our processing
We only carry out data processing if at least one of the following conditions is met:
- your consent to the processing operations has been obtained;
- the existence of our legitimate interest, or that of a third party, which justifies our processing of the personal data concerned;
- the execution of a contract binding us to you requires us to process the personal data concerned;
- we are bound by legal and regulatory obligations that require the processing of the personal data concerned.
4. The recipients of your data
The personal data we collect, as well as those collected subsequently, are intended for us in our capacity as data controller.
We ensure that only authorised persons can access these data. Our service providers may be recipients of these data in order to carry out the services we entrust to them. Some personal data may be sent to third parties or to legally approved authorities in order to meet our legal, regulatory or contractual obligations.
Your personal data may be linked, pooled or shared between all entities of the Nactis Flavours Group.
They may be communicated to these entities for the purposes referred to herein. These operations are carried out on the basis of instruments that comply with applicable regulations and are capable of ensuring that your rights are protected and respected.
5. Data retention periods
The retention periods we apply to your personal data are in proportion to the purposes for which they were collected. Consequently, we organise our data retention policy for the strict duration necessary for processing, in accordance with our retention period policy.
6. Your rights
6.1 Your right to information
You acknowledge that this policy informs you of the purposes, legal framework, interests, recipients or categories of recipients with whom your personal data is shared, and the possibility of data being transferred to a third country or international organisation.
In addition to this information and in order to ensure fair and transparent processing of your data, you declare that you have received additional information concerning:
- the retention period of your personal data;
- the existence of the rights you are granted and the terms and conditions of their exercise.
If we decide to process data for purposes other than those stated, you will be provided with all the information relating to these new purposes.
6.2 Your right to access and rectify your data
You have the right to access and rectify your personal data, which you can exercise by contacting [email@example.com] at the following address: Nactis Flavours, whose registered office is located at 36, rue Gutenberg, ZI La Marinière, 91070 Bondoufle.
As such, you have confirmation that your personal data are or are not processed and when they are, you have access to your data as well as information about:
- the purposes of processing;
- the categories of personal data concerned;
- the recipients or categories of recipients as well as the international organisations to which the personal data have been or will be communicated, in particular recipients located in third countries;
- where possible, the proposed retention period for the personal data or, where this is not possible, the criteria used to determine this period;
- the existence of the right to request the data controller to rectify or erase your personal data, the right to request a limitation on the processing of your personal data, a right to the portability of your data, the right to object to this processing;
- the right to file a complaint with a supervisory authority;
- information relating to the source of the data when they are not collected directly from the data subjects;
- the existence of automated decision-making, including profiling, and in the latter case, relevant information concerning the underlying logic, as well as the significance and expected consequences of such processing for the data subjects.
You may ask us, depending on the case, to rectify or complete your personal data if they are inaccurate, incomplete, ambiguous or out of date.
6.3 Your right to have your data erased
You may request us to erase your personal data when one of the following reasons applies:
- the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- you withdraw the prior consent given;
- you object to the processing of your personal data when there is no legal reason for such processing;
- the processing of personal data does not comply with the provisions of the applicable laws and regulations;
- your personal data have been collected as part of the company’s information services offered to children under 16 years of age.
However, the exercise of this right will not be possible when the storage of your personal data is necessary in accordance with legislation or regulations, in particular, for example, for the establishment, exercise or defence of legal rights.
6.4 Your right to limitation of data processing
You may request a limitation to the processing of your personal data in the cases provided for by law and the regulations.
6.5 Your right to object to data processing
You have the right to object to the processing of personal data concerning you when the processing is based on the legitimate interest of the data controller.
6.6 Your right to the portability of your data
From 25 May 2018, you will have the right to the portability of your personal data.
The data on which this right can be exercised are:
- only your personal data, which excludes anonymized personal data or data that does not concern you;
- declaratory personal data as well as the personal operating data mentioned above;
- personal data that do not infringe the rights and freedoms of third parties such as those protected by business secrecy.
This right is limited to processing based on consent or on a contract and to personal data that you have personally generated.
This right does not include derived or inferred data, which are personal data created by NACTIS FLAVOURS.
6.7 Your right to withdraw your consent
When the data processing we carry out is based on your consent, you may withdraw it at any time. We will then stop processing your personal data without jeopardising the previous operations for which you gave your consent.
6.8 Your right to file a complaint
You have the right to file a complaint with the French national data protection authority (CNIL) on French territory and this without prejudice to any other administrative or judicial remedy.
6.9 Your right to set out guidelines for after your death
You have the possibility to set out guidelines for the storage, erasure and communication of your personal data after your death with a trusted, certified third party responsible for ensuring that the deceased’s wishes are respected in accordance with the requirements of the applicable legal framework.
6.10 Terms and conditions of exercising your rights
All the rights listed above may be exercised by letter accompanied by a copy of an identity document sent to [firstname.lastname@example.org] or to the following address Nactis Flavours, whose registered office is located at 36, rue Gutenberg, ZI La Marinière, 91070 Bondoufle
Nevertheless, with regard to the exercise of the right to information, we may not be obligated to act on it if:
- you already have this information;
- the saving or communication of your personal data are expressly provided for by law;
- the communication of information is impossible;
- the communication of information would require disproportionate effort.
The security of personal data is important to Nactis Flavours.
In accordance with legal obligations, Nactis Flavours keeps this information in enhanced security conditions and for a limited period of time in proportion to the purposes for which you have provided it to us.
NACTIS FLAVOURS follows generally accepted standards to protect the personal data submitted to it, both during transmission and once NACTIS FLAVOURS receives it.
This policy may be modified or amended at any time by NACTIS FLAVOURS. You are invited to refer to it regularly. Last modification: 30/10/2019.