Personal Data Privacy Policy

SPRITZANDO – TCHERNOMOROFF NICOLAS processes personal data.

SPRITZANDO – TCHERNOMOROFF NICOLAS complies with the provisions of the General Data Protection Regulation (GDPR) and any applicable national data protection and privacy legislation.

This Privacy Policy explains how personal data is collected and provides details of how it is used.

The personal data collected varies according to how the services are used. Personal data collected or held may be provided directly by the individual concerned, obtained from third parties, or collected through activity on the website and the use of the services. Please refer to the section on cookies.

1. Data Protection Officer (DPO)

Any questions relating to this Privacy Policy and any requests to exercise data subject rights are handled by the Data Protection Officer, who may be contacted as follows:

SPRITZANDO – TCHERNOMOROFF NICOLAS – contact@spritzando.com – 10 RUE HUMBERT CHATILLON, 69400 LIMAS, France

Any request to exercise the rights of access, rectification, erasure or restriction of processing must be accompanied by a copy of an identity document belonging to the person making the request.

2. Personal Data Collected

The data collected through the Company’s website is as follows:

• Identity: surname, first name, telephone number and email address.

3. Purposes for Which Personal Data Is Collected

Provision of Services

This information is used for purposes relating to the services requested.

Such processing is permitted under applicable data protection legislation and is, in all cases, based either on the contract between the data subject and the Company or on the Company’s legitimate interests. Unless otherwise stated, the information referred to above is necessary for us to fulfil our contractual obligations.

Direct Marketing and Marketing Communications

The purpose of using this information, which constitutes personal data, is:

• To send communications relating to products and services for direct marketing purposes. Such communications may take the form of email communications.

• Where data has been collected in connection with the provision of a service or following a request for information, information about similar services or services tailored to previous requests may be sent, unless the data subject asks to stop receiving such marketing communications or chooses not to receive them.

Whenever an electronic communication is sent for direct marketing purposes, the recipient is given the opportunity to opt out of receiving future communications by using an unsubscribe link.

You may also request at any time that such marketing communications cease by emailing contact@spritzando.com.

The use of data and information as described above is permitted under applicable data protection legislation. In most cases, the processing of personal data for direct marketing purposes is based on the consent of the data subject.

Where the data subject has given consent directly to one of the Company’s partners, the Company may also receive their personal data. The Company may then use this information to promote its services under the conditions described above.

In this case, the processing is based on the Company’s legitimate interest in establishing a more direct relationship with the user and responding promptly to their enquiries.

Summary of Processing Purposes:

Purpose of Data Processing	Legal Basis for Data Processing
When you contact us and for any related correspondence	Based on your consent
For the technical provision of our services	Based on legitimate interests
For the processing, fulfilment and dispatch of your order following a purchase made through the website	Based on legitimate interests
For processing a request and providing any additional service	Based on your consent
For sending our newsletter, subscription communications and email marketing	Based on your consent
When registering as a website user and submitting reviews	Based on your consent
To ensure that our website is presented to you in the most effective and engaging manner, for example through anonymised analysis	Based on your consent

4. Retention of Personal Data

Personal data is retained for the purposes set out in this Privacy Policy. Unless otherwise stated in the preceding sections, personal data is retained for as long as the data subject maintains a contractual relationship with the Company.

Where the contract between the data subject and the Company comes to an end, including upon completion of the requested service, and there is no other reason to continue processing the data, the information will be retained for the periods required to comply with applicable legislation and statutory limitation periods, particularly those relating to contractual, accounting and tax obligations.

Where applicable, information may also be retained in order to deal with any claim or request relating to the services provided.

Customers’ personal data is retained for the duration of the contractual relationship and for a further three years for customer relationship management and direct marketing purposes, without prejudice to any applicable statutory retention obligations or limitation periods.

For the purposes of preventing money laundering and terrorist financing, data is retained for five years following the end of the relationship with the Company.

Data may also be retained for ten years following the end of the contractual relationship in order to comply with accounting and tax obligations.

5. Access to Personal Data

Personal data collected is intended for use by the Company’s sales and accounting departments.

Data collected by the Company may be transferred to service providers acting as processors in accordance with Article 28 of the GDPR. The Company’s service providers are strictly bound by the Company’s instructions.

These service providers are authorised to use the data supplied to them solely for the purpose of processing orders and may not use it for any other purpose.

Data collected by the Company may also be transferred to processors located outside the European Union.

Finally, where required, personal data may also be disclosed to individuals, organisations and authorities, including judicial authorities and public bodies, whose right to access such personal data is recognised by law, regulation or provisions issued by authorities legally empowered to do so.

6. Rights Relating to Personal Data

With regard to the processing of your personal data, the GDPR grants you certain rights as a website user:

• Right of access (Article 15 of the GDPR): You have the right to obtain confirmation as to whether or not personal data concerning you is being processed. Where such data is being processed, you have the right to obtain information about that personal data and the information set out in detail in Article 15 of the…

• Right to rectification and right to erasure, the “right to be forgotten” (Articles 16 and 17 of the GDPR): You have the right to obtain, without undue delay, the rectification of inaccurate personal data concerning you and, where applicable, to have incomplete personal data completed.

You also have the right to obtain the erasure of personal data concerning you without undue delay where one of the grounds set out in detail in Article 17 of the GDPR applies, for example where the data is no longer necessary in relation to the purposes…

• Right to restriction of processing (Article 18 of the GDPR): You have the right to obtain restriction of processing where one of the circumstances set out in Article 18 of the GDPR applies, for example for the duration of any necessary verification where you have objected to…

• Right to data portability (Article 20 of the GDPR): In certain circumstances set out in Article 20 of the GDPR, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format, or to have that data transmitted to another…

• Right to object (Article 21 of the GDPR): Where personal data is collected on the basis of Article 6(1)(f) of the GDPR, namely processing based on legitimate interests, you have the right to object at any time to the processing of your personal data on grounds relating to your particular situation.

In such circumstances, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or where the processing is necessary for the establishment, exercise or defence of legal claims.

• Right to lodge a complaint with a supervisory authority: In accordance with Article 77 of the GDPR, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you infringes data protection legislation.

This right may be exercised before a supervisory authority in the Member State of your habitual residence, your place of work or the place where the alleged infringement…

• Right to object to receiving direct marketing communications in the future and, in certain circumstances, the right to ensure that this information is transferred to the data subject or transferred to another…

7. Web Analytics

Google Analytics

This website uses Google Analytics, an online analytics service provided by Google Inc. (“Google”).

Google Analytics uses a specific type of cookie which is stored on your device and enables analysis of your use of our website. Information generated by this cookie about your use of the website is generally transmitted to a Google server located in the United States and stored there.

The Google Analytics service implemented on this website provides for the anonymisation of recorded IP addresses, commonly referred to as “IP masking”.

As a result of the IP anonymisation used on this website, your IP address is shortened by Google within the European Union and the European Economic Area.

In exceptional cases, the full IP address may be transmitted to a Google server located in the United States, where it will then be shortened.

Google refers to certification under the European Union – United States “Privacy Shield” framework:

https://www.privacyshield.gov/EU-US-Framework

Google uses this information on our behalf to analyse your use of the website, compile reports on website activity and provide additional services relating to website and internet usage.

Google may also disclose this information to third parties where required to do so by law or where such third parties process the data on Google’s behalf.

The IP address transmitted by your browser as part of Google Analytics is not combined with other data held by Google.

You may prevent these cookies from being stored by adjusting your browser settings.

You may also prevent Google from collecting and processing data generated by the cookie relating to your use of the website, including your IP address, by downloading and installing the browser add-on available here:

https://tools.google.com/dlpage/gaoptout?hl=en

8. Status of This Privacy Policy

This Privacy Policy was last updated on 14 June 2024.

We reserve the right to amend this Privacy Policy at any time in order to provide up-to-date information about how we collect and process personal data.