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Privacy policy

PRIVACY POLICY

Last updated: February 10, 2021

 

  1. DEFINITIONS

The capitalized terms refer to the following definitions:

The "Company" or "We" refers to BLGD Enterprise, whose registered office is located at 21 boulevard Kraëmer 13014 Marseille, France, and is registered in the Trade and Companies Register under number 850468331 00010, and whose VAT number intra-community is FR 37 850468331.

The "Site" designates the website(s) accessible from the URL link www.VKNGjewelry.com and their possible sub-sites (e.g. blog) allowing access to a content and space reserved for customers, which are provided by the Company.

"You" means the people concerned by the Processing carried out on the Site (users, prospects, customers, etc.).

The "Policy" means this privacy policy.

“Data” corresponds to any information on an identified or identifiable natural person (the “data subject”) directly or indirectly, in particular by reference to an identifier (name, identification number, location data, online identifier, etc.) or to one or more elements specific to its identity.

“Processing” corresponds to any operation applied to Data (collection, recording, organization, conservation, adaptation, communication by transmission, dissemination, erasure, etc.).

A “controller” is one who, alone or jointly with others, determines the purposes and means of processing, and a “processor” is one who processes Data on behalf of the controller. On the Site, unless otherwise specified, we are responsible for data processing.

A "recipient" is the natural or legal person, public authority, service, or any other body which receives communication of personal data, whether or not it is a third party.

The "Regulation" refers to Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (''GDPR''); Law n ° 78-17 of January 6, 1978 relating to data processing, files and freedoms; the applicable rules in terms of commercial prospecting provided for by the Post and Telecommunications Code, and more generally the laws and regulations applicable to the Data Processing that we carry out.

 

  1. SHOWCASE SITE AND COMMERCIAL PROSPECTING

The Site presents the activities of our Company and various forms (contact, newsletter subscription, etc.). By completing the forms and communicating with us via the Site, you are sending us the following categories of information:

 

  • Identity data: civil / gender; last name; first name; and optionally, we may ask you for your date of birth to provide birthday offers;
  • Contact details and correspondence: email address; postal address (address, postal code, city); phone number; in the event of a request to customer service, the nature of your request and the content of your request;
  • Data on reviews and contributions: pseudonym, date of the review, content of the review, product or service concerned, if applicable profile photo attached to the review; The Company may enrich its Site by collecting and republishing the opinions and contributions issued in relation to its offers by its customers on other sites (in particular social networks) when these contributions are freely accessible to the public;
  • Data necessary for carrying out loyalty, prospecting, study, survey, product testing, and promotion actions;
  • Data relating to the organization and processing of contests, lotteries, and any promotional operations;
  • Data collected through actions to exercise the rights enshrined in the Regulations.

In accordance with our legitimate interest, and when necessary for the execution of pre-contractual measures taken at your request or of a contract, we carry out processing of the aforementioned Data for the following purposes:

 

  • Presentation of the Company's products and services;
  • Management, processing and monitoring of requests and exchanges with the Company, via the Site (where applicable by offering you a chatbot, a call reservation tool, etc.);
  • Management of the relationship with prospects;
  • Management of people's opinions on products, services or content of the Company;
  • Prospecting and / or sending of information, management of technical prospecting operations, choice of people to carry out loyalty actions, prospecting, survey, product testing;
  • Organization of contests, lotteries or any promotional operation on the Site.

The data used for the management of commercial prospecting is kept for a maximum of three years from the last active contact from the prospect or customer, or sooner in the event of withdrawal of your consent to receive messages from us. Notice and contribution data is kept for the duration of public access to the notice on the Site.

In accordance with our legal obligations, identity and contact data will also be processed for the following purposes:

  • Updating of its prospecting files by the body in charge of managing the list of opposition to canvassing, in application of the provisions of the Consumer Code;
  • Management of requests for the right of access, rectification. and opposition, and more generally the rights described in the Policy.

 

  1. ONLINE SALES

The Site allows purchases to be made, which leads us to carry out Processing on the following Data:

  • Identity and contact data;
  • Data relating to the contractual and commercial relationship: Details of the content of the order; Pre-contractual exchanges relating to the order (subject, date, etc.); Communications with the Company;
  • Payment and transaction data: date of the transaction, amount, means of payment, order number, billing data.

This information is necessary for the management of our client-prospect file, and more precisely for the following purposes in accordance with our GTC accepted when ordering on the Site and our legal obligations:

 

  • Carry out operations relating to the management of files concerning: contracts including registrations; orders; the delivery of the product or service; legal and commercial guarantees; bills; accounting and monitoring of the commercial relationship (after-sales service) including opinions on the Company's offers;
  • Prevention and fight against fraud as means of payment and in particular against credit card fraud;
  • Management of unpaid bills and litigation, provided that it does not relate to infringements and / or that it does not lead to the exclusion of the person from the benefit of a right, a service or a contract.

Secure payment. All transactions made on our Site are secure. Payments by credit card are provided by our payment service providers ("PSP"), as indicated in our terms and conditions or on the order page for our products and services. We thus have an SSL encryption system to protect your personal data as well as the means of payment used. At no time are we directly in possession of your bank details through this process.

Retention periods. The personal data that we process are kept for the periods presented in the table below.

Data concerned

The duration of the conversation

Data processed for commercial prospecting purposes

3 yearsfrom the prospect's last active behavior or data collection

Data required to process your order and manage contractual and commercial relationships

3 yearsfrom the last active behavior of the customer or failing that, from the end of the contractual relationship.

 

For accounting documents (purchase orders, delivery notes, customer invoices): 10 years from the end of the financial year

Order contracts for an amount less than 120.00 euros

5 yearsfrom the conclusion of the contract.

Order contracts for an amount greater than 120.00 euros

10 yearsfrom the date of delivery or service.

Bank details: in the event of a single payment

13 monthsfor immediate debit payment cards and 15 months for deferred debit payment cards from the debit date (for the purpose of responding to a possible dispute)

Bank details: in the case of taking out a subscription with tacit renewal

13 monthsfor immediate debit payment cards and 15 months for deferred debit payment cards from the debit date of the last payment due, occurring at the end of the subscription (for the purpose of responding to a possible dispute)

 

  1. CREATION OF AN ACCOUNT

Creating an account is optional to place an order on the Site.

 

On the Site, you can create an account. If you choose to do so, the following information will be processed:

 

  • Identity and contact data;
  • Account connection data: username, password, which can be saved automatically on the Site only if you consent to it via your browser settings;
  • Account access and use data: IP address, connection time, connection duration, account settings, use of any account features.

Processing will be carried out for the purposes of managing authentication procedures, procedures for losing usernames or passwords and for the purposes of executing the order in accordance with the purposes provided for online sales.

 

The Identity and Contact Data entered when creating the account will be used with your consent to inform you about the Company's products and services.

 

The Company may provide tools for creating a profile by adding optional information to your account (identity, social networks, age, profile picture, profession, etc.).

 

 

  1. DELIVERY OF MATERIAL PRODUCTS

To deliver the products ordered on the Site, we will ask you for your delivery postal address, if the latter is different from the billing address. If the delivery of a good is to a third party, you must confirm that you have authorization to transmit their identity and delivery data. These Data will be transmitted to the carrier responsible for delivery.

Other information necessary for delivery will be processed in accordance with our T&Cs and our legitimate interest (delivery method, package size, delivery tracking information, delivery date, receipt, signature of the voucher, etc.).

The carrier responsible for the delivery applies its own confidentiality policy on the Data transmitted to it as part of the order, or which it is required to collect during delivery.

 

  1. PROVISION OF DIGITAL CONTENT

The legal basis for the Processing for the supply of digital content is contractual and, failing that it is provided for in the T&Cs, meets our legitimate interest. For this purpose, we will have to process the following Data:

  • Identity and contact data;
  • Content access data: Username and password, which can be saved automatically on the Site only if you consent to it via your browser settings; and connection information to the access area (IP address, time of connection, duration of connection, use of any tools available from this dedicated space, etc.);
  • Content data: Content consultation and monitoring data: Module consultation data, time spent on content; Information on downloaded and / or listened audio files;
  • Monitoring data: Progress indices, statistics and monitoring of progress; any ratings, surveys and quizzes carried out, past evaluations;
  • Publication data: Content of the publication of your contribution (comment, question, publications, notice, etc.) date, time, response rate, information on the publication space concerned.

The Site from which the content is accessible may include technical devices which allow the use of the Site to be tracked (account of the logged-in user, IP address, type of application used, various logs for connection and use to the User account, etc.). The Data obtained from these systems may be used in the context of the fight against counterfeiting, and / or to identify and / or prevent possible illicit or non-compliant use of the Site and / or violation of the applicable GTC.

 

  1. SOCIAL NETWORKS AND THIRD PARTY SITES

Exchanges on social networks.We may contact you or answer your questions via social media, if you have contacted us in the first instance through this. You are informed that the use of social networks involves the processing of personal data by the providers of these networks (see their privacy policy).

Public information. The information concerning you, which you have transmitted to us, can possibly be enriched for commercial purposes, prospecting, communication, solicitation or marketing, by means of other sources of information such as social networks. This includes information that is said to be "public" or to which we may have access as the administrator of a page or group. The legal basis for this processing is our legitimate interest as a trading company.

Interconnection. In the event that your member area can connect to another service (for example, a social network) to cross-send, then the third-party service can communicate to us information of which you have authorized the disclosure. You are informed that the publishers of third-party services may also collect information concerning the consultation and / or use of the Site, in accordance with their own personal data processing policy. More information on registering for the Site from a third-party account, for:

Facebook: https://www.facebook.com/help/223184117694507; https://developers.facebook.com/docs/facebook-login/overview

Google: https://support.google.com/accounts/answer/112802?co=GENIE.Platform%3DDesktop&hl=fr

 

  1. EXERCISE OF YOUR RIGHTS

For any request to exercise the aforementioned rights or for more information, you can contact the Company at the postal address: BLGD Enterprise 21 boulevard Kraëmer 13014 Marseille France.

In accordance with the regulations, you have the following rights over your Data:

  • Right of access to your Data, including the right to request a copy, and to the information provided in this privacy policy (art. 15 GDPR). When the legal basis for data processing is our legitimate interest, you have the option of requesting information relating to the balancing that we have carried out between the interests of our clients and those of the Company prior to this processing.
  • Right of rectification (art. 16 RGPD) and updating of your data which we have.
  • Right to the erasure of your Data (art. 17 RGPD) when the data are no longer necessary for us, when you have withdrawn your consent to their Processing (if it was based on our consent) or if you object to the Processing based on our legitimate interest or the processing carried out for prospecting purposes or for profiling purposes related to prospecting.
  • Right to withdraw your consent at any time (art. 13-2c RGPD) for all data processing based on the legal basis of your consent. In addition, in terms of commercial prospecting, you have the possibility to unsubscribe at any time from our mailing lists by clicking on the unsubscribe link in our communications or by contacting us to no longer receive a solicitation message.
  • Right to limit Processing, which, unless there is a compelling reason, can no longer be implemented without your consent (article 18 GDPR) when:
    • You dispute the accuracy of the data, for the time necessary for their verification;
    • If the data processing is unlawful but you oppose the erasure of the data and choose instead the limitation of the processing;
    • When we no longer need the data but they are still necessary for you to establish, exercise or defend your legal rights;
    • When you have objected to processing based on our legitimate interest, for the time necessary to weigh our respective interests.
  • Right to portability of Data directly provided by the data subject when they are subject to automated processing based on your consent or on a contract (art. 20 GDPR). This right means that you have the option of requesting the communication of this data in a structured, commonly used and machine-readable format so that it can be communicated to another controller.
  • Right to object (art. 21 GDPR) to the processing of your data when this Processing has our legitimate interest as a legal basis.
  • Right to define the fate of your Data after your death (art. 40-1 of law 78-17 of January 6, 1978) and to possibly choose a trusted third party to whom the Company must entrust them.

You can obtain more information on the CNIL website.

In the event of a request to exercise your rights, the Company reserves the right to ask you to specify your request and provide proof of identity (which will be kept for one year in the event of exercise of the right of access or rectification and three years in the event of exercise of the right of opposition). If our response did not give you full satisfaction, you still have the option of filing a complaint with the Personal Data protection and control authority under which you fall (in France, the CNIL).

 

  1. STORAGE PERIODS

Commitments.Means of effective deletion of the Data is undertaken as soon as the retention or archiving period necessary for the fulfillment of the determined or imposed purposes is reached, in particular after deletion of your account with our Company or at the end of the contract. with our Company.

Minimization. In any event, the Data subject to Processing is not kept beyond the time necessary for the performance of the obligations defined when the contract is concluded, or required by the force of legislation. Beyond that, they may be anonymized and kept for statistical purposes, in aggregate form.

Litigation. Likewise, we can archive information demonstrating the performance of our contractual obligations until the expiration of the limitation / foreclosure periods applicable to legal actions, for the good defense of our interests before the courts in the event of litigation. This concerns, but is not exclusively connected with, the periods provided for by the Commercial Code, the Civil Code and the Consumer Code.

 

  1. RECIPIENTS

Commitments.We are committed to ensuring that any recipient of data presents sufficient and appropriate contractual guarantees to respect your rights, so that the processing meets the requirements of the GDPR when this regulation applies (in particular with regard to subcontracting). On the basis of our legal obligations, your Data may be disclosed in application of a law, regulation or by virtue of a decision of a competent regulatory or judicial authority.

The information you communicate to us is for internal use by authorized persons, it is strictly confidential and may not be disclosed to third parties, except under the conditions provided for by the Regulations in the event of an express agreement.

Outsourcing. Our external service providers (eg: suppliers, carriers, etc.) may, as part of the processing described above, be recipients of personal data when this is necessary for the performance of their mission.

Transfer outside the EU. We are committed to ensuring compliance with the applicable regulations relating to data transfers to countries outside the European Union and in accordance with the following terms:

  • We will transfer the data of visitors, prospects and customers to countries recognized as offering an adequate level of protection;
  • When the country of destination does not benefit from an adequate level of protection, we supervise the flows using transfer tools that comply with the regulations (standard contractual clauses of the European Commission).

Aggregation of non-personal data.We may publish, disclose and use aggregated information (information about site users, prospects, customers, etc.) that we combine so that no individual is individually identifiable. This processing is carried out in accordance with our legitimate interest for statistical purposes, industry and market analysis, presentation of our activities, for promotional and advertising purposes and for other commercial purposes.

 

  1. COMPUTER SECURITY

Commitments.We undertake to implement the appropriate technical and organizational measures using physical and logistical means of security to limit the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or even destruction of personal data concerning you.

Warnings. We invite you to be cautious about what you decide to make public on the internet with regard to personal data, including those relating to your private life or sensitive made public at your initiative or deduced via your contributions, comments and positions of any kind on the Site, or even social networks on groups and / or conversations with other users of the Site.

Https protocol. The URL of the Site is accompanied by a closed padlock or a key appears at the bottom right of your browser indicating the existence of the Https security protocol, applicable to data storage. This means that you are in a secure browsing area, especially when you are asked for your credit card number.

Data breach. In the event of something that could lead to the risk of modification, disappearance or unauthorized access to the Data, we undertake to:

  • Examine the causes of the incident;
  • Take the necessary measures to limit the negative effects and damages that may result from the said incident;
  • Give notification about the incident to the competent authority and / or to the persons concerned as soon as possible when this meets a legal requirement.

Under no circumstances can the commitments defined in the above point be interpreted as any acknowledgment of fault or responsibility for the occurrence of this incident.

 

  1. GENERAL

Mandatory or optional characters. On the Site, you are informed of the mandatory nature of responses by the presence of an asterisk. In the event of an incomplete request (for example: registration or online order, request for information, etc.), the Company reserves the right to request additional information or to rule out by any technical means the possibility of validating the form concerned.

Hypertext links. The Site may provide links to sites, applications and services other than its own, which may be operated by third-party companies. We are not responsible for the processing of personal data carried out by these third party sites, or sites pointing to the Site, the user of which is invited to consult the personal data protection policies for more information. The Policy is applicable only to the activities of the Company, which cannot be held responsible for the breaches of a third party in its obligations with regard to the protection of personal data.

Scope. The Policy is not exhaustive of all processing and we reserve the right to supplement it by any means.

Language. The Policy is written in French. In the event that it is translated into one or more languages, only the French text will prevail in the event of a dispute.

Non-waiver. The temporary or permanent non-application of one or more clauses hereof shall not constitute a waiver on its part of the other clauses hereof which continue to produce their effects.

Changes - Updates. We reserve the right to modify this privacy policy. The persons concerned will be notified when this is provided for by the applicable regulations. The update date is indicated in the header and we invite you to consult it regularly.

 

COOKIES INFORMATION

 

Presentation:Cookies and tracers (hereinafter “cookies”) refer to connection cookies and more generally, any file - deposited when consulting a website or a mobile application, installing or installing it, use of software in the user's terminal equipment - the purpose of which is to read or write information in this equipment. Cookies allow us to collect Site consultation Data (IP address, Internet service provider, hardware configuration, software configuration, browser type and language, etc.).

Cookies may be placed by the Company or by third-party companies without your consent when they are strictly necessary for the operation of the site or to facilitate communication to the public online, for example when they are intended for authentication, to be kept in memory of the contents of a shopping cart, to generate attendance statistics, or to limit free access to a sample of content requested by users.

Duration: The maximum storage period for cookies is 13 months after their first deposit in your terminal and this period is not extended on each visit.

Consent to the deposit of cookies: You are informed of the presence of cookies not strictly necessary by an information banner on the Site. With the exception of cases of use not subject to consent, cookies and tracers will only be deposited on your terminal with your express consent. You may be asked periodically to reiterate your consent, in order to ensure that it is still valid.

Cookie settings: You can always change your preferences through your browser settings (Firefox with enhanced tracking protection; Firefox with cookie deletion; Chrome; Internet Explorer; Safari; Opera; Microsoft Edge). You can also configure your terminal's browser to activate the "Do Not Track" option, which will indicate to the sites visited, advertising agencies or applications that you do not wish to be "tracked". This feature is available for the following browsers: Firefox; Chrome; Internet Explorer; Safari; Opera; Microsoft Edge.

In the event of refusal of cookies that are not essential for the operation of the Site: Certain features of the Site such as video players or interactive content make use of services offered by third parties and place cookies allowing them to identify your consultation of the content. If the deposit of these cookies is refused, the personalization features will not be able to function and the content that will be offered to you (in particular video suggestions or advertisements) will still be present but will be unrelated to your areas of interest.

Types of cookies: In addition to cookies whose sole purpose is to allow or facilitate communication via our Site or cookies strictly necessary for the provision of the Site or Service to which you have subscribed, we use cookies and trackers for the following purposes:

Personalized advertising: BLGD Enterprise uses plotters to display personalized advertising based on your browsing and profile. These are the following third parties:

  • Facebook pixel is an analysis tool that allows us to measure the effectiveness of our advertising by tracking the actions taken by Internet users on the Site (https://www.facebook.com/policies/cookies/)
  • Pinterest pixel is an analysis tool that allows us to measure the effectiveness of our advertising by monitoring the actions taken by Internet users on the Site (https://www.pinterest.com/policies/cookies/)

Non-personalized advertising and audience measurement:BLGD Enterprise uses tracers in order to measure the audience for advertising on the Site without profiling you, in order to optimize the Site according to statistics on its frequentation and navigation Internet users. These are the following third parties:

  • Google Analytics

Geolocated advertising:BLGD Enterprise uses tracers to send you advertising based on your location. These are the following third parties:

  • Google adwords
  • Facebook ads
  • Pinterest ads

Personalization of content:BLGD Enterprise uses plotters to personalize the editorial content of the Site according to your use and to personalize the display of our offers according to those you have previously consulted on the Site. These are the following third parties:

  • Google adwords
  • Facebook ads
  • Pinterest ads

Sharing on social networks:The Site uses trackers to allow you to share content on the social networks or platforms present on the Site, namely Facebook, Pinterest, Instagram, Twitter.

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