INTRODUCTION

Clauger knows that you care about how your personal data is handled and recognizes the importance of protecting your privacy.
This Privacy Policy and protection of your personal data (hereinafter the “Policy”) explains how Clauger collects and processes your personal data. It contains information on the type of data we collect, how we process them, for what purposes, so as to make their use more suited to your needs.
Contact us at communication@clauger.fr for any type of request – request – remark, or if you want to exercise one of the rights relating to the processing of your data.

For the purposes of the Policy, the following terms are defined as follows:

• “Service(s)”: all services, products accessible online or via the Website, whether paid for or not;
• “Site”: refers to any website or software, application, widget or plug-in downloaded on a mobile device (smartphone, tablet, laptop as well as any device with an operating system allowing the downloading, install, operate and update said applications). If the Site includes notification or location features, please refer to sections 3.6 and 3.7 below.
• “We” and “Our”: refers to any company owned or operated, directly or indirectly, by any company in which we hold an interest and may collect or process your personal data and cookies, and their respective service providers located in France or abroad.
• “You” and “Your”: refers to any user of the Services, and who accesses one of the paid or free Services.

This Policy was last updated on August 26, 2020.

BASIC PRINCIPLE – OUR PRIVACY COMMITMENT

Clauger undertakes to process personal data in accordance with the regulations applicable to the protection of personal data and privacy, in particular in accordance with Regulation (EU) 2016/679 adopted on April 27, 2016 and relating to the protection of natural persons with regard to the processing of personal data and on the free movement of such data, (hereinafter the “Regulations”).

We are committed to respecting the following principles:

• you have no obligation to provide us with the personal data that we request from you. However, some of this data may be required to access certain Services. Thus, if you decide not to provide us with this data, you may not have access to some of these Services;
• we collect and process your data only for the purposes which are described in this Policy or for specific purposes of which we have informed you and/or for which you have consented;
• we adopt the principle of minimizing the collection of personal data: that is to say, collecting only the personal data necessary for the processing and uses envisaged, without collecting data in a superfluous way;
• if the personal data that we have is no longer useful for the processing of personal data that we carry out, and that no legal obligation imposes on us to keep them, we will do everything in our power to delete, destroy or anonymize them.

WHAT PERSONAL DATA DO WE COLLECT?

The personal data we collect varies depending on the purpose of the collection and the Service we provide to you.

Generally, we may directly collect the following categories of personal data:

• personal contact details, such as your surname, first name, e-mail address, postal address and telephone number(s);
• the identifiers used to access your online account, i.e. the username and password. This is necessary for us to create a personal user account attached to our online communities accessible online via our websites and applications;
• exchanges with us, which may include details of chat conversations;
• demographic information, such as your age, gender and lifestyle preferences (including your favorite products and your interest in them);
• browsing history, such as the pages visited, the date of the visit, the location during the visit, or the IP address;
  information from your profiles on social networks;
• if you apply for a recruitment offer via the Clauger recruitment site, we will collect additional personal data, such as your professional experience, your background and your recommendations.

We may also collect personal data about you indirectly when:

• you share content on social networks, websites or applications relating to our products or responding to our posts and promotional announcements on social networks; Where
• we read or collect personal data about you through information collected by other websites (for example, if we place an ad on a third-party website and you click on that ad, we may receive information about you and other site visitors to measure the reach and success of this ad).

FOR WHAT PURPOSES DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data in order to provide you with the best online experience as well as quality service and navigation. In particular, we may collect, hold, use and disclose your personal data for the following purposes:

• to process and respond to your inquiries and to contact you to respond to your requests and/or requests;
  to develop and improve our products, services, communication methods and the functionality of our websites, applications, Services;
• to provide you with information and to manage your registration and/or subscription to newsletter services or any other service for sending communications;
• to manage our day-to-day business needs in connection with your participation in our competitions, sweepstakes, promotional activities and requests;
• to authenticate the identity of individuals who contact us by telephone, electronically or otherwise;
• for internal training or to ensure the quality of our services;
• to better understand and assess the points of interest and desires of users as well as the changes that are necessary for them, in order to improve our websites/applications, our Services and/or to develop new products and services;
• to provide tailored communications or to recommend products to you based on your needs.

We may also need your personal data to meet legal obligations or as part of the contractual relationship built with you.

When we collect and use your personal data for the purposes mentioned below or for any other request, we will inform you before or at the time of collection.

Where necessary, we will seek your consent to process your personal data. If you have given your consent for processing activities of your personal data, you have the right to withdraw this consent at any time.

WHAT ARE YOUR RIGHTS ?

When we process your personal data, you are entitled to a number of rights which you can exercise at any time. Below we provide an overview of these rights and what this means for you.

The right to access your personal data and the right to rectification
It is important to us that the personal data we hold about you is accurate, current, complete, relevant and not misleading. In order to ensure that we comply with this commitment, you have the right to access, correct or update your personal data at any time.

The right to the portability of your data
You have the right to receive your personal data in a structured, commonly used and machine-readable format if we have processed your personal data on the following grounds:

• you have given us your consent to process your personal data for a purpose or purpose that we have previously communicated to you;
• we have processed your personal data in order to facilitate a business transaction, such as providing you with the products and/or services you order;
• we have processed your personal data using automated means (such as profiling).

The right to request the deletion of your personal data
You have the right to request the deletion of your personal data when:

• your personal data is no longer necessary for the purposes for which we collected it; Where
• you withdraw the consent you previously gave us to process your personal data, provided that there is no other legal ground allowing us to continue to process
• your personal data; Where
• you object to us processing your personal data for direct marketing purposes; Where
• you object to us processing your personal data for the legitimate interests of our company (such as improving the overall user experience on our websites); Where
• the personal data is not processed lawfully; Where
  your personal data must be erased in order to comply with the legislation in force.

If you would like the personal data we hold about you to be erased, please let us know and we will take reasonable steps to comply with your request in accordance with legal requirements.

If the personal data we collect is no longer necessary for any purpose and there is no legal obligation for us to retain it, we will make every effort to delete, destroy or anonymize this data.

The right to limit the processing of your data

You have the right to request the restriction of the processing of your personal data if:

you believe that the personal data we hold about you is inaccurate; Where
regarding personal data not lawfully processed, you prefer that we limit their processing instead of deleting this data; Where
we no longer need your personal data for the purposes for which we collected it, but you need the data in order to establish, exercise or defend legal claims; Where
you have objected to the processing of your personal data and are waiting to find out whether your interests related to this objection prevail over the legitimate grounds pursued by Clauger.

If you wish to limit our processing of your personal data, please let us know and we will take reasonable steps to comply with your request in accordance with legal requirements.

The right to object to the processing of your personal data
You have the right to object to the processing of your personal data at any time.

The right to lodge a complaint with a supervisory authority
You have the right to file a complaint directly with a supervisory authority, such as the CNIL, about the way we process your personal data.

HOW WE PROTECT YOUR PERSONAL DATA?

We are aware of the importance of the security of your personal data. We make our best efforts to protect your personal data from misuse, interference, damage, unauthorized access, modification or disclosure. We have many security measures in place to help protect your personal data. In particular, we use access controls, firewalls and secure servers.

SHARING YOUR PERSONAL DATA?

When we share your personal data with our subsidiaries or other structures, we make sure to do so with your consent and only with organizations that have a system relating to the security of your data and their storage and that respect the laws relating to the protection of privacy, under conditions equivalent to those which we comply with.

Your personal data will not be shared, sold, rented or disclosed for purposes other than those described in the Policy. We may, however, transmit your data, for purposes other than those provided for in the Policy, in cases where their communication is required by law and government authorities.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

Personal data may be processed outside the European Economic Area (EEA). If this is the case, CLAUGER will make every effort to ensure that this international transfer of data has an adequate level and guarantees of security.

The safeguards we use to protect international data transfers include:

• model standard contractual clauses validated by the European Commission. These standard clauses provide a sufficient guarantee because they make it possible to comply with the relevant levels of security as required by the regulations relating to the protection of personal data, and in particular in relation to the Regulations (the aforementioned regulations and the Regulations being hereinafter referred to together as “Regulations”); Where
• by certification mechanisms that certify that third parties located outside the EEA process personal data in accordance with the Regulations. These certifications must be approved either by the European Commission, or by the competent control authority under the Regulation, or by the national accreditation body designated under the Regulation.

AUTOMATED INDIVIDUAL DECISION AND PROFILING

We may use your personal data in automated decisions, including profiling for certain Services. We will inform you of our intention to apply these methods and give you the opportunity to object to them beforehand. You can also contact us at communication@clauger.fr to obtain more information on this type of processing.

COOKIES AND OTHER TECHNOLOGIES

Through our use of cookies and other technologies, such as pixel tags, device fingerprinting and web beacons, we may also collect personal data about you when you visit our websites or third-party websites, or our mobile or third-party applications. This may include:

• information about your device’s browser and the operating system you use;
• the IP address of the device you are using;
• the web pages you visit;
• the links you click on while interacting with our services.

LOCATION ON OUR SITE

The location of your device when accessing the Site is your responsibility.

Our Sites may contain features for tracking your device (including mobile) or our Services. The online platform or the browser from which our Site can be accessed determines, under its sole responsibility, the parameters compatible with the operating system of your mobile device allowing you to authorize or refuse the use of the functionalities of location.

Please refer to the terms and conditions of use of the distribution platform or browser from which our Site may be accessed. Please also refer to your mobile device settings to configure location. You can change the location settings at any time to allow or deny the use of location features.

Location features may allow us to provide you with access to our Services or Personalized Services based on your location. It also allows us to send you information, content, Services or personalized commercial offers that correspond to your centers of interest and your location.

HOW TO CONTACT US ?

If you have any questions or complaints or if you wish to send Clauger recommendations or comments aimed at improving our Personal Data Protection Policy, you can send an email to communication@clauger.fr or send a letter to the following address: Clauger – 7 rue de l’Industrie – 69530 BRIGNAIS.