Personal data management policy
Processing and protection of personal data
For the needs of its business and in order to satisfy the demands of its customers, SAS EURASIA TRADING INTERNATIONAL (E.T.I) is required to collect and process personal data.
Particularly committed to the privacy of its customers, SAS E.T.I strives to put in place a privacy policy to ensure greater security of personal data, using any measure at its disposal to ensure that the right balance between the performance of its activities and the security of data relating to its customers and users is respected, in accordance with the General Data Protection Regulation (GDPR).
In this context:
First, SAS E.T.I strives to inform its customers and, more generally, its users of the purposes of processing the data collected, to collect their consent as such, and undertakes not to collect, store and process exclusively the data strictly necessary for the purpose sought and for the proper performance of its obligations as a professional.
Next, SAS E.T.I the aim is to use data processing and storage tools to ensure a sufficient and optimal level of security. Also, SAS E.T.I has attached the services of providers guaranteeing a level of security of data stored and processed on behalf ofE.T.I, in accordance with the rules in force for the protection of personal data and using procedures approved by the competent authorities.
Finally, in general, SAS E.T.I undertakes to adopt internal processes to ensure the security of its users' data, to carry out any impact assessment and risk analysis where processing could be considered sensitive and to allow data subjects to use rights of deletion, modification and access to personal data under the following conditions.
When using the services provided by SAS E.T.I via its website, the user will be required to provide him with personal data concerning him, in particular to enable the latter, subject to the collection of his consent, to:
- Provide information about brands, promotions, novelties and invitations to private events (newsletter) ;
- Offer promotional offers, present products via advertising banners on the site or third party websites ;
- Enable it to identify network resellers likely to satisfy its demand ;
- Commercialize and ship its products ;
- Trust his clientele.
I. Newsletter subscription
SAS E.T.I offers to the user to communicate his e-mail address in order to receive, exclusively by e-mail, information relating to trademarks, new products, commercial operations and events organised by the company.
In this context, SAS E.T.I implement a processing of personal data.
Legal basis
Section 6 (1) (a) of the General Data Protection Regulations (GDPR).
Subject to the consent of the user, the main purpose of the data collected (exclusively the e-mail address) is to send commercial information and create a "prospects" file.
The legal basis for the treatment applied is Article 6 GDPR:
- the legitimate interest pursued by the publisher in: prospecting and animation; managing the customer/prospect relationship; organization/registration/invitation to events of the mark; management of subscriptions; development of service-related statistics ;
- implementation of pre-contractual measures.
The purpose of the processing is to manage the sending of the publisher's information letter concerning the mark.
Categories of data processed
E-mail address, subscription date, newsletter statistics.
Data source
Data from voluntary subscription to the newsletter (footprint of the site).
Processing does not provide for automated decision-making. The collection of the e-mail address is mandatory for sending the newsletter.
Subject to consent, E.T.I is authorised to send news letters (special offers, events, new products, promotions) and, where appropriate, to offer offers via banners on third-party websites or social networks.
At any time, the user can unsubscribe via the link in each e-mail ("unsubscribe"). Electronic prospecting for non-similar products or by third parties requires prior consent. The customer can also register on the Blockel list: www.bloctel.gouv.fr.
Shelf life
E.T.I keep the data for the duration necessary for operations and in accordance with the regulations. Prospective data are retained for 3 years without interaction. In case of unsubscribe, the deletion is immediate. Data are intended for authorised personsE.T.I and its providers.
II. Use of the geolocation service
E.T.I allows access to the list of distributors and selected models within a geographical area via a Google Maps module (cookies). E.T.I does not have access to personal location data; no user data is processed by the publisher as such.
The user can self-identify a city to search for a distributor. Only the data of the distributors (name, address, telephone, possible e-mail) are processed by E.T.I to communicate them to users (conditions defined by the General Terms and Conditions and possible Pro Space).
III. Purchase on site
As supplier, E.T.I implements processing of personal data.
Legal basis
- Order management: performance of contract (art. 6.1.b GDPR) ;
- Commercial solicitations for similar products: legitimate interest (art. 6.1.f GDPR) ;
- Requests for other products: consent (art. 6.1.a GDPR, art. L.34-5 CPCE) ;
- Transmission of e-mail to partners: consent (art. 6.1.a GDPR, art. L.34-5 CPCE).
Purposes of treatment
The legal basis is:
- the legitimate interest of EURASIA TRADING INTERNATIONAL in: prospecting/animation; managing the customer/prospect relationship; organization/registration/invitation to events of the mark ;
- implementation of pre-contractual/contractual measures for: production, management and monitoring of files; recovery ;
- compliance with legal obligations: LCB-FT and anti-corruption; Invoicing; accounting.
Data collected
Identity (civility, surname, first name, addresses, telephone, e-mail, etc.); order data (transaction, details, amounts, payments/unpaid/returns); means of payment (card number, valid end date, CVV — immediately deleted); loyalty data (purchase history).
E.T.I keep data only for the necessary period, depending on the obligations: contractual relations + 3 years (prospection); LCB-FT: 5 years after the end of the relationship; accounting: 10 years after year end.
E.T.I does not process or retain bank data: they are transmitted in figures to the payment institution.
Data are intended for authorised personsE.T.I and, where applicable, its providers (e.g., identity carriers/address/telephone).
Information may be provided to third party contractors bound by contract (execution of orders). These third parties have limited access and an obligation to comply with the legislation. Apart from these cases, E.T.I does not sell, rent, transfer or give access to data without consent, unless required by law.
In accordance with the IT & Freedoms Act and the GDPR, you have the rights of access, rectification, limitation, portability, deletion and opposition under the following conditions. E.T.I implements organisational, legal and technical measures to ensure confidentiality and security.
Right of access, rectification and deletion
In accordance with articles 38 to 40 and 70-18 to 70-21 of the LIL (amended on 22 June 2018), everyone has the right of access, rectification, questioning, limitation, portability, deletion, and a right of opposition (including prospecting).
It may establish guidelines for the exercise of rights after death: contact@reqins.fr or mail: 30 Cours Lieutaud, 13001 Marseille (attach a signed identity copy).
Response time: 1 month (2 months extended depending on complexity/volume). In the event of an abusive request (multiple, repetitive, unsubstantiated) or if the data is not stored, the publisher may refuse by reason of his decision. Possible claim to CNIL: 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.
Data are not transferred outside the EU. E.T.I implement technical and organisational measures to prevent unauthorized alteration, destruction and access.
E.T.I may change this policy; the new version will be published on the website and, if necessary, notified by e-mail at least 15 days before effect.
IV. Cookies
Cookies are used on the website. The user can disable them from his browser or use the version that does not use cookies.
In accordance with the deliberations of CNIL n°2013-378 (05/12/2013) and n°2020-092 (17/09/2020), cookies can store certain information. E.T.I uses different cookies to improve the interactivity of the site and its services (sharing buttons, tweet lists, embedded videos...).
A "cookie" is a suite of information transmitted to the browser by a website; it is kept for a duration and returned to the server at each connection. Cookies facilitate navigation, allow statistics and can be used for advertising studies.
Some third party cookies (social networks/platforms) can follow the navigation when the session is open. The publisher has no control over these treatments; it is up to the user to check the conditions of use with the services.
During the first visit, a banner informs about the presence of cookies; they are deposited only in case of acceptance or continuation of navigation. Consent is valid for a maximum of 13 months.
The user can set cookies (navigator, interprofessional platforms). Disabling may reduce accessibility to certain services.
Manage via the browser See CNIL "Your traces" (www.cnil.fr/vos-libertes/vos-traces/les-cookies/).
Management via interprofessional platforms : YourOnlineChoices (EDAA/IAB): www.youronlinechoices.com/fr/controler-ses-cookies/.
Types of cookies used
E.T.I uses a Google Maps/Prestashop cookie to identify nearby outlets. The user can accept the location or manually indicate a city.
The Google Maps module includes: store display; search by product/address; directions; Basic information (name, timetable, etc.); automatic location detection; latitude/longitude coordinates of distributors; display on the home page.
Responsible for geolocation processing: Google Commerce Limited, Gordon House, Barrow Street, Dublin 4, Ireland. E.T.I does not access other than location data and cannot identify the user by this alone.
Rights: access/rectification/deletion/opposition/limitation/portability. For Google: support.google.com/policies/troubleshooter/7575787.
For any request for information specific to Google/Maps cookies, please go directly to Google.