The purpose of this privacy policy (the “Policy”) is to provide you with all the information you need to understand how SUPERBIEN collects, processes and protects your personal data when using the website [to be completed by the last address of the website] (the “Website”).
During your browsing of the Website, SUPERBIEN may collect and process some of your personal data, as a data controller (hereinafter “Data Controller”) within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals regarding the processing of personal data and on the free circulation of such data (hereinafter “GDPR”).
As such, as the Data Controller, SUPERBIEN is sensitive to the privacy of its users and the protection of their personal data. SUPERBIEN is committed to ensure the compliance of its personal data processing with the applicable provisions of the GDPR and French law n°78-17 of January 6, 1978 relating to data processing, files and liberties.
This Privacy Policy may change according to the legal and regulatory context and the doctrine of the Commission Nationale de l’Informatique et des Libertés (“CNIL”).
I. Purpose of personal data processing
When using the Website, some personal data about the User (the “Data”) may be collected. SUPERBIEN takes care to collect and process only Data that is strictly necessary for the purposes to which it is collected.
Personal data is any information that can identify you as a natural person or to be recognized, directly or indirectly. It is, for example: name, first name, date of birth, postal address, e-mail address, IP address of a computer, browsing history, photo, videos, comment indicating your contact information, personal login and password,… etc.
(i) Subscription to our newsletters
When you subscribe to our newsletters, SUPERBIEN collects your e-mail address, your first name, your last name and may also collect your Company name if you wish to provide it.
Said data are solely processed to send the newsletter.
According to article 6.1 (a) of the GDPR, the legal basis of the process is your consent.
You may withdraw your consent at any time via the link provided in each newsletter or by sending us an e-mail to the address specified in the “contact us” section of this Policy.
Unless unsubscribed before, Data are stored three (3) years after the last contact with you and will then be deleted or archived.
At the end of this time-period, your collected data will be automatically erased, unless you exercise your right of erasure before this deadline, or if a longer retention period is imposed under a legal or regulatory provision.
(ii) Contact form
When you contact us via the Website, SUPERBIEN collects your e-mail address and your last name, and if you choose to, your phone number, your first name and/or you Company name.
Those data are processed to enable SUPERBIEN to answer your request.
Data are collected for the period of time strictly necessary to answer the request.
The legal basis of this process is the legitimate interest in answering your request, according to article 6.1 (f) of the GDPR.
At the end of this period, your collected data will be automatically erased, unless you exercise your right of erasure before this deadline, or if a longer retention period is imposed under a legal or regulatory provision.
(iii) Website visit
If you visit our Website without subscribing to the newsletters, or file a contact form, SUPERBIEN collects the personal data that your browser transmits to our server (“server log files”) that are necessary to display the Website:
- Browser used;
- Operating system used;
- IP address;
- Date and time of access;
- Amount of data sent in bytes;
- Source from which you came to the page.
Data is stored and used exclusively for the purpose of ensuring access to and functionality of our Website.
The legal basis of this process is the legitimate interest to provide access to our Website, according to article 6.1 (f) of the GDPR.
You may check our Cookie Policy to manage your settings and obtain detailed information about cookies.
(iv) Complementary Data collection
SUPERBIEN reserves the right to use additional and/or complementary means of data collection. SUPERBIEN will specify, in accordance with regulations, the precise purposes of the processing operation concerned on the data collection page.
II. How long do we keep your Data?
SUPERBIEN only keeps your Data for the duration necessary to the operations for which they were collected (as described in Article I above) and in compliance with the legislation in force.
The following table summarizes the period of time during which we store your personal data:
| Data category | Data storage |
|---|---|
| Data related to the newsletter subscription | Three (3) years after the last contact unless unsubscribed before |
| Data related to contact form | Period of time strictly necessary to answer the request |
| Cookies | Thirteen (13) months maximum from the drop of the cookie |
III. Data recipients
Data can be disclosed only to the competent and authorized recipients.
Data collected may be transmitted to our service providers, IT service providers and hosting companies in accordance with the provisions of this Policy. These service providers are external companies that may be used to help us carry out our activities.
Subcontractors and service providers and their staff are subject to a confidentiality obligation and may only use the Data, on our behalf, for the specific tasks entrusted to them, based on our instructions, in accordance with the aforementioned purposes and in compliance with the provisions of the GDPR.
We do not transmit your data to unauthorized third parties.
In some cases provided for by the law, your data may be transmitted to third parties legally entitled to access it upon specific request: judicial authorities, administrative authorities, etc. We may also communicate your data to third parties if such a measure is necessary to protect and/or defend our rights, to enforce compliance with these provisions.
IV. Your rights on your Data
You have rights over your Data. Thus, you have, at any time, the right to ask SUPERBIEN for access to your Data, the rectification or erasure of your Data, the right to limit the processing of your Data, the right to object to the processing of your Data and the right to request the portability of your Data. You also have the right to define instructions concerning what happens to your Data after your death.
If you wish to exercise these rights, you may send a written request to the following address: SUPERBIEN, 14, rue Crespin – 75011 – Paris – France. In case of doubt, proof of identity may be requested. We undertake to respond to requests to exercise users’ rights as soon as possible and, in any event, within the legal time limits.
If you have any questions about your personal data, you can contact us by sending an e-mail to: contact@superbien.fr
In the absence of a satisfactory response from us, you may contact the competent supervisory authority in France, the “CNIL” (Commission Nationale de l’Informatique et des Libertés) located at 3 Place de Fontenoy – TSA 80715, 75334 PARIS CEDEX 07 – FRANCE.
V. Our obligations
For the processing of personal data carried out through the Website, SUPERBIEN is the Data Controller.
As the person in charge of the processing, SUPERBIEN commits to:
- Process your personal data fairly and lawfully for specified purposes;
- Process your personal data only for the purposes described in Article I of this Policy;
- Implement all appropriate technical and organizational measures necessary to ensure the security, confidentiality, integrity, availability and resilience of the systems and process services;
- Limit access to your personal data to those persons duly authorized for this purpose;
- Raise awareness and train employees in the processing of personal data;
- Notify the competent supervisory authority of any security breach that presents a serious risk to the rights and freedoms of users of our Website within 72 hours of the occurrence of such a breach;
- Ensure that processors within the meaning of the GDPR have implemented all necessary technical and organizational measures to ensure the security, confidentiality, integrity, availability and resilience of processing systems and services.
VI. Security
Your Data are processed securely.
SUPERBIEN has implemented computer security and technical measures to limit any leakage, loss, deterioration, theft of data and to protect the data against any computer attack and against any virus.
SUPERBIEN ensures that subcontractors and external service providers implement appropriate security measures that comply with the requirements of the GDPR.
VII. Data transfer
SUPERBIEN keeps the personal data it collects in the European Union.
SUPERBIEN may use services provided by specialized companies, acting as subcontractors and mentioned above. When these companies transfer data outside the European Union, SUPERBIEN takes care to ensure that these companies provide a high level of protection in accordance with the requirements of the GDPR.
VIII. How do we use cookies?
Cookies are files that most websites drop on your computer when you visit them. Stored on your computer’s hard drive, they contain a small amount of data with a unique anonymous identifier. In your computer, cookies are managed by your Internet browser and are necessary for the use of the Website.
The technical cookies dropped on your terminal when you navigate on the Website are exclusively necessary for the operation of the Website. You cannot disable them.
Audience measurement cookies, social network cookies and advertising cookies that are not strictly necessary and are dropped on your terminal if you have consented to its by clicking on “accept”. The processing of your data collected from these cookies is therefore based on your consent, which you may withdraw at any time.
Cookies have a maximum lifetime of thirteen (13) months. Some cookies will require your consent in order to be kept for more than six (6) months.
You can find more information about the cookies used in our Cookies Policy.
IX. Changes to the Privacy Policy
SUPERBIEN reserves the right to change this Policy at any time.
X. Contact us
If you have any questions about the management of personal data by SUPERBIEN with respect to this Policy, you can contact us by e-mail at the following address: contact@superbien.fr or by post, at the following address: SUPERBIEN, Alexandre Mestrot – 14, rue Crespin – 75011 – Paris – France.
