Personal Data Protection Policy (PPDP)

LAST UPDATED ON 25/05/2018

The Personal Data Protection Policy (PPDP) applies to all of Sybarel's websites, applications, games/draws (the "Media") each time you (the "User") access the Media.

Data collection and purposes

SYBAREL collects personal data on the User who accesses the Media. In particular, we collect and process your name, address, email address, password, telephone number, IP address, connection and navigation data, order history, preferences and centres of interest, products consulted, delivery incidents, complaints.

This data collection is carried out in particular when the User :

• creates his customer account " My account " or identifies himself
• place an order on our website or our application
• navigate the Supports and consult products
• participates in a game or contest
• contact our Customer Service
• subscribe to newsletters or alerts proposed by SYBAREL

The data collected is exclusively intended for the use of SYBAREL. They may be transmitted to SYBAREL's subsidiary companies or to companies - subcontractors - that SYBAREL calls upon in the context of the execution of services and orders, in particular management, execution, processing and payment. They are necessary for the management and the follow-up of the commercial relations between SYBAREL and its customer (management of orders, deliveries, returns, payment, complaints...). They also allow SYBAREL to provide the User with personalized services on the Supports, to send him commercial offers. SYBAREL also uses them for statistical purposes and for the creation of audience and commercial activity dashboards.

SYBAREL may be required to transmit to its advertising partners data concerning the items consulted by the User when browsing on the Media as well as the nature of his purchases, if applicable, in order to display targeted advertising on the partner sites of its advertising partners as well as on social networks, and to improve the relevance of the information offered to the User.

SYBAREL, a limited liability company with a capital of 250,000 euros whose registered office is located at 33 rue de Gasperich, L-5826 Hesperange (Luxembourg), is responsible for processing this data. They may be transmitted to the companies and subcontractors that SYBAREL calls upon in the context of the execution of orders and the services offered (our providers of means of payment or payment security, our logistics and delivery providers). If required by law, your consent is collected or a possibility of refusal is provided to you before any data transmission.

The User is informed that this automated processing of information, in particular the management of users' e-mail addresses, has been declared to the National Commission for Data Protection (CNPD) under numbers T010793 and T010794 and complies with the amended law of 2 August 2002 on the protection of persons with regard to the processing of personal data, as well as with the General Regulations for Data Protection (RGPD). Internet users have the right to access, rectify, oppose and delete personal data concerning them. All requests for information concerning the personal data and/or the purpose of the processing in place, as well as the exercise of the rights of access, rectification, opposition and deletion will be made to the address

Transfer of data outside the EU

SYBAREL informs the User that his personal data may be transmitted to service providers located in the United States in the context of e-mailing campaigns (see "Sybarel newsletter" below), or for the management of the technical logs of the Supports (see "Technical data (logs)" below). These service providers act in compliance with the European provisions relating to the protection of personal data under the "Privacy Shield" convention.

Support Forms

The Media may ask the user to provide information through forms, for example when creating an account. In order to enable their validation, the User must fill in all the fields displayed in the forms presented to him/her, except for those fields indicated as optional. The optional information filled in by the User allows SYBAREL to better know its Users.

All fields marked with an asterisk are mandatory. Any failure to answer will lead to the impossibility to validate the form.

Mailing address and telephone number

The Customer's postal address and telephone number are necessary for the processing and management of orders as well as for commercial relations between SYBAREL and the Customer.

SYBAREL uses this personal data for commercial prospecting purposes. At any time, the Customer has the possibility to object to this in a simple and free way on the website www.lesybarite.fr (the "Site") or the iOS and Android applications (the "Applications") in the "My Account" section or by mail at the following address: SYBAREL, 33 rue de Gasperich, L-5826 Hesperange, Luxembourg.

SYBAREL may use the Customer's mobile phone number for order management and may also use it for commercial prospecting purposes. At any time, the Customer has the possibility to object to this in a simple and free way on the Site or the Applications in the "My Account" section or by mail at the following address: SYBAREL, 33 rue de Gasperich, L-5826 Hesperange, Luxembourg.

Cookies

SYBAREL also uses cookies in accordance with the legislation in force. During the consultation of the Site, cookies are deposited on your computer, your mobile or your tablet. The Site is designed to be particularly attentive to the needs and expectations of our customers and cookies are used, among other things, to recognise you when you return to the Site, to enable you to access your account, to manage and memorise your order basket even when not connected to your account, to memorise your consultations and to personalise the offers that we propose to you.

A cookie is a small text file placed on your computer when you visit a site or view an advertisement. Their purpose is in particular to collect information relating to your browsing on the sites and to send you personalised services. In your computer, cookies are managed by your Internet browser. SYBAREL also uses the browser's "localstorage" which has the same operating principle as cookies.

The User may at any time deactivate the use of these cookies by selecting the appropriate settings in his browser. The action of deleting cookies also removes the "localstorage" of the browser. However, this deactivation will have the consequence of preventing access to certain functionalities of the site allowing to personalize the services offered by SYBAREL.

When the User navigates on the Site, cookies from third party companies (for example advertising agencies or partners) may be deposited on your computer, tablet or mobile in order to identify your centres of interest through the products consulted or purchased on our Site and to personalise the advertising offer addressed to you on our Site or outside our Site.

The different types of cookies used

Different types of cookies are used on our site, they have different purposes. Some are necessary for your use of our site.

Functional cookies

Among other things, these cookies are used to recognize you when you return to the site and allow you to access your account easily, to manage and memorize your order basket so as not to lose it between several visits, even when not connected to your account, to memorize your product listing display parameters and other personalization choices that you may have made ...

Cookies for audience and performance measurement

These are cookies posted by tools that allow us to know the use and performance of our site and to improve its operation and relevance.

Sybarel's internal statistical and commercial cookies

These cookies are positioned and used exclusively by Sybarel for the purposes of statistical measurements or internal commercial monitoring. Some of these cookies are associated with discount coupons.

Cookies from our external partners

Cookies are used to present you with advertisements or information adapted to your interests outside our site during your browsing on the Internet. In particular, they are used to limit the number of times you see an advertisement and to help measure the effectiveness of an advertising campaign. Refusing advertising cookies will not result in the cessation of advertising. It will only result in the display of advertisements that do not reflect your interests or preferences.

Social network cookies

These social cookies aim to allow users to share pages and content via third party social networks.

Cookie management

The User can refuse these cookies at any time by selecting the appropriate parameters in his browser. This refusal will have the consequence of preventing access to certain functionalities offered by SYBAREL's partner companies. You can also use the services of the Youronlinechoices.com site, offered by digital advertising professionals grouped within the European Digital Advertising Alliance (EDAA). This European platform is shared by hundreds of Internet advertising professionals and provides a centralized interface allowing you to express your refusal or acceptance of cookies that may be used to adapt the advertisements that may be displayed on your device to your browsing habits: http://www.youronlinechoices.com/fr/controler-ses-cookies/.

Cookie management module

SYBAREL provides Site Users with a module enabling them to oppose cookies placed on the Site. To do this, the User can click on the link "I set" in the information banner mentioning the purposes of the cookies deposited or click on the tab "I set". My Account "under "My Cookies". He also has the possibility of modifying his choices at any time via the "Cookies" link at the bottom of each page of the site.

Sybarel Newsletter

The User can subscribe to SYBAREL newsletters and thus be kept informed of news and offers on the Site. He or she can at any time change the information he or she wishes to receive or unsubscribe by clicking on the link provided for this purpose located at the bottom of each newsletter. This link is also accessible on the Site in the section "Newsletters". My Account ».

Customers who have ordered products from SYBAREL also benefit from SYBAREL newsletters in which they can be offered products and commercial offers similar to the products already ordered.

Any user who subscribes to the SYBAREL newsletter has the possibility at any time to modify the information he wishes to receive or to unsubscribe by clicking on the link provided for this purpose located at the bottom of each newsletter. This link is also accessible in the section " My Account ».

When creating an account on the www.lesybarite.fr website and later on in the management of your preferences via the section "...". My Account ", the Client or the Identified User may choose to receive offers from Sybarel.com's partners. He or she can unsubscribe at any time in this same section.

How long your personal data will be kept

The personal data collected by SYBAREL in the context of the creation of an account by the User and the placing of an order are kept for 5 years from the last contact with SYBAREL.

Certain personal data will also be kept by SYBAREL within the time limits imposed by the legislation in order to meet its legal obligations.

Security measures taken to ensure the protection of personal data

SYBAREL implements all technical means in accordance with the rules of the art to maintain the integrity, security and confidentiality of the data and in particular to prevent it from being distorted, damaged or accessed by unauthorized third parties.

When placing an order, no banking data is collected or stored by SYBAREL. SYBAREL uses the services of PCI-DSS certified service providers to ensure the security of payments.

Technical data (logs)

The technical data on the use and operation of the Media (log files) are used solely for the security and quality of the Media (detection of possible intrusions or errors). They are kept in accordance with the applicable legislation. The User is informed in particular that anonymised application logs are shared with the Sentry company in the United States, which adheres to the Privacy Shield.