1. General Statement
We take your privacy very seriously and we are committed to protecting it. We believe that you should easily know what personal data we collect and use, as well as to understand your rights in respect of your personal data.
2. Who we are?
- ARNANO is a French simplified joint stock company (“société par action simplifiée”) with a capital of 120,000 euros, having its registered office at 7 parvis Louis Néel– 38000 Grenoble – France, registered with the Grenoble Trade and Companies Registry under number 513 950 493 RCS Grenoble.
You can find our contact details in section “How to contact us?” below.
3. What personal data do we collect and how is it collected?
Personal data is information relating to an identified or identifiable natural person. For example, it may include an individual’s name, address and gender.
We may collect personal data indirectly from you (for example from your electronic devices that interact with our website, electronic form or mobile application (“Digital Platforms”)).
3.1. Information you provide directly to us
You may provide us with information:
- When you create an account online;
- When you subscribe to our newsletter;
- When you use our Digital Platform;
- When you purchase products or services on our Digital Platform;
- When you participate in one of our events;
- When you contact our customer-services.
Depending on what you provide us with, such information may include:
- Your identity (including your first name, last name, gender, image);
- Your contact details (including your postal address(es), email address(es), phone number(s));
- Your personal status (including your title);
- Your purchases;
- Your preferences;
- Certain payment information (including billing information, payment type or method, charge or credit card number);
- Other information you may provide by filling forms or by contacting us (including your feedbacks, or other communications with us).
We will inform you when your information is required in order to process your request, to respond to your queries or to provide you with our products and services. If you do not provide this information, then it may delay or prevent us from processing your request, responding to your query or providing products or services to you.
We hope to ensure that the personal data we possess are accurate at all times and therefore we encourage you to update your information in case any changes have occurred. We also may ask you to update your information from time to time.
We recommend that you only provide the data requested or necessary for your query, with the exception of any sensitive information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning health, sex life or sexual orientation.
3.2. Information indirectly collected
We may also collect information about you from third parties, such as a spouse who contacts us on your behalf or from your friends who provide us with your information in order to invite you to events you may be interested in.
3.3. Minimum age
We remind you that we do not collect, directly or indirectly, personal data from persons under the age of 16, without prejudice to any local law setting a different minimum age. We therefore ask you not to provide us with personal data of persons who do not meet this requirement.
4. Why do we collect your personal data and how do we use it?
We collect and use your personal data based on one or many of the following legal basis:
- we have obtained your prior consent (for example, when you subscribe to our newsletter). Please note that for this specific legal basis, you have the right to withdraw your consent at any time (see below “What rights do you have on your personal data?”);
- the processing is necessary in connection with any contract between NATINSA and you (for example, when you make a purchase);
- we have a legitimate interest in carrying out the processing and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms (for example, to prevent payment fraud);
- we have to process your personal data to comply with applicable laws and regulations.
Depending on the context, we may use your personal data in order to:
- provide you with the products or services you requested;
- conduct checks to identify you and verify your identity;
- send you Promotional Communications - with your prior consent (see section “Promotional Communications”);
- provide you after-sale services and manage refunds;
- respond to your queries, suggestions and requests, including your data subjects’ rights exercises;
- manage complaints and litigation;
- manage the events you registered and/or participated in;
- to detect, prevent and fight against any fraudulent or illegal activity, including to protect your transactions from payment fraud, to act against counterfeiting and against the resale of our products in violation of our terms and conditions of sale and/or outside our distribution network
- protect you, employees as well as our property;
- manage the stock of certain types of rare products to allow a fair allocation of the products we sell;
- monitor and improve our Digital Platform;
- conduct statistical analysis, in particular to adapt our product offer (including the use of your nationality after anonymization);
- improve our products and services;
- respect our legal obligation, prevention and the fight against fraud, money laundering and the financing of terrorism.
5. How long do we keep your personal data?
Your personal data are processed for the period necessary for the purposes for which they have been collected, to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise or defend any legal rights.
In order to determine the most appropriate retention periods for your personal data, we have specifically considered the amount, nature and sensitivity of your personal data, the reasons for which we collected your personal data, the service you deserve and expect from us together with the applicable legal requirements. For example:
- - With regard to our prospects (potential customers): your data is stored for three years from your last action and then deleted or archived to comply with legal retention obligations;
- - With regard to our customers: your data is stored for the duration of our commercial relationship and for up to ten years and then deleted or archived to comply with legal retention obligations;
- - With regard to the cookies used on Digital Platform: they are stored for up to 13 months from the moment they were installed on your device.
6. How do we disclose and transfer your personal data?
We may disclose your personal data only to the parties indicated below and for the following reasons:
- We disclose your personal data to NATINSA employees that need to have access to your personal data and are authorized to process them in order to achieve the aforementioned purposes and who are committed to confidentiality.
For the specific purpose of combating payment fraud, your personal data are communicated to ARNANO in order to process your order and to fight against online payment methods fraud attempts. As part of our legitimate interest to fight against fraud with payment methods, ARNANO, acting as data controller, can transmit your financial information to an external service provider with a fraud detection tool in order to authenticate a payment. Such service provider is committed to confidentiality.
- We may also disclose personal data to third-party providers acting on behalf of NATINSA and approved by NATINSA.
All such processing is based on our prior instructions set out in a binding contract that is compliant with the requirements of applicable law. Such disclosures are made for different purposes including:
o IT development and support;
o Hosting and carrying out marketing and business studies and marketing campaigns;
o Verifying your information, authenticating payments and processing orders and payments, to third parties that provide credit reporting, payment or order fulfilment services;
o Delivery services
o Data quality management services (standardization, deduplication…)...
These providers are committed to confidentiality and are not permitted to use your personal data for any other purposes. We also require them to use appropriate security measures to protect your personal data.
- We may be required by the binding requirements of an applicable law, or for the purposes of responding to legal proceedings or other lawful requests to disclose your personal data to authorities or third parties.
- We may also disclose or otherwise process your personal data, in accordance with applicable law, to defend our legitimate interests (for example, in civil or criminal legal proceedings). For example, we may disclose such personal data as necessary to identify, contact or bring legal action against a person or entity who may be violating our Terms and Conditions of Sale and Use, or who may be causing injury to, or interfering with, other users of our Digital Platform.
- In the event that NATINSA or ARNANO, or all or part of its or their assets, are acquired by a third party, your personal data may be included in the transferred assets.
7. How do we protect your personal data?
All your personal data is strictly confidential and will only be accessible, on a need-to-know basis, to duly authorized personnel of NATINSA and other entities ARNANO and third providers acting on our behalf with appropriate technical and organizational security safeguards.
The NATINSA has implemented security measures to protect your personal data against unauthorized access and use. We follow appropriate security procedures in the storage and disclosure of your personal data so as to prevent unauthorized access by third parties and to prevent your data being accidentally lost. We limit those who access your personal data to those who have a genuine business need to access it. Those who do access your data will be subject to a duty of confidentiality towards NATINSA.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We also require those parties to whom we transfer your personal data to comply with the same. However, unfortunately, the transmission of information via the internet is not completely secure. So, we cannot ensure the security of your personal data transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorized use, distribution, damage or destruction of Your Information, except to the extent we are required to accept such responsibility under the law. Once we have received your personal data, we will use the security measures abovementioned.
8. What rights do you have on your personal data?
In accordance with the applicable data protection laws, you can, at any time, request access, rectification, erasure and portability of your personal data or restrict and object to the processing of your personal data. A summary of these rights is provided below:
Your right of access: the right to be provided with a copy of your personal data.
Your right to rectification: the right to require us to correct any mistakes in your data or to complete your information.
Your right to be forgotten: the right to require us to delete your personal data — in certain situations.
Your right to restriction of processing: the right to require us to restrict processing of your personal data — in certain circumstances, for example if you contest the accuracy of the data.
Your right to data portability: the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party — in certain situations.
Your right to object to processing: the right to object:
— at any time to your personal data being processed for direct marketing;
— in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
When the processing of your personal data is based on your consent, you may at any time decide to withdraw it. If your consent is withdrawn, it won’t affect the processing of your personal data based on other legal bases, such as fulfilling your orders and storing your order data as required by applicable law.
If you no longer wish to receive our marketing/promotional information, we remind you that you may withdraw your consent to direct marketing at any time directly from the unsubscribe link included in each electronic promotional message we send to you. If you do so, we will promptly update our databases, and will take all reasonable steps to meet your request at the earliest possible opportunity, but we may continue to contact you to the extent necessary for the purposes of any products or services you have requested.
You also have the right to lodge a complaint with your local data protection authority in case of alleged infringement of the data protection rules applicable to you.
To exercise any of those rights, please contact us using the contact information below (see “How to contact us”).
Please note that upon exercising any of the rights listed above, you will be requested to let us know what right you want to exercise and provide information (copy of an identity card, passport or other legally recognized identity) for identification purposes in order to process your request and protect you against fraudulent requests from third parties.
9. How to contact us?
In issues relating to your account, to withdraw your consent, to ask general questions or to lodge a complaint, please contact our Customer Service:
- By email: firstname.lastname@example.org
- By phone: +33 (0)6 75 07 80 25
- By mail: 7 parvis Louis Néel– 38000 Grenoble – France
In issues specifically related to marketing emails, we remind you that you can, at any time, directly unsubscribe through the “unsubscribe” link in any electronic marketing messages we sent to you.
Last updated: February 2nd 2021