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Data Protection Policy

Data Protection Policy

DATA PROTECTION POLICY

 

1. The collection of personal data

When creating your account and placing your orders on the website www.andre.fr (hereinafter referred to as the Site), PROMECO is required to collect personal data concerning you. All data collected is done so in an adequate, relevant, and limited manner to what is necessary for the purposes of processing (points 2 and 3).

The entity responsible for collecting this data is PROMECO, Promeco Doornikserijksweg 12, 8510 Bellegem (Courtrai), Belgium VAT: BE 0454.546.354 (hereinafter: PROMECO). The term "personal data" refers to all data that allows for the identification of an individual, which includes, in particular, name, first name, phone number, date of birth, email address, postal address, IP address, as well as any other information you choose to communicate to PROMECO about yourself. For the purposes of combating fraud mentioned below (points 2 and 3), PROMECO may also retain, for a limited time, (point 5) information related to transactions made on its Site.

 

2. The data controller

Your personal data is collected only for determined, explicit, and legitimate purposes, to meet one or more of the following objectives:

(I)manage your orders on the Site,

(II)develop commercial statistics, conduct market and behavior studies,

(III)create and manage prospect files, which notably includes technical operations such as standardization, enrichment, and duplication,

(IV)perform operations related to customer management,

(V)select a clientele to carry out prospecting and promotional actions,

(VI)send solicitations and promotional messages from PROMECO. You can unsubscribe at any time from these offers by clicking on the link provided for this purpose located at the bottom of the relevant emails.

(VII)comply with our legal and regulatory obligations.

(VIII)combat fraud under the conditions defined in point 3 below.

 

3. Examples of categories of personal data collected

To combat fraud, ANDRE has implemented a system that may lead him to:

(I) Request certain supporting documents from you to secure the transaction once payment has been made, in case of an automatic alert triggered by the information related to your order.

(II) block your order if your customer account has already been used to commit fraud.

(III) provide your personal data upon requests from judicial authorities in the event of a complaint or judicial requisition.

 

4. Purposes of data collection

Only our company and the external companies contractually linked to us for the processing of your order have access to the information you provide us. The categories of people who will have access to your personal data within PROMECO are, within the limits of their respective responsibilities, the sales department, administrative services, the technical department, and the departments responsible for control (auditor, departments responsible for internal control procedures, etc.). Public authorities may also receive your personal data, exclusively to meet legal obligations, legal auxiliaries, judicial officers, and agencies responsible for debt collection. PROMECO reserves the right to commercially transfer the data it has collected on its site if you have given your prior consent by checking the box "I wish to receive the good deals from André's partners." You can subsequently withdraw your consent at any time by unchecking this same box. Any processing based on consent given before its withdrawal is lawful.

 

5. Categories of recipients of personal data

The categories of recipients of your personal data are:

 

- ANDRE Internal Services

Access to your personal data within ANDRE SAS will be limited to categories of employees within the scope of their responsibilities and based on the purpose of processing this data.

 

The data we collect may be shared with some of our subsidiaries and certain external service providers, specifically regarding: product order processing, product delivery, and payment processing. These third-party service providers have access to the personal information necessary for the execution of their services and are not authorized to use it for other purposes and are also required to comply with applicable data protection laws.

 

- Some personal data is transferred to a country outside the European Union. When we transfer personal information to countries outside the European Economic Area, we ensure that this information is transferred in accordance with applicable data protection laws.

Example: a subcontracting contract with a company based in Madagascar that handles part of the customer service activity of ANDRE; All necessary measures and guarantees to secure such transfers have been taken.

 

- Public bodies may also be recipients of your personal data, exclusively to meet legal obligations, judicial officers, ministerial officers, and organizations responsible for debt collection.

 

6. The legal bases

We inform you that we take all necessary precautions to preserve the security of your personal data and, in particular, to prevent it from being distorted, damaged, or accessed by unauthorized third parties. Encryption and anonymization are two of the means used. Encryption and anonymization are two of the means used.

 

7. Examples of processing

Customer management

Purpose of processing: Management of the business relationship, orders, delivery, customer account.

Legal basis for processing: Necessary for the conclusion and execution of the contract

Category of recipients: ANDRE internal services, Subsidiaries, Subcontractor

Active retention period: 3 years*

 

* from the last active action: clicking on a hyperlink, ordering on the Site, logging into the customer account, visiting the Site.

 

Purpose of processing: Fighting fraud

Processed data: Documents requested as part of the fight against fraud

Legal basis for processing: Legitimate interest in preventing fraud

Data recipient services: ANDRE internal

Active retention period: 6 months

 

Invoice retention

Purpose of processing: Invoice retention

Category of recipients: ANDRE internal services

Legal basis for processing: Legal obligation

Retention period: 10 years from the date of invoice issuance

 

8. The retention period for personal data

How long do we keep your personal information?

We retain your personal information for a duration necessary to achieve the relevant purposes and to fulfill legal obligations such as tax or accounting obligations, or for any other duration that may have been communicated to you.

 

For the same processing, personal data goes through several retention phases. Depending on the type of processing and its purpose, the retention periods differ.

- The first phase of retention is active database archiving. Retention depends on the achievement of the purpose of processing that justifies the collection. The data is accessible to the operational services responsible for processing.

- The second phase is intermediate archiving. The collected data is no longer used to achieve the purpose for which it was collected, but it retains administrative interest, and is permitted by law, such as managing a dispute or an unpaid invoice. Access to this data will be restricted to a list of duly authorized employees of ANDRE.

- After this intermediate archiving phase, your data will be anonymized.

 

To determine the retention period of your data, it is necessary to define the starting point. In accordance with CNIL recommendations, this starting point is defined by the last positive action of the customer or prospect that indicates a genuine interest in ANDRE; for example:

- clicking on a hyperlink,

- placing an order,

- logging into the customer account

- visiting the site.

 

9. Security

In accordance with EU Regulation 2016/679, you have several rights, namely:

- a right of access

- a right to rectification

- a right to erasure

- a right to limit processing

- a right to portability

- a right to object

To assert your rights of access, rectification, and erasure, you can go to your customer account and do it directly.

To assert your rights to limit processing, portability, and opposition, you can contact:

by email: to dpo@andre.fr

by postal mail: to PROMECO,Doornikserijksweg 12,
8510 Bellegem (Kortrijk), Belgium
VAT: BE 0454.546.354

 

You can, if necessary, file a complaint with a supervisory authority.

 

10. Cookies

In order to allow our systems to recognize your browser or device and provide you with ANDRE services, we use "cookies".

 

These "cookies" are set up to better serve you.

We measure the number of pages viewed, the number of visits, as well as visitor activity on the Site and their return frequency. To this end, we use "cookies" technology. A cookie does not allow us to identify you. In general, it records information related to your computer's browsing on our site (the pages you have viewed, the date and time of the visit, etc.) that we can read during your subsequent visits.

 

The data collected by cookies are solely and strictly intended for internal use and are never shared with third parties. The use of cookies, whether first-party or third-party, not being necessary for the functioning of the site requires your express consent.

 

You can express your consent or object to the use of cookies by appropriately configuring your browser. Please refer to your browser's user guides for this.

 

Some cookies called "advertising cookies" allow us to track your browsing and record the products viewed, then within a maximum of 90 days present you with related or unrelated advertising banners based on your past browsing. These cookies are linked to your internet profile (but do not allow us to identify you). They also require your express consent in the same way as indicated above. If you no longer wish to receive these "advertising cookies," click on the following link:

Manage cookies

11. Right of access and rectification

In accordance with EU Regulation 2016/679, you have several rights, namely:

 

- A right of access, modification, rectification, and deletion of information concerning you.

- The right to request the portability of this information.

- The right to object to the processing of your personal information or to request that we restrict the processing of your personal information in certain cases.

 

You can also send your requests:

- by email: at dpo@andre.fr

- by postal mail: PROMECO, Doornikserijksweg 12,
8510 Bellegem (Kortrijk), Belgium
VAT: BE 0454.546.354

 

 

 

12. Right to file a complaint with a competent authority

You also have the right to file a complaint with the CNIL:

https://www.cnil.fr/fr/plaintes

 

13. Evolution of the personal data protection policy

This privacy policy is subject to change, particularly in light of legislative and regulatory developments.