Preamble
This personal data usage charter applies to the website accessible via the following URL: cyren-decoly.com, offered by the company Cyren Decoly (hereinafter the “Seller”). It aims to inform you about:

* How we may collect and process your personal data;
* The rights you have regarding your own data;
* The identity of the data controller of your data;
* The transfer of your data to third parties;
* Our cookie management policy.
This privacy policy complements the Legal Notice and the General Terms of Sale available on our Site.

We commit to processing all collected data in compliance with:

* Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data; ([Wikipédia][1])
* Law No. 78-17 of 6 January 1978 known as the “Informatique et Libertés” law, modified by Law No. 2018-493 of 20 June 2018 on personal data protection.
The person concerned whose personal data are processed by the Seller accepts that they may be processed in accordance with this policy.

Article 1: Data controller
The identity and contact details of the Data Controller are as follows:
Cyren-Decoly, Château Saint Benoît, 12 mouchet, 33570 MONTAGNE, France
represented by its duly authorised legal representative.
Requests relating to personal data should be addressed by postal mail to: Cyren-Decoly, Château Saint Benoît, 12 mouchet, 33570 MONTAGNE, France – or via email at cyren-decoly[@]wanadoo.fr

Article 2: Personal data collected and processed
Within the operation of the Site, we collect personal data relating to users.

2.1 General data collected for the site cyren-decoly.com

* Upon your connection: your IP address and navigation data, subject to your consent and your device settings;
* When using the contact form: your surname(s), first name(s), the name of your company, your address (street, postal code, city), your telephone number, and your email address. These data are indispensable for responding to your messages via the contact form;
* When you browse our Site and have authorised the collection of your data by cookies;
* When placing an Order for Product(s);
* When using the features offered on our Site;
* When participating in our promotional offers and direct marketing, such as entering a contest;
* When necessary under applicable regulation, we commit to collect your explicit, specific and prior consent and/or allow you to object to the use of your data for certain purposes.
Every user therefore has the right to withdraw their consent at any time.

2.2 We may process the following personal data in accordance with the purposes described in Article 3 of this Charter:

2.2.1 For site management when you place an Order and/or use the site’s features:

* Transactional information of your Product(s) Order
* Navigation information including browsing history, IP addresses, browser settings

2.2.2 For interaction with our Site: some data are automatically collected from your device or browser. The details are specified in Article 8 “Cookies” below. These include IP address and cookies.

Article 3: Purposes of processing
We collect and/or process your personal data in compliance with European and French data protection laws, as necessary:

* To identify persons using our Site;
* To perform statistics relating to the site’s usage and improve its functioning;
* To conduct maintenance and error-checking operations;
* To respond to messages you send via the contact form;
* To process your Order(s);
* To comply with applicable law or any legal obligation;
* To protect our systems’ security, to detect and prevent fraud, or safeguard our legitimate interests, without prejudice to your interests or fundamental rights requiring enhanced protection of your personal data.
You have at any time the right to withdraw your consent previously given, or to object to any processing of your collected personal data.
The collected and processed data thus cover the following purposes:
* Access to our Site, placing and processing an Order
* Prospecting and/or sending information to Users
* Operating, maintaining and improving the features of our Site, particularly for placing Orders
* Accounting and internal audit
* Technical issue detection
* Development of statistics for improving our services / online store and developing new features
* Improving our offered Products on our Site
* Offering personalised content and navigation
* Making Products on our Site more relevant based on Users’ interests, subject to having obtained Users’ explicit and prior consent
* Complying with legal obligations, preventing or detecting fraud, abuse, unlawful uses, violation of the General Terms of Sale, and complying with court decisions and government requests.

Article 4: Consent
When placing an Order or submitting a contact request, you may be asked to fill in forms and provide personal data so that you may place an Order.
When required by the applicable rules, we commit to collecting your explicit, specific and prior consent and/or allowing you to object to certain uses of your personal data, and/or to access and/or rectify data relating to you.

Article 5: Transfer of personal data to third parties
The personal data collected will be accessible:

* To authorised staff of the Seller, Cyren Decoly Services, handling site management and maintenance;
* They may nevertheless be communicated to third parties by virtue of legal or regulatory provisions, court decisions or if necessary for protection or defence of our rights.
The personal data that we have collected may be transmitted to third-party companies under subcontracting contracts signed with us solely for the needs of the purposes indicated in Article 3. Prior to transfers, we will take all necessary measures and guarantees to secure such transfers.
Transfers may thus be made within the context of the following activities and events: IT services, research and statistics.
We do not transmit any personal data to partners for commercial operations or any other purposes not related to the purposes indicated in Article 3. In the event that we intend to modify our data-transfer policy to transfer data to partners for commercial purposes, this may only occur once we have obtained your explicit and prior consent.

Article 6: Hosting and transfer of personal data
The personal data collected and processed is hosted by any service provider hosting our servers in France or any other European territory. The User is informed that we may, if necessary, transfer personal data to a third country or to an international organisation which is subject to an adequacy decision by the European Commission, provided that, in the case of a transfer to a country or an international organisation not subject to an adequacy decision, this may only be done if appropriate safeguards are implemented and the Users concerned have enforceable rights and effective remedies, in accordance with applicable regulation.

Article 7: Data retention
Personal data is retained for the period strictly necessary for achieving the purposes for which they are processed and in accordance with the recommendations of the French regulatory authority (CNIL) and inspired by simplified standard No. NS-048 related to automated processing of personal data concerning client and prospect management. They may then be archived with restricted access for a further period for reasons limited and authorised by law (payment, guarantee, disputes …).

Article 8: Cookies
When you visit our Site, cookies are stored on your computer, mobile or tablet. A cookie is a small text file stored in your device’s browser when visiting a site or viewing an advertisement. It is intended to collect information related to your browsing or deliver services adapted to your device. Cookies are managed by your Internet browser.

8.1 Cookies used and their purposes
Our Site uses:

* Operational cookies (mandatory) ensuring the proper functioning of our Site and enabling its optimization. Our Site cannot function correctly without these cookies.
* Analytics cookies allowing us to obtain anonymous visitor statistics of our Site in order to optimize its ergonomics, navigation and content. By disabling these cookies, we cannot analyse our Site’s traffic.
These cookies allow our services to operate optimally. They are essential for browsing and accessing our Site. They are consequently always active. The cookies collected are not transferred to third parties nor used for purposes other than those set out above.

8.2 Cookie configuration
You have various means to manage cookies.
You have the option below to manage your cookie settings at any time via a dedicated interface or via your browser and thereby oppose the registration of cookies by configuring your browser. Each browser’s configuration is different. It is described in the browser’s help menu, which will tell you how to modify your preferences regarding cookies.

8.3 Consent
By browsing our Site you consent to the use of the aforementioned cookies. During your first visit, we informed you of the presence of the cookies mentioned and of the possibility to object to them by accessing this Personal Data Usage Charter.
We inform you that refusing cookies:

* May cause issues with the functioning of our Site;
* Prevents analysis of our Site’s traffic.
In order to manage cookies as close as possible to your preferences, we invite you to set your browser taking the cookies’ purposes into account.

8.4 Right of access, deletion, objection
As with other personal data, you have the same rights specified in Article 10 below.

8.5 Retention period
We keep the cookies collected for a duration of:

* 13 months for operational cookies
* 13 months for analytics cookies
This duration is not automatically renewed at each new visit on the site. Beyond this duration, the data are either deleted or anonymised if they are not already.

Article 9: Data security
To ensure the security of personal data, particularly to prevent it being distorted, damaged or accessed by unauthorised third parties, we take all necessary precautions considering the nature of the data and the risks presented by the processing.

Article 10: Users’ rights
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data, and Law No. 78-17 of 6 January 1978 relating to information technology, files and freedoms, you have the following rights which you may exercise at any time by contacting the Seller (by email or postal letter):

* Right of access to your personal data;
* Right to correct and obtain modification of data that is inaccurate or incomplete;
* Right to request the deletion of your personal data, unless we have legal or legitimate reasons to retain it;
* Right to object to its processing and obtain restriction of processing, unless we have a legitimate interest to do so;
* Right to data portability of your personal data to the extent applicable;
* Right to organise the fate of your personal data after your death;
* Right to withdraw at any time your consent to the processing of your personal data (without affecting the lawfulness of processing based on consent prior to its withdrawal).
Any request must specify the right you wish to exercise, be accompanied by a copy of your valid national identity card (or passport) and include contact details (address, phone, email) to which we may respond. These details will be kept only for the time necessary to process your request.
It is specified that exercising your right to deletion of your personal data and/or your right to object to the processing of your personal data and/or your right to restrict processing of your personal data and/or your right to withdraw your consent at any time to the processing of your personal data may result in the User’s inability to use the site and / or place an Order.
In addition you are informed of your right to lodge a complaint with the French Data Protection Authority (CNIL) either by postal mail at 3 Place de Fontenoy – TSA 80715 – 75334 Paris 07 or by filing a complaint online at [www.cnil.fr](http://www.cnil.fr)

**Article 11: Information on the contractual nature of the provision of personal data**
With regard to whether the provision of personal data is regulatory or contractual, that it conditions the conclusion of a contract, or the obligation to provide personal data and the possible consequences of not providing such data, the user is informed as follows: the request for provision of personal data is contractual (in the context of the relationship the User wishes to initiate with the Seller on the Site to place a Product(s) Order); the provision of such data, being necessary for processing the Order conditions the conclusion of this contractual relationship; accordingly the User must communicate their personal data if they wish to place an Order on our Site; failure to provide such personal data does not permit placing an Order on our Site.

Article 12: Automated decision-making
It is stated that no automated decision-making is carried out using the personal data collected, in the sense of the applicable Regulation.

Article 13: Potential further processing of personal data
In the event that any further processing of personal data is carried out for purposes other than those for which the personal data were collected and as identified above, the Data Controller will provide the person concerned in advance with information regarding this other purpose and any other applicable legal information.

Article 14: Minimum age of person able to provide their personal data
Collection of personal data may only concern persons aged at least 18 years in France, and abroad the legal age for the purchase and consumption of alcohol. Users of our Site must be adults in their country of residence in order to access it and, if applicable to place an Order so that, by placing an Order via our Site and/or by communicating personal data to us, you declare and guarantee that you are of legal age in your country.

Article 15: Links to other sites
Our Site may contain links to other sites, over which we have no control. We are in no way responsible for the data protection policies or practices of other sites you choose to visit from our Site. You are therefore invited to review the data protection policies of these other sites in order to understand how they collect, use and share your data.

Article 16: Modifications
We reserve the right to modify or update this Personal Data Usage Charter at any time. These changes will be published within this section. You are invited to regularly consult the Personal Data Usage Charter and check if modifications have been made.

Learn more
You will find additional information about personal data protection on the website of the French Data Protection Authority ([www.cnil.fr](http://www.cnil.fr))