Personal data policy

Updated 6 septembre 2021

Our personal data protection policy (hereinafter, the "Policy") explains how Arc Web & Retail, a simplified joint-stock company with Boulogne-sur-Mer Trade Register number 483 855 227 and a registered office at 104 avenue du Général de Gaulle, 62510 Arques, France (hereinafter, "AWR"), processes its clients' personal data (hereinafter, the "Client(s)") as Data Controller.

Arc Web & Retail owns the www.latabledarc.com website (hereinafter, the "Website") and collects, stores and processes Clients' personal data when they use the Website. This Policy therefore only governs the processing of data collected direct on the Website.

AWR is committed to keeping your personal data as safe as possible. It takes all the measures required to process your personal data in line with the provisions of the amended French Data Protection Act No. 78-17 of 6 January 1978 and the EU General Data Protection Regulation 2016/679 of 27 April 2016.

This Policy sets out how Website Clients' personal data is collected and processed by AWR.

1. Which personal data do we collect and how do we collect it?

AWR may process or collect some or all of the following personal data for the purposes below:

▪ Identifying data (first name(s), surname, email address, billing and delivery address)

▪ Username(s) and password(s) for the Website

▪ Information about purchases and orders

▪ Identifying electronic data available on or from the Client's device such as cookies and IP addresses

AWR does not process data about racial or ethnic origins, political or religious opinions, philosophical beliefs, union membership, genetic information, sex life or sexual orientation.

The Client's personal data is collected when:

▪ The Client creates their account on the Website

▪ The Client registers on the Website, giving their explicit consent to receiving newsletters and marketing communications

▪ The Client places an order on the Website and makes a payment

▪ The Client contacts the customer services team

2. Information about children aged under 16

Our services are designed for adults over the age of majority. AWR does not intend to collect or process personal data about children aged under 16.
If it becomes clear that data about a child aged under 16 has been supplied for an order via our Website or by telephone, we will not be able to process the order unless confirmation is received from the child's legal guardians.

Parents or legal guardians can also object by contacting us at contact@latabledarc.com contact@latabledarc.com

Children who are under the age of majority when supplying their personal details for an order can email the same address to have their data deleted as soon as possible.

3. Why does AWR collect your data?

AWR collects personal data for the following purposes:

Processing on the basis of fulfilling contractual obligations:

Personal data must be processed to fulfil the contract between the Client and AWR. Personal data must be provided for remote selling in order to confirm and approve the Client's order and to track and ship the goods. If this data is not supplied, the Client's order cannot be processed.

Compulsory data is identified with an asterisk on the form filled in when an order is placed. Other information is optional and helps AWR improve communications and services for Clients. This data may be transmitted to AWR providers exclusively to ensure that the order is executed smoothly, especially payment and delivery, according to the options selected by the Client.
Personal data also allows AWR to communicate with the Client about their account or the contractual relationship between AWR and the Client (e.g. to inform the Client about changes to the Website or Policy, or about updates).

To summarise, the purposes of processing on the basis of the contract are:

▪ To manage the Client's account, basket and orders

▪ To manage delivery operations

▪ To manage payment operations: when the Client makes a payment on the Website, payments are secured by our banking provider. The Client's card details are encrypted using SSL and never travel on the network unencrypted AWR does not store banking information. Banking transactions are direct between the Client and AWR's banking provider. Payment can also be made using a PayPal account. If the Client has a PayPal account, payment can be made using PayPal's process requiring the email address and password supplied when the PayPal account was created. Client banking details are only collected by our certified payment services provider, guaranteeing that payment is secure

▪ To manage the Client relationship, by telephone or email and monitor the after-sales service, product returns and refunds

Processing on the basis of AWR's legal obligations:

AWR uses Client personal data to meet its legal obligations and/or defend its interests in court, including for the following purposes:

▪ Providing proof of transactions or operations

▪ Complying with legal or administrative requirements to which AWR is subject, the needs of its insurers, or audits

▪ Managing data subjects' requests to exercise their rights

Processing on the basis of your consent:

The Client agrees to their personal data being processed by AWR based on their explicit consent (opt-in), including when:

▪ Creating their Client account

▪ Accepting cookies being installed in order to show content and advertising targeting their interests, and take measures to improve their experience on the Website and social-media sharing

▪ Subscribing to the newsletter

▪ Entering competitions

The Client can withdraw their consent at any time using the unsubscribe link found in all marketing communications and in "My Account" > "Newsletter Subscription" on the Website.

Processing on the basis of AWR's legitimate interest:

AWR has a commercial interest in processing the Client's data which is justified, balanced and not intended to invade the Client's privacy. The Client can object to AWR processing their data based on its legitimate interest if it becomes clear that their interests or basic freedoms take precedence over AWR's legitimate interest.

Examples include:

▪ Marketing activities directed at Clients to advertise our products

▪ Sending out satisfaction surveys to improve our services

▪ Organising commercial events to increase Client loyalty

▪ Combatting fraud when orders are paid for

▪ Managing product reviews to improve our goods and services

▪Recording telephone conversations between customer services and the Client to improve our services

▪ Statistical analysis to manage and improve our services

▪ Managing social media to advertise our products and services for Clients

▪ Managing Client disputes to defend our interests in court

4. Who receives the Client's personal data?

AWR undertakes not to sell the Client's personal data to partner companies for commercial purposes. The Client's personal data remains the exclusive property of AWR. To fulfil the above purposes, AWR only shares personal data with:

Arc Group entities:

Only authorised staff at Arc Group (any entity, regardless of its legal form, regarding which Arc Holdings (Boulogne-sur-Mer Trade Register number 575 680 350) has direct or indirect equity links or voting rights) are permitted to access Client data where their role justifies accessing information for internal audits, managing the Client relationship including managing Client information in Client records, managing Client commercial relationships, managing Client orders and complaints/after-sales records, managing promotional operations and campaigns, improving the relationship between AWR and Clients, and managing purchases and payments.

Below is a list of Arc Group entities who may be authorised to process your personal data for the purposes stated.

• . Sub-contractors:

  
  Service providers and sub-contractors provide services following AWR's instructions and on its behalf only, including payment and delivery.

  
  

  AWR also uses commercial and technical sub-contractors, to which data may be temporarily and securely transferred, such as:

  Colissimo for order deliveries

  ▪ Chronopost for order deliveries

  ▪ Schenker for order deliveries

  ▪ Sendinblue for email routing

  ▪ Those who assist and help us manage the loyalty programmes, client relationship management and business monitoring (CRM)

  ▪ Those who assist and help us provide IT services to maintain our database and consequent software and applications. These services may have access to your data to carry out the tasks requested

 

• . Third parties to AWR:

  In the context of a restructure, reorganisation or transfer of any kind and for any reason (including a sale of a business, dissolution, liquidation, merger, etc.) of Arc Group entities.

 

• . Other third parties:

  ▪ AWR only shares your data with other third parties if i) AWR is obliged to do so because of its legal obligations (e.g. if requested by a court), or ii) if this sharing is permitted under relevant law

  ▪ Certain regulated professions such as lawyers, notaries and external auditors so they can fulfil their duties or direct with judicial or administrative authorities under statutory provisions

5. Transferring data outside the European Union

Client personal data collected on the Website by AWR may be accessed or transferred outside the European Union (list attached to the General Terms of Sale) and be accessible outside the European Union for Arc Group staff or its sub-contractors.

AWR will take the measures required to ensure its staff and sub-contractors follow its instructions and honour, on its behalf only, the commitments set out in this Policy, including by concluding suitable contracts in line with the European Commission's models or any other valid transfer mechanism that may be introduced in future.

6. Client data retention period

Client data will be kept for three years after the Client's last order on the Website or their last contact (e.g. requesting information, clicking on an email hyperlink, creating an account without placing an order, etc.).

Contractual data is stored and archived for the period necessary to fulfil contractual obligations (guarantee, conformity, etc.) and legal, accounting and tax obligations and/or for the relevant limitation periods.

If the Client expressly consents to receiving sales prospecting material, AWR will retain their personal data until they unsubscribe or ask AWR to delete it.

Client data is then archived and can be used in the event of a dispute, legal action or litigation during the relevant limitation period.

If a dispute goes to court, data may be retained until the appeal process has ended and will then be deleted or archived as provided for by the law.

Client data is then destroyed or anonymised.

7. Client rights

In line with the amended French Data Protection Act No. 78-17 of 6 January 1978 and EU General Data Protection Regulation 2016/679 of 27 April 2016, the Client has the following rights:

▪ Right of access: the Client can obtain information about how their personal data is processed, and a copy of their personal data.

▪ Right to rectification: if the Client believes that their personal data is inaccurate or incomplete, they can ask for it to be amended.

▪ Right to erasure: the Client can ask for their personal data to be deleted within the scope of the regulations.

▪ Right to restriction of processing: the Client can ask for their personal data's processing to be restricted.

▪ Right to object: the Client can object to their personal data being processed for particular reasons. The Client has the absolute right to object to their personal data being processed for sales prospecting purposes including profiling.

▪ Right to data portability: when this right applies, the Client has the right for personal data provided to AWR to be returned or, where technically possible, transferred to a third party.

▪ Right to decide what will happen regarding storage, erasure or sharing of their personal data when they die.

▪ Right to withdraw consent: if the Client has agreed to their personal data being processed, they have the right to withdraw this consent at any time using the unsubscribe link. This does not affect the legitimacy of processing carried out before consent is withdrawn.

The Client can exercise these rights at any time by emailing the Arc Group Data Protection Officer at dpo@arc-intl.com

Or by writing to:
Le délégué à la protection des données
ARC MANAGEMENT & SERVICES,
104 avenue du Général de Gaulle 62510 Arques, France

In line with relevant regulations, the Client can submit a complaint to a supervisory authority such as the CNIL in France.

8. Cookie information

A cookie is a file added to your device's hard drive by the Website server. This cookie (also known as a tracker) identifies the device to which it is added while consent is ongoing: no more than 13 months after it is first installed on the device.

Cookies do not contain or record isolated information. They can be read by a server via an internet browser and provide information allowing the Website to be made more suitable for users by recording elements including data and user preferences, detecting errors and/or assembling data for statistics. Information collected this way is mainly used to track the volume, type and patterns of traffic using the Website in order to develop its design and structure, for administrative and planning purposes, and more generally to improve the service we offer.
AWR must gain your consent before adding cookies to your device when you use the Website. Some cookies and trackers do not need your consent if strictly necessary to provide a service expressly requested by the user.

What types of cookies do we use?

 

Cookies strictly necessary for the Website to function (functional cookies)

These cookies are required to browse our Website, allowing you to use the main Website features and secure your connection.

For example, they allow you to access the restricted and private personal areas of our Website using login details or data you have previously supplied to us.

Functional cookies do not need Client consent.

Functional cookies allow AWR:

▪ To add security measures to the Website

▪ To make browsing easier by saving your language preferences, login details or order contents

▪ To adjust the Website's appearance to the device's display preferences (display resolution, etc.)

 

Analytics cookies

These cookies allow AWR to learn about how the Website is used and performs, and produce statistics and traffic and usage volumes for different Website elements. These cookies collect information about your behaviour on the Website by analysing URLs (where visitors come from, which banners they click on, who sent them to the Website) and visit times. They allow us:

▪ To produce statistics about Website traffic volumes (number of visits, pages viewed, etc.) and compile reports and statistics about the use of various Website elements (sections and content visited, visitor browsing journeys)

▪ To improve our Website as a result

▪ To better understand which products and services you prefer and offer you more personalised communications and/or content on our Website

▪ To detect any browsing issues

Your consent is needed before these cookies are added to your device.

Deleting analytics cookies does not stop you browsing the Website.

 

Marketing cookies

These cookies help AWR adjust its advertising on the Website. They allow us:

▪ To limit the number of times you see an advert or offer

▪ To show advertising targeting your interests on the Website or elsewhere, based on your device's behaviour on the Website (personalised advertising), with your prior consent and depending on the personal data you have supplied to AWR

▪ To combat click fraud (detecting when website publishers claim they are reaching a larger advertising audience than they actually are)

Your consent is needed before these cookies are added to your device.

Deleting marketing cookies does not stop you browsing the Website.

How to manage cookies?

Excluding functional cookies, the user chooses which cookies are added to their device. This choice can be made and changed at any time.

You can change your cookie settings

For Internet Explorer 8.0 and above: https://support.microsoft.com/en-gb/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

For Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB

For Mozilla Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

For Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac

You can also visit the CNIL website (in French) for further information about cookies and how to change your browser settings: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser

9. Changes to the Policy

The Policy may be amended to reflect changes in how AWR collects and processes Client data on the Website. The Client can find out about any updates by checking the Policy on the Website (the date it was last updated will be specified at the top). The Client will also be alerted to any substantial changes via the Website or the usual communication methods.

10. Contact

Any further questions about Client personal data is managed can be emailed to dpo@arc-intl.com. dpo@arc-intl.com

Or posted to:

Arc Management & Services,

Le délégué à la protection des données

104 avenue du Général de Gaulle 62510 Arques, France

The Client can also visit the CNIL's website: www.cnil.fr.The CNIL is France's data protection authority.