In a nutshell
1. WHO ARE WE?
We are SAS BAINS and we process your personal data as co-processors. This means that we are jointly responsible for the processing and protection of your personal data.
2. WHAT DO WE USE YOUR PERSONAL DATA FOR?
Among other purposes, we will use your data (obtained online or physically) to manage your registration as a user, manage the purchase of products or services, answer your questions and send you personalized communications, if you so choose.
3. WHAT IS THE PURPOSE OF PROCESSING YOUR PERSONAL DATA?
We are competent to process your data for various reasons. Most importantly, it is necessary to fulfill the contract you entered into with us when you registered and made a purchase or took advantage of one of our services or features, although there are other reasons that allow us to do so, such as the interest in answering your questions or the consent given to send you our newsletters, among others.
4. WITH WHOM DO WE SHARE YOUR DATA?
We share your data with service providers who assist us or provide necessary support, whether they are companies or external collaborators with whom we have an agreement, whether they are located in or outside the European Union.
5. YOUR RIGHTS
You have the right to access, rectify and delete your personal data. In some cases, you also have other rights, for example the right to object to the processing of your data or the right to portability, which will be described in more detail below.
Before you start
We are transparent about what we do with your data, so that you can understand the implications of the processing carried out or the rights you have over your data:
- Information about each processing of your personal data will also be provided to you as you interact with us.
1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?
The persons responsible for the processing of your personal data are :
- SAS BAINS, the company that currently sells the LES BAINS and LES BAINS GUERBOIS brands
- Postal address: 7 rue du Bourg l’Abbé, 75003 Paris, France
- E-mail of the Data Protection Officer: firstname.lastname@example.org
- In other words, SAS BAINS are jointly responsible for the processing. We have therefore jointly established guidelines and are responsible for the processing and protection of your personal data.
2. WHAT DO WE USE YOUR PERSONAL DATA FOR?
We will process some of your data based on the products, services or features you want at any given time. In general, these will be as follows:
- your identifying data (e.g. first name, last name, language and country from which you interact with us, contact data, etc.);
- economic and payment information (e.g. your payment or payment card data, information about your purchases, orders, returns, etc.);
- connection, geolocation and navigation data (if you interact with us from your cell phone, for example);
- commercial information (for example, if you have subscribed to our newsletter),
- data about your tastes and preferences.
When we ask you to enter your personal data to enable your access to one of the features or services of the Platform, please keep in mind that some boxes will be marked as mandatory, as this is data we need to provide the service in question or to enable you to access that feature. Thus, if you choose not to provide us with this data, your registration as a user may not be successfully completed or you may not be able to take advantage of these services or features.
Depending on how you interact with our Platform, your personal data will be processed for the following purposes:
- To manage your registration as a user of the Platform
If you decide to register as a user of our Platform, we will need to process your data to identify you as a user of the Platform and to enable you to access the various types of features, products and services that are available to you as a registered user. You can delete your registered user account by contacting us via Customer Service.
- For the implementation, application and execution of the purchase or service contract concluded with us in the Platform.
This purpose includes the processing of your data, in particular to:
- To contact you regarding updates or communications of information regarding features, products or services provided, including sending quality surveys on products or services provided.
- Manage the payment of the products you purchase, regardless of the payment method used. For example: If you choose to activate the functionality to retain your payment card data for future purchases, when purchasing one of our products through the website or app, we will need to process the data indicated for the activation and implementation of this functionality. Consent for the activation of this feature allows your payment data to be automatically displayed during subsequent purchases so that you do not have to enter it in each new process. They will be considered valid and in effect for future purchases. You will be able to modify or delete your payment cards at any time through the payment information section of your registered user account on the site.
- Activate the necessary mechanisms to prevent possible fraud against you and Us during the purchase process. If we consider that the transaction may constitute an attempt at fraud, this processing may result in the transaction being blocked.
- Manage possible returns after the purchase and manage requests for information on the availability of items, the reservation of products according to the availability of these options at each moment.
- For billing purposes and to make available to you the tickets and invoices for purchases made on the Platform.
- To ensure the use of other features or services available to you, such as the purchase, management and use of the Gift Card, as well as to facilitate your access to and use of the Wifi available to our customers in our spaces.
- To respond to requests or queries made through the Customer Service channels.
We only process personal data that is strictly necessary to manage or resolve your request or inquiry.
- For marketing purposes
This purpose includes the processing of your data, subject to your consent, in particular for:
- If you subscribe to our newsletter, we will process your personal data to manage your subscription, including sending you targeted information about our products or services through various means (such as email or SMS). Likewise, we may send you this information through push notifications if they have been activated in your mobile device.
- Remember that you can unsubscribe from the newsletter at any time and without any cost through the indications provided in them. If you don’t want to receive push notifications anymore, you can disable this option on your mobile device.
- Implementation of promotional actions (for example, for the realization of contests or the sending of your list of articles kept at the e-mail address you will indicate to us). By participating in a promotional action, you authorize us to process the data provided in relation to each promotional action and to be able to communicate them through various means such as social networks or the Platform itself. The legal bases of each promotional action in which you participate will be at your disposal, with more detailed information on the treatment of your data.
- Post on the Platform, or through our social media channels, photos or images that you have publicly shared.
- Analysis of the ergonomics and quality for the improvement of our services
Similarly, we sometimes carry out quality actions and surveys in order to know the degree of satisfaction of our customers and users and to detect the areas in which we can improve our performance.
3. WHAT IS THE PURPOSE OF PROCESSING YOUR PERSONAL DATA?
The legal basis for processing your personal data depends on the purpose for which it is processed, as explained below:
- Manage your registration as a user of the Platform
The processing of your data is necessary for the execution of the conditions governing the use of the Platform. In other words, the processing of your personal data is necessary to register you as a user of the Platform, otherwise this registration could not be managed.
If you choose to use access or identification through a social network, our basis for processing your data is the consent given when authorizing the transfer of your data from the social network.
- Implementation, application and execution of the purchase or service contract
The processing of your personal data is necessary for the execution of the purchase or service contract through which we are bound.
The activation of certain data processing associated with the purchase process can only take place if you request it or if you expressly authorize us, as in the case of the conservation of card payment data for future purchases or the data processing necessary to inform you of the availability of our products. In these cases, the legal basis for processing your personal data is your own consent.
We consider that we have a legitimate interest in performing the necessary checks to detect and prevent possible fraud when you make a purchase. We believe that the processing of this data is in the interest of all parties involved in the payment of a purchase and, in particular, for you since we can thus take preventive measures to protect you against fraud attempts by third parties.
- Customer Service
We consider that we have a legitimate interest in responding to the requests or inquiries you make to us through the various existing means of contact. We believe that the processing of this data is also in your interest as it allows us to properly handle your requests and answer your questions.
When you contact us, in particular for the management of incidents concerning your order or the product/service purchased on the Platform, the processing is necessary for the execution of the purchase contract.
When your question concerns the exercise of the rights we inform you about below, or complaints about our products or services, the processing of your data is based on compliance with the legal obligations that bind us.
The legitimate basis for processing your data for marketing purposes is the consent you give us, for example by agreeing to receive personalized information through various means, when you authorize the sending of push notifications to your mobile device, or when you agree to the legal conditions to participate in a promotional action or to publish your photos on the Platform or our social network channels.
In order to be able to show you personalized information, we consider that we have a legitimate interest in carrying out profiling with the information we have about you (the sites you visit, your preferences or the history of your purchases) and the personal data you have provided us with such as date of birth or language, since we consider that the processing of this data is also in your interest since it allows you to improve your experience as a user and to have access to information in accordance with your preferences.
- Analysis of ergonomics and quality
We consider that we have a legitimate interest in analyzing the ergonomics of the Platform and the degree of user satisfaction since we believe that the processing of this data is also in your interest since its purpose is to improve the user experience and offer a better quality service.
4. HOW LONG WILL YOUR DATA BE KEPT?
How long your data is kept depends on the purposes for which it is processed, as explained below:
- Manage your registration as a user of the Platform
Your data will be processed as long as you remain a registered user (i.e. until you decide to delete your user account).
- The implementation, application and performance of the purchase or service contract
We will process your data for the time necessary to manage the purchase of the products or services you have purchased, including any possible returns, complaints or claims associated with the purchase of the particular product or service.
In some cases, we will only process data until you decide to do so, such as in the case of payment data that you have asked us to retain for future purchases.
- Customer Service
We will process your data for the time necessary to respond to your inquiry or request.
We will process your personal data until you unsubscribe or cancel your subscription to the newsletter.
If you participate in promotional actions, we will keep your personal data for 6 months after the end of the action.
- Usability and quality analysis
We will process your data occasionally for the duration of a particular quality action or survey or until your browsing data is pseudonymized.
Apart from the processing of your personal data for the time strictly necessary to fulfil the corresponding purpose as indicated above, they will then be stored, suitably safeguarded and protected with restricted access for the time for which responsibility may be incurred as a result of the processing, in compliance with the regulations in force at any given time. The deletion of personal data will be carried out once the possible actions of each case are prescribed.
5. WILL YOUR DATA BE SHARED WITH THIRD PARTIES?
- financial institutions,
- fraud detection and prevention entities,
- technology service providers,
- suppliers and employees of logistics, transport and delivery services,
- service providers related to customer service,
- suppliers and collaborators of marketing and advertising related services.
For reasons of service efficiency, some of these suppliers are located outside the European Economic Area whose level of personal data protection is not comparable to that of the European Union, such as the United States. In these cases, we would like to inform you that the transfer of your data will be carried out with appropriate safeguards and always maintaining the security of your data:
- Some providers are approved by Privacy Shield, a certificate that you can consult at the following link: https://www.privacyshield.gov/welcome
- In the case of other suppliers, we have signed Commission-approved Standard Contractual Clauses, the contents of which can be viewed at the following link https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts- transfer-personal-data-third-countries_en
6. WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?
We are committed to respecting the confidentiality of your personal data and to guaranteeing the exercise of your rights. As Co-Leaders, we have agreed that these can be exercised without any cost by sending us an e-mail to a single e-mail address email@example.comSimply indicate the reason for your request and the right you wish to exercise. If we deem it necessary to identify you, we may ask you for a copy of an ID.
Regardless of the purpose or legal basis under which we will process your data, you are particularly entitled to:
- Request access to the data we have on you. We remind you that if you are a registered user of the Platform, this information can also be found in the section corresponding to your personal data.
- Request us to delete your data to the extent that it is no longer necessary for the purpose for which we might have needed to process it, as stated above, or for which we are no longer competent to do so.
- Ask us to limit the processing of your data, which means that in some cases you can ask us to temporarily suspend the processing of your data or to keep it longer than necessary if you need it.
- Provide instructions regarding the retention, deletion or disclosure of your personal data after your death.
If you have given us your consent to process your data for any purpose, you also have the right to withdraw it at any time. Some of the ways in which you can withdraw your consent are explained in paragraph 2 where we explain the purposes of processing your data.
As explained in paragraph 3, when the processing of your data is based on your consent or the performance of the contract, you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, so that it can be transmitted directly to another entity, provided that this is technically possible.
Furthermore, if the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data. Finally, we inform you of your right to lodge a complaint with the relevant data protection supervisory authority. The authority of the country where the company is located.
7. WHAT HAPPENS IF YOU PROVIDE US WITH THIRD PARTY DATA?
We offer certain features or services that require the processing of personal data from a third party that you provide to us, such as the activation and delivery of a Gift Card. If you provide Personal Data to third parties, you assure us that they have been informed of the purposes and manner in which we need to process their Personal Data.
9. INFORMATION ON COOKIES