Personal data protection policy

1. Who is the data controller?

2. What data do we collect from you?

3. Why do we collect your personal data?

4. Do we share your personal data?

5. For how long do we retain your data?

6. What rights do you have over your personal data and how can they be exercised?

7. What measures do we take to safeguard the personal data we collect?

8. What is our cookies management policy?

9. Cookie Declaration

Protecting your personal data is essential to CAVIAR PETROSSIAN and we are committed, via this personal data protection policy, to informing you how we collect and subsequently process such data.

When you use our website or make purchases at our physical outlets you consent to our being able to collect and use your personal data in accordance with the conditions set out below. Should you not wish to communicate such data to CAVIAR PETROSSIAN, we will be unable to deliver our services.

We, CAVIAR PETROSSIAN, as data controller, undertake to comply with Regulation (EU) No. 2016/679 of 27 April 2016 on the protection of personal data.

Accordingly, we take all the necessary measures in order to:

Provide you with clear and transparent information on how your data will be collected and processed;
Implement all the technical and organisational measures required to protect your data against disclosure, loss, degradation or access by any unauthorised third party;
Retain your data only for the time required for processing purposes or for the service in question;
Offer you the ability at any time to access and modify your data processed by us via your personal areas on our various websites.

This confidentiality policy (the "Policy") may be amended at any time by CAVIAR PETROSSIAN, notably in order to comply with all regulatory, legal, editorial and technical developments. Prior to commencing browsing, the user should refer to the latest version of the Policy.

1. Who is the data controller?

The data controller that collects and processes personal data is CAVIAR PETROSSIAN, a French société anonyme with share capital of 240,000 euros, whose registered office is located at 18 Bd de La Tour-Maubourg, 75007 Paris, France, RCS Paris registration number 652 050 329, Tel: +33144896766.

2. What data do we collect from you?

With your prior consent, we may be called on to collect your personal data when you browse the website www.petrossian.fr (hereafter the "Website") and when you make purchases in PETROSSIAN shops.

We only collect information that is strictly necessary to deliver our services. The personal data likely to be collected is as follows and is marked with an asterisk:

User account data: namely the data entered when creating an account and completing the registration form (first name, surname, delivery and invoicing postal addresses, e-mail address, mobile phone number and password for logging on to the customer account);
Personal data registered by the user in their customer account: date of birth;
Transaction data: namely the data entered by the user when they make purchases and information about orders placed and returns, such as telephone number, address, e-mail address and information about the method of payment;
Contacts with the Customer Service Department;
Data relating to browsing: notably the date, time of connection and/or browsing session, type of browser, the IP address and (geo)location data.

The data about the means of payment (bank card number, expiry date, authorisation number and security code) is collected directly by our service provider AdYen and is never forwarded to us.

Third-party suppliers of applications, tools, gadgets and plug-ins on our Website and the networks on which we publish editorial and promotional content (such as Facebook and Instagram) may also use automated systems, relating to areas of interest and the context, in order to collect user data (interaction with the functions and profiling of online activity). This data is collected directly by these service providers and/or third parties and is covered by their own policies. To the extent permitted under applicable laws, we are not responsible for the practices of the said service providers.

In compliance with the law, we do not collect data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data about health or data about the sex life or sexual orientation of any person.

These categories of personal data are never collected or processed by CAVIAR PETROSSIAN.

3. Why do we collect your personal data?

The data collected during your use of the Website or at our physical outlets is processed for the purposes set out in the table below.

Current regulations protect the private lives of users and require every data controller to be able to demonstrate a legitimate basis for the said processing. Regulations specify the various legal bases for processing, including:

Execution of a contract to which the person concerned is party, such as a contract of sale. Certain of the customer's personal data is therefore required in order to deliver the goods, to administer the customer account and carry out returns;
Compliance with a legal obligation, notably of an accounting nature by retaining invoices;
Prior consent of the person concerned;
The legitimate interest of the data controller, while respecting user rights and freedoms. Accordingly, improving the customer experience and preventing fraud may justify the collection of data.

Purpose of processing	Utilisation of data	Legal basis for processing
Administration of orders, product sales and service delivery; administration of complaints, contract withdrawals and product returns.	Data is used to provide products and services (from the shopping basket and orders; sale, return and reimbursement of purchased products).	Execution of a contract entered into by the customer and the business.
Completion of transactions, notably payment transactions.	Our payment service provider (Adyen) uses the information relating to means of payment when conducting payment of each order. This data may also be used to prevent fraud when paying for the order and/or managing post-order late payments.	Execution of a contract entered into by the customer and the business.
Creation and administration of the customer account.	The personal data of a customer registered on the Website is used (e-mail address and password).	Execution of a contract entered into by the customer and the business Compliance with a legal obligation.
Delivery of products ordered.	The personal data (contact details, e-mail address) is used to carry out deliveries.	Execution of a contract entered into by the customer and the business.
Fight against internet fraud (prevention of fraud against means of payment, identity theft).	The personal data (security cookies) may be used to collect information about the terminal used to complete the order (notably the operating system used, location of the device, use or otherwise of a proxy, etc.).	Prior consent of the person concerned. The legitimate interest of the data controller to prevent internet fraud.
Customer Service: contact with the department.	The personal data is used to interact with customers. To this end, contacts between Customer Service and the customer by telephone or chat may be recorded in order to improve the quality of service. The customer may refuse consent at any time.	Execution of a contract entered into by the customer and the business.
Participation in special events (such as competitions, games, prize draws and offers) and in the loyalty program, excluding online gambling covered by approval from the French online gaming authority, the Autorité de Régulation des Jeux en Ligne.	The personal data (including purchase information) is used to administer participation in various special events and in the loyalty program.	Execution of a contract entered into by the customer and the business (competition rules) The legitimate interest of the data controller to make special offers.
Management, evaluation and improvement of products, services and user experience (notably in order to develop new products and services and analyse the customer base; data analysis, accounting and audit), profiling.	The personal data is used to evaluate and improve the user experience as well as the products and services offered by Caviar Petrossian. This data is obtained via the analysis of statistics and anonymised customer behaviour and also by the measurement of website and mobile application usage.	The legitimate interest of the data controller to offer products and services adapted to customer needs.
Forwarding of newsletters and special offers provided that the user ticks the box confirming their acceptance when registering for the service.	The personal data is used to inform customers about our products and services and to personalise the products and services on social networks.	The legitimate interest of the data controller to offer products and services adapted to customer needs.
Compliance with obligations under all contracts or agreements by which Caviar Petrossian is bound to its customers.	The personal data is used to inform customers about our products and services and to personalise the products and services on social networks.	The legitimate interest of the data controller to offer products and services adapted to customer needs; consent (box to be ticked).
Analysis of Website visits and visit frequency, audience measurements, analysis, statistics, surveys (cookies) and improving the user experience on the Website and mobile application.	The personal data (including cookies) is collected to understand the utilisation of the Website and mobile application.	The legitimate interest of the data controller to offer products and services adapted to customer needs.

4. Do we share your personal data?

We do not share any personal data with any third party for commercial purposes.

We ensure that only authorised persons within CAVIAR PETROSSIAN are able to access your data and only when such access is required in order to properly conduct our commercial relationship.

Our service providers may also be recipients of data strictly required to deliver the services we have entrusted to them (e.g. delivery and online payment).

Service providers with access to users' personal data

The personal data collected is forwarded to service providers of CAVIAR PETROSSIAN, which may process the said data on behalf of CAVIAR PETROSSIAN (subcontractors) and/or on their own behalf (data recipients).

The data recipients are:

AdYen, a payment services provider;
Chronofresh, Chronopost and UPS, delivery services providers;
Any police or administrative authority within the context of court requisitions concerning fraud;
Customs services and providers for international deliveries.

The subcontractors of CAVIAR PETROSSIAN may have access to the data collected for the purposes of:

Preparing and dispatching orders, product returns;
Improving the Website and mobile application content;
Technical maintenance and development of the Website and internal applications of CAVIAR PETROSSIAN, including entities providing internet hosting services and information storage, namely Alioze and its subcontractor, Always Data (managed hosting provider), the e-mail services provider MailChimp, and the tag administration and analysis services by Google Analytics, Google Ads, Facebook Pixel, Google Tag Manager and Numberly.

To obtain more details about these analytical services and about your rights of refusal, please consult the following website:

Google Analytics: https://support.google.com/analytics/answer/6004245?hl=fr

CAVIAR PETROSSIAN may also share the personal data of customers that hold an account with its physical outlets. Their access is restricted to the orders placed by the customer.

5. For how long do we retain your data?

User data is not retained in excess of the period strictly required for the purposes specified in this Policy and in accordance with applicable laws and regulations.

In this regard, data used for the purposes of sales development may be retained for a maximum period of 3 years after closure of the user account or from the last contact with the relevant potential customer. The user's data will be deleted on expiry of the said retention periods. However, the data may be archived beyond the specified periods for the purposes of the investigation, ascertainment and pursuit of criminal activity with the sole purpose of making such data available to the judicial authorities, as and when required.

Archived data will be anonymised and will no longer be available online but will be extracted and conserved on a stand-alone and secure medium.

6. What rights do you have over your personal data and how can they be exercised?

You may modify your personal data and withdraw your consent at any time by logging on to your customer account.

In accordance with Articles 14 to 22 of Regulation (EU) 2016/679 of 27 April 2016, any natural person using the Website www.petrossian.fr is entitled to exercise the following rights:

The right to access, rectify and erase collected data;
The right to object to the processing of personal data;
The right to restrict processing;
The right to portability of collected data;
The right to issue instructions relating to the retention, erasure and communication of one's personal data after death, in accordance with Article 40-1 of Law no. 78-17 of 6 January 1978 (the French Data Protection Act).

The user may exercise all these rights by logging on to their customer account, by contacting the Customer Service Department at contact@petrossian.fr or by post to: PETROSSIAN Customer Service, 189 rue d'Aubervilliers, Voie A, porte 47, 75019 PARIS.

The user's request must include proof of identity.

In the event of the user not receiving any response or of the response being unsatisfactory, they may refer the matter to the supervisory authority of their country of residence (CNIL in France: https://www.cnil.fr/).

Finally, should we detect any violation of personal data that may entail a high level or risk regarding user rights and freedoms, we undertake to notify the users concerned without undue delay.

7. What measures do we take to safeguard the personal data we collect?

As data controller, we undertake to implement all the necessary precautions in order to maintain data security and confidentiality, notably to prevent it being corrupted or distorted, or accessed by any unauthorised third party.

We have entered into service contracts with partners offering a certain expertise in the field of data protection.

All data is hosted in France or the European Union.

Payment of purchases made on the Website takes place on the secure platform of our payment services provider, ADYEN.

ADYEN is service provided by Adyen N.V., a dutch company registered with the Dutch Chamber of Commerce under number 34259528 and having its seat at Simon Carmiggeltstraat 6-50, 1011 DJ in Amsterdam, the Netherlands.For further information, please consult the following website: https://www.adyen.com .

We have no access to your payment data.

Revision and updating of the Policy

The Policy will be updated as and when required in order to meet regulations applicable to data protection. It will be revised at least every three (3) years.

8. What is our cookies management policy?

When using our Website, with your prior consent we may place cookies on your computer via your browser. During their period of validity, cookies enable us to identify your computer during your subsequent visits. Partners or service providers of CAVIAR PETROSSIAN, or third-party companies, may also place cookies on your computer. Certain cookies are vital for browsing activities on our site, notably for the proper execution of the order process, and deleting them may pose problems. Only the issuer of a cookie will have reason to read or modify the information it contains.

Please find below information about cookies that may be placed on your device when you visit any page of www.petrossian.fr, either by CAVIAR PETROSSIAN or by a third party, in addition to the process you may follow for deleting cookies or declining consent for them to be placed on your device.

What are cookies used for?

Cookies are used to monitor browsing activity or analyse user behaviour, and notably to:

Measure traffic on our Website and application, including content;
Save information about the customer account when the user is logged on;
Save the shopping basket for a 30-minute period;
Personalise the content displayed to the user.

There are many categories of cookies, some of which are issued directly by CAVIAR PETROSSIAN and its service providers, others may be issued by third-party companies.

A. Cookies issued by CAVIAR PETROSSIAN and its service providers

- "Essential" cookies

These cookies are essential for browsing purposes, notably for the proper execution of the ordering process. Deletion may cause browsing problems on the Website, making it impossible to place an order.

These cookies are also required by CAVIAR PETROSSIAN to track its business.

- "Analytical & Personalisation" cookies

These cookies are not vital for browsing on our Website but may, for example, make it easier for you to conduct searches and optimise your purchasing experience and for us to better target your preferences, improve our offering and optimise the functioning of the Website.

B. Cookies issued by third-party companies

The issue and utilisation of cookies by third parties on the Website are subject to the privacy protection policies of the third parties in question. These cookies are not vital for browsing on the Website.

C. Cookies issued by third-party applications integrated within the Website

We may incorporate within the Website certain computer applications emanating from third parties that enable you to share the Website contents with other persons or to inform these other persons of your visit or your opinion concerning any particular content of the Website. This notably applies in the case of the "Share" and "Like" buttons on social networks such as Facebook, Twitter, etc.

Any social network providing this type of button may identify you from it, even if you did not use it when visiting the Website.

This type of button may enable the social network concerned to track your activity on the Website, simply due to the fact that your account with the social network concerned was active on your device (open session) when browsing the Website.

We do not control the process employed by social networks to collect information about your visit to our website relating to the data that they hold.

We recommend that you consult the privacy protection policies of the said social networks in order to understand the purposes and usage of the browsing information they may gather through the use of these buttons, particularly advertising.

These protection policies should enable you to exercise your rights regarding the said social networks, notably be configuring your user account for each network.

To view the privacy protection policies of the aforementioned social networks, click on the name of the social network of your choice:

How can you manage the cookies placed on your device?

The storage of cookies on your device requires your consent.

Via your browser settings you may simply, at any time and free of charge, choose to accept or reject the storage of cookies on your device. You may configure your browser as you wish, so that cookies are stored on your device or, conversely, rejected.

You can configure your browser so that:

Acceptance or refusal options are given on a case-by-case basis, prior to any cookie being stored;
The storage of cookies on your device is always rejected.

Note: any configuration of your browser regarding the acceptance or refusal of cookies is likely to affect your use of the internet and your conditions of access to certain services that require cookies.

If you choose to refuse the storage of cookies on your device, or delete those that are already stored, we decline all responsibility for the consequences of any impaired functioning of our services resulting from the impossibility for us to store or consult the cookies you have refused or deleted which we require for delivery of our services.

Configuration of all software packages is different. It is generally described in the help menu of your browser. We therefore suggest you familiarise yourself with it in order to decide how to change your cookie preferences:

For Internet Explorer 8.0 and later:

Select the "Tools" menu, then "Internet Options"
Click on the "Privacy" tab
Select the privacy level required using the cursor

For Mozilla Firefox:

Select the "Tools" menu, then "Options"
Click on the "Privacy" icon
In the "Cookies" section, select your desired options

For Chrome:

Select the "Settings" menu
Click "Advanced" at the bottom of the page and go to "Privacy"
Click on "Content settings" and select your desired options

For Opéra:

Select the "File" menu, then "Settings"
Click on the "Privacy" icon
Define your privacy settings

For Android:

Tap the button at the top right
Go to "Settings", then "Privacy and security"
Define your privacy settings

For Dolphin on Android:

In the menu go to "Plus" then "Settings"
Select the "Privacy" menu, then "Security"
Define your privacy settings in the "Cookies" menu

For Safari on iOS:

In the application go to "Settings" and select "Safari"
Go to "Accept cookies" in "Privacy"
Define your privacy settings

You may also refuse the storage of cookies by advertising cookie administration platforms, notably the website http://www.youronlinechoices.com/fr/controler-ses-cookies/

9. Cookie Declaration