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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 (the “Policy”), to informing you how we collect and subsequently process such data.

When you use this website (the “Website”) or make purchases at our physical outlets, we will process your personal data in accordance with this Policy.

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 (commonly known as the General Data Protection Regulation, or GDPR).

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 Website or by contacting the Customer Service Department at clients@petrossian.fr or by writing to us by post to: PETROSSIAN Customer Service, 189 rue d'Aubervilliers, Voie A, porte 47, 75019 PARIS.

This 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 responsible for this Website and that collects and processes your 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.

Every order placed via this Website will be operated by a UK subsidiary company of CAVIAR PETROSSIAN called A TOUCH OF CAVIAR LTD (company number 10235446), whose registered office is at Unit 9, Rufus Business Centre, Ravensbury Terrace, London SW184RL.

2. What data do we collect from you?

We may be called on to collect your personal data when you browse this 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:

Your user account data: namely the data entered when creating an account and completing the registration form (first name, surname, date of birth, delivery and invoicing postal addresses, e-mail address, mobile phone number and password for logging on to your customer account);
Transaction data: namely the data that you enter when you make purchases and information about orders placed and returns, such as telephone number, address, e-mail address and information about the means of payment;
Any personal data included in communications between you and our Customer Service Department;
Personal data relating to your browsing of our Website: notably your IP address and (geo)location data.

The Website is not intended for use by children and we do not knowingly collect or use personal information relating to children.

The data about the means of payment (bank card number, expiry date, authorisation number and security code) is collected directly by our service providers 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 on the lawful grounds set out in the table below. These grounds include:

Execution of a contract of which you are part of, such as a contract to purchase our products. Some Customer personal data is therefore required in order to deliver the products to you, to administer your customer account and to handle returns;
Compliance with a legal obligation, notably of an accounting nature by retaining invoices;
Your prior consent;
Our legitimate interests (unless there is a good reason to protect your personal information which overrides these legitimate interests). - for example, preventing fraud.

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 providers (Adyen) use the information relating to means of payment when conducting payment of each order.	Execution of a contract entered into by the customer and the business.
Completion of transactions, notably payment transactions.	This data may also be used to prevent fraud when paying for the order and/or managing post-order late payments.	The legitimate interest of the business to prevent fraud Compliance with a legal obligation
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.).	The legitimate interest of the business to prevent internet fraud.
Customer Service: personal information provided in order to interact with our Customer Service department.	The personal data is shared with members of our Customer Service team so that they can help resolve any issues pertaining to any orders you have placed on the Website and can verify your identity.	Execution of a contract entered into by the customer and the business.
Training of our Customer Service staff for the purpose of improving the quality of our services provided to our Customers	We want to give you the best possible customer experience. One way to achieve is to record conversations that you may have with our Customer Service team via telephone or chat.	Your consent, which you can refuse or withdraw at any time.
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.	Your consent, which you can refuse or withdraw at any time.
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.	When we send newsletters to you by email, the lawful basis is your consent (which can be withdrawn at any time).
		When we send newsletters to you by post, this is done on the basis of our legitimate interests to offer products and services tailored to our customers’ needs. If you do not wish to receive newsletters from us in future, you can opt out of this.
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.	Your consent, which can be withdrawn or refused at any time.

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:

A TOUCH OF CAVIAR (our UK subsidiary company which processes orders made through this Website and related invoices);
Adyen, a payment services provider;
Streetwise and Riverside Despatch, delivery services providers;
Any police or administrative authority within the context of court requisitions concerning fraud;
Customs services and providers for international deliveries.

Where any of the above data recipients are located outside the European Economic Area (EEA), we have procedures in place to ensure that your data receives the same protection as though it were processed inside the EEA. For example, our contracts with third parties stipulate standards they must follow at all times. If you require further information, please contact us by email at clients@petrossian.fr or by writing to us by post to: PETROSSIAN Customer Service, 189 rue d'Aubervilliers, Voie A, porte 47, 75019 PARIS.

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.

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

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

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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, if requested to do so by law enforcement authorities, 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 such authorities, as and when required.

Archived data 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 the GDPR, you are entitled to exercise the following rights:

The right to access and to receive and correct any mistakes in your personal data that we hold;
The right to object to the processing of personal data concerning you for direct marketing and/or object to or otherwise restrict our processing of your personal data in certain circumstances;
The right to object to decisions taken by automated means which produce legal effects concerning you or significantly affect you;
The right to transmit your personal data that we hold to a third party in certain situations;
The right to require the erasure of your personal data in certain situations, or issue instructions relating to the retention, erasure and communication of one's personal data after death,

You may exercise all these rights by logging on to your customer account, by contacting the Customer Service Department at clients@petrossian.fr or by writing to us by post to: PETROSSIAN Customer Service, 189 rue d'Aubervilliers, Voie A, porte 47, 75019 PARIS. If you would like to exercise any of those rights, please provide your name and email address linked to your account (so that we can identify you), as well as proof of your identity and address (such as a copy of your driving licence or passport), and let us know the information to which your request relates. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We hope that we can resolve any query or concern you raise about our use of your information. However, if you are not satisfied with our response, the GDPR gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work or normally live, or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner, who may be contacted at https://ico.org.uk/concerns/ or by telephone on (+44)(0)303 123 1113.

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 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, we may place cookies on your computer via your browser. Cookies are small text files that are placed on your computer used in order to make this Website work, or work more efficiently, as well as to provide certain information to us. 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 with your prior consent. 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.

8.1. Cookies issued by CAVIAR PETROSSIAN and its service providers

"Strictly necessary" cookies

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

Subject to you providing consent by clicking the relevant button on our cookie banner, CAVIAR PETROSSIAN also uses the following non-essential cookies 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.

8.2. 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 non-essential cookies are not vital for browsing on the Website. These cookies are only placed on your device with your consent (given by clicking the relevant button on our cookie banner).

8.3. 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 non-essential cookies on your device requires your consent. You consent by clicking the relevant button on our cookie banner.

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