SBE (« we ») takes the utmost precautions to respect your privacy and take responsibility for the processing of personal data. This Privacy Policy informs you about how we treat your personal data and is an integral part of the General Terms and Conditions of Sale and Use.
In accordance with the regulations in force, this Personal Data Protection Policy (the "Policy") applies when you browse the Site in order to inform you of the collection, use and more generally the processing of your personal data.
The personal data we process
We only collect personal data that is necessary for the purpose for which it is being processed. The mandatory nature of the communication of information is indicated in the collection form when you register or change the information.
These data are as follows :
- Your identification data, such as your first name, surname, gender ;
- Your contact information, such as your postal address and e-mail address ;
- Your transactional information, namely all information related to your Orders on the Site, such as products purchased, and information related to your payment method ;
- Your login data, such as information about the hardware and software on your computer or mobile device. This information includes your IP address, device type and model, browser type, device identification. This information is used for the proper functioning of the Site, to maintain its quality and for general statistical purposes and to meet our legal and regulatory obligations.
- Cookies : we invite you to consult the paragraph below concerning the placement of cookies.
All or part of this personal data is obtained when you:
- visit our Site (for example, through cookies) or participate in a promotional operation ;
- fill in this information via our Site or by telephone, e-mail, post, form ;
- send us comments or questions ;
- and more generally, by any other means by which you contact us.
Your personal data may be collected by us and/or third party service providers who help us operate the Site, such as, but not limited to, hosting providers, partners or subcontractors.
Cookies placed during navigation on the Site
A "cookie" is a text file placed on your device using a navigation tool. Cookies allow the sender, and only the sender, to identify the device in which it is stored, during the period of validity or registration of the cookie and cannot be used to run programs or transmit viruses to your computer.
We use cookies or other similar technologies to facilitate your browsing on the Site, (ii) to use the main features of the Site and to secure your connection as well as to access personal areas of the Site directly, using identifiers or data that you may have previously entrusted to us, (iii) to adapt the presentation of the Site to your device's display preferences during your visits, (iv) to conduct statistical studies.
You have the option to accept or reject cookies. Most browsers automatically accept cookies, but if you prefer, you can usually change your browser settings to refuse cookies. If you choose to decline cookies, you may not be able to take full advantage of the Site's features.
You can configure your browser so that:
- cookies are recorded or, on the contrary, that they are rejected, either systematically or according to their issuer ;
- the acceptance or rejection of cookies is offered on an ad hoc basis, before a cookie is likely to be stored on your device ;
- cookies placed on your device are deleted at any time.
For cookie management, the configuration of each browser is different. It is described in the help menu of each browser and in particular at the following addresses provided for information purposes:
- For Chrome : https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
- For FireFox : https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
- For Internet Explorer : https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
- For Opéra : https://help.opera.com/en/latest/web-preferences/#cookies
- For Safari : https://support.apple.com/fr-fr
The purposes for which we process your personal data
The personal data we collect is processed in accordance with current regulations to meet explicit, legitimate and determined purposes, either on the basis of the General Conditions of Sale or Use, or to meet a legal and/or regulatory obligation or subject to your prior consent. These purposes are as follows:
- Allow you to purchase Products, services and use your account
We collect and use your personal data in order to be able to supply the Orders we offer via the Site. These data are processed in particular for:
- manage your online registration request and be able to validate it,
- process Orders, in particular by managing their follow-up and payment as well as, if necessary, handling any incidents (fraud management, payment incidents, etc.);
- provide assistance.
Your personal data is also essential to us in the context of our interactions with you in the context of your browsing on the Site and more generally, in the context of our commercial relations with you.
In order to ensure the quality of our products and services and to improve them, we also compile general statistics, which are subject to an anonymization procedure when the processing of your personal data does not appear necessary for their performance.
- Inform you about our products and/or services
We may use your personal data to inform you of the products or services we offer to our customers, either after having obtained your prior consent to receive such information, or as a result of a purchase on our Site.
If you no longer wish to receive special promotional information, advertisements or other messages from us, you can click on the link at the bottom of the email. For technical reasons, we need a reasonable time to satisfy your request and you are likely to receive some messages following your request while we take it into account.
- Securing the Site
We ensure the security of your personal data, as well as the personal data of third parties against any fraudulent access, use or disclosure by implementing enhanced data protection through the use of appropriate physical and logical technical security measures to ensure the integrity of your data, as well as its confidential and secure processing.
However, we remind you that no security system is infallible and we cannot guarantee that your information is completely secure.
Finally, when browsing the Site and in particular in the event of publication of notices, we recommend that you exercise the greatest vigilance as to the nature of the information that you may be required to disclose, directly or indirectly, which may then be accessible to third parties and processed or exploited under conditions of which neither you nor we could have knowledge or prevent.
- Comply with our legal and regulatory obligations
In the context of the operation of the Site, we are bound by various legal and regulatory obligations involving the storage of your personal data. This data may also be used in connection with operations to identify the authors of illegal content.
The recipients of the personal data processed
We process your personal data exclusively for the purposes described in this Policy.
To this end, we may solicit trusted partners acting as subcontractors in order to be able to provide you with all the services offered on the Site and more particularly:
- at the time of an Order in order to ensure payment (payment interface and management of bank cards by our bank) or to manage delivery ;
- generally when using the Site to host your data, to send you an e-mail, to assist you in using the Site or to help us perform statistical analyses.
These third parties are contractually prohibited from using the personal data we transmit to them for any purpose other than that for which they have been mandated, and they are required to maintain the security and confidentiality of your information with protection equal to or greater than that which we provide.
We will only disclose your personal data, without notice, to:
- if required by current regulations,
- if such disclosure is necessary to comply with applicable laws or regulations, judicial proceedings and/or administrative or judicial injunctions ;
- to protect and defend our rights or property or that of our partners ;
- more generally, to act in urgent circumstances to protect the personal safety of users of the Site or third parties.
Subject to your express and prior agreement, our partners may contact you directly or through us in order to propose commercial prospecting offers.
The length of time your data is kept
We retain your personal data only for as long as necessary for the proper provision of the proposed Services, unless the law requires that your personal data will not be retained otherwise.
As a result, we retain your account data for a period of five (5) years from the closure of your account, unless the law requires that some of this data be retained for a shorter period. Your bank details are not kept for longer than necessary to complete the transaction without your prior consent.
As an exception, this data may be archived to manage ongoing claims and litigation as well as to meet legal and/or regulatory obligations and/or to respond to requests from authorities authorised to make such requests.
Cookies placed on your browser have a lifetime of thirteen (13) months.
Finally, this data may be archived for as long as necessary to manage ongoing complaints or disputes and/or to respond to requests from authorities authorised to make such requests.
The transfer of your data outside the European Union
As part of the provision of the Services, we may transfer your personal data to countries outside the European Union that have not been subject to an adequacy of protection decision by the European Commission.
In this case, we ensure that this transfer is carried out in accordance with the regulations in force by taking all appropriate measures and in order to ensure the confidentiality and security of this data under legal, technical and operational conditions and guarantees.
Your rights and how to exercise them
In accordance with the regulations in force, you have the right to access, oppose, rectify, and delete your personal data as well as the right to limit the processing carried out, to be portable and to define the fate of your data in the event of death, subject to the legal and regulatory obligations that would require us to keep them. The exercise of some of these rights may prevent us from providing you with access to the Site and/or from using all or part of the services offered on the Site, and in particular from making purchases.
These rights can be exercised by contacting us at the following address contact@sbedirect.com and providing proof of your identity. In addition, you are reminded that you can directly exercise some of these rights through your Account settings.
You have the right to file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the supervisory authority in charge of ensuring compliance with personal data obligations.
Finally, it is specified that we may communicate your personal data, under the conditions provided for by law, to a duly authorised judicial or administrative authority.
Changes to this Policy
We may, at any time and from time to time, make changes to this Policy, in particular because we are changing our services and/or because the regulations in force would require us to do so: these changes will then apply to personal data collected after the effective date indicated in the Policy and we will inform you via a notice on the Site or any other means.
In any event, we recommend that you regularly review this Policy for the latest information on our privacy practices.
The most recent version of the Policy is as of the date indicated at the end of this document.
Date of the last update of this Policy: 04/01/2019