CONFIDENTIALITY AND GENERAL PERSONAL DATA PROTECTION POLICY

INTRODUCTION

Confidentiality, protection of personal data and respect for the privacy of its customers are at the heart of the daily precautions of the company SAS Odorem (hereinafter “NotaBané Parfums”).

This General Personal Data Protection Policy therefore aims to explain in complete transparency the rules for implementing the processing of personal data carried out by SAS Odorem, in accordance with the legislative and regulatory provisions in force, which are in particular the law n°78-17 of January 6, 1978 (hereinafter “Informatics and Liberties Law”), European regulation n°2016/679 of April 27, 2016 (hereinafter “GDPR Regulation”) or the recommendations issued by the National Commission for Information Technology and Liberties (hereinafter “CNIL”).

This General Personal Data Protection Policy may be modified at any time by SAS Odorem. Due to changes that may occur, we invite you to read it regularly.

SUMMARY

  • SAS Odorem, Responsible for Personal Data Processing
  • Why does SAS Odorem collect your data?
  • What data is collected ?
  • When and through what channel is your data collected ?
  • On what basis and for what purposes are your data collected ?
  • The fate and secure processing of your data
  • What communications will you receive ?
  • Keeping your data
  • The recipients of your data
  • Your rights regarding the management of your personal data
  • Your data and social networks

 

SAS ODOREM, RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

The Data Controller is the company that determines the purpose and manner in which your personal data is used. Personal data collected via the website www.notabane-parfums.com, on computer, mobile and in stores under the NotaBané Parfums brand are processed by: SAS Odorem, Simplified Joint Stock Company, registered with the RCS of Dakar.

 

To support it in this process, SAS Odorem has appointed a Data Protection Officer, known as “DPD” or “DPO”. His mission is to ensure compliance with all processing of personal data by the company that designated him. He raises awareness among the teams, is the preferred contact for the CNIL and responds to requests from customers who wish to exercise their rights on the personal data collected.

 

The Data Protection Officer of SAS Odorem can be contacted by writing to:

  • By email: contact@notabane-parfums.com
  • By post: SAS Odorem – Data Protection Officer – Villa 25 3rd floor SCAT Urbam – Dakar

 

Also, in the event that your data is collected directly in store, the latter acts as Data Controller (in particular collection and commercial prospecting).

He can also act as joint data controller with SAS Odorem, with regard to consultation, modification of customer data and for all actions relating to the NotaBané Parfums loyalty program.

WHY DOES SAS ODOREM COLLECT YOUR DATA ?

Personal data is defined as any information relating to an identified or identifiable natural person. SAS Odorem may therefore collect some of your personal data at different times, via different channels, for different purposes and on different grounds.

WHAT DATA IS COLLECTED ?

SAS Odorem may collect your name, first name, postal address, email address, password, telephone numbers, CV, connection and navigation data, IP address, order history, elements relating to order tracking, elements relating to delivery and payment of orders, preferences and interests or even location data.

 

It may also be required, through its salespeople, to collect health data relating in particular to your skin type, your allergies or even any medical problems.

 

Some data is collected automatically due to your actions or voluntarily by you. The mandatory nature of the data to be communicated is indicated during collection by an asterisk.

 

SAS Odorem also collects various browsing information via the deposit of cookies which are installed on your computer, mobile and/or tablet.

WHEN AND THROUGH WHICH CHANNELS IS YOUR DATA COLLECTED ?

SAS Odorem collects your personal data in a fair and transparent manner through several collection points:

 

In NotaBané Parfums stores: During a simple visit or purchase in stores, SAS Odorem may ask you to provide a certain amount of personal data: when creating a loyalty account, when creating your customer file.

 

Certain health data (skin type, allergies/reactions, medical problems, medical treatment, diet, etc.) may be requested from you as a preventive measure to detect your possible contraindications and in order to be able to provide you with the most appropriate aesthetic treatments. adapted to your skin type. The same could be true in the event of reporting of adverse health events.

 

On the website www.notabane-parfums.com: By browsing our website you may be required to provide personal data: online purchases and order tracking, creation of a customer account, loyalty card membership, subscription to our newsletter, recruitment forms, etc.

 

A geolocation service also lets you know the address of a store/perfumery near you as well as the availability of a service or product in the store closest to you.

 

We also use your browsing information which is recorded in files called “Cookies” installed on your computer, mobile and/or tablet.

 

During your exchanges with our customer service: By contacting our Customer Service, our agents may ask you to provide a certain amount of personal data concerning you in order to process your requests or complaints. If you have not objected, telephone conversations may also be recorded to ensure satisfactory quality of service and for evidentiary purposes.

 

When you participate in our competitions or in a satisfaction survey.

 

When using social networks: The use of social networks to interact with SAS Odorem (and including in particular the tools, the “share” buttons of Facebook, Instagram or Twitter) is likely to result in data exchanges between SAS Odorem and these social networks. SAS Odorem invites you to carefully consult the personal data management policies of the various social networks to be aware of the personal data that may be transmitted by them.

ON WHAT BASIS AND FOR WHAT PURPOSES ARE YOUR DATA COLLECTED ?

SAS Odorem only collects data that is relevant and necessary for the objective pursued. Depending on the legal basis of collection, your data is processed for different specific, explicit and legitimate purposes, explained below:

 

  • Due to the execution of a contract concluded with SAS Odorem: When you conclude a contract with SAS Odorem (purchase of products in store or purchase of products online for example), your personal data is collected for different purposes: management of your customer account, your shopping cart and your orders, delivery management, order tracking and invoicing, management of complaints with Customer Service, management of your payments...

 

  • Due to compliance with a legal obligation: SAS Odorem may be required to collect and process your personal data because this processing is made mandatory by a legal provision. For example, SAS Odorem, as a distributor of cosmetic products, has the possibility of establishing a cosmetovigilance sheet when a product presents serious adverse effects. This obligation results from Article 23 of Regulation No. 1223/2009 of the European Parliament and the Council of November 30, 2009 relating to cosmetic products, as well as Articles L. 5131-5, L. 5431-8 and R.5131- 6 to R. 5131-15 of the Public Health Code.

 

  • Due to your consent: SAS Odorem may collect and process your data on certain subjects only if you have expressly accepted the processing of your personal data (when you check a box indicating this, for example). The purposes concerned are in particular the following: sending personalized commercial offers by email, SMS, on social networks or other electronic media, organizing competitions, geolocation, processing applications, collecting opinions customers or comments on the products or services marketed; improving the customer experience; audience measurements on the website; sharing data with commercial partners or even storing cookies to improve your browsing, personalize content on the site and display targeted advertising.

 

Your consent is required when collecting your personal data. Your choice can be modified at any time (see opposition methods explained below) Due to the existence of a legitimate interest: SAS Odorem may be required to collect and process your data because there is a legitimate interest in this treatment. This is particularly the case for: statistical analyses, claims management by our brokers and insurers, the fight against fraud, particularly during online payment of orders and processing of reimbursement requests.

THE FATE AND SECURE PROCESSING OF YOUR DATA

In its capacity as data controller, SAS Odorem undertakes to take measures to protect the security of your personal data, and in particular to prevent their destruction, distortion, loss, alteration, disclosure or unauthorized access to them. .

 

To do this, SAS Odorem implements various technical and organizational processes, such as: data encryption to protect personal data files entering or leaving the information system, storage on secure servers, limitation of the number of our employees having access to data, regular tests of our information systems, etc. .

 

SAS Odorem also ensures that its subcontractors comply with regulations regarding personal data.

 

Concerning your banking data, SAS Odorem uses a certified service provider for payments by bank card. No storage of your banking data is carried out without your consent.

WHAT COMMUNICATIONS WILL YOU RECEIVE ?

SAS Odorem may use your contact details to send you various communications aimed at various objectives.

 

Service emails: these emails follow the placing of an order and allow you to follow the progress of the order: order confirmation, delivery information, etc. . These communications are essential for the proper execution and perfect information of the tracking of your orders.

 

Offres commerciales/Newsletters NotaBané Parfums et/ou Partenaires : Lors de la création de votre compte sur le site internet www.notabane-parfums.com ou en magasin, vous serez invité à donner votre consentement express et préalable relatif à la réception de diverses offres commerciales/ newsletters adressés par la SAS Odorem ou ses partenaires commerciaux, par email et/ou SMS.

 

These commercial offers allow you to be informed of news, promotions applicable in NotaBané Parfums stores and/or our Partners.

 

You can object to these email/SMS prospecting when your data is collected and then at any other time:

  • In your online account, “My account”, “My personal information” section, then “My Newsletter subscriptions”
  • By clicking on the unsubscribe link at the bottom of each commercial email
  • By sending the word “STOP” to the number indicated in the received SMS

 

Participation in satisfaction surveys/product reviews: following your purchases on the internet or in store NotaBané Parfums, SAS Odorem and/or any other approved partners may ask you by email via questionnaire. You can object to this participation during the collection of your data and then at any other time via the unsubscribe link present in each of the emails sent or via the contact form present on this NotaBané Parfums website on the following page: https ://notabane-parfums.com/contact-us/

 

Courrier postal : Vous pouvez être contactés par nos services et/ou nos partenaires pour vous proposer des offres commerciales. Vous pouvez vous opposer à ces envois postaux lors de la collecte de vos données puis à tout autre moment notamment via le formulaire de contact présent sur le site internet sur la page suivante : https://notabane-parfums.com/contact-us/

 

Telephone solicitation: You may be contacted occasionally by our telephone operators or our partners to offer you commercial offers. You can object to this telephone solicitation during the collection of your data and then at any other time by registering on the list of opposition to telephone canvassing accessible at the address www.bloctel.gouv.fr

 

SMS notifications: The website www.notabane-parfums.com may send you notifications in order to offer you different products and offers.

 

The same applies when using certain social media features (like, share, etc.). At any time, you can deactivate notifications via your phone's settings.

CONSERVATION OF YOUR DATA

Personal data will be kept by SAS Odorem according to precise rules that comply with current regulations. Generally speaking, your personal data is kept for a limited period, in a form which allows your identification only for the period necessary for the purposes for which they are collected.

 

Thus, for illustration purposes, the retention period of your data is 5 years from the last purchase or the last contact with SAS Odorem if you have made a purchase (active customer) and 3 years from the last shipment /contact if you are a prospect customer, that is to say if no purchase has been made.

 

The retention period of cookies is limited to a maximum of 13 months.

RECIPIENTS OF YOUR DATA

SAS Odorem, in strict compliance with the purposes set out in this General Personal Data Protection Policy, is required to communicate your personal data to various types of contacts/partners:

 

  • Subcontractors: The data collected may be transmitted to our subcontractors. The latter process the data collected only on our behalf, and according to our instructions. We ensure when referencing that they comply with the applicable regulations regarding the subcontracting of personal data. By way of illustration, our subcontractors intervene for the following purposes: the management, shipping, processing or payment of your orders on the site, the management of customer service, the fight against fraud, promotional campaigns, recruitment, etc.

 

  • Companies belonging to the same group as SAS Odorem: Data concerning you may also be transmitted to other parent companies and/or subsidiaries (as defined in articles L233-1 et seq. of the Commercial Code) controlled by and/or controlling the company. SAS Odorem.

 

  • Third parties: Various third parties with whom we collaborate within the framework of the purposes expressed in this General Personal Data Policy may be recipients of your personal data such as in particular: our franchised stores under the NotaBané Parfums brand, our partner suppliers during purchases made on the internet or during marketing operations, commercial partners, advertising agencies, affiliation partners, social networks, our brokers and/or insurers or even administrative or judicial authorities, for example in the context of reporting events undesirable health conditions or even legal requisitions. If applicable, personal data collected by SAS Odorem could be transferred to third parties in the context of a change of control of the company, an acquisition, a collective procedure, a transfer of assets of the company. company or in the event of transfer of business assets.

 

Transfer of your data outside the EU: In certain cases, and for the purposes of the purposes expressed in this general personal data policy, it is possible that your data is transmitted by SAS Odorem or by our subcontractors to companies located in countries outside the European Union. In this context and prior to any data transfer, SAS Odorem will take all necessary measures and guarantees to ensure that these are carried out securely and in compliance with applicable regulations.

 

By way of illustration, transfers outside the European Union can be carried out in particular within the framework of our Customer Service activity (Senegal), the management of Colissimo shipments (Morocco, Mauritius) or even the use of data linked to networks social networks such as Google or Facebook (USA).

YOUR RIGHTS

In accordance with current regulations, you have the rights of access, rectification, deletion, portability, limitation, opposition to the processing of your data and to define your post-mortem directives. You can exercise them with our Data Protection Officer (DPO) at the following address: contact@notabane-parfums.com or via the NotaBané Parfums Customer Service form by clicking below: Customer Service.

 

To facilitate the processing of your request, we thank you for specifying your last name, first name, email address, and where possible, your customer reference. It is best to indicate the address to which you would like to receive the response. SAS Odorem may, in the event of reasonable doubt, carry out identity checks. You may be asked for a copy of an identity document bearing your signature. A response will be sent to you within one month of receipt of your request. You also have the right to lodge a complaint with the CNIL at any time: cnil.fr.

YOUR DATA AND SOCIAL NETWORKS

In order to improve our commercial relationship and be closer to our customers, SAS Odorem is present on social networks (Facebook, Instagram, Twitter, Tik Tok, etc.).

 

You can follow our page, “like” or “share” our content. We draw your attention to the fact that the use of social networks to react with SAS Odorem, and in particular the use of tools and “Share” or “Like” buttons on these networks, is likely to lead to exchanges data between SAS Odorem and these social networks, based on your consent.

 

We therefore invite you to read the personal data policy specific to the different social networks.

 

SAS Odorem cannot be held responsible for the subsequent use of your personal data by these networks. Furthermore, we inform you that personal information linked to your browsing is collected by social networks. This capture is implemented for advertising purposes, via cookies placed when browsing the NotaBané site. This data processing is based on your consent, which you can withdraw by setting your cookies.