It illustrates the strong commitment of DEL ALMA SARL to respecting your privacy and the protection of your personal data that may be collected and processed when you use the Site (hereinafter, the “Data”).
No collection or processing of your Data may be made without your prior, free and informed consent.
In order for consent to be free and informed, it must be given with full knowledge of the facts, i.e., by a person who is sufficiently informed of the consequences of his/her consent, both qualitatively (the right to understanding) and quantitatively (the right to information).
- Inform you, in advance and transparently, with regard to the Data that may be collected and the use that may be made of such Data;
- Enable you to browse the Site with confidence and to use the features we offer you with comfort;
- To inform you of all the rights that you have regarding the Data we may collect, in the event that you have previously given us your consent to process the Data, by ticking the acceptance box provided for this purpose.
- Article 1 – Data sent to the Site
- Article 2 – Data collected by the Site
- Article 3 – Legal basis and purposes for the Data processing
- Article 4 – Recipient of the Data
- Article 5 – Security of the Data
- Article 6 – Retention of the Data
- Article 7 – Third-party sites
- Article 8 – Rights of access, modification and erasure of the Data
- Article 9 – Confidentiality with regard to children
- Article 11 – Additional questions
Article 1 – Data sent to the site
None of the personal information that you voluntarily put online (in your profile or in messages) is accessible to the public and it cannot be collected and used by third parties.
Article 2 – Data collected by the site
The Data collected and subsequently processed by our Site are those that you voluntarily transmit to us when you open your User account (the “Account”), via the Registration Form, and concern at least (i) a valid e-mail address and/or an identifier chosen by you (for example your first and last name), and (ii) a password also chosen by you to access your Account.
Certain advanced features of the Site may also, for authentication purposes, require you to provide additional Data, such as your first and last names, your postal address and your telephone number, particularly in connection with purchasing Products on the Site. For example, this information is required in the sub-headings “account details” and “addresses” of your User Account (see our General Sales Conditions).
Your consent to the processing of your Data transmitted in connection with Using the Site will result from the validation of the creation of your User Account by means of the registration procedure, as well the validation of any Product order you may make on the Site, by checking the box provided for this purpose (see our General Sales Conditions).
The Data automatically collected by the Site are your IP address (the internet address for your computer) which are associated with the version of your browsing software, the address of the page displayed and the date of your request.
Furthermore, browsing the Site may result in the automatic installation of cookies on your connection terminal (computer, tablet or smartphone). Cookies are small texts sent by a website to your browser and stored on your computer. In this case, they allow our servers to identify you and thus to offer you personalised information and to connect you automatically to our services. They are used to simplify your browsing and to improve the ergonomics of the Site.
However, you may refuse the installation of cookies on your connection terminal by modifying the relevant parameters of your browser software, but such a refusal may prevent access to certain services on the Site.
These cookies, and their use, are the subject of a dedicated Policy established by the Company and which you can consult now in the “Cookies Policy” section of the Site.
Article 3 – Legal basis and purposes for the data processing
The Data identified as mandatory in the Registration Form, and also in the Product ordering process set out in the General Sales Conditions, are necessary in order to use the features of the Site. We will use this information to operate and maintain our Site, to enable you to benefit from personalised features, and to process any reports or correspondence from you.
The Data collected automatically by the Site allows us to compile statistics on the use of its web pages.
We do not use your e-mail address or any other personally identifiable information without your consent, whether this is to send you advertising or marketing messages, except as part of a specific programme or feature that you may choose to enable or disable.
In order to provide and to improve our Site and its features, but also to help us better protect you, communicate information to you and provide you with new offers that may be of interest to you, we implement various processing operations with the following legal bases: contractual performance, your consent, our legal and regulatory obligations, the Company’s legitimate interest.
The purposes associated with each of these legal bases are listed below:
A/ On the basis of the performance of the pre-contractual terms adopted at your request and/or the performance of the contract you have signed, we implement processing for the following purposes:
- the management of your orders on the Site, including in particular the confirmation and validation of your order as well as its follow-up (with, in particular, the sending of an order confirmation e-mail, including the details of the order and the contact data);
- the management of our relationship with you, as a User of the Site, including in particular:
- creating your personal account on the Site (including sending you a welcome e-mail);
- password reset (including sending a password reset e-mail);
- the use of the Site and the features offered (in this context, the Company may in particular send e-mails to the User to inform him/her of changes to the Site or send to him/her the newsletters to which he/she has subscribed);
- the management of communications and the follow-up of exchanges with Users
B/ On the basis of your consent, we implement processing for the following purposes:
- the sending of communications by electronic means relating to promotions and offers, whether or not they are personalised, (in this context, the Company may thus send the User e-mails to inform him/her of the existence of various products and/or services that it offers directly or through one of its partners, in parallel with the Site, and which may be of interest to the User);
- the management of cookies subject to consent;
- the management of your participation in our events, games and competitions.
C/ On the basis of compliance with our legal and regulatory obligations, we implement processing for the following purposes:
- compliance with the regulations applicable to our activity;
- the management of the general accounting;
- retaining invoices and other mandatory documents relating to transactions, in accordance with our obligations;
- the management of responses to official requests from public or judicial authorities authorised for this purpose;
- the management of requests to exercise rights.
D/ On the basis of our legitimate interests, we implement processing for the following purposes
- the management of your requests for information and complaints (in this context, the Company may thus respond by e-mail to the User who requests assistance in connecting to the Site, modifying or accessing his/her Account or for any comment or suggestion submitted to the Company through the “Contact Us” section available on the Site);
- preventing and combating fraud, in particular credit card fraud, including the management of the consequences of such fraud (in this context, the Company may send the User e-mails to verify his/her identity and request, if necessary, a copy of any official document that may attest to this);
- the establishment of any means of proof necessary for the defence of the Company’s rights;
- the production of statistics and analyses in order to improve the use of the Site and/or the Services offered;
- the management of cookies not subject to consent;
- the retention of computer traces in order to preventively detect security incident
The purposes pursued on the basis of our legitimate interests are always in accordance with your rights and freedoms.
If we need to process your data for purposes other than those listed in the paragraph above, we will inform you in advance and take any additional steps that may be necessary.
- None of the processing operations listed above are intended to result in any automated decision-making, including profiling, concerning you.
- At certain times, we may ask for your consent to use your Data for certain specific purposes (a new purpose, or a modification or elimination of an existing purpose). You are of course free to decide whether or not to accept this request.
- You may decide at any time to withdraw your consent to all or part of the processing listed above by changing some of the settings available in your Account profile page or by sending your request to the Company (in the context of exercising your rights as provided in Article VIII below). However, you should bear in mind that some parts of the Site and some Services will then be unavailable.
Article 4 – Recipient of the data
The Company is committed to protecting your privacy and the confidentiality of your Data.
Consequently, we undertake never to share or disclose your Data to third parties, except in the following limited situations:
- When we are obliged to do so by a court authority, police authorities and in general by any administrative authority authorised by law.
- When you have given us your prior consent to share all or part of this information (in particular in the context of your access to our telephone technical IT assistance services, provided by our Partners).
Article 5 — Security of the data
Mindful of the trust that the User demonstrates when he/she connects to our Site, we attach great importance to the security and protection of his/her Data and we have put in place all the technical and organisational measures necessary (i) to limit the risks of loss, deterioration or misuse (ii) and to prevent any breach of the Data.
Thus, in order to guarantee optimal security, the Company uses standard 256-bit SSL (Secure Socket Layer) technology. The use of the SSL protocol, one of the most effective and widely used encryption methods currently in use, ensures maximum protection for your Data.
In addition, in connection with this security policy, we inform you that:
- Your User account is protected by a personal password stored in an encrypted manner in our database.
- A system of secure cookies is available to you to make any attempt to steal your cookies ineffective.
- Your e-mail address is only accessible to the Site administrator, and to our webmasters, if you have agreed to be contacted by e-mail by the Company.
- In accordance with the provisions of the GDPR, we will notify the supervisory authority (the CNIL) of any possible breach of personal data that we may suffer despite our security measures and we will communicate to you, when appropriate, any possible breach concerning your Data in particular, if this breach entails a high risk for your rights and freedoms.
Article 6 – Retention of the data
Beyond this period, they will be anonymised and kept for statistical purposes and will not be used in any way whatsoever.
Article 7 – Third-party sites
By means of links on the Site, you may access third-party sites (whether or not they are partners of the Company) that are not governed by these data protection provisions. Therefore, you should review the rules applicable to the use and disclosure of information that you provide on such sites.
Article 8 – Rights of access, modification and erasure of the data
The Company complies with the regulations applicable to the processing of personal data and in particular with Law No. 78-17 of 6 January 1978 relating to information technology, computer files and freedoms, as amended since then (hereinafter referred to as the “French Data Protection Act”), as well as with the European General Data Protection Regulation No. 2016/679 of 27 April 2016 (hereinafter referred to as the “GDPR”).
Thus, in accordance with the French Data Protection Act and the GDPR, you have at all times:
- A right of access: you can, by proving your identity, obtain communication of the data concerning you and check their accuracy.
- A right of rectification: in the event of inaccuracy of this information, you can demand that it be rectified, completed, updated, locked or erased.
- A right of erasure (the “right to be forgotten”): you may obtain the erasure of data concerning you as soon as possible.
- A right to the limitation of processing: you can, in certain cases provided for by the regulations, obtain the limitation of the processing of data concerning you.
- A right to data portability: you may, under the conditions set by the regulations, demand the transmission of data concerning you to another data controller, without the Company that initially collected it being able to object.
- A right of opposition: you have the possibility to object to your data being processed or to refuse the communication of information concerning you to third parties.
You can exercise these rights either by postal letter addressed to the Company at the following address:
DEL ALMA SARL
« Forsurevintage.com »
16, rue Milton – 75009 Paris
Or by e-mail at the following address: email@example.com
For any additional information you may wish to obtain concerning these protective provisions, or for any possible complaint to a supervisory authority, you may contact the Commission Nationale de l’Informatique et des Libertés (the French National Data Protection Agency, the CNIL), at the following address
3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07
Téléphone: + 33 (0)1 53 73 22 22
Web site: https://www.cnil.fr
Contact link: https://www.cnil.fr/fr/contacter-la-cnil-standard-et-permanences-telephoniques
In addition, we inform you that (i) you may choose not to transmit your Data to the Site. In this case, you will be able to browse freely on the Site, but certain parts of the Site and certain functionalities will then be unavailable (for example, placing an order for Products). And (ii) you can, at any time, update or correct your personal information on the profile page of your Account (by means of your “Dashboard” in particular).
Article 9 – Confidentiality with regard to children
The Site and the Services are only available to users who are 18 years of age or older. We therefore do not authorize users under the age of 18, nor do we knowingly collect the personal data of any person under the age of 18, who is subject to specific protection under the GDPR.
Article 11 — Additional questions