Personal Data Management Policy

Laboratoires Vitalaë intends to make the control of your data and the respect of your privacy a fundamental priority as part of our cooperative values of trust and transparency.

Therefore, Laboratoires Vitalaë, intends to rigorously respect the General Data Protection Regulation (GDPR) which came into force on May 25, 2018, as well as the Data Protection Act of January 6, 1978, amended accordingly.

The GDPR is the European framework concerning the processing and circulation of personal data, the information on which companies rely on to offer services and products. This text covers all persons residing in the European Union.

This regulation is based on two main objectives: on the one hand, to reinforce the rights of people whose data is processed, and on the other, to reinforce the obligations of the structures that process such data.

On this occasion, we inform you of the rigorous steps taken by Laboratoires Vitalaë to comply with this regulation.

This Privacy Policy is intended to help you better understand our privacy practices, including what Personal Information we collect, why we collect it, what we do with it and how we protect it, as well as your individual rights.

1. Purpose of this Policy

This Personal Data Management Policy describes the conditions under which we undertake to comply with all French and European regulations and legislation concerning the protection of such data.

This document may be modified at any time in order to comply with any regulatory, legal, editorial or technical developments. The user must refer to the latest version of the declaration before any navigation on the site. The user’s Personal Data will always be treated in accordance with the policy in force at the time of collection, unless a legal and imperative requirement stipulates otherwise.

The Personal Data Management Policy is an integral part of our General Conditions of Use. By using the service or submitting personal information to us, the user acknowledges that he or she has read, understands, and agrees to be bound by this Privacy Policy.

We undertake to comply with Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such data (GDPR), the French Data Protection Act (Lois Informatique et Libertés) No. 78-17 of 6 January 1978 as amended, as well as the French Act on Confidence in the Digital Economy (Loi pour la Confiance dans économie Numérique) No. 2004-575 of 21 June 2004 (Article L. 33-4-1 of the French Post and Telecommunications Code and Article L. 121-20-5 of the French Consumer Code).

2. What is personal data?

Any information that allows a natural person to be identified directly or indirectly: name, postal or e-mail address, telephone number, loyalty account number, IP address are examples of personal data.

3. Who is responsible for processing it?

Laboratoires Vitalaë collects and processes Personal Data on its own behalf and as processing controller, in accordance with the provisions of Regulation (EU) 2016/679.

4. Who has access to your Personal Data?

The Personal Data collected is intended for Laboratoires Vitalaë, responsible for processing it as a controller and for outside service providers such as for example, a communication agency, which would receive and process data as a controller in the context of its own temporary mission.

Only those persons involved in the processing of data for a specific purpose (a goal), of which you are informed on a case-by-case basis, will have access to your data and solely for that purpose.

Personal Data may be processed by subcontractors (service providers), in full compliance with the above principle, exclusively to achieve the purposes covered by this policy.

The User’s Personal Information is intended for the use of the service. User Personal Information will not be shared with commercial or advertising entities.
We share Personal Information to complete a transaction or provide a requested product or service. We may also disclose and transfer Personal Information to partners, suppliers and other third parties for the purposes described in this Privacy Policy and to assist in the operation of the Services and/or related transactions.

In addition, we may exchange data between the different subsidiaries of SILL ENTREPRISES, of which Laboratoires Vitalaë is a part, in accordance with the legitimate interest that leads us to optimize the distribution of the different tasks within the group. SILL ENTREPRISES will not use your personal data for purposes other than those indicated in this policy without informing you and obtaining your consent. In any case, you have the right to object to such an exchange by justifying particular circumstances.

If we sell or divide all or part of our business, transfer assets, or otherwise participate in a change of control transaction, or in the unlikely event of bankruptcy, we may transfer Personal Data covered by this policy to one or more third parties as part of the transaction.

In addition, we will access, transfer, disclose and retain Personal Data when we believe in good faith that it is necessary to:

– Comply with applicable law or comply with a valid legal process, including from judicial or other governmental authorities.
– Protect our users, for example to prevent unsolicited email or fraud attempts.
– To operate and maintain the security of our products and services, including to prevent or stop an attack on computer systems or our networks; or
– To protect our rights or property, including the enforcement of terms governing the use of products or services.

Within these limits, all information collected is kept confidential and as far as necessary anonymous. Only information that is exclusively necessary is passed on to the relevant party.

As the case may be, we process your Personal Data, either directly obtained from you or resulting from the use of products or services. We may also be the recipient of data that has been collected from you by a third party.

In the event of a proven violation of legal or regulatory provisions, this Personal Data may be communicated to the judicial authorities upon justified request.
Within the limits of their respective attributions and for the purposes mentioned above, the people most likely to have access to the data of our Customers are mainly the personnel of our customer service (Sales and marketing, Sales administration, technical).

We also use the services provided by several specialized companies (mailing, audience analysis), a list of which can be communicated to the parties concerned on request at the contact below.

5. How is your Personal Information collected?

We handle the personal data that you may communicate to us, in particular during the following operations:

– When you subscribe to one of our Services;
– When you use our Services;
– When you browse our Service;
– When you provide us with Content or Services;
– When you participate in events or public relations activities organized by us;
– When you consent to receive newsletters and other marketing information from us;
– When you contact us with questions or complaints.

We collect data to provide products and services to customers and to conduct our business.

Some of this data is provided directly, for example when the user creates an account on our Service, or contacts us for advice or to perform other services.
We also receive data by recording how users interact with our products and services (websites, cookies, etc.).

The data collected depends on the products, services and features used and may include the following:

– Name and contact information. Marital status, identity, identification data, contact information (address, telephone, e-mail, fax, etc.) and other contact information.
– Verification of authorizations. We collect information used for authentication and account access for example.
– Payment data. We collect data necessary to process payments for purchases made, such as bank account information, bank transfers and/or any other financial information associated with a possible payment.
– Usage Data. We collect data about how users interact with the products and services we offer. For example, we collect service usage data, Web Service activity data, performance data, product/service preference information, transaction history, and the Web pages the user visits.
– Cookies. The Service may collect certain types of data that may include personal information during visits, including by using cookies, the operation of which is detailed in the “Policy for the Management of Personal Data Collected via Cookies”.

6. Consequences of a failure to respond

In certain circumstances, the collection of Personal Data identified by an asterisk is mandatory.

It is compulsory to transmit real and exact information and it is necessary to contact us for any possible update of the latter.

Failure to do so may result in the request not being processed or being delayed.

7. Use of Personal Data

We only process data or a category of data if it is strictly necessary for the purpose for which it was collected. You can find information on these purposes below.

We use, disclose, transfer and process data, including personal information, in several ways:

– To process contact information for the services we provide:
o for information requests;
o for complaints about the products we manufacture;
– To operate our business and provide and support related products and services (including enhancement and personalization); and
– To send certain communications, including promotional communications.

Where applicable, when users register, we use the personal information provided, including payment information where necessary to provide the products or services requested in a transaction. We store the personal information required to manage the profile and communicate with the user.

Personal Information may also, subject to the requirements of applicable law, be used, disclosed, and transferred to law enforcement authorities and others in situations where we believe it is necessary to identify, contact or bring legal action against anyone suspected of misusing the Service, interfering with our rights or those of other users, or where we reasonably believe that the law requires or permits such disclosure.

8. Purposes and legal bases of processing

We process Personal Data only for specified, explicit and legitimate purposes. We undertake not to process any data in a manner incompatible with these purposes.

Your Personal Data is collected in the context of the performance of a contract, in particular, for the purpose of:

– Enabling you to access our services and order our products where applicable.

In this context, the legal basis of the processing is the execution of the contract binding us with you.

– Managing your subscription and your use of our services.

In this context, the legal basis for the processing is the performance of the contract binding us with you.

– Managing the contractual relationship with our customers, service providers and partners (contract management, orders, deliveries, invoices, public relations, etc.).

In this context, the legal basis for the processing is the performance of the contract between us and you.

The data collected in this way will not be processed or transmitted for other purposes.

Your data will be kept for the time necessary to achieve the purposes mentioned above. In the case of processing relating to the performance of the contract, the data may be kept for a maximum of 3 (THREE) years from the end of the relationship.

We also process data for purposes other than the strict performance of contracts. In this case, we ensure that we have a legitimate interest in carrying out the data processing. Moreover, the processing may be subject, as far as necessary to the obtention of your consent, which you may withdraw at any time.

– Sending you promotional information about us.

In this context, the processing is based on our legitimate interest, more specifically our economic interest in communicating personalized offers to you, to better understand your needs and to offer you adapted services, in particular by means of computer tools allowing us to analyze your centers of interest according to your purchases, according to criteria of recency/frequency/amount.

– Analyzing your navigation on our Services and improve their use (please see the section above on cookies).

In this context, the legal basis for the processing is our legitimate interest, more specifically our economic interest in continuously improving our Services and to understand your needs to meet your expectations.

– Responding to your questions and complaints.

In this context, the legal basis for the processing is either the performance of the contract if the request is related to the contractual relationship between us and you, or our legitimate interest, more specifically our economic interest to communicate clearly with you and to understand your needs and expectations.

– Processing your transactions and payments.

In this context, the legal basis for processing is either the execution of the contract binding us to you when it comes to managing your transactions and payments, or the respect of legal obligations if we put in place means to fight against fraud.

Your data is kept for the time necessary to fulfill the purposes mentioned above.

We also process your data to meet our legal or regulatory obligations:

To this end, the purposes are as follows:

– To keep the data required to be able to meet legal obligations
– To manage data communication requests from authorized authorities

Your data may be kept for the time necessary to enable us to meet our legal obligations.

We may also process your data for statistical purposes, including marketing the statistics obtained. In this case, all data is first anonymized.

9. Personal Data on Social Networks

You may have the possibility to click on the icons dedicated to social networks (Twitter, Facebook, LinkedIn and Google Plus …) on our Service.

Social networks allow to improve the usability of the Service and help to promote it through sharing. Video sharing services allow to enrich the Service with video content and increase its visibility.

When the User clicks on these buttons, we may have access to personal information that the User has indicated as public and accessible from their social network profiles. However, we do not create or use any database independent of these social networks from the personal information that the User may post on them, and we will not process any of his/her personal data in this way.

If you do not want your personal information to be transmitted from the Service to social networks, we advise you in this case:

– Not to interact with these social networks by clicking on the plug-ins made available to you on the Service.
– To deactivate your account on the social network in question before browsing our Service.
– To browse in “Private” mode via your browser.

10. Personal Data Security

In accordance with applicable regulations, we maintain technical and administrative procedures that comply with applicable regulations and that is state of the art to protect Personal Data against accidental or unlawful destruction, accidental loss, modification, or unauthorized disclosure.

11. Links to Other Websites

The elements set out in this Personal Data Management Policy apply to all the services and activities of LABORATOIRES VITALAË. Other Services hosted by third parties may have different practices. If a user creates a link to or visits other sites managed by third parties, he or she should consult the confidentiality rules published on these Services. We have no control over these Services and are not responsible for the policies and practices followed by third parties.

12. Storing Personal Data

Personal Data is only kept for a period that is necessary and proportionate to the purpose for which it was collected. We may, however, retain your Personal Data for a longer period to comply with legal obligations and in particular with applicable statute of limitation periods.

We undertake to delete the data from our databases at the end of a predetermined period, or in accordance with the regulations and guidelines laid down by the CNIL (The French National Commission for Information Technologies and Civil Liberties).

In order to define an adequate data retention period, we use the following criteria in particular:

– Data relating to your subscription, your possible payments and the use of our services are kept for the entire duration of the subscription/contractual relationship and then in compliance with the applicable statute of limitation periods.
– Data relating to the management of the business relationship with our service providers and partners are kept for the duration of the contractual relationship and then in accordance with the applicable statute of limitation periods.
– When you have consented to receive marketing material, we keep your personal data until you express your wish not to receive any further communications, otherwise in accordance with a period defined by the applicable legislation.
– When your data is collected in the context of requests/questions relating to IT services and applications, we keep this data for the time necessary to process these requests.

Personal data concerning you may be kept:

– 1 year for connection logs from the last connection;
– 13 months for the cookies from their posting on your computer or terminal;
– 13 months for bank details, if you have made a payment;
– 3 years for user identification data (last name, first name, e-mail address, etc.) from the last time it was used;
– 6 years for tax documents;
– 10 years for accounting documents;
– If necessary, for the entire duration of any litigation and until all avenues of appeal have been exhausted.

At the end of the retention period, the Personal Data is deleted or made anonymous. Data required to meet a legal or regulatory obligation may be archived for the time required to fulfill the obligation in question.
Archived data must be deleted when the reason for archiving is no longer relevant.

13. Transfer of Personal Data

To provide its services, Laboratoires Vitalaë uses various partners and service providers, carefully selected to perform tasks that may involve the transfer of data outside the EEA, in situations where this is essential given the organization of information technology and communication around the world.

In such cases, we make the necessary arrangements with our subcontractors and partners to ensure an adequate level of protection for your data in accordance with the applicable regulations. When data is transferred in this way, we ensure that it is protected according to European Union standards, using a transfer mechanism approved under the GDPR by the supervisory authorities.

We conduct due diligence on suppliers. We seek a mechanism such as an adequacy finding from the European Commission or binding corporate rules. Where necessary, we make use of the European Union’s standard contractual clauses to govern the transfer.

14. What rights can I exercise over my personal data?

In accordance with applicable personal data protection legislation, you have a number of rights regarding the collection and processing of your personal data, namely:

– The right to be informed: You have the right to be informed in a concise, transparent, understandable, and easily accessible manner of how your personal data is processed.
– The right of access: You have the right to obtain (i) confirmation as to whether or not your personal data are being processed and, if so, to obtain (ii) access to and a copy of such data.
– The right of rectification: You have the right to obtain a rectification of personal data concerning you that are inaccurate. You also have the right to have incomplete personal data completed, including by providing an additional declaration.
– The right to erasure: In certain cases, you have the right to have your personal data erased. This right is not, however, an absolute right and we may have legal or legitimate reasons to retain such data.
– The right to restrict processing: In certain cases, you have the right to obtain a limitation of the processing of your personal data.
– The right to portability: You have the right to receive the personal data about you that you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transfer that data to another data controller without our interference. This right only applies where the processing of your personal data is based on your consent or on the performance of a contract and where such processing is carried out using automated processes.
– The right to restriction: You have the right, on grounds relating to your particular situation, to object to the processing of your personal data where such processing is based on our legitimate interests. We may, however, invoke compelling legitimate grounds for further processing. When your personal data is processed for the purpose of canvassing, you have the right to object to the processing of such data at any time. You can take advantage of this right by clicking on the “unsubscribe” link available at the bottom of the messages you receive.
– In case of dispute about the conditions relating to the collection and processing of your Personal Data, you also have the right to lodge a complaint with a supervisory authority: You have the right to contact a supervisory authority (such as the CNIL) in order to lodge a complaint about our practices relating to the protection of personal data.
– The right to give instructions concerning the use of data after death: you have the right to give us instructions concerning the use of your personal data after your death.

These rights can be exercised by sending a request to the following address: contact@laboratoires-vitalae.com or by post to LABORATOIRES VITALAË, Données Personnelles – Rue Gustave Eiffel, 29400 Landivisiau.
You must prove your identity and indicate the context in which you have transmitted your Personal Data to us (date of the complaint and/or reason).

In case of dispute about the conditions relating to the collection and processing of your Personal Data, you also have the right to lodge a complaint with the CNIL (www.cnil.fr).

If, while using the Service, you access Personal Data, you must refrain from any collection, any unauthorized use and any act that may constitute an infringement of the privacy or reputation of individuals. We do not accept any responsibility in this regard.

Personal Data management policy collected via cookies

1. Cookies

The Service may collect certain types of data that may include personal information when you visit, including using cookies. Cookies are small text files sent from a Service to the hard drive of a user’s device to store information about that user or device. Cookies may store device and user information, including IP addresses, navigational data, server information, data transfer times, user preferences and passwords needed to access special areas of the Services. We may use cookies to facilitate the downloading of materials from the Services and for other business purposes such as analyzing traffic to the Services.

A cookie does not identify you personally. It allows its issuer to recognize your terminal and to collect a certain amount of information relating to the navigation made from this terminal.

A cookie has a limited validity period. It is deposited and stored on your terminal in compliance with applicable legislation and subject to the choices you have made and which you may modify at any time, under the conditions specified in Article 9 below.

If the user chooses to create a user profile, we will use cookies to store the personal information of his profile. The user’s browser can be set to block, reject, delete, or disable cookies and other tracking technologies. However, if the user rejects or deletes cookies or other tracking technologies, he or she may not be able to access certain pages or use important features, including downloading documents and creating a user profile.

Cookies serve a number of purposes, such as allowing you to navigate a Service or mobile application efficiently, remembering your choices, the goods and services you wish to purchase, and serving you relevant advertising content based on your browsing interests. You can find more information about cookies on the following Services:
www.cnil.fr
www.allaboutcookies.org
www.aboutcookies.org
www.youronlinechoices.eu
The cookies stored under your choices give us access to the following information in particular:

– Identification of the equipment you use (IP address of your computer, Android ID, Apple ID, etc.),
– Type of operating system used by your terminal (Microsoft Windows, Apple Os, Linux, Unix, BeOS, Android, iOS, etc.),
– Type and version of browser software used by your terminal (Microsoft Internet Explorer, Apple Safari, Mozilla Firefox, Google Chrome, etc.),
– Dates and times of connection to our services,
– Address of the Internet page from which you came (“referrer”),
– Browsing data on our services, content viewed.

2. Other Technologies

The Service also uses IP addresses, log files and other technologies to identify problems and usage of the Service. We also use web beacons to perform standard traffic analysis on the Service in the same way we use cookies and to track usage of the Service for statistical purposes. We may also use standard Internet technologies, such as scripts, pixels, and redirects. Scripts (sometimes called tags), written in javascript, are programs that run in your browser or mobile application and perform various actions, such as sending information to our servers. Scripts are also capable of creating pixels. Pixels (sometimes called transparent GIFs, clear GIFs, or web bugs) are lines of code that display a graphic image (usually invisible) on a web page or in an email. Redirects make a web page available under multiple page addresses (URLs). When a browser opens a redirect URL, a page with a different URL is opened.

We reserve the right to introduce new tracking technologies and techniques related to the use of the Services, although we do so in compliance with applicable data protection laws and regulations.

The purpose of these technologies is to enhance your experience on the Service, including to provide you with content customized to your interests. For example, when a user clicks a share button on an article, a script creates a pixel that tracks the share. This allows us to track the number of shares, and we can rank the shares.

These technologies give us access to the following information, among others:

– Information about your use of our Service;
– Information about the presence of cookies on your device, the time and date you view a page, and a description of the page where the web beacon is placed;
– Information about whether or not you read the emails we send you, and whether or not you click on the links in those emails.
Our Service may also include third-party scripts, pixels, and redirects. These technologies allow third party service providers to collect certain information such as your browser type, and the web page that redirected you to our Website. These third-party service providers process the information they collect for auditing purposes, research, and to report information about our Services and applications and the advertisements viewed on them. We do not share your identifying information with these third parties in connection with their use of these technologies.

You may choose to have a cookie placed on your browser. You can change your choices at any time regarding the acceptance or refusal of cookies placed on your terminal, either on your browser or online with various operators.

In order to manage cookies in accordance with your wishes, we invite you to configure your browser taking into account the purpose of the cookies.

3. How to make your choices?

– Cookie exempted from consent

Some cookies are exempt from consent insofar as their purpose is strictly limited to measuring the audience of the site or application (performance measurement, detection of navigation problems, optimization of technical performance or ergonomics, estimation of the power of the servers required, analysis of the content consulted), for the exclusive account of the publisher.

– Making your choices from the cookie setting tool

The Service provides you with a simple tool that allows you to configure the use of cookies according to their category: “social network” cookies, audience measurement cookies, advertising cookies, etc.

The choices you make using this tool will be valid only in the context of your navigation on the Service.

You may also express your choices regarding cookies on your computer’s browser software or on the Online Services. In both cases, your choices will apply to your entire web browsing experience, not just the Service.

– Making your choices on your browser

You can set your browser to either accept or reject cookies from time to time, before a cookie is stored, or to accept or reject the storage of cookies on your computer.

We warn you that any setting on your browser software concerning the refusal of technical and functional cookies may alter your browsing comfort on our Services, or even prevent the use of some of our Services requiring the use of these same cookies.

If necessary, we decline all responsibility for the consequences related to the degraded functionality of our services resulting from the impossibility for us to record or consult the cookies necessary for their proper functioning and which you would have refused or deleted.

For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to modify your wishes regarding cookies.
• Microsoft Internet Explorer
http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
• Microsoft Edge
https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy
• Apple Safari
http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
• Google Chrome
http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• Mozilla Firefox
https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
• Opera
http://help.opera.com/Windows/10.20/fr/cookies.html
• Cookies Flash de Adobe Flash Player
Adobe Flash Player is a computer application that allows the rapid development of dynamic content using the Flash computer language. Flash (and applications of the same type) memorizes the settings, preferences, and use of this content through a technology like cookies. However, Adobe Flash Player manages this information and your choices through a different interface than that provided by your browser.

Insofar as your terminal is likely to view content developed with the Flash language, we invite you to access your Flash cookie management tools directly from the Service http://www.adobe.com/fr
• “Do not track”
You can also set your browser to send a code to indicate to the Web Services that you do not wish to be tracked (“Do not track” option).
• Microsoft Internet Explorer
http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11
• Microsoft Edge
https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy
• Apple Safari
http://support.apple.com/kb/PH11952
• Google Chrome
https://support.google.com/chrome/answer/114836
• Mozilla Firefox
https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister
• Opera
http://help.opera.com/Windows/12.10/fr/notrack.html
– Make your choice online
For audience measurement cookies and analytical cookies
Analytical cookies allow us to obtain anonymous statistics on the number of visitors to our Service in order to optimize it and to detect any malfunctions. They are stored on our Services and applications by the companies Google Analytics…
If you do not want our Services and applications to store cookies in your browser for audience measurement purposes, you can click on the following links where you will find additional information:
– Google Analytics cookies https://tools.google.com/dlpage/gaoptout
For “Social Network” cookies, we use several sharing buttons on our Service:
– To manage your data on Facebook
https://www.facebook.com/help/cookies/
Deactivating these cookies therefore prevents any interaction with social networks.
You also have the possibility to connect to the Service http://youronlinechoices.com, proposed by digital advertising professionals grouped together within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France.
This European platform is shared by hundreds of Internet advertising professionals and constitutes a centralized interface allowing you to express your refusal or acceptance of the cookies used by these companies to adapt the advertisements likely to be displayed on your terminal to your navigation information:
http://www.youronlinechoices.com/fr/controler-ses-cookies/
Finally, some cookies are placed by third-party service providers for the purpose of personalized advertising.