The present charter for the protection of personal data and management of cookies details the policy of WAGRAM FINANCES, a public limited company with a capital of 2,662,900 euros whose registered office is 103 rue La Fayette 75010 Paris registered in the Paris Trade and Companies Register under the number 339 592 685 and its subsidiaries, with regard to the protection of privacy, the collection of personal data and cookies.
It applies to data collected on the COLUMBUS CAFE Website (hereinafter referred to as “the Website” or “the Site”).
The purpose of this charter is to inform you:
- on the means that we implement to collect your personal data, in the strictest respect of your rights,
- on the data that may be collected on our Site,
- on the use that may be made of the data collected and the rights you have over this data.
WAGRAM FINANCES specifies by the present charter and/or each time you are asked for personal data, the purposes of the processing as well as the means of any operation (collection, recording, modification…).
WAGRAM FINANCES undertakes to :
- ensure the respect of the principles on the protection of personal data,
- inform individuals about the existence of their rights of access, rectification and opposition,
- proceed with the completion of legal and/or regulatory formalities.
We inform you that we comply, in the collection and management of your personal data, with the law n° 78-17 of January 6, 1978 relating to data processing, files and freedoms, as amended and in its current version, as well as with the general regulations on data protection, adopted on April 27, 2016 by the European Parliament, and with the laws and regulations arising therefrom.
I. DATA PROTECTION
1) Definition and nature of personal data
During and through your use of our Website, we may collect personal data, which is communicated to us when :
- you fill in an information form to apply for a job with us at our head office or as a franchisee of the network in the “Join us” section;
- you create a customer account and order coffee in our eshop ;
- you give us your ideas in the “suggestion box”;
- you contact customer service.
By “personal data”, we mean all data that enable us to identify you directly or indirectly (by gathering information) such as surnames, first names, pseudonym, date of birth, photograph, postal and e-mail addresses, telephone numbers, profession, training courses, diplomas, career path and professional experience, data relating to your transactions on the site, details of your purchases and subscriptions, bank details…
2) Rights of access, rectification, deletion, portability and opposition to processing
In accordance with the French law n°78-17 of January 6, 1978 “informatique et libertés” and the provisions of the General Data Protection Regulations, adopted on April 27, 2016 by the European Parliament, you have the right to access, rectify, delete, portability and oppose the processing of personal information concerning you. You also have the possibility to object to the processing for canvassing purposes, in particular for commercial purposes.
You can exercise your right of access to data concerning you and have it corrected in two ways. Either in :
- sending us an email on email@example.com ;
- writing to us by post to WAGRAM FINANCES, COLUMBUS CAFE, legal department, 103 rue La Fayette, 75010 PARIS.
In both cases, remember to sign your request and to send us with the mail a proof of identity (national identity card or passport) bearing your signature.
3) Management of personal data by WAGRAM FINANCES
3.1 Means of data collection
When you browse the COLUMBUS CAFE website and in order to be able to offer you the services offered on it, we may collect personal data about you. Before each collection of personal data, we collect your consent by means of a form to be completed and a box to be ticked after having read this Data Protection Charter.
3.2 Purpose of data collection
Your personal data is collected for one or more of the following purposes:
- To create customer accounts in order to allow the taking into account of your orders (online), to manage and process your orders, to communicate with you on this management, to reimburse you if necessary, to establish invoices, to manage and process deliveries ;
- To ensure the follow-up of the customer relationship in particular in the management of your complaints and your requests;
- For applications submitted online, in order to study your request and to be able to contact you if an opportunity arises in our network or if a position becomes available or is created in our company;
- To process your suggestions in the suggestion box and to respond to you if necessary;
- On the basis of your consent, to send you newsletters, newsletters and promotional offers to keep you informed of new products;
- To manage your subscriptions and unsubscriptions to newsletters and satisfaction surveys;
- To make you win gifts via competitions;
- Develop reports, commercial statistics, market and behavioural studies, with the aim of improving our products and meeting your expectations by offering you products adapted to your needs;
- Manage your requests for access, rectification and opposition of your data;
- To keep your data in legal documents in accordance with accounting standards, for the legal duration necessary, in order to respond to requests from tax authorities and social organisations if necessary.
We undertake to collect your data by limiting ourselves to the data strictly necessary for the purpose of the envisaged processing, in order to be able to process your requests and offer you the services proposed on our website.
3.3 Data Retention
The personal data that we are led to collect are kept for a period that does not exceed the duration necessary for the purposes for which they were collected and for a maximum of 3 years from the date of collection of the data.
At the end, as soon as the data collected is no longer necessary for the purpose for which it was collected:
- we undertake to contact you again in order to find out whether or not you wish to continue to receive commercial solicitations ;
- if not, the data will be archived and anonymised or destroyed.
At any time, you may object to the processing of your personal information as you have the right to access, rectify, delete and object as described above.
3.4 Recipient of the data
The personal data collected about you is intended for WAGRAM FINANCES and its subsidiaries.
In order to be able to carry out the processing operations listed above, we are led to share your data, by giving access to authorized and duly empowered personnel, namely :
- our IT service providers;
- our marketing service providers;
- our internal departments, namely the legal, financial, development, purchasing and marketing departments.
In particular, this data may be communicated to our service providers or internal services for credit card processing, website hosting, email and mail delivery, tracking, product and service delivery, analytical services, or the conduct of academic research. Other service providers assist us, with your consent, where required by applicable law, in evaluating, developing and providing you with promotions and special offers that may be of interest to you, administering contests, sweepstakes and events or for other promotional purposes.
The data we collect from you is not intended to be transferred outside the European Union. However, should this be the case, we guarantee that, in the event of transfer of your data abroad and particularly outside the European Union, we will implement all appropriate measures to guarantee a sufficient level of protection for your data, such as :
- Moving to so-called “safe” countries, i.e. countries offering a high level of protection for your data;
- Requesting the necessary authorisations from the Control Authority before any data collection, if required by the Authority depending on the country;
- Obtain guarantees of security and confidentiality from subcontractors, for example by imposing strict contractual clauses, reserving the right to check them regularly and conducting audits.
4) Security and confidentiality of personal data collected
The security and confidentiality of the personal data you entrust to us is a priority for us.
Indeed, we make sure that we take all the technical and organisational measures that are useful with regard to the nature of the personal data that you communicate to us and the risks presented by their processing.
This is in order to preserve the security of your personal data and, in particular, to prevent it from being distorted, destroyed, damaged or accessed by unauthorised third parties.
The security and confidentiality of personal data are also based on good practices. Thus, we invite you not to communicate your login and password to third parties, to systematically disconnect from your profile and customer account (especially in the case of linked accounts), to close your browser window at the end of your session, especially if you access the Internet from a computer shared with others, and not to save your login and password in your browser. This will prevent other users from accessing your personal information.
II. DATA MANAGEMENT POLICY
The term “cookies” includes all the tracers deposited during the consultation of a website, the reading of an e-mail, the use of a software or a mobile application in particular. It is a text file that the site you visit saves on your hard disk or in the memory of your browser. A cookie enables your computer to store various technical data allowing the general control of public access to our sites (number of visits, frequency of exposure to an advertising banner, connection to other sites, etc.) or the personalisation of the pages displayed for your next interactions with this site.
When you browse our Site, information relating to your browsing is likely to be recorded in “Cookies” files installed on your computer or tablet or smartphone.
Cookies are important for the proper functioning of a site. Cookies are used to keep connection information and provide a secure connection, collect statistics to optimize the site’s functionality and adapt the content to your interests.
1) Types of cookies
Several types of cookies exist and allow you to have access, as soon as you accept them, to a certain number of functionalities.
Cookies issued by WAGRAM FINANCES on its Website:
These are cookies placed by WAGRAM FINANCES on your computer, tablet or smartphone, in particular for the purposes of browsing our Website.
During your browsing on our Site, your computer dialogues with a server which provides it with all the resources requested by automatically recording each operation in a specific file in which your computer is identified by its IP address. Your browser thus automatically transmits certain standard data to us: in addition to your IP address, this data includes the type of browser you use, its functionalities, your operating system, the identification of third-party sites (Facebook, Twitter, etc.) from which you may have connected, as well as the dates and times of access to our sites.
These data and in particular your IP address do not allow us to identify you personally.
The cookies we issue allow us to do this:
- to monitor the general activity of our Site, to detect errors and to ensure that our Site benefits from the appropriate material resources;
- to establish statistics and volumes of frequentation and use of the various elements composing our Site;
- to adapt the presentation of our Site to the display preferences of your terminal (language used, operating system, etc.).
- to make it easier for you to consult our Site by not having to provide the same information each time you visit or by customising the content of our Site according to any preferences or interests you may have expressed;
- to improve the ergonomics of navigation and to identify the interests of Internet users as a whole.
Cookies issued on our Site by third parties:
Cookies for audience measurement :
We use Google Analytics to collect information about your use of our Site in order to :
- help us measure and study the effectiveness of the content on our Site,
- track analytical data on our sites and the use made of our sites by Users,
- improve the services of our sites.
Google Analytics collects information about the pages you visit and the time you spend there. We do not collect your personal information.
We do not authorize the sharing or use of this data.
You can define in the settings not to send information to the Google Analytics service.
2) Cookie lifetime
In accordance with the regulations in force, the cookies collected on our Website have a maximum lifespan of 13 months.
3) Managing cookie preferences
You have different ways to manage cookies. Your browser can also be set to notify you of cookies that are placed on your computer, tablet or smartphone and ask you whether or not to accept them.
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 change your wishes regarding cookies.
III. CONTACT US
We welcome your questions, comments and concerns about privacy. You can contact the COLUMBUS CAFE customer service department by sending us an e-mail at firstname.lastname@example.org or by writing to us by post at WAGRAM FINANCES, COLUMBUS CAFE, Legal Department, 103 rue La Fayette, 75010 PARIS.
IV. UPDATING THE CHARTER
We reserve the right to modify this Charter, at any time, in whole or in part, taking into account changes and developments in our internal practices and procedures. The latter will ensure that they always comply with any changes in French and European laws and regulations. We invite you to regularly consult this Charter, before any collection of your data, for a better knowledge and understanding of the use of your personal data. We may ask you, at regular intervals, to validate your knowledge of this Charter.
Date of update and last update of this Charter: April 1st, 2020.