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This charter (the "Charter") details the policy of Sophie Carbonari on personal data and cookies. This Charter aims to inform you of the conditions under which Sophie Carbonari collects your personal data, the reasons for which these data are collected, the use that is made and your respective rights. It applies to all information provided by you or collected by Sophie Carbonari during your interaction (s) with us. Sophie Carbonari, as data controller, attaches great importance to the protection and respect of your privacy. As it is an important subject, we invite you to read the Charter carefully in its entirety to know and understand our practices regarding the processing of your personal data. This Charter sets out the rules relating to the personal data of all our customers and prospective customers, regardless of the channel through which this data is collected. When we refer to our Platform, we mean one of the digital and/or physical channels and/or means that you may use to interact with us via the website, (the "Site"), by post or by telephone. When using our Platform, Sophie Carbonari may process personal data about you that we have collected from you or that you have provided to us. When you use our Platform, you are subject to the Charter then in force and mean that you accept the latter. As we may modify our Privacy Policy at any time in accordance with the conditions set out in Article 6, we invite you to check it before each use of our Platform.1. General informationThe persons responsible for processing your personal data are : Sophie Carbonari - Paris Thus, we have established guidelines and we are responsible for the processing and protection of your personal data. Through our Platform, you may be asked to provide personal data to Sophie Carbonari for example in creating a customer account, ordering products or registering for the newsletter. Sophie Carbonari may also collect certain information relating to your navigation on the Site, under the conditions more fully described under the heading "Cookies" below. In accordance with applicable regulations, Philippe Fournier has been appointed Data Protection Officer (DPO).2. Data concernedThe data we collect and use varies according to the products, services or functions you wish to use. The personal data that we collect or that you decide to provide to us includes in particular : identification data, such as your first name, surname, company, telephone numbers and email address, which you provide when you visit the website or decide to commit to a project by signing a contract or quotation; electronic identification data available on or from your computer (such as "cookies" or "IP addresses"). Your electronic identification data makes it possible to identify or geolocate (without being more precise than the town) your connection terminal or the pages consulted on the Site during your browsing and is generally insufficient on its own to identify you by name. For more information on the browsing information collected, please consult Article 5 on cookies and connection cookies;3. Your rightsIn accordance with the regulations in force, you have various rights concerning your personal data. These rights may be exercised directly and at any time by contacting us at, simply stating the reason for your request and the right you wish to exercise. If we have any doubts about your identity, we may ask you for a copy of your identity card or other proof of identity. You have the following rights: The right of access: The right to request a copy of the personal data we hold about you. If your request is unjustified or abusive, we may charge you a fee for this request. The right of rectification: The right to request the correction of inaccurate personal data that we hold about you. We would like to remind you that if you have a customer account, you can access the section corresponding to your personal data in order to modify or update it. You must ensure that this information is true and accurate. Similarly, you undertake to inform us of any changes or modifications to this data. We also remind you that, in principle, you should only communicate your own personal data and not that of a third party. Any damage or loss caused as a result of providing inaccurate or incomplete information in our data collection forms is the sole responsibility of the user of our Platform. The right to erasure: The right to request the deletion of your data, when one of the following conditions is met: your personal data is no longer required for the purposes for which it was collected, you have withdrawn your consent and there is no other legal basis for continuing to process your personal data, you have validly exercised your right to object, the processing of your data is not lawful, or your personal data must be deleted to comply with a legal obligation. However, there are cases where you cannot exercise your right to erasure, even if one of these conditions is met (in particular when the processing of your data is necessary for freedom of expression and information, to comply with a legal obligation, to contest/exercise/defend a legal right or for statistical, archival purposes in the public interest, or for scientific or historical research). To delete your customer account, simply send us your request to The right to object: The right to object on grounds relating to your particular situation to the processing of your personal data based on our legitimate interests. In this case we will stop processing your data, unless we have a legitimate reason to continue processing your data. If your data is used for commercial prospecting purposes, you have the right to object to this without having to justify yourself. The right to restrict processing: The right to request, in certain cases, the temporary suspension of the processing of some of your data or its retention, if you need it, for longer than necessary. The right to portability: If the processing of your personal data is based on your consent or the performance of the contract and if the processing is carried out by automated means, you will have the right to request receipt of your data in a structured, commonly used and machine-readable format, so that it can be transferred to another entity, provided that this is technically possible. The right to define directives concerning the fate of your personal data in the event of your death. You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you habitually reside, your place of work or the place where the breach is alleged to have occurred, if you consider that the processing of your personal data constitutes a breach of the applicable regulations. In France, the supervisory authority is as follows: Commission Nationale de l'Informatique et des Libertés (CNIL), 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, Tel: 01 53 73 22 22 You also have the right to withdraw your consent, at any time, for any processing that is based on consent. To simply unsubscribe from our newsletter, simply click on the unsubscribe link in each e-mail.4. Management of personal data by Sophie Carbonari4.1 Purposes and legal basis of data collectionThe following summary allows you to understand what are the uses of your personal data by Sophie Carbonari (the "purpose") and the legal basis (the "legal basis"): To carry out commercial prospecting and marketing actions: If you decide to subscribe to the newsletter, you consent to us processing your data in order to manage your subscription and/or to send you information relating to our products and/or services as well as commercial prospecting messages through various means, such as email or SMS. If you enter a competition via the Platform or our social networks, you consent to your data being used in connection with the competition and the award of the prizes you have won. Unless you give your express consent, the data collected will not be used for advertising purposes by us or our commercial partners. If you agree in advance to the legal terms and conditions applicable (in particular to the social networks you use), we may publish on our Platform or our various social networks photographs that you share publicly or with us. Provided we have your prior consent, we may record data relating to your preferences (such as your size or colorimetry) to personalise your experience with Sophie Carbonari. Legitimate interest: We have a legitimate interest in contacting you by telephone or post to inform you of our offers, provided you did not object when your data was collected (please note that you can object at any time by sending an email to Similarly, unless you object, we have a legitimate interest in sending you commercial communications by electronic means (e.g. SMS or e-mail) if you are already a customer and if these communications relate solely to products or services similar to those we have already provided to you. To respond to any questions, requests or complaints you may have via the channels available to us. If your request relates to a contact by email or telephone, the processing is necessary for the proper management of our services. Legal obligations If your question concerns the exercise of the rights set out in Article 3 "Your rights" or relates to a complaint about our products or services, we will need to process your data in order to comply with our legal obligations. To produce anonymous statistics on site traffic We consider that we have a legitimate interest in analysing the ergonomics and quality of our Platform in order to improve the experience of our users and offer a better quality Platform to our customers. Please read Article 5 "Cookies" for more information. Carrying out customer satisfaction surveys or studies We consider that we have a legitimate interest in carrying out polls and surveys designed to analyse the degree of satisfaction of our customers in order to improve the quality of our products and services.4.2 Data retention periodManagement of our customer and prospective customer files Retention for a period of 3 years from your last contact with us (for example, in the case of customers, a purchase or, in the case of prospective customers, a click on a hypertext link contained in an e-mail) or until you withdraw your consent. Your questions sent via the contact form Retention for the time necessary to process your request. Your electronic identification data (your connection logs collected, subject to your consent and the settings on your terminal, via the use of cookies and other tracers placed on our Site). Retention in accordance with applicable regulations for a period not exceeding 13 months. For more details on cookies, how they work and how you can deactivate them, see "5. Cookies and Connection Cookies" below. Secondly, regardless of the retention period required to achieve the purpose of the data processing, it may be justified for us to archive your data for a limited period of time, in a secure manner and with restricted access, for various reasons: To comply with a legal obligation to retain data (for example, personal data for accounting purposes must be retained for 10 years). To protect against any liability claims arising from the processing of your personal data. In order to manage pre-litigation and litigation, we may archive your data for evidential purposes for the period during which we may be held liable (duration of the related statute of limitations: civil, commercial, etc.). Once the retention period imposed by law has elapsed and any actions have become time-barred, your personal data will be deleted or made anonymous.4.3 Recipients of dataYour personal data are intended for the services of Sophie Carbonari concerned by your requests. However: The processing of your personal data is authorized to third parties we use to provide certain services. This includes : providers of technical services, logistics, transport and delivery, payment service providers and fraud detection and prevention entities. Only when you have given us your consent may we share your data with certain commercial partners. In any case, there is no transfer outside France and Sophie Carbonari does not transmit your personal data, except: If Sophie Carbonari must share this information with third parties to provide the service you request, or If Sophie Carbonari is summoned by a judicial authority or any other administrative authority to communicate information, or If you have given your prior consent for the sharing of this information. In this case, the transfer out of France of your personal data will be carried out by setting up the appropriate guarantees and by preserving the safety of your data. Sophie Carbonari may be required to transfer your personal data to judicial and police authorities, regulatory authorities, public bodies or third party companies in order to comply with a court order, subpoena, summons, search or any other legal or regulatory obligation or request. Such transfer may also be made for the purposes of fraud protection or the investigation of possible offences. 4.4 Data Security Sophie Carbonari has endeavored to implement reasonable precautions to preserve the confidentiality, integrity and availability of personal data processed and prevent them from being distorted, damaged, destroyed or that unauthorized third parties have access. Technical and organisational security measures have been put in place for this purpose. However, Sophie Carbonari does not control all the risks associated with the operation of the Internet and draws the attention of Internet users to the existence of possible risks inherent in its use and operation. For the needs of the technical storage of your personal data, your data will be centralized at Sophie Carbonari. Sophie Carbonari attaches the greatest importance to the protection and security of its information systems. Tools have been put in place to enable Sophie Carbonari to detect potential security vulnerabilities. These tools may incidentally lead to access to personal data by security teams. This data will be collected and processed for the sole purpose of managing these vulnerabilities and in compliance with applicable regulations on the protection of personal data. 5. Cookies and connection cookies 5.1 What is a cookie? A cookie is a text file that may be stored in a dedicated space on the hard disk of your electronic equipment when you consult an online service using your browser software. A cookie file enables its issuer to identify the terminal in which it is stored, during the period of validity or storage of said cookie. 5.2 Cookies issued on the Site When you connect to the Site, Sophie Carbonari may be required, subject to your choices, to install various cookies to recognize the browser you use for the duration of validity of the cookie concerned. The purpose of cookies is to to establish statistics and volumes of frequentation and use of the various elements composing the Site (headings and contents visited, course), allowing Sophie Carbonari to improve the interest and the ergonomics of the services, as well as the visibility of the published contents; to allow or facilitate your navigation on the Site, or to provide you with the online communication services that you request during your navigation; to adapt the presentation of the Site to the display preferences of your terminal (language used, display resolution, operating system used, etc.) during your visits to the Site, according to the hardware and software for viewing or reading that your terminal has; to store information relating to a form that you have filled in on the Site (registration or access to your account) or to products, services or information that you have chosen on the Site. 5.3 Cookies issued on the Site by third parties Sophie Carbonari is likely to include on the Site computer applications from third parties, which allow you to share content of the Site with other people or to let these other people know your consultation or your opinion on a content of the Site. The issuance and use of cookies by third parties are subject to the privacy policies of these third parties. Sophie Carbonari does not control the process used by social networks to collect information about your browsing on the Site. Sophie Carbonari invites you to consult the policies of protection of the private life of these social networks in order to take note of the purposes of use, in particular advertising, of information of navigation which they can collect thanks to these applicative buttons. These protection policies should enable you to exercise your choices with regard to these social networks, in particular by configuring your user accounts for each of these networks. The Site may contain cookies issued by third parties (advertising agencies, audience measurement companies, etc.) which, during the period of validity of these cookies, enable them to collect browsing information relating to Terminals consulting the Site, in particular in order to measure the effectiveness of paid search engine referencing campaigns. 5.4 Your choices regarding cookies Several options are available to you for managing cookies. Any settings you make may affect your browsing on the Internet and your conditions of access to certain services requiring the use of cookies. You can choose at any time to express and modify your wishes with regard to cookies, by the means described below. You can configure your browser software so that cookies are stored on your terminal or, conversely, so that they are rejected, either systematically or depending on the sender. You can also configure your browser software so that you are offered the option of accepting or rejecting cookies from time to time, before a cookie is likely to be stored on your terminal. For more information, see "How to exercise your choices, depending on the browser you are using". To modify your choices concerning cookies, consult the "Cookie settings" section at the bottom of the Site page. (a) Agreement on Cookies The recording of a cookie on a terminal is essentially subject to the will of the terminal user, who may express and modify this will at any time and free of charge by means of the choices offered to him by his browser software. If your browser software allows cookies to be stored on your terminal, the cookies embedded in the pages and content you have consulted may be stored temporarily in a dedicated space on your terminal. They will only be readable there by the sender. (b) Refusing cookies If you refuse to accept cookies on your terminal, or if you delete the cookies stored on your terminal, you will no longer be able to benefit from a certain number of functions which are nevertheless necessary for browsing certain areas of the Site. This would be the case if you attempted to access content or services that require you to be identified. This would also be the case when Sophie Carbonari or its providers could not recognize, for technical compatibility, the type of browser used by your terminal, its language settings and display or the country from which your terminal seems connected to the Internet. If necessary, Sophie Carbonari declines any responsibility for the consequences related to the degraded operation of its services resulting from our impossibility of recording or consulting the cookies necessary to their operation and which you would have refused or removed. (c) How do you exercise your choices, depending on the browser you use? Each browser has a different configuration for managing cookies and your choices. This is described in the help menu of your browser, which will tell you how to modify your wishes with regard to cookies. 5.5 If you share the use of your terminal with other people If your terminal is used by several people and when the same terminal has several software of navigation, Sophie Carbonari cannot ensure in a certain way that the services and advertisements intended for your terminal correspond well to your own use of this terminal and not with that of another user of this terminal. If necessary, the sharing with other people of the use of your terminal and the configuration of the parameters of your navigator with regard to the cookies, concern your free choice and your responsibility. For more information on cookies and their use, you can consult the file of the Commission Nationale de l'Informatique et des Libertés at the following address: 6. Modification of the charter Sophie Carbonari may have to modify the Charter and will ensure that you are informed either by a special mention on the Site, or by a personalized warning in particular in the context of sending newsletters.