GABAKY respects the law “Informatique et Libertés” n ° 78 of January 6, 1978 modified, the law for “Trust and the Digital Economy” n ° 2004 – 575 of June 21, 2004 as well as Regulation 2016/679 of April 27, 2016 (hereinafter the “Applicable Regulations”).
1. WHAT PERSONAL DATA ARE COLLECTED ON THE SITE AND WHY?
We collect declarative data as well as behavioral data (collectively referred to as “your Personal Data”).
The data is collected in order to allow you to benefit from our products and/or services, to receive personalized information, to offer you suitable commercial offers, and, where applicable, to allow you to benefit from offers from our partners. Some data also allows our services to administer and improve our marketing activities and services for our customers.
When collecting your personal data, you are informed of the mandatory or optional nature of the information requested, as well as the consequences of not providing data.
In all cases, you are informed of the processing carried out, the rights you benefit from, and the means of exercising them.
When we collect, process and store your data with your consent, you will be able to withdraw your consent at any time. However, you will not be able to question the legality of the processing carried out before the withdrawal.
Declarative data: GABAKY collects the information that you voluntarily communicate to us to benefit from the service of your choice. The data is thus collected when you register for one of our services or during any other marketing event.
These data are generally your identity and your contact data (e.g. postal and/or electronic address, telephone number) and may also be associated with various data (information related to the household, family, centers of interest, etc. ).
You may be offered to receive commercial offers from GABAKY and/or its partners. GABAKY will then seek your consent in accordance with the applicable regulations.
All this data is stored in our customer database, in order to be able to communicate with you and provide offers tailored to your needs.
Behavioral data: The behavioral data collected makes it possible, during each of your visits, to carry out global statistical studies on the audience of our services, to identify you if necessary, to adapt the content of a service or advertising offer to your behavioral data and, more generally, to study your behavior during your browsing on our sites in order to offer you a better browsing experience and use of the services offered by GABAKY.
Browsing data: GABAKY is also likely to store interaction events between you and GABAKY’s services (page loads, button clicks, click rate on newsletters, banners, etc.) in order to offer you suitable offers. to your wishes, and generally improve our services according to the expectations of our customers.
Cookies: a cookie is a small text file, saved on the hard drive of your computer at the request of the server managing the website visited. It contains information on the navigation carried out on the pages of this site and makes it easier to use the site later on your next visit. The information collected by a cookie can only be read by its issuer. You can oppose the installation of cookies, but in this case you risk having degraded access to the services offered.
We therefore advise you to leave them active to take full advantage of our services and your browsing on our sites.
Data not collected directly from you: In certain cases, personal data concerning you may have been collected from third parties. Thus, GABAKY may collect Personal Data from these partners. These sources are non-public. Where appropriate, we will not fail to provide you with all the information on the processing as well as any useful information regarding the exercise of your rights of opposition, erasure, limitation, access, rectification and of portability.
2. HOW IS YOUR PERSONAL DATA USED ON GABAKY?
2.1. Declarative data
They may, with your consent by ticking the boxes provided for this purpose, be used by GABAKY (1 and 2) or/and by its partners (3) or/and by its service providers (4).
(1) The declarative data is necessary to enable you in particular to create and manage your personal accounts, to record and manage your orders and subscriptions, or to access and use the services offered by GABAKY, to participate in marketing animation operations (contests, product tests, etc.) and other promotional activities.
If you are a customer of a GABAKY company, this same company may send you offers of products similar to those you have already ordered.
The data concerning your centers of interest can allow GABAKY to make you proposals adapted to your needs or centers of interest.
2.2. Behavioral data
During your visits to GABAKY, cookies may be placed on your computer.
The site www.gabaky.com respects the recommendation of the CNIL dated December 5, 2013 concerning cookies:
– During your first visit to a site, a banner informs you of the installation of cookies, of your ability to oppose them and of the procedure to follow to do so;
– Cookies that allow you to browse our sites and be identified on your next visit are not affected, or cookies that allow us to compile statistics on visits to our sites or to memorize your shopping cart.
2.3. Links to third-party sites and connection to social networks
Our website may contain links to websites belonging to our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these sites have their own personal data protection policies and that we are not responsible for these policies. We encourage you to read the terms of these policies before submitting any personal data to these websites.
We can also offer you the possibility of connecting through your social networks. If you decide to proceed in this way, we draw your attention to the fact that you provide us with your profile information according to the settings of the social networks you use. We invite you to visit the social media concerned and consult its personal data protection policy in order to understand how your data is shared and used in this context.
Social media and user-generated content
GABAKY allows users to upload their own content. We remind you that any content transmitted to one of the social networks that we use may be accessible to the public. Thus, we invite you to exercise caution with regard to the communication of certain personal data such as financial data or an address. We are not responsible for any actions taken by third parties in the event that you post personal data on one of our sites or applications, and we recommend that you do not communicate this information.
3. WHO ARE THE RECIPIENTS OF YOUR PERSONAL DATA?
The Personal Data collected is intended for GABAKY and the departments and employees who need to know it in order to achieve the intended purpose.
They can also be managed by GABAKY’s advertising agency with regard to advertising cookies and/or be transmitted to subcontracting companies expressly mandated by the site.
Your Personal Data is only communicated to third parties in the following cases:
– when you have given your prior consent for the sharing and/or disclosure of your Personal Data; GABAKY does not transmit your Personal Data to third-party advertisers for targeted marketing purposes unless you have given your prior consent.
– when GABAKY must share your Personal Data with its business partners and service providers, in order to achieve the intended purpose.
GABAKY in particular provides your Personal Data to third-party companies to provide services on its behalf, including the processing of mailing campaigns, the hosting of services, the processing of certain marketing aspects of the services or activities offered on our sites.
– pursuant to a law, a regulation or pursuant to a decision of a competent regulatory or judicial authority or, if necessary, in order to preserve its rights and interests, GABAKY may communicate your data.
– in the event of a change of control of the GABAKY site and its subsidiaries or the transfer of all or part of its assets, GABAKY will be authorized to transfer your Personal Data.
Please note, however, that advertisers may obtain your Personal Data from other public sources. GABAKY cannot in the same way be held liable in this respect.
On the other hand, the GABAKY site may use and share with third parties certain non-personal technical or aggregated data relating to your browsing on the GABAKY site. The collection, processing and disclosure of such anonymized data shall not be subject to the restrictions set forth herein.
4. HOW LONG WILL YOUR PERSONAL DATA BE RETAINED?
The retention period for your Personal Data varies depending on the purpose of the collection. Personal Data is stored in accordance with the provisions of simplified standard No. 48 adopted by the CNIL .
Legal obligations may require GABAKY to keep them for a minimum period. In other cases, the data concerning you will be kept within the limits of the achievement of the purpose pursued.
Beyond that, the data will be kept for commercial prospecting purposes for a period of three (3) years from the last active manifestation on your part.
When the processing is based on your consent, the data is kept until you withdraw your consent or request the deletion of your data.
Data collected automatically such as navigation or connection data (e.g. cookies), as well as raw traffic data associating an identifier, will not be kept for more than thirteen months from the installation of the cookie in the terminal. of the user.
We may retain certain personal data in order to fulfill our legal or regulatory obligations, and in order to allow us to exercise our rights (eg, file an appeal before any court) or for statistical or historical purposes.
We may also retain certain personal data in order to maintain a deletion list if you have requested not to be contacted.
5. SECURITY OF PERSONAL DATA
5.1. GABAKY implements all the technical and organizational means to guarantee the security of your personal data, and to prevent any risk of loss, deterioration or misuse of it.
Similarly, we limit access to personal data to employees whose functions require consultation of this data.
When we no longer need or no longer need to use your personal data, we anonymize them so that they cannot identify you or we erase them from our systems and files.
5.2. Login credentials allow you to identify yourself and log into your account on our site. These Login IDs, created by you, are personal and confidential.
You agree to keep your login details secret and you agree not to disclose them in any form whatsoever to third parties.
Unless proven otherwise, any transaction made from your account will be deemed to have been made by you.
We invite you to explicitly disconnect at the end of each session.
Any loss, theft, misappropriation or unauthorized use of login details and their consequences are the responsibility of the user.
A Cookie allows its issuer, during its period of validity, to recognize the terminal concerned each time this terminal accesses digital content containing Cookies from the same issuer. Cookies do not keep track of personal information about a user and identifiable data will never be recorded.
In particular, they allow GABAKY to understand how users browse our site, and to obtain data from which we can improve the browsing experience in the future, to send you personalized offers, to identify you when you access to your customer account, but also to indirectly finance the free services that we offer and that are provided to you by our various sites.
In accordance with the regulations in force regarding the protection of privacy on the Internet, in particular the Ordinance of August 24, 2011, GABAKY has, except in legal exceptions, the obligation to seek your prior consent, which is valid for a maximum of 13 months. .
Internet browser settings are usually set by default to accept cookies, but you can easily change this by changing your browser settings.
Many cookies are used to improve the usability and operation of websites/applications, therefore disabling cookies may prevent you from using certain parts of the sites.
If you wish to restrict or block all cookies that are set by our site (which may prevent you from using certain parts of the site), or by other websites/applications, you can do so by going to the settings of your browser.
7. WHAT ARE YOUR RIGHTS AND HOW TO EXERCISE THEM?
In accordance with the applicable regulations, you have the following rights:
- The right to be informed – You have the right to obtain clear, transparent, understandable and easily accessible information on how we use your personal data and on your rights. This is why we provide you with the information in this Policy.
- The right of access – You have the right to access the personal data we hold about you (subject to certain restrictions). Manifestly unfounded, excessive requests, in particular because of their repetitive nature, are likely not to receive a response.
- The right to rectification – You have the right to demand that your personal data be rectified and/or completed if they are inaccurate or outdated and/or incomplete.
- The right to erasure/right to be forgotten – In certain cases, you have the right to obtain the erasure or deletion of your personal data. This is not an absolute right, as we may be required to retain your personal data for legal or legitimate reasons.
- The right to object to commercial prospecting, including profiling
You can unsubscribe or oppose the processing of your data at any time, unless it is based on legitimate and compelling reasons, either by clicking on the “unsubscribe” link in any email or any communication that we send you. send, or by contacting us at the contact details below.
- The right to withdraw the consent given, at any time – You can withdraw your consent to the processing of your data when it is based on consent. However, the withdrawal of this consent does not affect the lawfulness of the processing carried out before its withdrawal.
- The right to restriction of processing – You have the right to request the restriction of the processing we carry out on the data concerning you.
This right means that the processing of data concerning you that we carry out is limited, so that we can keep this data, but not use or process it.
This right applies in specific circumstances provided for by the General Data Protection Regulation, namely:
- the accuracy of the personal data is contested by the data subject (i.e. you), for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject (i.e. you) opposes their erasure and requests the restriction of their use instead;
- the controller (i.e. GABAKY) no longer needs the personal data for the purposes of the processing but these are still necessary for the person concerned for the establishment, exercise or defense of legal rights;
- the data subject (i.e. you) has objected to the processing based on the legitimate interests pursued by the controller pending verification of whether the legitimate grounds pursued by the controller prevail on those of the person concerned.
You also have the right to lodge a complaint with the data protection authority (the CNIL) to challenge GABAKY’s practices in terms of personal data protection and respect for privacy.
More information on your rights at https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles
(updated – November 2020)