1. PRIVACY POLICY



1. Privacy Policy

ÉCLAIR is the owner of this website https://www.eclair-parfumeries.com/en/ (the "Website") through which it offers information about the products that, at any given time, it deems appropriate, and markets them online (the "Services"). In order for ÉCLAIR to provide the Services, it needs to collect personal data and information from users (the "Personal Data").

For ÉCLAIR, the privacy and protection of users' personal data is very important, therefore, it has adapted to and complies with the requirements established in the regulations in force on Data Protection, in this case, with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter, the "GDPR") on the protection of natural persons with regard to the processing of personal data and the free movement of data, and with the other national regulations applicable at any given time. In any case, you can consult the European Regulation in this link provided by the Spanish Data Protection Agency:

http://www.agpd.es/portalwebAGPD/canaldocumentacion/legislacion/union_europea/reglamentos/common/pdfs/Reglamento_UE_2016-679_Proteccion_datos_DOUE.pdf

For this purpose, ÉCLAIR has prepared this privacy policy (the "Privacy Policy"), which applies, together with the Cookies Policy, the Terms and Conditions of the Website, and the General Conditions of Contract to any user who accesses or registers on the aforementioned Website.

References to "user", "you" and "your" refer to any person or entity that accesses the Website or any of its pages and additionally to any person who uses the Services and therefore may receive the status of consumer.



1.1. Responsible for the processing of your Personal Data

Whether the user resides in a country of the European Union or in a country outside the European Union, the responsible for the collection and processing of your Personal Data through the Website is ELS LIMITS MESTRAL SAU ("ÉCLAIR"), a Spanish company, with VAT number A17045972 and registered office at C/ Fatima 4, 17709 El Portús, Spain, with contact telephone number 972 55 42 75, contact e-mail address hola@eclair-parfumeries.com and with contact for Data Protection at the e-mail address: hola@eclair-parfumeries.com.

ÉCLAIR is interested in protecting the privacy of the Personal Data of users and, to this end, has a delegate for the protection of personal data to which users can contact. The contact details of ÉCLAIR's data protection officer are as follows: lopd@latramuntana.com.



1.2. What data is collected and how it is used

When a user registers on the ÉCLAIR Website, or fills in any of the forms provided on the same, their Personal Data will form part of the personal data file created and managed by ÉCLAIR under its own responsibility, for the following purposes:

1. To allow the user to contract and pay for the Services offered by ÉCLAIR (including, among others, the online purchase of products and services, the management of its commercial relations, as well as the legal and fiscal information corresponding to the aforementioned relationship);

2. Authenticate and authorize users to access and use their profile;

3. The carrying out of promotional and advertising activities both for products, services or activities related to ÉCLAIR or companies of the Tramuntana Group (mainly in the food, fashion and/or consumer products sector), in the event that the user has explicitly consented to this;

4. Communicate with users and send them messages about the Website, as well as security notifications, network updates, reminders or other issues related to the Services;

5. To assist users when they contact ÉCLAIR in connection with the Services; and

6. Tailor and enhance your experience on the Website according to your needs through cookies.

Personal Data provided to ÉCLAIR through the Website will not be used for purposes other than those set out in the Privacy Policy.

The Personal Data and other information proving the purchase made by the user through the Website will be kept in electronic format. In the same sense, the Personal Data will only be processed for as long as they are necessary, useful and relevant. In any case, once the user's relationship with ÉCLAIR has ended or the user's consent to the processing based exclusively on the same has been revoked, the Personal Data will be kept only for the time necessary and for the sole purpose of complying with the legal obligations applicable in each case.



1.3. Legitimacy for the treatment

The legal bases for the processing of your Personal Data in the terms set out in the previous section are as follows:

1. The provision and execution of the Services themselves is the legal basis that enables ÉCLAIR to process the Personal Data necessary to (i) enable the contracting and payment of the Services offered by ÉCLAIR (including, among others, the online purchase of products and services, the management of its commercial relations, as well as the legal and fiscal information that corresponds to the aforementioned relationship); (ii) to authenticate and authorize users to access and use their profile; (iii) to communicate with users and send them messages about the Website, as well as security notifications, network updates, reminders or other matters related to the Services; and (iv) to serve users when they contact ÉCLAIR in connection with the Services;

2. The legal basis for carrying out promotional and advertising activities for products, services or activities related to ÉCLAIR or companies of the Tramuntana Group (mainly in the food, fashion and/or consumer products sector), is the express and explicit consent given by you by ticking the specific box. Likewise, the processing of Personal Data through cookies to improve your experience on the Website is also based on consent. In these cases, you may withdraw the consent given when you deem it appropriate in the manner provided for in the applicable legislation.



1.4. Explicit Consent and the veracity of Personal Data

A) Explicit Consent

Where applicable, the user must provide explicit consent for ÉCLAIR to use the information entered by the user. The specific cases that require explicit consent are those detailed in the section "Legitimation for processing" and more specifically in its second section.

ÉCLAIR may transfer this Personal Data only to the entities that collaborate with it in the processing of the information and for the purposes previously indicated and authorised by the user. Where appropriate, the transfer of Personal Data will be carried out in accordance with the provisions of the section "Transfer or Assignment of Data".

B) Accuracy of the Personal Data

ÉCLAIR informs you that the fields marked with an asterisk (*) in the respective forms provided on the Website are strictly necessary to respond to the request in question, the inclusion of data in the remaining fields being voluntary.

You represent and warrant that the Personal Data you provide to ÉCLAIR are true and accurate and you agree to notify any change or modification thereof. You further represent and warrant that you are responsible for any loss or damage caused to ÉCLAIR or any third party by the provision of information or Personal Data that is erroneous, inaccurate or incomplete.

ÉCLAIR informs that it does not carry out checks on the veracity of the personal information, so that it will abide, in each case, to the consented treatment of the data entered by the user, whether they are true or not, and in case of being incorrect, the affected users can exercise the rights established in the European General Data Protection Regulation (GDPR).



1.5. Transfer or Assignment of Data

The Personal Data will NOT be transferred to third parties except in those cases in which ÉCLAIR is legally or contractually obliged to provide them (such as banks or collaborating bodies and entities of the Public Administrations or to the same) or except to those companies to which ÉCLAIR has entrusted management, control, maintenance, computer hosting and web hosting services as well as to companies that provide tax, accounting and legal advice among others, in which case, the corresponding contract for the processing of Personal Data will be signed.

Notwithstanding the foregoing, Personal Data may be communicated to companies of the ÉCLAIR group within the European Union for the purpose of unifying the management and internal administration, such communication being necessary to execute the purposes for which they have been collected.

ÉCLAIR has NOT contracted services from technological suppliers located in countries that are not European or do not have regulations equivalent to those of Europe.

Any future contracting of services to data processors carried out by ÉCLAIR will always comply with all the requirements established by European data protection regulations, applying the necessary guarantees and safeguards in the processing of your data in order to preserve the privacy of said information.

At any time the user may exercise their rights against the sending of this information. As well as any other right recognized by the data protection regulations, in the manner and via the route indicated in the section "Exercise of rights by users" of this Privacy Policy.

We may also share statistical data on potential and/or actual sales, volume of users and customers, web traffic data which in no case will contain Personal Data.



1.6. Exercise of rights by users

ÉCLAIR informs the user about the possibility of exercising the rights inherent to the users as stated in the European Regulation RGPD by contacting ÉCLAIR's Data Protection Officer at the e-mail address hola@eclair-parfumeries.com or by sending a letter to the address of ÉCLAIR's head office or by visiting the offices located at C/ Fàtima 4, El Portús (17709), to discuss the matter with the Data Protection Officer.

Said communication of request must contain the following data: name and surname of the User, address for the purpose of notifications, photocopy of the National Identity Document or Passport, and the request in which the request is made. In the case of acting on behalf of a third party, this must be proven by means of a reliable document.

In any case, you can file a complaint with the competent data protection authority.



1.7. Information Security

ÉCLAIR undertakes to comply with its obligation to preserve the secrecy of Personal Data and its duty to store it in accordance with current legislation by adopting, among others, the security measures established in the Register of Activities relating to the processing of Personal Data.

Likewise, all ÉCLAIR personnel, as well as its possible suppliers, subcontractors or collaborators, assume the commitment to carry out their professional work respecting the confidentiality, obligations and security measures established in the framework of data protection.





2. COOKIE POLICY



2.1. What is a cookie?

Cookies are small amounts of information that are stored in the browser used by each user so that the server remembers certain information that later only the server that implemented it will read. Cookies generally have a limited duration in time.



2.2. What cookies do we use?

ÉCLAIR uses the following cookies:

- Technical Cookies: These are those that allow the user to navigate through a web page or application and the use of the different options or services that exist in it such as, for example, controlling traffic and data communication, identifying the session, accessing restricted access parts, etc.

- Customization Cookies: These are those that allow the user to access the service with some predefined general characteristics such as the language, the type of browser through which you access the service, the locale from which you access the service, etc..

- Analysis Cookies: These are those that allow the monitoring and analysis of user behavior. The information collected through this type of cookies is used to measure the activity of the website and/or application and to create user browsing profiles in order to make improvements.



2.3. Who Uses Cookies?

The information obtained through cookies will be collected and processed by ELS LIMITS MESTRAL SAU, whose details are given below:

- Company name: ELS LIMITS MESTRAL SAU

- Address: C/ Fatima 4, 17709 - El Portús (Girona)

- Telephone: 972.554.275

- Fax: 972.554.687

- E-mail: hola@eclair-parfumeries.com.



2.4. How can cookies be deactivated?

You can block or delete cookies through your Internet browser, but if you do so there may be some problems when using or loading the Platform.

The configuration of your internet browser for this purpose will depend on the browser you are using. Below are links to the instructions provided by the main browsers for deleting cookies:

- Internet Explorer: http://windows.microsoft.com/es-ES/internet-explorer/delete-manage-cookies#ie=ie-11-win-7

- Firefox: https://support.mozilla.org/es/kb/Borrar cookies

- Chrome: https://support.google.com/chrome/answer/95647

- Safari: https://support.apple.com/kb/ph5042?locale=es_ES