Guillemot Corporation S.A. (hereinafter “Guillemot” or “we”) respects the right to privacy of users of the Site (hereinafter “Users”, “User” or “you”), and is committed to protecting the information (including personal data) collected on or via the Site. In order to demonstrate this commitment, Guillemot has adopted this Policy.
Personal data consists of “any information relating to an identified or identifiable natural person (hereinafter the “data subject”); an “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person” (extract from the Regulation of the European Parliament and of the Council of April 27, 2016 relating to the protection of natural persons with respect to the processing of personal data, often referred to as the “GDPR”).
Your personal data is collected and processed according to the legal bases specified in the legislation:
– On the basis of your consent;
– For the purposes of legitimate interests;
– Within the context of the fulfillment of a contract or the intention to enter into a contract; and/or
– In order to comply with a legal obligation to which we are subject.
You have the right to ask Guillemot for access to your personal data, or to correct or erase said data, or to request a processing limitation with regard to the data subject (you or your under-age children), as well as the right to object to the processing and the right to the portability of your data (portability is inapplicable here a priori, but you may make a request, and we will review this point). In order to exercise your rights with respect to your data, please use the link to our contact form, found at the bottom of each page of the Site. You will have to send us, by email, a front-side copy of your piece of identification (this is necessary, unfortunately, as we must verify your identity before implementing the right(s) that you wish to exercise regarding your data).
Guillemot limits the collection of your personal data to the strict minimum: our online forms minimize the data collected. In order to avoid including excessive information in our online forms (which would detract from the overall readability, including with regard to the information and your decision), the form gives you a first level of information, and directs you to the Personal data protection charter, which then directs you to this Policy for a third level of information. Here, you will find further details regarding the objectives, the data recipients, and so on.
WHAT INFORMATION IS COLLECTED?
User-supplied information: our online forms, the fields that you fill in and your actions (an upload, for example) guarantee your consent to the collection of the corresponding personal information. Guillemot collects information in the following cases: (1) contact form; (2) registration as a member (if available on the Site); (3) registration for participation in a contest (if available on the Site); (4) personal space / “my space” (if available on the Site); (5) newsletter (if available on the Site); (6) online forum (if available on the Site); (7) registration as a candidate for sponsorship (if available on the Site); (8) blog (if available on the Site). Among the information that we collect, we may ask you for personal information such as your family name, your given name(s), your date of birth, your email address, your orders, your billing address, your delivery address, your telephone number, your fax number, your comments and exchanges with the individuals responsible for customer relations, your nationality, your country of residence, and your language. In addition, we may collect information regarding the hardware and/or software that you own, your introductory text, your tastes regarding music and/or video games, links (to your blog, for example), your influences, your musical project or your e-Sports project, and your live dates.
Specific case regarding banking information: online payment by bank card or charge card on the Site is carried out via the secure banking server managed by Guillemot’s partner, PayPal. This means that no banking information relating to you is stored on the Site.
Specific case: you need to provide us with a copy of a piece of identification in order to exercise a right to access, correct, object to, limit the processing of, or erase your data, or a portability right regarding your data.
Guillemot also stores the messages, comments and emails that you send us (including personally identifiable information).
For security reasons, Guillemot also keeps tracks of Internet Protocol (IP) addresses. An IP address is a number that is used by computers on the network to identify your device every time you connect to the Internet.
Information via server log files: the Site, like many other sites, passively collects and stores information (connection data) via the server’s log files. This process allows for a record of activity on the Site to be stored, including how many “hits” a particular web page is getting. These entries are generated in a non-nominative fashion and are not associated with any particular User, device or browser.
You should bear in mind that whenever you voluntarily disclose personal information online (by email, or via the forums, or via your public profile, for example), your information can be collected and used by others. Although Guillemot strives to protect your personal information, Guillemot cannot ensure the security of information that you transmit to us should you neglect to take the appropriate precautions on your end: any transmission of information is therefore at your own risk. You are also solely responsible for maintaining the secrecy of any passwords that you set up and/or of any information regarding any account that you create on the Site, if available on the Site (hereinafter the “Account”).
WHAT HAPPENS IF I REFUSE TO PROVIDE MY PERSONAL INFORMATION?
Should we not have access to certain personal information, it will not be possible to contact you (as we need to know how to reach you), requests will not be able to be properly directed (we are unable to see to it that a request is dealt with by the appropriate person if we are not aware of the contact subject and type), some requests may not be processed (if you have a technical problem, we need to know about the context, as well as the hardware and software environment; we will not be able to send you anything by post if you do not provide us with your mailing address), and access to some areas of the Site and some features of the Site (if available on the Site) will be affected: online purchases, participation in the forum, registration of your participation in a contest, requests to be a candidate for sponsorship, video playback. However, this personal information is not required to access the Site and enjoy most of its content.
HOW WILL MY PERSONAL INFORMATION BE USED?
We use your information in accordance with its category.
IP addresses allow for geolocation of visitors to the Site, although said geolocation is limited (it does not provide a higher level of precision than identifying the User’s city or town).
With respect to how User-supplied information is employed, the corresponding data may be processed for all or some of the following purposes:
– Creation and use of a mailing list for information or external communication purposes relating to Guillemot’s aims or activity;
– Use of the Site’s connection data for statistical purposes;
– Carrying out of customer management operations with respect to: contracts, orders, deliveries, invoices, accounting, and in particular management of customer accounts, loyalty programs, following-up of customer relations including by means such as satisfaction surveys, management of claims and of after-sales service, selection of customers for studies, polls and product tests;
– Carrying out of operations related to prospecting: management of technical prospecting operations (including in particular technical operations such as standardization, enrichment and deduplication), the selection of individuals with whom to carry out initiatives regarding loyalty-building, prospecting, studies, surveys, product testing and promotion, as well as carrying out of marketing campaigns;
– Compiling of trade statistics;
– Updating of prospecting files by the agency in charge of managing the telephone solicitation opt-out list, in accordance with the provisions of the Consumer Code;
– Organization of quiz contests, sweepstakes or any promotional campaigns; management of requests to access, correct, oppose, limit the processing of, or erase your data, as well as with regard to data portability;
– Management of delinquency and litigation (does not relate to offenses and/or does not involve excluding an individual from a right, benefit or contract);
– Management of your opinions regarding products, services or content;
– Assessment of risks and prevention of payment and delivery fraud with respect to purchases on the Site.
For example, regarding an application form with respect to a community of people interested in our products, Guillemot may use your personal information to create and manage a community of people interested in our products, put in place a platform for communication, information and support between members of the community, including for the management of a forum (in particular, in order to restrict participation in the forum and the blog to community members only), for commercial prospecting, for the implementation of contests, and to respond to a candidacy for sponsorship.
With respect to a form for creating an account for purchases, Guillemot may use your personal information for commercial prospecting, for the implementation of contests, to respond to emails that you send us, to compile statistics and establish anonymous profiles on individuals interested in our products and study their needs, and for external communication purposes. Moreover, this information may be used to customize the Site and verify the identity of the User. After having received your consent to do so, Guillemot may also send you a newsletter.
Copies of a piece of identification provided in order to exercise a right to access, correct, object to, limit the processing of, or erase your data, or to exercise a portability right regarding your data, will be used for verification and evidentiary purposes and, where appropriate, for litigation.
With respect to how information from cookies is employed: thanks to cookies, Guillemot aims to offer a more efficient, more useful, more secure and higher-quality Site, along with more personalized content on the Site.
Essential cookies are cookies required in order to access your secure space, and your shopping cart.
Functional cookies record information (non-nominative in nature) regarding your preferences with respect to visiting certain web pages, language, location, etc.
Performance cookies allow for analysis of the use and performance of the Site in order to improve its operation (they generally relate to the most frequently visited pages, and error messages from web pages). These cookies do not collect information allowing for identification of the visitor.
Advertising cookies are used in order to present the most relevant advertisements according to your areas of interest. Should these advertising cookies be disabled, the advertisements remain but no longer reflect your areas of interest.
With respect to how information obtained via server log files is employed: this information (non-nominative in nature) allows Guillemot to evaluate the Site’s overall activity, follow the interest shown with regard to our communications, and find solutions for technical problems. We also use this information for internal marketing studies or demographic studies, so that we are able to bring you products with increasingly high levels of performance, and ever more interesting features. Information obtained via server log files is only used internally.
As Guillemot is responsible for the storage of writings, images, sounds and/or messages to be made available to the public online, Guillemot is required by law to retain and store data allowing for the identification of anyone who has contributed to the creation of content or of one of the contents of the Site.
Your personal information will not be used for the purposes of profiling which may disclose sensitive data (racial or ethnic origins; philosophical, political, trade-union or religious opinions; individuals’ sexuality or health).
WHO ARE THE RECIPIENTS OF PERSONAL DATA?
The mailing list for information or external communication purposes relating to Guillemot’s aims or activity is accessible to authorized Guillemot personnel responsible for financial communication.
The server log files are accessible to Guillemot personnel responsible for information systems. Data from server log files may be provided to Guillemot personnel responsible for marketing. Extracts from server log files may be provided or made accessible to authorized personnel of the legal service, to court officers and judicial officers, and to government agencies as part of their control or justice mandate.
Data from audience measurement tools is intended for personnel responsible for information systems, as well as Guillemot personnel responsible for marketing. Processing of this data is subcontracted to Google Inc.
The data files relating to customer and lead management are accessible:
– to authorized personnel of the marketing service, the sales department, the services responsible for managing customer relations and prospecting, the administrative services (including the legal service), the logistics and IT services, as well as their line managers;
– to authorized personnel of the services responsible for control (services responsible for internal control procedures).
The following parties may be recipients of data relating to customer and lead management:
– Guillemot’s subsidiaries;
– Subcontractors (banks, canvassers, data hosts, PayPal, postal employees, carriers, etc.) which provide adequate safeguards with respect to the protection of your rights;
– Developers and publishers of software used for data processing (the data is then rendered anonymous) ;
– Auditors and external auditors as part of their audit mandate;
– Government agencies as part of their control or justice mandate;
– Agencies, court officers and judicial officers, as part of their debt recovery mandate;
– Agencies in charge of managing the telephone solicitation opt-out list(s).
Copies of a piece of identification provided in order to exercise a right to access, correct, object to, limit the processing of, or erase your data, or to exercise a portability right regarding your data, are accessible to authorized personnel responsible for information systems, to authorized personnel of the legal service, and to government agencies as part of their control or justice mandate.
COULD MY PERSONAL INFORMATION BE TRANSFERRED OUTSIDE OF THE EUROPEAN UNION?
Data from data files relating to customer and lead management may be transferred outside of the European Union, as some of Guillemot’s subcontractors and some of Guillemot’s subsidiaries are located outside of the European Union.
Data from data files relating to customer and lead management is not subject to being transferred outside of the European Union unless at least one of the following conditions is met:
– The transfers are being made to a country recognized by the European Commission as ensuring an adequate level of protection;
– Firstly, appropriate safeguards exist, and secondly, the data subjects (i.e. you) have enforceable rights and effective legal remedies;
– The CNIL has approved binding corporate rules (which give you enforceable rights with regard to the processing of your personal data) ;
– The data corresponds to one of the derogations or exceptions stipulated by legislation.
WITH WHICH ENTITIES MAY GUILLEMOT SHARE MY PERSONAL INFORMATION?
Guillemot does not sell, lease or exchange its customer files or its lead files. Therefore, apart from the above-mentioned recipients of personal data, we do not share any personal information with third-party companies.
FOR HOW LONG WILL MY PERSONAL INFORMATION BE KEPT?
To begin with, data archiving is time-limited: the data required in order to comply with a contractual, legal or regulatory obligation may be archived for the amount of time necessary to comply with the obligation in question. The archived data is deleted when the grounds that justify its archiving no longer exist (for example, data archived in order to support a legal claim is deleted when said action has become time-barred).
The mailing list for information or external communication (non-commercial) purposes relating to Guillemot’s aims or activity is updated annually. The data is kept for the period of time necessary in order to deliver the information, or for the period of time necessary to provide the external communication (for example: in the event of a request for a new annual report which is not yet available, the request will be subject to a holding reply, followed by dispatch of the annual report when it becomes available).
Data from the data file relating to customer management is kept for three years (from the date of the most recent invoice) for use with prospecting.
Data from the data file relating to customer management is kept for ten years (from the year-end date of the fiscal year during which the invoice was issued) for accounting archiving (invoice data).
Personal data relating to a non-customer lead is kept for a period of three years from the time of collection, or from the last contact by the lead.
In the event that the right of access or correction is exercised, the data relating to the pieces of identification may be kept for the period stipulated in Article 9 of the Criminal Procedure Code (i.e. for one year). In the event that the right of objection is exercised, this data may be archived during the limitation period stipulated in Article 8 of the Criminal Procedure Code (i.e. for three years).
HOW CAN I EXERCISE MY RIGHTS WITH REGARD TO MY PERSONAL INFORMATION?
If, for whatever reason, you wish to access your personal data, or correct or erase said data, or limit processing relating to the data subject (you or your under-age children), or object to the processing of said data, or exercise your right to the portability of your data, you must contact us via the Site using the link to our contact form, found at the bottom of each page of the Site.
Your request must indicate: (1) the right that you wish to exercise; (2) the identity of the requester; and (3) if the requester is not the data subject, the identity of the data subject.
Please be aware that incomplete requests will not be processed:
– if the data subject in the request is the requester (that is to say, if you are acting on your own behalf), your request will only be valid following receipt of a copy of the proof of identity regarding the data subject (if this is an identity card, a black-and-white copy of the front side will suffice) ;
– if the data subject is not the requester (that is to say, if you are acting on behalf of another person), the request will only be valid following receipt of a copy of the proof of identity regarding the requester, and a copy of the proof of identity regarding the data subject.
Currently, our contact form does not allow attachments to be sent. After having received your request via the contact form, we will contact you at the email address you have provided in your request in order to ask you to send us the proof(s) of identity by other means.
If you are a registered User with an account or personal space (if available on the Site), then you have access to and can also correct some of your personal information in your account or personal space.
If you do not wish to be sent any newsletters by Guillemot, do not select the “I agree to receive the newsletter…” option. Moreover, each communication sent to you by Guillemot gives you the option to no longer receive new communications.
If you are not satisfied with our exchanges, you may lodge a complaint with the competent control authority:
Commission Nationale de l’Informatique et des Libertés
[National Commission for Information Technology and Civil Liberties]
3 Place de Fontenoy
75334 PARIS CEDEX 07
DOES GUILLEMOT COLLECT PERSONAL INFORMATION FROM USERS UNDER 18 YEARS OF AGE?
We do not have a deliberate intention to collect personal information from users under 18 years of age, but it is possible for such users to access the Site.
Minors under 13 years of age must not submit personal information allowing for them to be directly or indirectly identified.
With regard to Users aged 13 or more, we provide these Users (as we do for adults) with a questionnaire that is limited to the required information. In some cases it is necessary to collect personally identifiable information from Users over 13 but less than 18 years of age (hereinafter “Teenagers”), in order to respond to their requests for information or technical support, allowing them to participate in the forum, and in order to allow them to take part in contests.
Parental consent: Guillemot is committed to protecting Teenagers’ privacy. Guillemot encourages parents to visit the Site with their children, to monitor their children’s use of the Site, and to help us protect their privacy by instructing them never to provide personal information (family name, address, telephone number(s)…) without your permission. Guillemot believes that parents’ help represents the best solution in order to avoid Teenagers providing personal information in inappropriate places. Users less than 18 years of age should not submit any information to the Site without a parent or legal guardian’s consent.
Parental access: a parent acting on behalf of his or her child and/or a parent who has given Guillemot permission to collect his or her child’s information can: consult, correct, modify or object to the processing of said information, or request the portability of the personal data relating to the child in question.
HOW DOES GUILLEMOT PROTECT MY PERSONAL INFORMATION?
Access to some areas and contents of the Site is protected by a password, which you must not divulge to anyone. Guillemot will never ask you for your password by way of a phone call or by email. You must never disclose your password to anyone else. Remember to sign out of your Account at the end of each session. If you share a computer with someone else or are using a computer in a public place such as a library or Internet café, remember to close your Web browser and end your session when you are done with your visit, to prevent anyone else from accessing your personal information or correspondence.
To protect your personal information, Guillemot maintains appropriate safeguards to ensure the security, integrity and privacy of the information you have provided. The Site has security measures in place to protect the User from loss, misuse or alteration of the information under our control. The personal information collected by Guillemot is stored in secure operating environments which are not accessible to the public (secure rooms with restricted access, for example). Guillemot protects the information collected against any unauthorized access by way of a firewall-protected server.
Copies of a piece of identification provided in order to exercise a right to access, correct, object to, limit the processing of, or erase your data, or to exercise a portability right regarding your data, are encrypted by the personnel responsible for information systems.
In addition, Guillemot takes appropriate measures to ensure that third parties provide a high level of protection for the personal information collected and/or used on our behalf.
The Site may contain links to third-party sites. Guillemot is not responsible for the privacy practices of these third-party sites. For more information, please consult the respective privacy policies of the third-party sites.
You can contribute to your own protection. Guillemot suggests that you delete the emails that we send you after having read them: in this way, if a third party manages to access your emails, said third party will not immediately have knowledge of the content of the emails that you have deleted.
By using this Site, you consent to the Policy. If you do not agree to this Policy, you must stop using the Site. We reserve the right to modify this Policy without prior notice, so please consult it regularly in order to take note of any changes. Your continued use of the Site signifies your acceptance of these changes.
In the event of the deletion of your Account for whatever reason, Guillemot will cease using your personal information but will retain said information temporarily in accordance with current legislation.