We place great importance on the privacy and security of your personal data.
The purpose of this Privacy and Cookie Management Policy (hereinafter ‘this Policy’) is to provide you with clear, simple and transparent information on the processing of the personal data you entrust to us, or that we may collect when you browse our website www.glenmoray.com (hereinafter the ‘Site’), its possible transfer to third parties, and your rights and options for controlling your personal information and protecting your privacy.
It applies to the content of the online Services and Services defined below and governs the use of personal data by the online Services or through our Services.
For the purposes hereof, the terms below are defined as follows:
‘Group’: refers to any company that is owned or operated, directly or indirectly, by any company in which COFEPP holds an interest and that may collect or process your personal, traffic, location and cookie data, as well as their respective service providers in France or abroad;
‘We’ and ‘Our’: refers to the company Bardinet and any company that is owned or operated, directly or indirectly, by any company in which COFEPP holds an interest and that may collect or process your personal and cookie data, as well as their respective service providers located in France or abroad;
‘Service(s)’: all Services that can be accessed online via the Site, whether for a fee or otherwise;
‘User’: any natural person, whether or not they have a personal User account, using the Site or any of the Services offered thereon;
‘You’ and ‘Your’: refers to any User of the Services, whether registered or not, who accesses any of the paid or free Services.
PRIVACY AND DATA PROTECTION
What is personal data?
Personal data is any information relating to an identified or identifiable natural person.
When do we collect your personal data?
This data is collected when you:
- sign up for newsletters ;
- contact Site customer services by any available means of communication;
- browse the Site and view items;
- fill in a data entry form or questionnaire on the Site.
Why do we collect your personal data?
We only use your personal data in cases provided for by the regulations in force:
- The performance of a contract we have entered into with you, and/or;
- Compliance with a legal obligation, and/or;
- Your consent to the use of your data, and/or;
- The existence of a legitimate interest to use your data. ‘Legitimate interest’ covers a range of commercial or business reasons that justify the use of your data by Bardinet.
The data collected is necessary for the following processing operations:
- Sending marketing messages (see ‘Newsletters’ paragraph);
- Compiling audience tracking statistics and market research;
What type of personal data do we collect?
In general, you can view our Services without revealing your identity and without providing us with personal information.
However, sometimes, we may collect and process your personal data when we communicate with you. Therefore, when you call us, send us an email or use the contact form, your personal data (email address, subject of your message and any other information you choose to share with us) will be used to process and monitor your requests.
The personal information we collect includes your name, email address, and any other information relating to the use of our Services
Who has access to your personal data?
Your personal data is processed by the staff of Bardinet. We make sure that only authorised persons within Bardinet can access your personal data when necessary for the purposes of managing our commercial relationship or our legal obligations.
We may also disclose your personal data to:
- data processors such as:
- Site hosting and maintenance service providers and the providers of our electronic personal data collection solutions;
- our service providers in the organisation of contests and distribution of newsletters.
- Bardinet may also disclose your data to third parties in order to meet legal, regulatory or contractual obligations, or in response to requests from legally authorised authorities.
What security measures are put in place when processing your data?
We are committed to implementing the appropriate technical and organisational measures to protect your personal data against alteration, accidental or unlawful loss, or unauthorised use, disclosure or access.
These measures are determined by taking into account current technology, the nature, scope, context and purposes of the processing and the identified risks.
Do we process data outside the European Union?
Some recipients of your personal data may be located outside the European Economic Area. Any transfer of your data outside the European Economic Area is subject to appropriate guarantees, including contractual, technical and organisational, in accordance with applicable personal data protection regulations.
For how long do we keep your data?
Your data is collected by Bardinet for the time necessary to carry out the processing operations covered by this Policy. The legal storage periods stipulated by Bardinet follow the recommendations of the French Data Protection Authority (hereinafter the ‘CNIL’) and/or the legal obligations to which Bardinet is subject.
The broad categories of data collected by Bardinet are stored for the following periods:
- processing operations relating to visitors to the Site: 13 months from the collection of the data during the last visit;
- processing operations relating to prospective customers: 3 years from the last contact from the prospective customer;
At the end of this period, the User’s, customer’s or prospective customer’s data will be deleted or anonymised.
However, information that may establish proof of a right or contract, or that is stored in compliance with a legal obligation, may be stored in accordance with the legal provisions in force.
What are your rights and how can you exercise them?
In accordance with the regulations in force, particularly the GDPR, you have the right to access and correct your personal data, as well as the right to request its deletion, object to its processing, limit its processing for legitimate reasons, and to portability insofar as it is applicable.
You also have the right to provide instructions relating to the storage, deletion and disclosure of your personal data after your death.
In accordance with the law, you may provide:
- General instructions, which apply to all your personal data and may be recorded in a single record with a trusted digital third party certified by the CNIL;
- Specific instructions, which apply to certain personal data processing operations that you have specifically identified. These instructions must be sent to the data controllers of the processing operations concerned, such as Bardinet.
You can change or revoke these instructions at any time. In the absence of instructions, your heirs may exercise the rights of access, rectification or opposition necessary for the organisation and settlement of your estate.
These rights may be exercised by applying directly to Bardinet:
- by email to the following address email@example.com ;
- by letter to the following address: Bardinet, Domaine de Fleurenne, 33290 BLANQUEFORT, FRANCE
A response will be sent to you within a maximum of one (1) month of the date of receipt of your request.
To object to the processing of your data for marketing purposes, you can contact us as indicated above at any time to change your choices in terms of communications on the Site.
To withdraw your consent to the processing of your data by us for the purposes of customisation, behavioural and/or targeted advertising, and audience tracking, you can contact us as indicated above or change your cookie settings at any time.
You also have the right to make a complaint to the CNIL: 3, place de Fontenoy, TSA 80715, 75334 Paris Cedex 7. For more information on your rights with regard to your data, please see the CNIL website: www.cnil.fr.
Registration form for the newsletter
The User must complete all fields of the form. All information marked with an asterisk is mandatory. The User must provide this information.
Failure to do so will result in the personal User account not being created or the data entry form not being submitted. The Site will not respond to requests from the User.
What is a cookie? What is it used for?
A ‘cookie’ is a sequence of information, usually small and identified by a name, that may be sent to your browser by a website to which you connect. Your web browser will store it for a certain time, and will send it to the web server every time you reconnect.
Cookies have several uses: they can remember your customer login for an e-commerce website, the current content of your shopping basket, a login that can track your browsing for statistical or advertising purposes, etc.
The User can disable cookies stored on their device at any time. This can be done by selecting the appropriate browser settings. However, disabling cookies will prevent access to some Site functionalities allowing personalisation of the Services offered on the Site.
The different types of cookies used
• Cookies that are strictly necessary: these cookies allow you to browse on the Site and are essential for the proper functioning of the Site. Disabling them will result in problems using the Site and will prevent access to some functionalities.
• Functional cookies: these cookies remember your preferences and choices to personalise your experience on the Site.
• Performance and statistics cookies: these cookies collect information on how Users use the Site (number of visits, number of pages visited, activity of visitors) via Google Analytics and Facebook analytics tools. These cookies also allow us to identify and resolve problems with the functioning of the Site and to improve it.
• Advertising cookies: these cookies store information to send you personalised advertising tailored to your interests. They also help us keep a record of the activity of our advertising space, measure traffic, etc. Examples include cookies linked to operations relating to targeted advertising and social network trackers generated by share buttons for social networks such as Facebook, Twitter, Pinterest, YouTube, Google + and Instagram (social network plugins).
• Social network buttons: the Site provides Internet users with share buttons for Facebook, Twitter, etc. (see ‘Social network plugins’ paragraph below).
The configuration process for managing cookies and your choices is different on each browser. It is described in your browser’s help menu, which will tell you how to change your cookie choices.
Disabling cookies via the main browsers:
- Internet Explorer
1) In the ‘Tools’ menu, select ‘Internet Options’.
2) Then click on the ‘Privacy’ tab.
3) Click on the ‘Advanced’ button to display the ‘Advanced Privacy Settings’ window.
4) Tick the box ‘Override Automatic Cookie Handling’, then select ‘Reject’ and save your preferences by clicking on ‘OK’.
- Mozilla Firefox
1) In the menu at the top of the page, click on ‘Tools’, then ‘Options’.
2) Select the ‘Privacy’ tab.
3) In the ‘Storage Settings’ menu, click on ‘Use Custom History Settings’.
4) Untick the box ‘Accept Third-Party Cookies’ and save your preferences by clicking on ‘OK’.
- Google Chrome
1) In the menu, click on ‘Settings’, then on ‘Show Advanced Settings’.
2) Select the ‘Privacy’ tab, then the ‘Content Settings’ menu.
3) Tick the box ‘Block Third-Party Cookies and Data’ and save your preferences by clicking on ‘OK’.
1) In the menu at the top of the page, click on ‘Safari’, then on ‘Preferences’.
2) Click on the ‘Privacy’ tab.
3) Untick the box ‘Accept Cookies’ and save your preferences.
Disabling cookies via an interprofessional platform
You can also go to the YourOnlineChoices site, provided by digital advertising professionals who are members of the EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France. This European platform is shared by hundreds of Internet advertising professionals and acts as a central interface allowing you to express your rejection or acceptance of cookies that may be used to tailor advertising that may be displayed to your device’s browsing history.
The Site informs the User that this procedure will not prevent advertising being displayed on the websites you visit. It will only block technology that tailors advertising to your interests.
The Site uses web beacons on some of its pages that allow it to count the number of visitors to the page. These web beacons may be used with some of our business partners, particularly to measure and improve the effectiveness of certain advertising. The information collected via these web beacons is anonymous and allows us to find out how often certain Site pages are visited, in order to improve assistance to Site Users.
Social network plugins
The Site uses plugins for social networks such as Facebook and Twitter (hereinafter ‘Social Networks’). For example, if the User is logged in to Facebook when browsing on the Site, Facebook may link the visit to the User’s Facebook user account even if the User has not used the share button. If the User interacts through plugins (for example, by clicking on the ‘like’ button or leaving a comment), the relevant information will be sent and stored on a Facebook server. It will be posted on the User’s Facebook account.
The Site does not manage data collected by Social Networks via buttons. The User must read the personal data protection policy published by the Social Networks concerned to find out how the data they collect is processed and used as well as settings options to protect privacy. If the User does not want the Social Network to link information collected through the Site to the User’s Social Network user account, the User must log out of the Social Network before visiting the Site.
Security measures taken by the Site to ensure the protection of personal data
The Site uses all technical means in accordance with industry standards to maintain the integrity, security and privacy of data and, in particular, to prevent it being altered, damaged or accessed by unauthorised third parties.