PRIVACY POLICY
This privacy policy ("Policy") is intended to inform you about how MINUTY collects and processes your personal data when you use our online services, sign up for our newsletter on our website or when you visit the winery, create an account on our website or place an order online.
This Policy is also intended to inform you of your rights in relation to your personal data. It is therefore important that you read it and any other specific information we may provide to you from time to time when we collect and process your personal data.
- The data controller
The company MINUTY SAS, a simplified joint stock company with a capital of 273.273,000, registered in the Fréjus Trade and Companies Register under number 597 180 488, whose registered office is located at 2491 route de la Berle - 83580 GASSIN, hereinafter referred to as "MINUTY", is the data controller within the meaning of the regulations applicable to personal data, and in particular Law No. 78-17 of 6 January 1978, known as the "Data Protection Act", and EU Regulation No. 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("RGPD").
In this Policy, the terms "we", "us" and "our" refer to MINUTY.
- The origins of the collection of your personal data
The sources of collection of your personal data are :
- The contact form that you can fill in when you visit our cellar;
- The contact form that you can fill in online to receive our newsletter;
- Creating your online account;
- Purchases you make online on our site.
- The personal data we collect
In the course of providing its services, MINUTY collects and processes the following categories of personal data about you:
- Identification data, such as your first name, last name and password;
- Login data, when you log in to your account ;
- Contact data (billing and delivery, if different), such as your email and postal addresses and your telephone number;
- Transaction and order tracking data, when you make online purchases (order information, description of products purchased, quantities, amounts, payment methods, possible application of discounts or promotional offers).
This data is collected according to the MINUTY services you use and for the purposes described in article 4 below.
Where we need to collect personal data from you (under a legal obligation or contract we have entered into with you, or intend to enter into with you, such as in the context of an online purchase and sale) and you do not provide such personal data when requested, we may not be able to provide you with the services you require. The mandatory nature of the data is indicated at the time of collection by an asterisk.
- The purposes of processing personal data
The purpose of the processing corresponds to the objective pursued by the use of your personal data. MINUTY collects and processes your personal data in order to :
- Allow you to create an account on our site, access and manage your account;
- Send you our newsletter;
- Process and manage the orders you place online;
- Respond to your requests to exercise your rights.
- The legal basis for processing your personal data
We collect and process your personal data when :
- The processing of your personal data is necessary for the execution of the contractual relationship between you and us, as is the case for the management of orders that you place online;
- The processing is necessary to comply with a legal obligation to which we are subject, for example in the context of product recall or withdrawal procedures or for the accounting processing of your orders;
- The processing is necessary for the pursuit of our legitimate interests, in particular when we send you marketing emails about the same or similar products that you have previously ordered online;
- You have given your consent, in particular for the sending of our newsletter.
- The recipients of your personal data
In order to provide our services, we may communicate your personal data internally to a limited number of people and departments authorised to have access to it and transmit or give access to your personal data for technical, logistical or commercial reasons to our hosting provider, development and maintenance of our site, our service provider in charge of sending the newsletter and commercial prospecting, our service provider in charge of the development and maintenance of the customer relationship management platform as well as to payment service partners and carriers in charge of delivering orders placed online.
MINUTY may also communicate your personal data to third parties when such communication is required by law, a regulatory provision or a judicial decision, or if this communication is necessary to ensure the protection and defence of its rights.
- Data transfers outside the EEA
MINUTY ensures that no transfer of personal data to a country outside the European Economic Area (EEA) is carried out by it or by its partners or subcontractors in the absence of an adequacy decision issued by the European Commission or the implementation of appropriate and adequate safeguards to ensure the security and protection of your personal data, such as the European Commission's standard contractual clauses.
- How long your personal data is kept
Your personal data is kept by MINUTY for the time necessary to achieve the purposes for which it was collected.
In determining the appropriate retention period for your personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk arising from unauthorised use or disclosure of the personal data, the purposes for which we process your personal data and our legal obligations. Please note that for the purpose of sending marketing emails, MINUTY will only retain your personal data for a period of 3 years after your last interaction with MINUTY.
To meet our tax and accounting obligations, we retain personal data of a transactional nature (and associated identification and contact data to the extent required for these purposes) for the statutory limitation period after an individual ceases to be a customer.
During the period of storage of your personal data, MINUTY puts in place all the necessary and appropriate means to ensure the confidentiality and security of your personal data, against any risk of deletion, alteration of these data, or access by unauthorised third parties.
- Your rights
Depending on your personal situation, you have the rights listed below in application of the RGPD and the Loi Informatique et Libertés.
Right of access: You have the right to obtain confirmation that we are processing personal data about you. Where applicable, you have the right to access the personal data we hold about you. This gives you the right to receive a copy of your personal data and certain information about the processing of your personal data.
Right to Correction: You have the right to ask us to correct your personal data if it is inaccurate or out of date. If you have created an online profile, you can correct your information at any time by visiting your account.
Right to erasure: In certain circumstances, you have the right to request the erasure of your personal data. Please note that your personal data can only be deleted when it is no longer necessary for the purposes for which it was collected and we have no other legal basis for processing it.
Right of restriction: You may request that we restrict the use of your personal data in certain circumstances, such as where the data is not or is no longer required, or where you have challenged the accuracy of the data, until we can verify its accuracy.
Right to portability: We will provide your personal data to you, or to a third party chosen by you, in a structured, commonly used and machine-readable format. Please note that this right only applies to your personal data that we process in an automated way (i) with your consent or (ii) in the performance of a contract with you.
Right to object: Where we process your personal data on the basis of a legitimate interest, you may object to such processing where your particular circumstances so warrant. In some cases, we may not comply with your request if we demonstrate that our legitimate interest prevails. You also have the right to object to the processing of your personal data for direct marketing purposes at any time and without justification.
Withdrawal of your consent: If the processing of your personal data is based on your consent, you have the right to withdraw it at any time. In particular, if you wish to unsubscribe from any mailing list (newsletters, commercial prospecting) at any time, you can do so by clicking on the link at the bottom of all our communications.
Fate of data after death: You may also formulate instructions concerning the retention, deletion and communication of your personal data after your death.
You will not be charged a fee to access your personal data or to exercise any of the other rights mentioned above. However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. We may also refuse to comply with your request in these circumstances.
We may ask you for specific information to help us confirm your identity so that we can respond to your request to exercise one of your rights.
We try to respond to all legitimate requests within one month. Sometimes it may take longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will inform you and keep you informed of the progress of your request.
- Contact us
If you have any questions about how we use your personal data or wish to exercise any of the above rights, you can contact us by email or post:
- MINUTY SAS, 2491 Route de la Berle - 83580 Gassin
You also have the right to lodge a complaint about the processing of your personal data with the French data protection authority (the CNIL: www.cnil.fr).
- Security measures
We are committed to taking the necessary and appropriate measures to ensure the protection, confidentiality and security of your personal data.
To this end, we have put in place technical measures (such as firewalls) to protect your data against unlawful or accidental destruction, alteration or loss, misuse and unauthorised access, alteration or disclosure.
In addition, organisational measures (such as systems for managing access rights etc.) are in place to safeguard the confidentiality of your personal data. Thus, access to your personal data is strictly limited to our staff, who are expressly authorised, and to our partners and subcontractors, who are themselves acting on our instructions and in accordance with our contractual stipulations and the applicable legislation.
- Policy updates
We may revise the Policy from time to time. We will ensure that the most recent version is posted on the site. When material changes are made to the Policy, we will notify you in advance by posting a notice online or sending you an email. Changes will take effect at least one month after they are posted or communicated to you in advance.
The Policy has been updated to March 31, 2022.
