1. PURPOSE OF THE PRIVACY POLICY

This privacy & cookies policy (the "Privacy Policy") is published by the KEYPROD company (the "Company") whose legal notice is available on the "Legal notice" tab.

The purpose of this Privacy Policy is to set forth the terms and conditions under which the Company collects and processes information provided by users ("Users") via the website accessible at www.keyprod.com ("the Site"), including:

information relating to personal data communicated by the User via the Site, in particular via the personal account that the User has the possibility of creating (the "Personal Account") in particular in order to place orders ("the Orders");

information obtained by the use of trackers (or cookies) placed on the Site.

This Privacy Policy is not intended to govern the terms and conditions of the processing of information provided by the User to third party sites, including Interface Sites as defined in the terms of service (TOS).

2. ACCESS TO THE SITE AND ACCEPTANCE OF THE PRIVACY POLICY

Access to and use of the Site shall be subject to the following cumulative conditions:

• • The terms of service, available at the following link: the "TOS";
  • This Privacy Policy;

The User is informed of the possibility of restricting access to this Site to minors by means of content filtering software or by modifying the computer settings (via the operating system or the browser).

No personal data of minors will be collected via the Site. In the event that the Company becomes aware of, or legitimately believes that certain personal data communicated via the Site is personal data of minors, the Company will use its best efforts to delete such data and will not retain any copies of it.

3. PERSONAL DATA

3.1 Definition

Personal data is data that identifies or makes identifiable a natural person. 

In France, personal data processing is determined by the General Data Protection Regulation n°206/679 called "GDPR" and the French Data Protection Act as amended (hereinafter the "Applicable Regulations"). 

In accordance with the Applicable Regulations, the Company is responsible for processing personal data collected via the Site (the "Data").

3.2 Type of data collected 

The Company colletcs via the Site : 

• • Data directly communicated by the User, in particular via his Personal account; and
  • Data automatically generated by the Site or obtained from third parties

3.2.1 Data directly communicated by the User

This includes, for example, the following Data:

• • Identity and contact details (such as surname, name, postal address, telephone number, e-mail address),
  • Demographic data (such as date of birth, age or age range and gender)
  • Online registration data (username, password and other authentification information)
  • Payment data (such as credit card information, billing adress)
  • Data provided through online questionnaires (such as answers to satisfaction survey or market research) 

3.2.2 Data communicated collected/generated automatically or obtained from third parties

This Data may relate to the device used to log on to the Site (such as computer, PC, tablet, cell phone), the use and navigation of the Site and third party sites ("Interface Sites") to which the Site links.

This includes, for example, the following Data:

• • Data relating to the operating system, the browser used, the IP address,
  • Data relating to the unique usernames associated with the device used, 
  • Data relating to the Internet pages visited,
  • Data relating to products viewed online (including information about products searched or viewed, purchased or added to an online shopping cart)
  • Data relating to the time spent on certain parts of the Site, or an Interface Site or an application, including the date and the time of the visit
  • Data appearing on User-generated content (such as blogs and social media posts),
  • Identification and profile data for social networks (photograph, number of followers etc.)
    
    
    

3.3 Mode of Data collection

3.3.1 Data directly communicated by the User

Data may be communicated directly by the User via the Site, for example in the following situations: 

• • participation in an intervention, a promotional event; 
  • response to an online questionnaire on the Site (satisfaction survey, market research)
  • request for information from the Company 
  • sending messages of any kind to the Company 
  • communication with the Company via social media
  • creation of a customer account on the Site
  • use of an Interface Site
  • publishing reviews or comments online on the Site 

Before providing any Data, the Company shall inform the User as to whether the Data is mandatory or optional, as well as the consequences of refusing to provide the mandatory Data.

3.3.2 Data communicated collected/generated automatically or obtained from third parties

When the User consults or uses the Site, the Interfaces Sites, as well as certain third-party websites of which the Company is a partner, the Company uses tracers (cookies and similar technologies) that automatically collect information from the device used.

The Company also uses certain automated Data processing technologies to infer or generate additional information about the User, for example by analyzing or predicting certain personal aspects, such as preferences or interests.

The User is informed that, when they log on to the Site, and each time they visit a web page, the User's IP address is automatically reported to the Company by the browser. IP addresses are generally recorded in files called "log files".

The Company may also obtain Data through the services of third parties with whom the Company has entered into partnerships, and for which these third parties have obtained the User's permission to share it with the Company. Examples include sponsorship, newsletters, etc.

Finally, the Company may obtain Data when it is publicly available (directories). 

3.4 Purposes of Data processing

The Company collects and processes the Data for the following purposes: 

Communicate with the User by text message or e-mail, for example to inform them of new products and services, or to propose special offers (for example, on the occasion of their birthday). The User is informed of the possibility offered to them to oppose at any time the sending of these communications;

Evaluate customer reactions and comments regarding the products and services marketed by the Company, to evaluate the impact and effectiveness of marketing campaigns or promotional operations, to analyze the number and types of visitors to the Site. The processing of this Data is carried out exclusively on Data that has been previously anonymized;

Display advertising that is best suited to the profile of Users using the Site through online behavioral advertising and programmatic advertising techniques, and to determine whether the User using the Site is a member of a social networking platform in order to display advertising on that platform and/or to identify prospects with similar interests and characteristics to the User of the Site. These techniques imply that certain Data are communicated to the Company's service providers. The User is informed that they may at any time refuse that their Data be used for targeted online advertising purposes;

Monitor digital advertising to ensure that it does not appear on inappropriate third-party sites or near inappropriate content, and that it is visible to and seen by real people online (and not by "robots" or similar fraudulent techniques); 

Send information or products to a third party upon request by the User, for example when placing a gift order. It is the responsibility of the User who placed the order to ensure that the recipient is authorized to consume alcoholic beverages according to the legislation applicable to them;

Authenticate access to the Site to determine what content may be displayed on the Site (for example, by verifying the age or location of the user of the Site);

Authenticate the author of any request (question, claim, exercise of rights) by asking for proof of identity;

Allow the Company to disclose the Data to any entity involved in a sale, merger, consolidation, change of control, transfer of substantial assets, financing, reorganization and/or liquidation; 

Provide services to the Users of the Site, for example distance of selling services or products, which implies to process Data of banking nature to fill the Personal account and to manage the on-line transactions;

Inform the User of any changes to the Site, the Terms of Service (TOS), the Terms & Conditions of sale and/or this Privacy Policy;

Enable the Company to comply with its legal obligations and its security and audit requirements;

Allow the Company to defend its interests, including in court, particularly against any attack on the integrity of the Site;

Enable the Company to administer the Site, to diagnose operational problems, which problems may be related to IP addresses controlled by a specific internet company or internet service provider ("ISP").

3.5 Legal basis for Data processing

The Company processes Data only on one of the following legal bases:

• • Consent: this is the case when the User's consent is requested prior to the processing of their Data. The User is informed that they can withdraw their consent at any time, for example by clicking on the "unsubscribe" link at the bottom of each marketing e-mail they receive;

• • Legitimate interest of the Company: this is the case when the Company uses the Data to better understand the needs and expectations of its prospects and customers, while preserving the interests and fundamental rights of the persons concerned.

3.6 Recipients of the Data

The Data is primarily intended to be processed by persons who are employees of the Company, employees of one of the Company's subsidiaries, or employees of one of the companies in the group to which the Company belongs.

Where necessary, the Company may disclose Data to third-parties.

This may include the following individuals:

• • service providers, subcontractors and other partners of the Company, such as: social media platforms, search engines, advertising agencies, credit institutions, IT development and maintenance companies, web hosting and management companies, legal, accounting, auditing and other professional service providers related to the Company's business provided that such service providers and subcontractors and partners have entered into written agreements with the Company, and do not process Data for any purpose other than to provide services to the Company ;
  • third parties involved in a sale, merger, consolidation, change of control, transfer of substantial assets, financing, reorganization or liquidation of the Company, any of its subsidiaries, or any of the companies in the group to which the Company belongs; 

• • public or judicial authorities, government agencies, regulatory agencies or other third parties to comply with applicable law, or to detect, protect or defend the interests of the Company. 

3.7 International transfers of Data

Data may be tranferred outside the European Economic Area.

In this case, the Company undertakes to take all measures to preserve the confidentiality and security of the Data by relying on Data transfer mechanisms approved by the European Commission (such as "standard contractual clauses") to ensure that the Data are subject to equivalent protection measures in the receiving country.

At any time, the User may ask the Company for a copy of the protection measures taken to secure the transfer of their Data outside the European Economic Area by sending a request by email to the following address: rgpd@keyprod.com 

3.8 Data security

3.8.1. Data communicated on public forums

The attention of the User of the Site is drawn to the fact that all the publications are visible by all the Internet users having access to the Site, and are consequently non-confidential, in particular the possible data of a personal nature (such as name, first name, personal address, identifier, e-mail address, telephone number) published by the User of the Site on or via the public forums 

The User is informed that such personal data published on or via the public forums may be collected and used by others, resulting in unsolicited messages or other forms of contact, or any other damage. 

Therefore, it is strongly discouraged to publish personal data on or via public forums. 

3.8.2. Data communicated via the Site

Data security is one of the Company's priority.

To this end, the Company has implemented proper physical, technical and organizational measures to protect the Data collected via the Site.

However, the User is informed that the security of the Internet network cannot be fully guaranteed. Thus, during the transit phase of the Data, the Company cannot exercise any control over the confidentiality and security of communications. It is therefore recommended not to include any Data, and in general any information, of a proprietary, confidential or sensitive nature in such communications.

In the event that the security of the Site appears to be compromised, for example if the User has reason to believe that their Personal Account has been hacked, they must immediately inform the Company via the following e-mail address: rgpd@keyprod.com 

In the unlikely event of a breach of security of Data, the Company will contact the persons concerned in a timely manner by email, using the email address provided by the User via their Personal Account. In this regard, the User shall ensure that the Data in their Personal Account is accurate and up-to-date.

3.9 Rights of the User on their Data 

The User is informed that they have the following rights on their Data, under the conditions and within the limits provided by the applicable Regulations:

• • the right to withdraw consent at any time when the processing of their Data is based on consent;
  • the right to object to the processing of all or part of their Data;
  • the right to request the limitation of certain Data processing;
  • the right to access their Data and to receive a copy of their Data in a structured, commonly used and machine-readable format;
  • the right to request the deletion of their Data;
  • the right to request any rectification of their Data;
  • the right to arrange for the disposition of their Data after their death;
  • the right to file a complaint with the Commission Nationale Informatique et Libertés ("CNIL") under the conditions set forth below.
    
    

These rights can be exercised directly with the Company by e-mail at rgpd@keyprod.com or by post at the following address: 66 avenue des Champs Elysées 75008 PARIS

Proof of identity may be requested.

Any complaint may be lodged with the CNIL (information available at www.cnil.fr ). 

However, before any claim, the User is invited to contact the Company at the following address: rgpd@keyprod.com. The Company undertakes to do its utmost to resolve the difficulty encountered by the User.

3.10 Data retention period

The Data is kept by the Company for the period of time required to achieve the purposes described above, unless a longer retention period is required or permitted by the applicable Regulations. 

 At the end of the retention period described above, the Data will either be deleted or, in some cases, made anonymous.

4. COOKIES

The Company uses cookies, scripts, pixel tags, web beacons and similar technologies (collectively "Cookies") to collect and store information about users of the Site and certain third party sites with which the Company partners. 

4.1 Definition

A cookie is a string of textual information that a website transfers to the cookie file of the browser on the hard drive of the device used to browse the Site. A cookie typically contains the name of the domain from which it originated, its lifetime, and a value, usually a randomly generated number. 

The Company uses two types of cookies:

• • Internal Cookies that are sent directly to the device when the Site is consulted; 
  • Third-party Cookies used by a third party on behalf of the Company a visitor visits the Site or third-party sites that the Company partners with.

These Cookies can be divided into session cookies or persistent cookies.

• • Session Cookies are temporary cookies that remember the User's choices and preferences and are then deleted when the User leaves the Site;
  • Permanent Cookies remain in one of the browser's subfolders until they are manually deleted or until they expire.

4.2 Purposes of cookies

The Cookies are used by the Company for the following purposes: 

4.2.1 Proper functioning of the Site

These Cookies are strictly necessary to browse the Site and use its features (such as shopping cart, electronic billing, personal account, etc.). Without these Cookies, the Site cannot function properly.

Strictly necessary Cookies include Content Management Cookies that are required by the Site for the proper functioning of the content management system, and Template Preference Cookies that are required for mobile versions of the Site and give the Site the desired appearance.

4.2.2 Site funcitioning

These are Cookies that allow the Site to remember the User's choices (such as the User's name, the language used, the User's location) and thus provide improved and personalized functionalities (comment area, video playback etc.). 

These Cookies can also be used to remember changes made by the user to the pages of the Site that can be personalized.

The information collected by these Cookies can be made anonymous and cannot track the user's browsing activity on other sites.

Theses Cookies automatically expire after thirteen (13) months.

4.2.3 Advertising and marketing

These Cookies allow us to offer the User more relevant content adapted to their interests, depending on their previous browsing on the Site, the keywords obtained from the URLs of the Internet pages from which the User accessed the Site, the IP address, and the search engines used to access the Site.

These cookies may also be used to serve online advertisements based on the User's interests. These Cookies remain on the computer and remember the sites visited by the User. These cookies can be deleted manually.

The Company also uses third-party Cookies to analyze visits to specific sections of the Site and to collect certain information regarding product purchases (contents and amount of the shopping cart, pages viewed, etc.)

The Company may use social network sharing plug-ins and Cookies. The social network sharing plug-in connects the User to sites such as Facebook™, Twitter™, Instagram™ and LinkedIn™ and allows interaction between activity on social networks and on the Site as directed by the User, for example, using the Facebook username and password to log in to the Site, and using the Facebook "Like" and "Share" buttons on the Site.

When the User browses a page of a social network managed by the Company, it is likely that Cookies are also installed on their device. These Cookies are defined by the social network itself. To modify these Cookies, it is necessary to modify the settings provided by the social network.

4.3 Cookies management

There are different ways to manage Cookies on the Site.

4.3.1 Cookie Preference Center (CPC)

When visiting the Site for the first time, the Company asks the User for their preferences regarding Cookies via the CPC. Thanks to the CPC integrated at the bottom of the page under the name "Manage my cookies" and accessible on each page of the Site, the User can choose to accept or refuse his consent to Cookies that are not strictly necessary for the functioning of the Site.

On the CPC, each Cookie is presented by purpose and, depending on the case, can be accepted or rejected by activating the switch that appears in each section. The user also has the option of checking the box "accept all" or "delete all".

In case of inaction of the user during the first visit, only the Cookies strictly necessary for the functioning of the Site will be installed.

The User may disable these Cookies at a later time via the browser settings as described below.

4.3.2 Browser settings 

The User has the ability to accept or decline Cookies by modifying their browser settings (such as Google Chrome™, Mozilla Firefox™ or Microsoft Edge™).

The User is advised to follow the instructions or help screen of their browser to learn more about the Cookie management features offered by their browser. If all Cookies are disabled, some features of the Site may not work.

If the User is using a mobile application, the mobile device's operating system (e.g., Apple iOS™, Google Android™ or Microsoft Windows™) provides privacy settings that manage how mobile applications use technologies similar to Cookies to recognize the device and, in some cases, make interest-based advertising available in mobile applications.

The User is encouraged to follow the instructions or help screen of their mobile operating system to learn more about the privacy management features offered.

5. CONTACT

Any inquiries regarding this Privacy Policy should be sent to: rgpd@keyprod.com

6. APPLICABLE LAW

This Privacy Policy is governed by French law.

7. COMPETENTE COURT

In the event of a dispute arising between the Company and the User relating to this Privacy Policy and/or resulting from access, operation or use of the Site which could not be resolved amicably, the French court shall have sole jurisdiction to hear the dispute. 

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