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General Data Protection Policy (GDPR)

General Data Protection Policy (GDPR)

1. INTRODUCTION

The following information is communicated to you so that you can be aware of the personal data protection commitments of Original Dulce - which acts as data controller for the processing of personal data mentioned in this document.

Original Dulce is committed to a policy of respecting and maintaining high standards in terms of ethics and in particular the protection of personal data.

On the site https://originaldulce.com/ the company Original Dulce implements the processing of personal data as data controller. The identity and contact details of the Original Dulce are specified in the “legal notices” section of the said website.

The purpose of this personal data protection policy is to inform you about the way in which this data is processed by Original Dulce and the extent of your rights.

It may change depending on the applicable legal and regulatory context.

2. PRINCIPLES APPLICABLE TO PERSONAL DATA

The Original Dulce company is committed to respecting the following principles in the context of the collection and use of personal data.

2.1 Legitimate and proportionate use of your data

Personal data is collected permanently by Original Dulce for specific, explicit and legitimate purposes.

The personal data collected by Original Dulce cannot be used subsequently in a manner incompatible with the initial purposes for which they were collected.

For each processing operation, Original Dulce undertakes to collect and process only data that is strictly necessary for the objective pursued.

2.2 Fair and transparent collection

For the sake of loyalty and transparency vis-à-vis users of the https://originaldulce.com/ site and members of the Original Dulce loyalty program, it takes care to inform the persons concerned of each processing that it implements by information notices.

These data are collected fairly; no collection is carried out without the knowledge of the persons concerned and without their being informed. 

2.3 Relevance adequacy and minimization of data collected

The personal data collected is strictly necessary for the purpose pursued by the collection. Original Dulce strives to minimize the data collected and to keep it accurate.

The personal data collected is updated regularly and stored by Original Dulce in its secure databases.

2.4 Protection of personal data by design and by default

Original Dulce has adopted internal policies and processes and implements measures that respect the principles of protection of personal data by design and protection of personal data by default.

Thus, when developing, designing, selecting and using applications, services and products that rely on the processing of personal data, Original Dulce takes into account the right to protect personal data or makes sure with their publishers that they meet legal requirements and ensure the protection of the data that will be processed there.

As such, for example, Original Dulce uses pseudonymization and encryption techniques for personal data whenever possible or necessary.

3. THE PROCESSING OF YOUR DATA

3.1 Legal bases and purposes of processing

The company Original Dulce implements various processing operations whose legal bases are as follows: contractual performance, your consent, its legal and regulatory obligations, and its legitimate interest. 

The purposes associated with each legal basis are listed below:

Based on the execution of the pre-contractual measures taken at your request and/or on the execution of the contract you have signed, we implement processing for the following purposes:

management of the loyalty program, which involves:

- registration for the loyalty program, including in particular the creation of the account or the loyalty card, the management of the recognition of the loyalty card when you present it in the spaces participating in the program and the provision of your loyalty personal space;

- the implementation of the collection and use of your loyalty benefits when you go to checkout in participating areas; - access to services specially reserved for you, as a member of the loyalty program, with partners, on simple visual presentation of the card.

the management of your orders on the website https://originaldulce.com/

the management of our relationship with you, as users of the website https://originaldulce.com/


Based on your consent, we implement processing for the following purposes:

the sending of communications relating to promotions and offers personalized or not, by post or electronic means, including by mobile notifications;

the sending of communications on any medium such as the websites or mobile applications of the company Original Dulce, the websites of Original Dulce or the websites or third-party applications that you may consult; 

the management of cookies subject to consent;

the management of your participation in our contests;

transferring your purchase history data so that Google can create a personalized shopping list when you use Google Assistant's built-in voice shopping service. Google can thus offer you products corresponding to your purchasing habits thanks to the analysis of the purchases you have made on the site https://originaldulce.com/, via the Google application or directly in-store in using a loyalty card. This service is not necessary to place an Original Dulce On Board order . You always have the option of doing this directly from the website. Your Original Dulce On Board and Google accounts can be disconnected at any time.  

Based on compliance with our legal and regulatory obligations, we implement processing for the following purposes:

general accounting management;

the management of responses to official requests from public or judicial authorities empowered for this purpose;

compliance with the regulations applicable to our activity;

keeping invoices and other mandatory documents relating to transactions in accordance with our obligations;

information for members of the loyalty program and users of the https://originaldulce.com/ website  concerning product recalls;

management of requests to exercise rights.

Based on our legitimate interests, we implement processing for the following purposes: 

the management of your requests for information and complaints; 

the prevention and fight against fraud, also including the management of the consequences of this fraud;

the establishment of any means of proof necessary to defend our rights;

the production of statistics and analyzes with the aim of improving the offer of the loyalty program and the use of the site https://originaldulce.com/; 

the production of statistics and analyzes to improve our products and services;

the management of cookies not subject to consent; 

the use of your data in your capacity as a customer, member of the loyalty program or user of the site https://originaldulce.com/ in order to be recognized as such with other services offered by other companies in the Original Dulce group ;  

keeping computer traces to prevent security incidents.

The purposes pursued on the basis of our legitimate interests are pursued with respect for your rights and freedoms.

3.2 Data collection 

The company Original Dulce undertakes vis-à-vis the users of the site https://originaldulce.com/ to collect and process only the data necessary for its activities. As a result, Original Dulce collects various personal data about you.

The association of Original Dulce On Board and Google accounts allows the personalization of the shopping list for the purpose of using the integrated voice shopping service of the Google Assistant. In this context, Google shares your name, email, and profile photo with Original Dulce to ensure the technical linking of the accounts. Original Dulce will only use this information for the purposes of the technical link between the accounts.

 

3.3 Persons concerned

The persons concerned by the processing carried out by Original Dulce are:

customers and prospects of Original Dulce;

users of the Google Assistant's integrated voice shopping service with a Original Dulce user account ;

any user of the https://originaldulce.com/ website.  

3.4 Data recipients

To achieve the purposes described above and within the limits necessary for the pursuit of these purposes, the data collected by Original Dulce may be transmitted to all or part of the recipients.

3.5 Data retention periods

The Original Dulce company keeps the personal data it collects only for the time necessary for the purposes of the processing and in accordance with the applicable legislation.

The data collected by the Original Dulce company will thus be kept for the time necessary to fulfill the purposes described above, plus the period of legal prescription.

3.6 Security of your data

Original Dulce attaches particular importance to the security of your personal data.

It has implemented technical and organizational measures adapted to the degree of sensitivity of the personal data, in order to ensure the integrity and confidentiality of the data and to protect them against any malicious intrusion, any loss, alteration or disclosure to third parties. unauthorized third parties.

The company Original Dulce regularly carries out audits in order to verify the correct operational application of the rules relating to data security.

Thus, it undertakes to take the physical, technical and organizational security measures necessary to:

protect its activities; 

preserve the security of the personal data of users of the site https://originaldulce.com/,

against any unauthorized access, modification, distortion, disclosure, destruction or access to the personal data it holds.

Nevertheless, the security and confidentiality of your personal data are based on everyone's best practices, so you are invited to remain vigilant on the issue.

3.7 Transfer of data outside the European Union

The different categories of data collected and processed within the framework of the https://originaldulce.com/ site   may be transmitted to service provider companies located in countries outside the European Union such as the United States.

These data transfers are governed by a cross-border flow agreement drawn up in accordance with the standard contractual clauses from controller to processor issued by the European Commission and currently in force. 

4. YOUR RIGHTS AND HOW TO EXERCISE THEM

4.1 The content of your rights

You have the following rights related to the data concerning you:

permission to access ; 

right of rectification; 

right to erasure;

right to define directives relating to the fate of your data after your death, and this with a trusted third party, certified and responsible for enforcing your wishes, in accordance with the requirements of the applicable legal framework. 

Under the right of access, Original Dulce may ask you to pay reasonable fees based on administrative costs for any additional copy of the data to that will be communicated.

You also have:

a right to obtain the restriction of processing;

a right to the portability of the data provided; 

of a right of opposition.

4.2 The right to object

You can ask to exercise your right to oppose the processing of personal data concerning you for reasons relating to your particular situation when the processing is based on the legitimate interest of Original Dulce. This right of opposition also applies to profiling. 

In the event of the exercise of such a right of opposition, the company Original Dulce will cease the processing except when there are legitimate and compelling reasons for the processing which prevail over your interests, rights, and freedoms or for the observation, the exercise or defense of legal claims. 

You can also object to any processing related to prospecting without it being necessary to invoke reasons relating to your particular situation.

4.3 Exercising your rights

The communication of specific post-mortem directives and the exercise of your rights are carried out by e-mail to the address support@originaldulce.com, specifying the information allowing your identity to be established.

4.4 Withdrawal of consent

You can also withdraw your consent at any time, in cases where it has been requested.

4.5 Submitting a complaint

If you believe, after contacting us, that your rights to your data have not been respected, you can file a complaint with the National Commission for Computing and Liberties tel.: +1 (833) 463-8523.

 

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