The purpose of this document is to set out the conditions under which the company RP FINE WINES (hereinafter "RP FINE WINES") manages the personal data (hereinafter the "Data") of its customers and users of the website rpfinewines.com (hereinafter the "Website"), in accordance with the requirements of the Data Protection Act of 6 January 1978 and Regulation (EU) 2016/679 of 27 April 2016 on data protection (RGPD).
The RP FINE WINES Privacy Policy may be updated according to legal evolutions and/or personal data processing carried out by RP FINE WINES. If you have a Customer Account, you will be informed of such updates by sending an email or a notification in your account.
This Personal Data and Cookie Management Policy is governed by French law, and only the French language version shall be deemed authentic for the purposes of its interpretation.
Date of last update: 23 November 2023
1. DATA CONTROLLER
1. The company RP FINEWINES is the controller of personal data processing implemented through the Website, within the meaning of Article 1 of the GDPR.
EURL RP FINEWINES
Registered office: 1 Rue du Champ Carré 21190 TAILLY-FRANCE
RCS DIJON n°819 200 031
Telephone number: +33 (0)611718335
2. RP FINEWINES specialises in the distance selling and buying of wines (hereinafter the "Products"), exclusively for private individuals and legal entities not acting in a professional capacity.
The purchase or sale of Products to RP FINEWINES are subject to the prior validation of the RP FINEWINES Terms of Saleand the Terms of Use of the Site.
2. INFORMATION COLLECTED
RP FINE WINES collects several types of personal data about you:
2.1 Information supplied directly by you
1. We collect information that you communicate directly to us when you use our Site, in particular when :
• Create a Customer Account,
• You order Products on the Site,
• You sell us Bottles of wine as part of our cellar purchase service,
• You can contact our Customer Service by telephone, e-mail or chat,
• Subscribe to our newsletter,
• You are taking part in a competition,
• You are responding to a survey.
Although the provision of your personal information is voluntary and subject to your consent, we may be unable to provide you with certain products, services or information if you do not provide all or part of the information requested.
2. The categories of information we collect include:
a) Identification and contact information (such as surname, first name, date of birth, postal address, delivery address, means of contact) required to identify you when you use one of our services (e.g. creation of an online Customer Account),
b) The transactional information required to process your order (products chosen, delivery and billing address, telephone number and email address, method of payment, including in particular your bank card number and expiry date, as well as the holder of the card or bank account when you make an online payment).
c) History data relating to your online orders and your contacts with us.
3. The data that we ask you to provide and that is essential to respond to your requests is identified by an asterisk or an equivalent procedure on the collection forms, or specified as such verbally at the time of collection. If you do not fill in the compulsory fields or do not provide the information indicated as compulsory, we will not be able to respond to your requests, and in particular to process your orders for Products.
2.2 Information collected automatically
We automatically collect certain information about you when you access or use the Site or carry out a commercial transaction with us:
a) Connection data: We collect information about the device with which you connect, as well as about your use of the Site (such as the operating system, the type of browser you use, whether or not you use a proxy, the location of the device deduced from your IP address, which makes it possible to identify your device, the access times, the pages visited and the link that enabled you to access our Site).
b) Information about your browsing: We may use cookies and other tracking technologies to collect information about you when you interact with our Site or with e-mails we send you. To find out more about cookies and how to deactivate them, please refer to the provisions of article 10 of our Privacy Policy.
2.3 Information concerning third parties
We may also collect information that you provide about other people, in particular when you purchase Products on the Site and request that they be sent to someone other than yourself. We only use such information for the purposes of such communications, such as sending Products to third parties.
3. BASIS AND USE OF INFORMATION COLLECTED
The personal data described in article 2 above is collected because it is, cumulatively or alternatively :
A. Carried out on the basis of your consent
Your personal data is collected on the basis of your consent, in particular when you fill in a contact form, create a Customer Account on the Site, send us a complaint or subscribe to a newsletter, or when such consent is legally required.
B. Necessary to perform distance selling contracts concluded with you
We also use your data to meet our contractual obligations, in the context of concluding and performing distance selling or purchasing contracts concluded with you, and in particular to :
• Providing you with the Products you have ordered on the Site, purchasing Bottles of wine from you, processing transactions and invoicing, ensuring delivery, including the management of internet and payment fraud and payment incidents;
• Manage your Customer Account ;
• Offer and manage any other current or future services related to the Products.
Information relating to your orders for Products on the Site, as well as information relating to the device used to place the order (in particular the operating system used, the location of the device, whether or not a proxy is used, etc.) is collected automatically and is used to analyse your transactions for the purposes of detecting fraud and preventing non-payment.
This information may be transmitted to any third party authorised by law or designated by us for the sole purpose of verifying your identity, the validity of the order, the method of payment used and the planned delivery. If you have any questions about these checks or if your Customer Account is blocked, please contact Customer Services using the contact details given in article 9 of this document.
C. Necessary to meet the legitimate interests of RP FINE WINES
a) To dynamically manage and lead the commercial relationship, enhance the image of RP FINE WINES and promote our Products, including carrying out consumer surveys and market research.
b) To ensure your browsing on the Site and improve your user experience.
Information about your browsing is automatically collected (see article 2.2 "Information collected automatically").
c) Produce studies and statistics.
We may use the information collected for research and statistical purposes, after making it anonymous.
D. Necessary to comply with our legal obligations
Data concerning you is kept and archived to meet our legal obligations, particularly in accounting and tax matters, and to ensure the defence of our interests in the event of a dispute or legal action.
4. DURATION OF RETENTION OF YOUR DATA
Your Data will only be kept by RP FINE WINES for the time necessary to fulfil the purposes described in Article 3 above, plus the statutory limitation period.
If you are a customer of RP FINE WINES, i.e. if you have created a Customer Account, we will retain your Data for the duration of the validity of your Customer Account, plus a period of three (3) years from the closure of your Customer Account.
Your Data may be kept for a longer period, when you have placed an order on the Site, under specific legal obligations or with regard to applicable legal limitation periods. For example, data may be kept for :
• 6 years for tax documents ;
• 10 years for accounting documents ;
• For the duration of the dispute and until all avenues of appeal have been exhausted.
Data relating to the surnames, first names and addresses of customers suspected of fraud and at the origin of unpaid invoices will be recorded in a specific treatment, kept for 36 months, with a view to detecting new transactions presenting a risk of fraud.
If you are not a customer of RP FINE WINES but you have subscribed to our newsletter, we will keep your e-mail address until you unsubscribe from the newsletter.
5. DATA SHARING WITH THIRD PARTIES
To achieve the purposes described in article 3 above and within the limits necessary for the pursuit of these purposes, your Data may be transmitted to all or some of the following recipients:
a) Authorised persons within RP FINE WINES (e.g. departments responsible for marketing, research and analysis, customer service, legal affairs, accounting and tax or IT and information systems security);
b) To the payment service providers and agents of RP FINE WINES who must necessarily have access to your Data in order to carry out their duties (lawyers, chartered accountants, etc.), our advisers, or third parties authorised by law, to enable us to ensure the collection of our debts, the management of disputes, the prevention of non-payment and litigation.
c) RP FINE WINES' service providers and subcontractors are involved in the following operations, for example:
• IT services,
• Site management,
• Preparing, dispatching, transporting and tracking your orders,
• Fighting fraud,
• Customer relationship management.
d) Administrative or judicial authorities, where necessary to comply with our legal obligations or to enable us to defend our rights and interests.
In the event that all or part of the activities of RP FINE WINES are transferred, your Data will be communicated to the acquirer in order to ensure the continuity of the activity of the Website and your Customer Account.
We do not transfer any Data outside the European Union.
6. SECURITY OF PERSONAL DATA
We implement the appropriate technical, physical and organisational measures to preserve the security and confidentiality of Data and prevent it from being distorted, damaged or accessed by unauthorised third parties.
We choose subcontractors or service providers who offer guarantees in terms of quality, security, reliability and resources to ensure the implementation of technical and organisational measures, including security of processing.
Where applicable, we ensure that our service providers and sub-contractors provide guarantees and implement sufficient security measures to ensure the protection of the Data entrusted to them in accordance with the requirements of legislation on the protection of personal data.
7. YOUR RIGHTS WITH REGARD TO YOUR DATA
In accordance with the provisions of the Law of 6 January 1978 and Regulation (EU) 2016/679 of 27 April 2016 on data protection (RGPD), and within the limits set by these provisions, you have the following rights with regard to the Data concerning you:
a) Access to your Data: Exercising this right allows you to receive a copy of the Data we hold about you and to check that we are processing it in accordance with the applicable legislation.
b) Rectification of your Data: Exercising this right allows you to correct any incomplete or inaccurate information we hold about you. You also have the option of requesting the correction of any Personal Data concerning you that is incorrect and the restriction of its processing for the time required to correct it.
c) Deletion of your Data: By exercising this right, you can ask us to delete your Data if we have no legitimate reason to continue processing it. In this case, your Customer Account will have to be closed and your subscription to our newsletter terminated.
You may also request the deletion of your personal data in the following cases:
• You consider that our processing of your Data is no longer necessary, or that the fulfilment of the purposes set out in this policy or its retention is contrary to law,
• You have withdrawn your consent to the processing of your Data,
• You object to the processing of your Data,
• You oppose the use of your Data for commercial prospecting purposes.
d) Objection to the processing of your Data: where the legal basis for the processing is in our legitimate interest, you may at any time object to the use of your Data for reasons relating to your particular situation. If you exercise your right to object, we will cease processing your Data except where there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. You may also object to any processing linked to commercial canvassing, or withdraw your consent at any time, in cases where you have been asked to do so (withdrawal of your consent will not affect the lawfulness of the processing carried out prior to the withdrawal of consent).
e) Limiting the processing of your Data: By exercising this right, you can ask us to restrict the processing of your Data.
f) Portability of your Data: Exercising this right allows you to receive the Data we process about you, in a structured, commonly used and machine-readable format and to transfer it to another data controller without us interfering.
We draw your attention to the fact that even in cases where you have asked us to benefit from your right to erase or limit the processing of your Data, we may retain certain Data concerning you when the law requires or authorises us to do so, when we have a legitimate reason to do so (in particular to enable us to justify the fulfilment of orders for Products) or for the exercise or defence of legal rights.
You can exercise these rights by logging into your Customer Account.
If you do not have a Customer Account, if you cannot access it or if the rights you wish to exercise concerning your Data cannot be exercised via access to your Customer Account, please write to us at the following address: RP FINE WINES - 1 Rue du Champ Carré 21190 TAILLY-FRANCE - contact@rpfinewines.com, giving us your full name, e-mail address and, if possible, your customer reference number.
In accordance with the regulations in force, your request must be signed and accompanied by a photocopy of an identity document bearing your signature, and must specify the address to which the reply should be sent. We may ask you to provide further information in order to respond to your request. We will endeavour to respond to your request as soon as possible.
A reply will be sent to you as soon as possible.
If we are unable to respond to your requests to your satisfaction, you may also lodge a complaint with the CNIL, 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07. Tel: 01 53 73 22 22).
8. MANAGING YOUR SUBSCRIPTION TO NEWSLETTERS AND PROMOTIONAL E-MAILS RP FINE WINES
You can also unsubscribe at any time by clicking on the unsubscribe links in our newsletters and promotional emails or by replying "STOP" to any text messages you may receive.
Please note, however, that even if you unsubscribe from promotional communications, we may continue to send you non-promotional mail, calls and/or e-mails, such as those relating to your account or ongoing transactions.
9. CONTACT RP FINE WINES
For any information or questions regarding this Data and Cookie Management Policy, please contact RP FINE WINES:
- by telephone on +33 (0)611718335, Monday to Friday, 9am to 12pm and 2pm to 6pm (CET);
- by e-mail to contact@rpfinewines.com or by using our contact form;
- by post to the following address RP FINE WINES - 1 Rue du Champ Carré 21190 TAILLY-FRANCE.
10. CONDITIONS SPECIFIC TO COOKIES
Connecting to and browsing our Site implies, subject to your prior acceptance, the installation of various cookies on your device for consulting the Site (hereinafter referred to as your "Device").
A "cookie" is a file saved in the browser or on the disk of your Device when you connect to the Site. This cookie file makes it possible to identify the Device in which it is stored and thus to track the activity of the user of the Device, and to remember information, such as the user's preferences or information previously entered by the user in the forms present on the Site, for the duration of the validity or storage of the cookie.
We use two categories of cookies:
- A "Google Analytics" cookie used to measure the audience for the various contents and sections of the Site, in order to evaluate and better organise them, and in particular :
• To compile statistics and volumes of visits to and use of the various elements making up the Site (section and content visited, route taken), with the aim of improving the interest and ergonomics of the Site,
• To adapt the presentation of the Site to the display preferences of your Device (language used, display resolution, operating system used, etc.) during your visits to the Site, depending on the hardware and viewing or reading software that your Device is equipped with.
The "Google Analytics" cookie only produces and sends to Google and ourselves aggregated statistics and traffic volumes, excluding any individual information about you.
- Technical cookies, i.e. cookies that are strictly necessary for browsing the Site (such as session identifiers), as well as cookies that enable you to access specific functions, in particular to recognise you, to indicate that you have visited a particular page and thus to improve your browsing experience:
• To store information relating to a form that you have filled in on the Site (registration or access to your account) or to products, services or information that you have chosen on our Site (contents of an order basket, etc.),
• To allow you to access reserved and personal areas of our Site, such as your Customer Account, using identifiers or data that you may have previously entrusted to us,
• To implement security measures, for example when you are asked to log in again after a certain period of time,
• To adapt the presentation of the Site to the display preferences of your Device.
Cookies do not contain any personal information about you, as they only allow us to identify the Device on which they are installed.
The length of time that this cookie is stored on your device is indicated in the table below, bearing in mind that when it expires and you log on to the Site again, new cookies will automatically be placed on your device.
Nature of the Cookie Shelf life
- Google Analytics cookies 14 months
- Technical cookie 20 days
When you log on to our Site, we inform you that we use cookies by means of a banner, which refers you to these provisions so that you can find out in detail about the nature, purpose and management methods of the cookies used on our Site.
As a result, by browsing our site, you consent to the use of the aforementioned cookies. You may, however, by selecting the appropriate browser settings on your Device, reject or deactivate all or some of the cookies, it being specified that this will make it difficult, if not impossible, to use the Site.
• For Internet Explorer™: https://support.microsoft.com/fr-fr/windows/supprimer-et-g%C3%A9rer-les-cookies-168dab11-0753-043d-7c16-ede5947fc64d
• For Microsoft Edge™: https://support.microsoft.com/fr-fr/microsoft-edge/supprimer-les-cookies-dans-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
• For Safari™: http://support.apple.com/fr-fr/HT1677
• For Chrome™: https://support.google.com/chrome/answer/95647?hl=fr
• For Firefox™: https://support.mozilla.org/fr/kb/activer-desactiver-cookies
• For Opera™: https://help.opera.com/en/latest/web-preferences/#cookies
Cookie management tool specific to Google Analytics: https://support.google.com/analytics/answer/181881?hl=fr
Personal data and cookies management policy RP FINE WINES