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Personal data and cookies

Personal data and cookies charter

PERSONAL DATA AND COOKIES POLICY FOR THE AELIA DUTY FREE SITE

Last updated : 30/09/2019

 

  1. Personal Data section
  2. Cookie section
 

This policy (hereinafter the "Policy") informs any natural person who navigates through the site available at the following url www.aeliadutyfree.com (or its variants by country)  (hereinafter the “Site”) and uses the services as described in the General Conditions of Use of the Site (hereinafter the "Services") about the processing of his/her personal data resulting from his/her navigation and use (hereinafter the “User/Users”).

The processing are carried out by the company Lagardère Duty Free, a simplified joint-stock company with capital of 5,853,930 Euros, whose head office is located at 4-6 avenue d’Alsace, 92 400 Courbevoie, listed in the Trade and Companies Register of Nanterre, under no. B 380 253 518, (hereinafter the “Company”), belonging to the “Lagardère Travel Retail Group” and acting as a data controller. The Company is determined to respect the privacy of its Users and protect their personal data.

The Policy may be amended at any time by the Company, depending on the legal and regulatory context, and to keep the User informed about changes in the Company personal data processing practices.

The Company therefore recommends that the User always becomes acquainted with the latest version of the Policy before using the Services, by clicking on the “Personal Data and Cookies Policy” icon at the bottom of the home page of the Site.

The Policy must be read in accordance with the General Conditions of Use of the Site (hereinafter the “GCU”), especially concerning some specific terms which are defined in the GCU and are mentioned with an uppercase.

I. DATA PROTECTION

A. Processing for which the Company is responsible

When navigating through the Site and using the Services, the User’s personal data are collected by the Company, and processed.

This Policy informs the User about all the processing which are carried out by the Company and especially about:

-      The categories of personal data which are collected by the Company;

-      The objectives of the collection of this personal data (purposes);

-       About his/her rights and how to exercise them in relation to the data controller;

-      The individuals who receive these personal data (recipients).

1) What categories of personal data are collected?

The Company collects the information that the User discloses to the Company directly when the User uses the Site and the Services.

 This is for instance the case when the User creates an account online, subscribes to receive the Company newsletters or makes a reservation using the Click & Collect services.

 The Company collects the following personal data directly from the User: 

-          Identification information, such as Surname, First name, Date of birth, Country of residence and Nationality, needed when the User contacts the Company or wants to beneficiate from the Services;

-          Contact information, such as Email address and Telephone number, needed to respond to the User’s requests;

-          Information about the User’s flight, such as Flight number, Flight date, airline company, needed when the User makes a reservation;

-          Reservation-related information needed (items chosen, delay to pick up the item, airport outlet where the User can pick up the item);

 

-          Data concerning the monitoring of the commercial relationship (reservation number, the chronology of the User’s reservation, his contacts and requests or his correspondence with the Company’s customer services).

 

The personal data that are indispensable for the Company to fulfil the purposes described behind are highlighted in the various pages of the Site. Should the User not disclose those data in the mandatory fields, the Company may not be able to respond to the User’s requests and/or supply the User with the services that he wants. All other data is merely optional and enables the Company to know the User better and to improve the way in which the Company communicate with the User and the services that the Company provides to the User.

In the framework of the Company policy on quality and of a constant improvement of the Company Services, the Company will also collect the information the User submits when he contacts the Company customer services.

Other personal data are collected automatically when the User accesses the Site or uses the Services:

-          Connection data concerning the terminal used: IP address, the type of browser and various information about the User’s browsing of the Site are also gathered for purposes of administration and/or to generate statistics, as detailed in the Cookies section ;

 

-          Information about the User’s browsing habits: the Company uses cookies and other tracking technologies to gather information concerning the User, such as his preferences and interests.

 

2) Why does the Company collect the User’s personal data?

The User’s personal data are only gathered when the Company has a legal basis for doing so.

The personal data collected in the context of the Site and the Services is subject to processing, with the aim of achieving the following purposes:

A/ To provide the User with Services and fulfil the reservation that the User places, and to comply with the Company contractual obligations, and in particular:

  • To enable the User to create an account and make a reservation of the Company products online;
  • To manage the User reservation and enable the User to pick up the product at the outlet of the User’s departure or arrival terminal;
  • To enable the Company to contact the User in case of any difficulties related to the User’s reservation;
  • To manage any other service, whether current or future, in connection with the Services and registered in the corresponding General Terms of Use;

B/ Based on the User’s consent, e.g.:

  • To send the User information about the Company offers, news and events;
  • To improve the operation of the Site by generating statistics, to personalise the interface of the Site based on the User preferences, and for the purposes listed in the Cookies section;

C/ For the legitimate interests of the Company:

  • To enable the Company to contact the User to respond to any claim or requests and to give any assistance that may be necessary
  • To manage the Company relationship with the User by keeping an up-to-date centralised database of the Company’s existing and potential User;
  • To ensure the security of the Site.

For all these purposes founded on the Company’s legitimate interest, the Company takes into consideration any potential impact that the gathering of this personal data may have upon the Users of the Site. Should the Company believe that the User’s interests or his fundamental rights and freedoms transcend the Company legitimate interests, the Company will refrain from using the User’s personal data on this basis and may ask the User for his consent on a case by case basis.

3) The recipients of the personal data collected

The User’s personal data will only be transferred or made accessible to any third party in order to operate the Site and to ensure the continuity of the Services provided.

Data transferred to the authorities and/or public bodies:

In accordance with regulations in force, personal data may be forwarded to the competent authorities on request, and in particular to public bodies, solely in order to satisfy legal obligations, and to court officers, ministerial officers and bodies responsible for the recovery of debts, and also in the context of the search for the authors of violations committed on the Internet.

Data transferred to third parties:

The authorized staff of the Company (such as personnel operating the Site or working in the Company’s outlets) and other companies of the Lagardère Travel Retail Group shall have access to the personal data collected, solely in the context of the use of the Services or based on the User’s consent.

For example, when the User contacts the Company through the form “customer care”, any information related to his/her request may be transferred to other entities of the Lagardère Travel Retail Group in order to manage this request.

Personal Data may be transferred to the Company’s subcontractors or services providers who are involved in a purely technical or logistical capacity (providers of hosting and maintenance services to the Site for example).

The User’s personal data may be transferred outside the territory of the EU to our outlets, entities and services providers located outside the European Economic Area, in countries where the applicable data protection rules and regulations differ from those that are applicable within the European Economic Area, such as Australia and New Zealand.

These transfers shall only take place where this is necessary to deal with the User’s requests and to provide the Services.  

These transfers shall only take place subject to appropriate guarantees designed to ensure a sufficient level of protection to the User’s privacy and fundamental rights, such as the signature of the standard contractual terms adopted by the European Commission. A document detailing the guarantees put in place by the Company shall be disclosed immediately upon receipt of a request sent to the Company.

4) The rights of the User

Access and rectification

The User has the right to access his/her personal data and to request the rectification or the destruction of any data that should turn out to be inaccurate. Should the User have a client account, he/she may directly access the data contained in his/her online account and rectify/eliminate it where applicable, as well as access his/her choices in terms of newsletters.

 Other rights

 Erasure. The User may also request the erasure of his/her personal data provided that it is no longer necessary for the Company to keep it.

 Object. The User can also object the processing of his/her personal data or request the restriction on such processing, unless the processing is necessary for the management of the Services that the User requests.

Withdrawal of consent. Where the processing of the User personal data is based on his/her consent, he/she may withdraw this consent at any time. It includes the right to request to no longer receive newsletters from the Company by using the hypertext link that is included for this purpose in each e-mail that the Company sends to the User.

 Portability. The User may moreover exercise his/her right to portability, i.e. obtain, in a structured, machine-readable form, the personal data that he/she provided to the Company directly on the basis of his/her consent or of a contract drawn up and signed with the User and that that is undergoing automated processing.

 Directives. The User may also let the Company know his/her instructions regarding the preservation, erasure and disclosure of his/her personal data after his/her death and modify these directives at any point in time.

The User has the right to register on the ‘bloctel’ list to object to the use of cold calling http://www.bloctel.gouv.fr/.

The User may make a claim with the CNIL, following the process set out on its site (https://www.cnil.fr) or with the data protection authority of the Country in which the User habitually lives, works, or where the alleged violation of his/her personal data took place.

These rights may be exercised at any time by contacting the Company via the “Contact us” section on the Site (select subject “Personal Data) or by sending an email to donneesperso-dfa@lagardere-tr.com or by sending a letter addressed to Data privacy Department - Lagardere Duty Free - 4-6 Avenue d’Alsace, 92400 Courbevoie – France .  The User may be asked for proof of his/her identity.

5) Period of time for which personal data will be stored

Users’ personal data will not be kept for any longer than the period of time strictly necessary for the purposes set out herein, in accordance with personal data protection regulations and the applicable laws.

Personal data will not be kept for any longer than the period of time strictly necessary for the provision of the Services, i.e. throughout the entire duration of the contractual relationship between the User and the Company and for a period of three years as of the date of the last contact between the User and the Company.

The User’s personal data is deleted when these periods expire. Nevertheless, personal data may be stored for longer than the periods stipulated for the keeping records.

7) Security

The Company has put suitable organisational, technical and administrative measures in place to protect personal data from any destruction, loss, alteration or unauthorised disclosure.

The Company takes every effort to protect the personal data, taking account of the sensitivity of the information in question and the potential risks associated with a data leak. The Company takes every appropriate measure to guarantee the confidentiality, integrity, availability and resilience of personal data, stores personal data in information systems that offer a suitable level of security, to which access is protected, restricted and recorded, and the Company concludes strict confidentiality agreements with all persons involved in the processing of personal data on its behalf.

8) Contact

The User can contact at any time the Data Protection Officer by sending an email to   donneesperso-dfa@lagardere-tr.com or by sending a letter addressed to Data privacy Department - Lagardere Duty Free - 4-6 Avenue d’Alsace, 92400 Courbevoie – France.

 

 

II. COOKIES

(i)                  What is a Cookie?

A cookie, and all similar tracking files (hereinafter "Cookie(s)”) are tracking files which can be saved on the User’s device (computer, tablet device, smartphone) when he/she uses the Service using browser software, via the Site.

Cookies enable the party that issues them, throughout their validity period, to recognise the device in question each time it accesses digital content that incorporates cookies from the same issuer, and, depending on the Cookie, to collect additional information about the User’s behaviour while using the Service. 

(ii)                Who uses Cookies?

Cookies may be put in place by the Company, by its technical service providers or by its partners.

(iii)               Why are Cookies left on the Company's Site

Cookies enable the Site to operate effectively, and to remember the preferences of the User, and provide the Company and its partners with information for statistical or advertising purposes.

  • BROWSER COOKIES:

These Cookies are necessary for the User to be able to navigate properly around the Site and for the proper functioning of the Applications; they are useful, in particular, to:
- Adapt the presentation of the Site to the display preferences of the User’s device (language used, image resolution, operating system used, etc…);
- Memorise information related to the User’s login details;
- Offer the User access to his/her account or to any other reserved space through his/her login details;
- Put security measures in place, for example when the User is asked to reconnect to a piece of Content or a Service after a certain period of time has elapsed.

  • STATISTICAL AUDIENCE-MEASURING COOKIES:

Audience-measuring cookies help to draw up statistics and figures on the visiting and use of the various constituent parts of the Site (sections and content visited, path followed), enabling the Company, in particular, to make the Services more interesting and user-friendly. 

  • FRAUD-DETECTION COOKIES

Third parties may deposit Cookies which make it possible to counteract advertising fraud.

  • SOCIAL MEDIA COOKIES

Social Media Cookies result in the transfer of information about the User browsing on the Site and information about his/her identity to the social networks concerned. These cookies enable to link the User’s activity on the Site with the personal data previously held by the social network concerned. The Company invites the User to read the privacy policies of the social networks concerned.

(iv)              Consequences of the User’s refusal of Cookies

Disabling Browser Cookies will prevent the User from using the Site under normal conditions and to beneficiate from the Services.  

Disabling Statistical Audience Measuring Cookies, Fraud-Detection Cookies and Social Media Cookies has no consequence on the use of the Site or Services.

(v)                Period of storage

Cookies allow its issuers to identify the device on which it is stored for as long as the Cookie is valid or stored, that means 13 months maximum.

(vi)               How can these be checked?

  • THE AGREEMENT ON COOKIES

The User has given his/her consent:

  • By clicking on the icon "I agree" in the information banner visible the first time he/she connect to the Site;
  • By managing his/her choices concerning Cookies when clicking on the icon “Manage your consent for each purpose”;
  • MAKING CHOICES

Some Cookies are deposited on our Site by the Company or its technical service providers and operated by the Company; others are issued and operated by third-party partners.

The Users may, however, express their choices to the Company's partners and, at any time, configure their browser software in such a way that Cookies are saved on the device or, on the contrary, rejected, either automatically, or depending on who issues them.  Users may also configure their browser software in such a way that they may promptly accept or reject Cookies, before a Cookie can be saved on their device. 

  • Making choices regarding Cookies deposited by third parties:
  • ON NAVIGATION COOKIES

-          Insofar as the User’s device is able to visualise the content developed with the Flash script, the User can access its tools for managing Flash Cookies, directly from the website http://www.adobe.com/fr/

  • ON STATISTICAL AUDIENCE-MEASURING COOKIES

Google Analytics: https://tools.google.com/dlpage/gaoptout?hl=fr

  • ON FRAUD-DETECTION COOKIES
  • Making choices regarding Cookies issued by the Publisher or on its behalf:

Managing cookies

  • Other ways of making your choices:

VIA YOUR ONLINE CHOICES:

Users may connect to the site Youronlinechoices, offered by professionals in digital advertising, grouped together in the European association EDAA (the European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France. Users may thus familiarise themselves with the companies registered on this platform which offer the option of refusing or accepting the Cookies used by these companies to adapt the advertisements which may be displayed on their devices to Users’ browsing information: http://www.youronlinechoices.com/fr/controler-ses-cookies/

VIA ABOUTADS:
This site, create in English, also enables Users to express their online choices via the following link: http://www.aboutads.info/choices/.

VIA THE BROWSER SETTINGS

When it comes to managing Cookies, each browser has different settings. The settings are described in the browser's help menu, which will enable Users to find out how to edit their preferences as regards cookies:

For Internet Explorer™ :
http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

For Safari™
https://support.apple.com/kb/H19214?locale=fr_FR&viewlocale=fr_FR

For Chrome™ :
http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647

For Firefox™ :
http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

For Opera™ :
http://help.opera.com/Windows/10.20/fr/cookies.html

 

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