Privacy policy

1

Introduction

Welcome to the privacy policy of Delta Dore SA (Delta Dore). This policy is for UK citizens.

Delta Dore respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. The policy also gives you information on how Delta Dore collects and processes your personal data through your use of this website. This includes when you agree to receive marketing data, purchase a product or participate in a competition or other promotional activity.

This policy regulates the rights of UK citizens whose personal data we process. This is either to sell to them our goods; send to them marketing material or allow them to participate. Visitors to our site from other countries should access the portal which relates to their country.

If you are a UK citizen:

  1. The processing of your personal data is conducted in France and subject to the General Data Protection Regulation (GDPR). Accordingly, the processing of personal data by Delta Dore may evolve according to the legal and regulatory context set by the European Data Protection Board and the recommendations of the Commission Nationale de l'Informatique et des Libertés;
  2. As Delta Dore’s business and the regulatory regime evolves Delta Dore will update the privacy policy. We will inform visitors to our website and those to whom we market of any changes;
  3. Your privacy rights are protected by the UK privacy legislation (this mirrors the GDPR);
  4. Delta Dore has appointed a data protection officer to manage how personal data is processed;
  5. Should you have any queries as to our data processing or wish to exercise your rights as a data subject then please contact our UK branch. The UK branch will deal direct on your behalf with Delta Dore and where necessary on Delta Dore’s behalf with the ICO. The contact details are as follows: privacy@deltadore.com

This website is not intended for children and we do not knowingly collect data relating to children.

You will receive marketing communications from us if you have requested information from us or agreed to receive these communications and you have not opted out of receiving that marketing. At any time you can contact us requesting that you no longer receive marketing information.

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Important information and who we are

Controller

Delta Dore is the data controller and responsible for your personal data. Delta Dore has a capital of 2,227,496 euros, located in Le Vieux Chêne - 35270 BONNEMAIN, registered with the Saint-Malo Trade and Companies Register under number 897 080 289.

Your personal data is also accessible to Delta Dore’s partner companies, in order to enable you to fully benefit from the services offered, provided that you have consented to the communication of your data.  Delta Dore is responsible for the data collected for all its subsidiaries. When we share your personal data with our partner companies, we ensure that they provide sufficient guarantees to implement appropriate technical and organisational measures to ensure compliance with applicable data protection laws.

Changes to the privacy policy and your duty to inform us of changes

As referenced above we keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

When you place an order to buy our products or complete an online form, you will disclose to us :

  • Surname
  • First name
  • Email address
  • Phone number
  • Address
  • Order numbers and date of purchase
  • Content of your request messages

In addition, we process personal data related to your browsing and use of our Sites and Online shop (https://shop.deltadore.co.uk). This data is largely collated by "Cookies" and our policy regarding the use of cookies. In particular, we collect the following data :

  • IP address (internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website)
  • Preferences (details about payments to and from you and other details of products and services you have purchased from us)
  • Login data (username and password)
  • Navigation data (information about how you use our website, products and services)
  • Marketing and communications data (your preferences in receiving marketing from us and our third parties and your communication preferences). 

We also collect, use and share “aggregated data” such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate data regarding your use of the site to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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How is your personal data collected ?

We use different methods to collect data from and about you including through :

  • Direct interactions. When you place and order you will give the identity data outlined above.
  • Participatory interactions.  When using any type of form on the Websites or Online shop (e.g. after-sales service form, form to request the exercise of rights, newsletter registration etc.); when you contact us (e.g. telephone, email, social networks); when you leave comments (e.g. forum, social networks, blog); and when you use the live chat on the Websites and Online shop.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect the data re IP addresses and browsing actions referred to above.
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Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purposes of Processing

Data Collected

Retention Period

Order management

Identification data

Order data

5 years from the end of the execution of the contract

Response to customer requests and solicitations

Identification data

Order data

3 years from the last contact

Sending commercial communication

Identification data

3 years from the last commercial activity

Sending prospecting messages

Identification data

3 years from the last contact

Statistics

Navigation and login data 

Variable, maximum 13 months

Understanding of customer usage

Navigation and login data Preferences

Variable, maximum 13 months

Proper operation of the Sites and Online shop

Navigation and login data 

Variable, maximum 13 months

Manage litigation and pre-litigation 

Identification data

Order data

Your data is stored for the duration of the procedure and is then archived in accordance with the statutory periods of limitation.

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Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

The retention periods have also been determined with regard to our business needs. The nature of our products being one off purchases which are upgraded as technology evolves and the technical queries we receive throughout the product’s life dictates the retention period.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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Basis of processing

Your personal data is processed for the purposes of managing, executing and following up orders placed on the Online shop, including preparing and dispatching the order, issuing and sending invoices relating to the orders and in order to comply with our legal and/or regulatory obligations.

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances :

  • Where we need to perform the contract (namely the sale terms) we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. This processing includes but is not limited to :

               a)      studying the feedback we get from our customers regarding our products;

               b)     running our business, provision of administration and IT services, and network security;

               c)      in the context of a business reorganisation or group restructuring exercise;

               d)     understanding customer needs in relation to our products;

               e)     keeping our website updated and relevant;

               f)      developing our business and to inform our marketing strategy. This includes using your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you.

 

  • Where you have given us your consent. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product/service experience or other transactions.
  • Where we need to comply with a legal obligation. This includes dealing with any regulatory or law enforcement organisation and maintaining financial records.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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Disclosures of your personal data

We may share your personal data as follows :

Internally :

a)  the sales department, in particular to ensure our relationship and the management of your orders 

b)  the marketing department, in particular to improve the Products and Services, to carry out statistical analyses of the use of our Products and Services or to send you commercial or prospecting messages

c)   the customer relationship management service, in particular to accompany you, help you and respond to your requests

d)   the legal department and senior management, in particular to organise our defence in the context of a dispute or in the context of an audit or a procedure initiated by a supervisory authority

 

External Third Parties.

a)  Mollie.com for processing your payment and related processing;

b)  Salesforce.com, for customer relationship management and related processing;

c)  Kiamo.com, for the call centre, the interaction forms and our contact chat;

d)  Mailchimp, for the operational management of our prospecting and newsletter;

e)  SurveyMonkey, to manage our satisfaction surveys;

f)   Shopify, for the creation of the Online shop and the storage of data;

For some of our products or services, this privacy policy may be supplemented by specific privacy rules, for example, for processing related to your Smart Home installation including the Tydom Application.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9

International transfers

Save for arranging delivery of products and our dealings with our UK branch we do not transfer your personal data outside the European Economic Area (EEA). Should that change then we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

10

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We undertake, in particular with the support of companies qualified PASSI by the ANSSI, to guarantee the security, integrity, quality and confidentiality of the information automatically collected when you visit the Sites and the Online shop. To this end, we have opted to set up strong technological partnerships with companies that have security certifications and whose security practices are regularly audited. The subscriptions taken out with these operators guarantee availability rates and data backup and recovery functions that protect our customers against data loss and disruption to their Services.

We evaluate and upgrade these security measures on a frequent basis. You are regularly notified of developments relating to our solutions and their operation. You must accept these notifications in order to integrate the latest services and functionalities as well as security features.

11

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data :

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at the following address: privacy@deltadore.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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Contact

▪ By post:

DELTA DORE
DPO
Le Vieux Chêne
35270 BONNEMAIN
FRANCE

▪ By email:

privacy@deltadore.com

Last update : 26/01/2021