PRIVACY POLICY

Update October 10, 2018

This document, "Personal Data Protection Charter" describes below the personal data that is collected or generated and processed when you use our website and also explains how the data is used, shared and protected, the choices and rights available to you and how to contact us.

I – IDENTITY OF THE PROCESSING RESPONSIBLE

Mr Frédéric Lener, Chairman and Chief Executive Officer, is the data controller of LENER CORDIER SA, registered in the Dunkirk RCS Trade and Companies Register under number 308199140, having its registered office at 39 rue de Merville 59529 Hazebrouck Cedex France

II - TERMINOLOGY

USER : any natural person, having a Maison Lener account, or using the Maison Lener SITE or one of the services offered on it as mentioned below.

SERVICES : this concerns the management of the commercial relationship and associated services, as well as communication and promotion actions to enable the USER to benefit from offers or obtain information on the Maison Lener brand.

SITE : this is the site http://www.maisonlener.com as well as mobile and desktop.

Collection and purposes of data processing: Maison Lener collects personal data on any USER browsing, consulting and ordering on our SITE, in particular through the use of cookies in accordance with the legislation in force.

III – USER PERSONAL DATA

3.1 Information provided by USERS

In order to place your order on our website, you create a customer account; you also contact us by phone or email or subscribe to our Newsletter, follow us and interact on our social networks. The information provided is generally the following data:

Your identification data and your contact details: your first name, your last name, your e-mail address, your billing address, your delivery address, your telephone number, the language and the country from which you connect.

Payment information related to your activity on the site: your bank details (please take into account that all payment transactions are encrypted by the receiving bank, we do not store any card number), information on your purchases, your orders, returns, etc.

Connection, geolocation and navigation data,

Profile data - if you open a customer account, which you create and use to identify yourself during your visits to our website. This data (customer ID and password, your recent purchases or your preferences) will therefore be saved.

Your personal preferences: this includes your wish list, marketing preferences and cookie preferences

Additional Personal Information - You may also provide us with other personal information such as your date of birth, gender, etc. We are the only ones to collect and store this additional information. We use them in our analyzes to improve our services.

Some required data are mandatory fields since they are data that we need to allow you to access this functionality (for example, to deliver a package to you, we need your postal address).

This personal information shared about you must be correct and up-to-date. Please inform us of any change in information regarding your personal data.

In accordance with the legislation in force, we do not store sensitive personal information.

In application of the GDPR of April 14, 2016, which entered into force on May 25, 2018, the USER gives his consent to the processing of data concerning him.

3.2 - Data obtained via cookies

We use cookies for the processing for which you have given us your consent to facilitate your navigation on our site to offer you products that correspond to your purchasing habits.

Usage data (products you have purchased from us, how you use our website and apps, etc.)

Technical data

Your IP address, search engine and version, location and time zone, browser extension, operating system and platform.

Information about your visit, including URLs and your clickstream, from and to our website (including date and time); the products you viewed or searched for; page response time, errors, time spent on pages, page interaction (such as clicks and cursor movements), how you navigate away from pages.

IV – PROCESSING OF USER PERSONAL DATA

The data collected is necessary for the following processing:

Business relationship management and customer service

Management and follow-up of commercial relations between Maison Lener and the customer (in particular operations relating to orders and their relative follow-up, deliveries and returns, payments and invoices, complaints, etc.).

This data also allows us to prevent possible fraud against you and against us during the purchase. If we consider the action to be fraudulent, this processing may allow us to block the transaction. Any order over 2000 euros will be blocked.

You can delete or modify your account at any time by making a request to us in accordance with article 7 of the GDPR law.

Marketing actions

Your consent for any direct marketing is essential. You can also unsubscribe from our communications at any time (for example to unsubscribe from the newsletter, simply click on the button "If you no longer wish to receive the newsletter, click here" present at the bottom of all our newsletters and confirm your unsubscription).

In the event that you have given us your consent to receive direct marketing content, via our newsletter, we may use the information you have provided to us for the following purposes:

Sending commercial prospecting: We use your data to manage your subscription and send you targeted information via e-mail or SMS according to the preferences you have mentioned.

Sharing information relating to our events, information and product launches, services and specific offers

Provision of sharing buttons to social networks

Implementation of promotional actions

Production of audience measurement statistics and marketing studies to meet your expectations and improve our quality of service.

V - ACCOUNT CREATION, FORMS, QUESTIONNAIRES AND NEWSLETTER SUBSCRIPTION

5.1 – Account creation

The USER must fill in all the fields of the account creation form or any form for entering information on the Site with the exception of the fields displayed as optional, that is to say not marked with an asterisk. Optional information is collected by Maison Lener and allows us to know the USERS of the Site better.

All information marked with an asterisk is mandatory. The USER must answer it.

Any lack of response will result in the non-creation of an account or the non-validation of the information entry form. Maison Lener will not respond to USER requests.

5.2 - Maison Lener newsletters

When creating their account and later when managing their preferences via the "My Account" section, the USER can subscribe to the Maison Lener newsletter and thus choose to be informed at regular intervals of the offers offered on the Site. He has the possibility at any time to modify the information of his unsubscribe account by clicking on the link provided for this purpose, located at the bottom of each of the newsletters. This link is also accessible on the SITE in the “My account” section.

VI - DATA MANAGEMENT WITH THIRD PARTIES

The data collected is intended for the use of Maison Lener. Data may be transmitted subject to a confidentiality agreement:

To banks and payment services in order to make the payment,

To delivery companies in order to deliver your order,

In case of suspected fraud to a fraud prevention agency to verify your credit and identity,

The data may also be processed by subcontractors that Maison Lener uses in the context of the activities mentioned in Article IV.

We require third parties to undertake to respect the security of your personal information in accordance with the law. Third parties may only use your personal information on our instructions and not for their own use.

VII - RIGHT OF ACCESS, RECTIFICATION AND DELETION

7.1 – Legal bases

When you buy products from our site, we need your personal data to perform the contract between us and you. For example, we need your contact details to deliver your order:

Postal mail and telephone number

The customer's postal address and telephone number are necessary for the processing and management of orders as well as for commercial relations between Maison Lener and the customer.

We also rely on other legal grounds such as your legitimate interests. For example, we consider it to be in your interest that:

Your identity cannot be used for fraudulent purposes,

Our customer service people have access to your order information to serve you better,

We can better understand your use of our site to improve its ergonomics and the services we offer you

We respect the importance given to consent in the new GDPR regulation

7.2 – Consent

Consent must be given clearly and unequivocally. So when you agree to receive our communications:

We explain the use we will make of your data and the type of communication you will receive

You must tick a box confirming your consent to subscribe

Children under 13 cannot give their consent

You can withdraw your consent at any time. If you wish to unsubscribe from our direct marketing via newsletter, you can unsubscribe at any time by clicking on the link at the bottom of each e-mailing.

If you have a customer account on our website, you can also unsubscribe or change your preferences by logging into your profile.

At any time, the customer has the possibility of opposing it in a simple and free manner on the Site in the “My account” section or by mail to the following address: LENER CORDIER – Service Maison Lener - 39, rue de Merville - 59190 HAZEBROUCK.

Cookies (including those in banner ads) require specific opt-out.

SMS / mms

Maison Lener may use the customer's mobile phone number for order management and may also use it for commercial prospecting purposes. At any time, the customer has the possibility of opposing it in a simple and free manner on the Site in the “My account” section or by mail to the following address: LENER CORDIER – Service Maison Lener s - 39, rue de Merville - 59190 HAZEBROUCK

Alerts

The identified USER can register for size and model alerts offered by Maison Lener. He can at any time unsubscribe from the alerts to which he has subscribed in the "My account" section of the SITE. Size alerts are automatically deactivated if there is no restocking after a period of 3 months.

Notice

This service allows the customer to post a review on the Site for a purchased product and to share their experience. Posted notices are publicly accessible and available on the Site at any time. The customer authorizes Maison Lener to publish and communicate on the Site its opinion on the product. The notice must not constitute a message of a defamatory, abusive, tortious, vulgar, slanderous nature with regard to third parties, natural or legal persons, racist, inciting discrimination, undermining the honor / reputation of others , violent or pornographic, and more generally, not in accordance with the legislation in force.

As such, Maison Lener reserves the right to delete any review that does not comply with the provisions mentioned above.

7.3 Other rights

In accordance with the amended Data Protection Act of January 6, 1978, and in accordance with Regulation (EU) 2016/679 of April 27, 2016 relating to the protection of individuals with regard to the processing of personal data and to freedom of movement of this data, the USER has a right of access, rectification, deletion and opposition for legitimate reasons, as well as a right to be forgotten and a right to the portability of said data. You can exercise them, subject to the provision of proof of identity to the following electronic contact details:

rgpd@lenercordier.fr

or send us a letter to the following address:

LENER CORDIER – Service Maison Lener s - 39, rue de Merville - 59190 HAZEBROUCK

Maison Lener has a period of 1 month from receipt of the USER's request to respond to it.

If you have a customer account, you can also modify your personal details from your customer area by identifying yourself using your email address and your password.

Maison Lener uses this personal data for commercial prospecting purposes. At any time, the customer has the possibility of opposing it in a simple and free manner on the Site in the “My account” section or by mail to the following address: LENER CORDIER – Service Maison Lener - 39, rue de Merville - 59190 HAZEBROUCK.

VIII - DATA STORAGE DURATION

8.1 - General

Maison Lener keeps the data for a period of five years from the end of the relationship with the client or prospect. The period starts from either the last order, or the last connection to the customer account, or the last call to customer service, or the sending of an email to customer service, or a click on a hypertext link an email sent by Maison Lener, or the placing of products in the basket without the purchase being made, or finally a positive response to an email asking if the customer wishes to continue to receive commercial prospecting on the expiry date of the five-year period. At the end of this period, the data of the customer or prospect will be deleted.

Nevertheless, the information allowing to establish the proof of a right or a contract, or kept for the respect of a legal obligation can be archived in accordance with the legal provisions in force.

8.2 - Fate of personal data after death

Maison Lener informs the USER that he can define, during his lifetime, directives relating to the storage, erasure and communication of his personal data after his death. These directives can be general or specific. The USER may modify or revoke his instructions at any time. To do this, the USER can contact LENER CORDIER – Service Maison Lener - 39, rue de Merville - 59190 HAZEBROUCK.

IX - COOKIES

9.1 Cookie definition

A cookie is a small text file that is placed or stored on your device (computer, tablet or mobile device) when you visit a website. The cookie allows a site to recognize you, help you navigate from page to page on a website, provide secure connections and remember your preferences on future visits.

Maison Lener uses cookies to recognize the USER (customer or not) when connecting to the Site. Maison Lener also uses the "Local storage" of the browser which has the same operating principle as cookies. The action of deleting cookies also deletes the "Local storage" of the browser.

9.2 Deleting cookies

The USER may at any time deactivate the cookies stored on his terminal. To do this, he just has to select the appropriate settings in his browser. However, this deactivation will result in preventing access to certain features of the Site allowing the services offered by Maison Lener to be personalized.

9.3 The different types of cookies used

Strictly necessary cookies: these cookies allow you to browse the Site and are essential for the proper functioning of the Site. Their deactivation will cause difficulties in the use of the Site and will result in preventing access to certain functionalities.

Functional cookies: these cookies make it possible to memorize your preferences, your choices in order to personalize your experience on the Site.

Performance and statistics cookies: these cookies collect information on how USERS use the Site (number of visits, number of pages viewed, visitor activity) via market analysis tools These cookies provide us with also make it possible to identify and resolve problems with the operation of the Site and to improve it.

Advertising cookies: these cookies record information to send you personalized advertisements adapted to your areas of interest. They also help us to count the activity of our advertising spaces, to measure the audience, etc.). For example, cookies related to operations relating to targeted advertising, social network tracers generated by social network sharing buttons such as Facebook, Twitter, Pinterest, Youtube, Google +, Instagram (Social plugins).

Partner cookies: these cookies placed on the terminal by partner companies make it possible to identify the items consulted or purchased on the Site and to collect navigation data in order to personalize the advertising offer which is addressed to the USER outside the Site. As part of this type of advertising partnership, Maison Lener may be required to transmit to the partner data concerning the articles consulted by the USER during his navigation on the site as well as the nature of his purchases. The USER can refuse these cookies at any time by selecting the appropriate parameters in his browser. This refusal will result in preventing access to certain features offered by Maison Lener's partner companies.

Social network buttons: Maison Lener provides Internet users with sharing buttons such as Facebook, Twitter (see paragraph “Social network plugins” below).

9.4 Cookie management

For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to know how to modify your wishes in terms of cookies.

Disabling cookies via the main browsers:

internet explorer

1) In the “Tools” menu, select “Internet Options”

2) Then click on the "Privacy" tab

3) Click on the “Advanced” button to bring up the “Advanced privacy settings” window.

4) Then check the box "Override the automatic management of cookies", then select "Refuse" and save your preferences by clicking on "OK".

Mozilla Firefox

1) In the menu at the top of the page click on “Tools”, then “Options”

2) Select the “Privacy” tab

3) Configure the "Retention rules" menu, click on "use custom settings for history"

4) Uncheck the “accept third-party cookies” box and save your preferences by clicking “OK”.

Google Chrome

1) In the menu, click on “Settings” then on “Show advanced settings”

2) Select the “Confidentiality” tab then the “Content settings” menu.

3) Check the box “Block cookies and data from third-party sites” and save your preferences by clicking “OK”.

Safari

1) In the menu at the top of the page, click on “Safari”, then “Preferences”

2) Click on the “Privacy” tab

3) Uncheck the "Accept cookies" box and save your preferences.

9.5 Web beacons

Maison Lener uses web beacons on certain pages of the Site which make it possible to count the number of visitors to the page. These web beacons may be used with some of our business partners, in particular to measure and improve the effectiveness of certain advertisements. The information collected via these web beacons is anonymous and makes it possible to know the frequentation of certain pages of the Site, in order to better assist the USERS of the Site.

9.6 Social media plug-ins

The Site uses social network plugins such as Facebook, Twitter (hereinafter “Social Networks”). For example, if the USER is connected to Facebook when browsing the Site, Facebook may directly link his visit to his Facebook USER account even if the USER has not used the share button. If the USER interacts by means of the plugins, for example by clicking on the "Like" button or by leaving a comment, the corresponding information will be transmitted and stored on a Facebook server. They will be published on the USER's Facebook account.

Maison Lener does not manage the data collected by Social Networks via the buttons. The USER must read the policy relating to the protection of personal data published by the Social Networks concerned, in order to know the methods of processing and use of the data collected by the latter as well as the possibilities of settings which he available to protect their privacy. If the USER does not want the Social Network to link the information collected through Maison Lener to his USER Social Network account, he must disconnect from the Social Network before consulting the Site.

X - SECURITY MEASURES TAKEN BY MAISON LENER TO ENSURE THE PROTECTION OF PERSONAL DATA

10.1 – Securing personal data

Maison Lener implements all technical means in accordance with the rules of the art to maintain the integrity, security and confidentiality of the data and in particular to prevent them from being distorted, damaged, or from unauthorized third parties having access to them.

Our website has appropriate security measures in place to prevent the risk of loss, unauthorized use or access, modification or disclosure of your personal information. All data you provide to us is stored on secure servers. Maison Lener has implemented procedures to manage any personal data breach.

In particular, when placing the order, no bank details are collected or stored by Maison Lener. Maison Lener uses the services of PCI-DSS certified service providers to ensure payment security.

All of our service providers work within the European Economic Area (EEA) and must therefore comply with the same legislation as us.

10.2 - Prevention and fight against fraud

The data collected is also used in the context of the prevention and fight against fraud, particularly with regard to bank cards. Maison Lener reserves the right to verify the personal data communicated by the customer when placing the order and to adopt all the measures deemed necessary to verify that the person whose bank account is debited is indeed the one who placed the order. the order, in order to avoid any fraudulent payment. This verification may take the form of a request for proof of identity and/or residence.

In the absence of a negative response from the customer, Maison Lener reserves the right to cancel the order placed by the customer.

In the case of an account creation, you have chosen a password. We recommend that you choose a sufficiently strong password and remind you that you are responsible for keeping this password confidential.

We recommend that you only connect to secure networks, preferably private networks. Be aware of the risks incurred on public wifi networks.

If you receive an email claiming to be our brand requesting personal information or an update to that information, please do not respond and forward that email to us so that we can take the necessary action.