Privacy Policy - Ganador

PRIVACY POLICY

NEOVIA a simplified joint stock company with a capital of 30,589,692 euros, is located in Talhouët – 56 250 SAINT NOLFF, registered in the Vannes Trade and Companies Register under number 636 320 038, validly represented by Mr. Pierre-Christophe DUPRAT, Chairman, is the controller of the data collected on the website https://asia.ganador-petfood.com (Here in after “Website”),

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, relating to the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “GDPR”) and with the French Law of 6 January 1978 relating to computers, files and freedoms (together the “Laws in force”), NEOVIA has established this Privacy Policy, which is intended to govern the processing of personal data (the “Personal data”) of the users of the website, (hereinafter the “Users” or “You”) created by NEOVIA in the framework of the services provided / the presentation and the sale of products online by NEOVIA through the Website (the “Services”).
Countries that are members of the European Economic Area are individually or collectively referred to as “EEA member countries”.

CONTACT DETAILS OF THE DATA CONTROLLER

NEOVIA, simplified joint-stock company (“société par actions simplifiée”) with a capital of 30,589,692 euros,
Registration number: 636320038 RCS VANNES, VAT No.: FR 29636320038;
Head office: Talhouët; 56250 SAINT NOLFF France

EU Data Protection Officer

c/o ADM Germany GmbH

Ferdinandstraße 5

20095 Hamburg

Germany

Telephone: 0049 (0) 40 3013 774

Mail : info-gdpr@adm.com

PERSONAL DATA PROCESSED AND PURPOSES OF THE PROCESSING

NEOVIA only collects and uses Personal Data to the extent necessary:

to inform Users of products or services that may be of interest to them, through personalised electronic communication, in particular via newsletters relating to users’ areas of interest and with their prior consent ;
to register and process orders, deliver products, process payments and communicate with users in connection with their orders within the framework of the established contractual and/or pre-contractual relationship ;
to provide functionalities, analyse performance, correct errors and improve the accessibility and effectiveness of the Website / Services, on the basis of NEOVIA’s legitimate interest ;
to present personalised advertisements, recommend features, products and services that may be of interest to Users, identify their preferences and personalise their experience, with their prior consent ;
for evidential purposes and to comply with the legal obligations to which NEOVIAis subject ;

(the “Purposes”).

Your data are collected at the moment your contact form is submitted and/or your subscription request is made for the newsletter and/or your order is placed for an online purchase, as well as during your visits to our Website/use of the Application as part of the use of cookies, when you have accepted them (see below under Article 3).

In the context of the Purposes mentioned above, the Personal Data is collected from Users in the following manners:

through the contact form: Last name, first name, e-mail and postal address, Company Name, phone number and other data submitted by the User
through the application for subscription to the newsletter: e-mail address , last name and first name
through the navigation on the Website : User information such as IP address, device type and browser, time zone, location, and information about how users interact with our services, such as what features are used and which buttons are clicked
through an online order : last name, first name, e-mail address, bank details (No credit card number, delivery address)

In cases where Users’ Personal Data are processed for Purposes other than those mentioned above, NEOVIA would inform the Users in advance of these new Purposes in accordance with applicable Laws.

In any case, NEOVIA may freely use the collected data, as long as they are anonymised (i.e. processed in such a way that the person concerned is not or no longer identifiable).

COOKIES

A cookie is a block of data that is used to record information about users’ navigation on the Website.

Cookies retain your settings for our Website/Application, such as your preferred language or location. This allows us to present you with personalised information corresponding to your needs.

Cookies may contain a wide variety of information, including personally identifiable information. However, this (personally identifiable) information may only be retained if you provide it yourself to the Website/Application.

NEOVIA uses three types of cookies on the website.

cookies with functional purposes ;
cookies with analytical purposes ;
targeted advertising cookies.

Functional cookies (i.e. those necessary for the proper functioning of this Website) that we create allow us:

to identify you when you log on our Website ;
to adapt the presentation of our Websites, Applications and advertising spaces to the display preferences of your device (language used, display resolution, operating system used, etc.), according to the hardware and the visualization or reading software used by your device;
to make your searches easier by saving your automatic searches;
to improve your user experience by pre-filling for you certain fields in our forms.

These cookies are kept for a maximum of 13 months.

The analytic cookies that we create allow us to analyse the use of the Website and to improve our user experience by establishing statistics and volumes of site visits and usage (topics and contents visited, etc.).
These cookies are kept for a maximum of 13 months.

When you visit our website, we may, after you have given your consent, place cookies on your device/or allow third party partners to place cookies, in order to create user segments based on your interests and to provide you with targeted advertising content relevant to you and your interests on our Website/Application, on the Website of a third party partner, or through a personalised electronic communication.
Targeted advertising cookies are also used:

to limit the number of times you see an ad and to help measure the effectiveness of an ad campaign ;
to allow us or to allow the third party partnerto know if a user who saw an advertisement subsequently visited the advertiser’s site and took an action (for example, subscribing to a newsletter) ;

Targeted advertising cookies are kept for a maximum of 60 days.

Any User not wishing to have cookies stored on their computer will be able to block all cookies or some of them, if applicable (since the cookies necessary for the proper functioning of the Website cannot be refused if the User wants to visit our Website), by modifying the parameters of his or her browser.
The links below indicate the procedure for each browser:

PERSONAL DATA OF MINORS

NEOVIA’s Services may be/may not be intended for minors under 16 years of age. Therefore, NEOVIA will not knowingly collect information from minors under the age of 16. It is the responsibility of the parents and of any person exercising parental authority to decide whether their minor child is authorised to use NEOVIA’s Services, and to expressly consent thereto.

LEGAL BASIS AND RETENTION PERIOD

The processing of Users’ Personal Data is justified by different bases (legal basis) depending on the use we make of the Personal Data. You will find below the legal bases and retention periods that we apply to our data processing.

Legal basis of the data processing
Among the applicable legal bases:

The contract: The processing of Personal Data is necessary for the performance of the contract to which you have agreed.
Consent: You agree to the processing of your Personal Data by express consent. You may withdraw this consent at any time.
Legitimate interest: NEOVIAmay have a commercial interest in processing your data that is justified, balanced and does not infringe upon your privacy.

Retention period
NEOVIA will store the Personal Data of the Users as long as NEOVIA will need such Personal Data to fulfil the Purpose(s), except when a longer storage time is required by law (for example to fulfil tax or accounting obligations), or is specifically demanded by a competent administrative or judicial agency.

The legal basis and the retention period of your Personal Data varies according to the nature of the data and the purpose of their collection.

Collected data	Purpose of the data processing	Legal basis	Retention period	Observations
Data relating to your credit card	Management of the orders of products or services	Contract	13 months (or 15 months if it is a deferred debit card)	Data are kept by our payment provider until full payment and for the management of the after-sales services (reimbursement in case of complaint). Your card’s cryptogram is only kept for the duration of the payment transaction.
Customer data (identity, email address, usage history of services)	Customisation of our services (emails, recommendation of products on our site, etc.)	Contract	3 years from the end of the business relationship
Customer and prospect data : Last name, First name, Postal address, delivery address, email, telephone number	Sending messages by email or SMS (e-business prospecting)	Consent or Legitimate Interest.	3 years from the last response of the concerned individual to a solicitation, or after the date of renewed consent.	The data collected by means of cookies are processed based on consent and kept for a limited period of 13 months.
Navigation data	Targeted advertising/advertising profiling/Audience tracking	Consent	13 months from the deposit of advertising cookies and analytic cookies
Navigation data	The provision, improvement and development of the Services	Legitimate interest	13 months from the deposit of analytic cookies as analytic purpose

At the expiration of the retention period, and subject to applicable archiving rules, or at the request of a User in accordance with the law, the Personal Data will be deleted. NEOVIA nevertheless reserves the right to anonymise the data (that is, processed in such a way that the data subject is not or no longer identifiable) to perform subsequent quantitative and qualitative processing.

RECIPIENTS OF PERSONAL DATA

The data collected on the Website only comes from the use of the Website and the voluntary provision by Users of their personal data. Unless third-party cookies are used in accordance with Article 3, collected data is intended for internal use only and is only available to those responsible for processing the request within NEOVIA. They are, in no way communicated, transferred or disclosed to third parties. Notwithstanding the foregoing, NEOVIA may disclose such Personal Data to NEOVIA’s affiliates or third party service providers, to host the said Website to deliver email messages/to send more targeted communications (in this case, upon the User’s consent, if this communication is not compatible with the purpose of the initial data processing).
In these cases, NEOVIA will only provide them with the data they need to perform the service for which they have been mandated, and will require them to protect this data, in accordance with the requirements of the GDPR, and to refrain from disclosing it to third parties.

In addition, NEOVIA may, after anonymization, provide the data to third parties for analysis, for statistical purposes and for improving NEOVIA’s products, services, Websites and Applications.

In the event that NEOVIA needs to communicate the User’s Personal Data to a third party in a non-EEA country, NEOVIA will ensure that adequate measures such as standard contractual clauses based on the GDPR are concluded with the recipient for protecting the Personal Data of Users.

LINKS TO THIRD PARTY SITES

Users may be able to access third party websites through links available on the Website. The use of these third party sites will be governed by the privacy policies of these sites and not by this Privacy Policy.

RIGHTS & OBLIGATIONS OF USERS

In accordance with the provisions of the GDPR, Users may make the following requests to NEOVIA in regards to their Personal Data processed by NEOVIA:

Access: any User may request information relating to the Processing of his Personal Data, as well as a copy of this Personal Data.
Correction: any User who believes that his or her Personal Data is inaccurate or incomplete may require that Personal Data be modified accordingly.
Deletion: any User may request the deletion of his or her Personal Data, to the extent permitted by law.
Limitation: any User may request the limitation of the processing of his or her Personal Data.
Opposition: Any User may oppose the processing of his or her Personal Data, for reasons related to his or her particular situation, except in case of contrary provision of the law. Each User may in particular oppose the processing of his or her Personal Data for direct marketing purposes, including profiling related to this type of direct marketing, without NEOVIAbeing able to refuse the request.
Portability: any User has the right to receive the personal data concerning him or her that he or she has provided to NEOVIA, in a structured, commonly used and machine-readable format, and has the right to transmit this data to another data controller.
Access to data after death: Any user may define guidelines for the storage, erasure and communication of his or her personal data after his or her death.

In addition to the aforementioned rights, all Users have the right to withdraw their consent at any time when the given consent serves as the legal basis for the relevant processing of his or her Personal Data. Under these conditions, the withdrawal of the consent of a User will have the effect of interrupting the concerned data processing in the future, but will not affect the lawfulness of said data processing carried out beforehand.

Finally, under the right to portability, any User has the right to recover the Personal Data concerning him or her that NEOVIA has in its possession, and, when technically possible, he or she may ask NEOVIA to transfer them to a third party.

Users may exercise their rights with NEOVIA by sending their request to the contact point mentioned in Section “11. Contact” below. NEOVIA may refuse User requests if NEOVIA believes that such requests are unfounded or excessive.

Users are required to comply with the provisions of the GDPR and the French Data Protection Act of 6 January 1978, the violation of which is punishable by criminal penalties. In particular, they must abstain, in regards to the personal information to which they have access, from any collection, misuse, and, in a general way, from any act likely to infringe on the privacy or reputation of the persons.

SECURITY MEASURES

In order to ensure the security and confidentiality of the Personal Data, including protection against loss, theft or any unauthorised access or use, NEOVIA implements appropriate technical and organisational measures that take into account the nature, scope, context, and purposes of the data processing, as well as the risks for the rights and freedoms of Users.

LEGAL REMEDIES

Without prejudice to any other administrative or jurisdictional remedy, any User has the right to file a complaint with a supervisory authority, in particular in the Member State in which his or her habitual residence is located or the place where the breach would have been if he or she considers that the processing of Personal Data concerning him or her constitutes a violation of the laws in force.

In France, the supervisory authority competent to receive such claims is the National Commission for Information Technology and Liberties (CNIL).

CONTACT

Any User may contact NEOVIA about any question relating to this Privacy Policy or request related to the data processing undertaken by NEOVIA concerning him or her, at the address indicated below:
by contacting:

NEOVIA Communication Department – Website
BP 234
56006 VANNES CEDEX
France

CHANGES TO THIS PRIVACY POLICY

NEOVIA may periodically make changes to this Privacy Policy. If we make any material changes to this Privacy Policy and to how we use your Personal Data, we will post such changes on this page and will undertake to notify you of any material changes. NEOVIA invites you to regularly review this Privacy Policy.

Last update: November 30th, 2019.