Update on October, 10 2018
This document, « Confidentiality and Personal Data Processing » describes below the personal data which are collected, generated or processed when you use our WEBSITE and explains how these personal data are used, shared and protected as well as the options and rights that you have at disposal and how to contact us.
I – IDENTITY OF THE PERSON RESPONSIBLE FOR PROCESSING THE PERSONAL DATA
Mr. Frédéric Lener, President and Chief Executive Officer, is responsible for the processing of personal data of LENER CORDIER SA, registered in the Dunkerque trade register under number 308199140, which head office is located 39 rue de Merville 59529 Hazebrouck Cedex France.
II - TERMINOLOGY
USER: Any natural person, having an account on Chemins Blancs WEBSITE, or using the Chemins Blancs WEBSITE or one of the services proposed on the WEBSITE as mentioned below.
SERVICES: It relates to the commercial relationships management and associated services, as well as communication and promotion actions to bring attention to the USER of commercial offers or provide him information about Chemins Blancs brand.
WEBSITE: This is the Website http://www.cheminsblancs.com as well as mobile and desktop.
III – USERS PERSONAL DATA
3.1 Information provided by USERS
For the purpose of placing the orders our WEBSITE, you create a customer account; furthermore, you contact us by phone or by email or you subscribe to our Newsletter; you follow and interact on our social networks. The information provided are generally, the following data:
Your personal identification data and your contact details: your first name, your surname, your e-mail address, your invoicing address, your delivery address, your phone number, the language and the country from which you log in.
Payment information or linked to your activity on the website: your bank details (please note that all payment transactions are encrypted by the receiving bank, we do not hold any credit card number), information regarding your purchases, your orders, your returns, etc.
Log in data, geo tracking and web browsing data,
Profile data – Should you open a customer account, then you create a profile and identify yourself when you log in on the WEBSITE. These data (username and password, recent purchases or personal preference) will be registered.
Your personal preference, including in particular your wish list, your marketing and cookies preferences.
Additional personal information: You can also provide other personal information like your birth date, your gender, etc. We alone collect and keep this information. We use them for the purpose of our analysis conducted in order to improve our service level.
Some data required are compulsory fields since we need these data to allow the access to such functionalities (For example to deliver a parcel, we need your postal address)
These personal data shared about you, must be accurate and updated. Please inform us of any change in your personal data.
Conformément à la législation en vigueur nous ne conservons pas les informations personnelles à caractère sensible.
According to law in force, we do not save any personal data of a sensitive nature. Under the Law, GDPR of April 14, 2016 that came into effect on May 25, 2018, the USER gives his consent to the processing of his personal data.
3.2 -Data obtained via cookies
Your IP address, your search engine and its version, your location and time zone, your browser plug-in, the operating system and the platform.
Some information on your visit, including the URL and your click traffic, from and on our website (including date and time); the products you have reviewed or researched; the response time of the pages, errors, time spent and interaction on the pages, (such as clicks and cursor movements), how you leave pages.
IV – PROCESSING OF USERS PERSONAL DATA
Data collection is necessary so that we may process it for the following purposes:
4.1 Management of Commercial relations and Customer service
Management and follow up of commercial relationships between Chemins Blancs and the Customer (Including Actions regarding the order and its follow up, deliveries and returns, payments and invoices, claims etc.)
These data allow us as well to prevent from potential fraud against yourself or us during the purchase process. Should we suspect the action as being fraudulent, then we may block the transaction. Any transaction exceeding 2000 euros will be blocked.
You may at any time cancel or change your account by making the request directly to us, in compliance with Art. 7 of GDPR law.
4.2 Marketing Actions
Your consent is indispensable, for any direct marketing actions. You may also, at any time, unsubscribe from our communication (For example, you may unsubscribe from our newsletters by clicking on the button « in order to unsubscribe, please visit this page » at the bottom of the newsletter pages and confirm the unsubscription).
Should you have given your consent to receive direct marketing content, via newsletter, we may use this information provided by you for the following purpose:
Sending of commercial prospecting messages: We use your data to manage your subscription and send you targeted information by e-mail or “text message” according to your mentioned preference.
To share information relating to our events, product launch, special offers and services
Availability of social networks sharing buttons
Promotional actions proposals
Statistics analysis to measure the audience and marketing studies in order to better meet your expectations and improve our service level.
V - ACCOUNT CREATION, FORMS, QUESTIONNAIRE AND SUBSCRIPTION TO THE NEWSLETTER
5.1 – Account creation
The USER will have to fill out all fields of the account creation form or any form to fill in on the WEBSITE, except fields identified as optional (Non-optional fields are identified with a star (*)). The optional information is Collected by Chemins Blancs in order to better know the WEBSITE USERS.
All information identified with a star (*) are compulsory. The USER Must be filled out in.
Any missing answer will end to the absence of account creation or the non-validation of the form. Chemins Blancs won’t follow up USERS requests.
5.2 - Chemins Blancs Newsletters
When you create an account and then after when you manage your preference in the section « My account », the USER may subscribe to Chemins Blancs Newsletter and thus be informed regularly of the offers proposed on the WEBSITE. He/she may at any time change the information of his/her account and unsubscribe by clicking on the link provided for this purpose, located at the bottom of all our newsletters. This link is also accessible on the WEBSITE in the section “My account”.
VI - DATA MANAGEMENT WITH THIRD PARTIES
Data are collected for the use of Chemins Blancs. These data may be transferred subject to appropriate undertaking of confidentiality:
To banks and payment services company in order to proceed with the payment,
To delivery companies, in order to deliver your order
In case of fraud suspicion, to fraud prevention agencies in order to check your credit and identity
These data may be processed as well by sub-contractors hired by Chemins Blancs for the purpose of the activities abovementioned in article IV.
We require to third parties to undertake in respect of personal data security and in compliance with the law in force. Third parties may use these personal data only according to our instructions and not for their personal use.
VII - ACCESS, MODIFICATION AND CANCEL RIGHTS
7.1 – Legal considerations
When you buy a product on our WEBSITE, we need your personal data in order to execute our contract with you. For example we need your address detail to deliver the order:
Postal address and phone number
Postal address and phone number are necessary to the process management of the order as well as the commercial relationships between Chemins Blancs and the CUSTOMER.
We also rely on other legal consideration such as legitimate interests. For example, we consider that It your interest that your identity may not be used for fraudulent purposes,People from our customer service department may have access to your information to bring better service, We may better understand your use of our WEBSITE to improve its usability and the services that we may propose.
We respect the importance of your consent that prevails in the new GDPR law.
7.2 – Consent
The consent, must be clearly and unequivocally provided. In that respect, when you consent to receive our communication:
We explain how we are going to process your data and the type of communication you are going to receive
You must tick the box that will confirm that you consent to become a subscriber
Children under the age of thirteen (13) years cannot give their consent.
You can at any time withdraw your consent. Should you wish to unsubscribe from our direct marketing, via our newsletter, you can at any time unsubscribe by clicking on the link found at the bottom of the e-mailing page.
If you have a CUSTOMER account on our website, on Internet, you can unsubscribe or change your preferences by logging into your profile.
At any time, the customer has the possibility to simply and freely oppose to subscription to our direct marketing, on the WEBSITE, section « My account » or by postal mail to the following address: LENER CORDIER – Chemins Blancs Department - 39, rue de Merville - 59190 HAZEBROUCK, France .
Cookies (including those inserted in the advertising banners) require a specific un-subscription process.
Sms / mms
Chemins Blancs may use mobile phone number of the CUSTOMER to manage the order and may use it for commercial prospection as well. The CUSTOMER may, at any time, refuse the use of sms/mms by Chemins Blancs, simply and freely, on the section « my account » of our WEBSITE or by postal mail at the following address: LENER CORDIER – Chemins Blancs Department - 39, rue de Merville - 59190 HAZEBROUCK, France .
The USER identified may subscribe to size alerts and models proposed by Chemins Blancs. He/she may, at any time unsubscribe from these alerts in the section « My account » of the WEBSITE. The size alerts are automatically unchecked if the assortment has not been made within 3 months.
This service allows to the CUSTOMER to provide notifications on the WEBSITE for a product bought and to share his/her experience. Published notifications are accessible to Public and available on the WEBSITE at any time. The CUSTOMER gives his/her consent to Chemins Blancs to publish and communicate his/her notification about a product on his WEBSITE. This notification shall not be slanderous, offensive, criminal, vulgar, libelous toward third parties, natural or legal persons, of racist nature, encouraging discrimination, infringing the rights or honor of others, violent or pornographic, and more generally not compliant with legislation in force.
As such, Chemins Blancs reserves the rights to cancel a notification that would not comply with the provisions referred to above.
7.3 Other rights
In compliance with the Data Protection Act of January 6, 1978 modified, and compliant with EU regulation 2016/67 dated April 27, 2016 relating to the protection of individuals with regard to the processing of personal data and of the free movement of such data, the USER is entitled to have access, make corrections, delete data or the right object for legitimate interests, as well as the right to oblivion and portability of these data. You can exercise this right subject to the proof of you identity by sending it to the following email address:
Or send it by postal mail at the following address :
LENER CORDIER – Service Chemins Blancs s - 39, rue de Merville - 59190 HAZEBROUCK
Chemins Blancs must reply to such request from the USER within One (1) month starting from the receipt of the request.
Should you have a CUSTOMER account, you may as well change your personal contact data from into your customer account in the WEBSITE by identifying yourself with your email address and password.
Chemins Blancs uses these data for commercial prospection purpose. At any time, the CUSTOMER may oppose to the use of these data by simply and freely do it in « My account » or by postal mail to the following address : LENER CORDIER – Service Chemins Blancs - 39, rue de Merville - 59190 HAZEBROUCK .
VIII - RETENTION PERIOD OF PERSONAL DATA
8.1 - In General
Chemins Blancs preserves these data during five (5) years starting from the end of the relationships with the customer or prospect. The time limit shall start either from the last connection to the customer WEBSITE, the last call to the customer service, or an email to the customer service, or a click on an hyperlink on an email sent by Chemins Blancs, or a product add to the cart without purchase or a positive answer from the CUSTOMER mentioning his wish to still receive commercial prospection after the five (5) years’ time limit. After five (5) years the CUSTOMER or Prospect personal data will be cancelled.
Nonetheless, this information allowing to prove a right or contract or kept in order to abide by a legal obligation may be stored in accordance with the legal provisions in force.
8.2 - Fate of personnal data upon USER’s death
Chemins Blancs inform the USER that he/she may, during his/her lifetime, provide instruction regarding the storage, cancellation and communication of his/her personal data after his/her death. These instructions may be general or specific. The USER can modify or revoke these instructions at any time. To that end, the USER may contact LENER CORDIER – Service Chemins Blancs - 39, rue de Merville - 59190 HAZEBROUCK.
IX - COOKIES
A cookie is a computer text file located or stored on your terminal (computer, desktop or mobile) when you browse into a website. The cookie allows a website to identify you and help you to browse from one page to another into a website, provides secured connections et register your preferences for your future visits.
9.2 Cookies desactivation
The USER may at any time, disable cookies registered on his/her terminal. To that end, he/she simply needs to select the appropriate parameters into his/her browser. However, this deactivation will consequently prevent the access to some functionalities of the WEBSITE which allow to personalize services proposed by Chemins Blancs.
9.3 Types of cookies used
Cookies strictly necessary: These cookies allow to browse on the website and are essential for the proper functioning of the WEBSITE. The deactivation will end with difficulties in using the WEBSITE and as a consequence will prevent from the access to some functionalities.
Functional cookies: These cookies allow to memorize your preferences, choices in order to personalize your experience on the WEBSITE.
Performance and statistics cookies: These cookies are collecting information about the way USERS are browsing the WEBSITE (Number of visits, number of pages viewed, visitors’ activities) via cookies analysis tools available on the market. These cookies allow as well to identify problems and solve operating problems on the WEBSITE and improve it.
Advertising cookies: These cookies register information in order to direct personalized and adapted advertisement taking into account your main focus. In addition, they help to register the activity of our advertising spaces, measure the audience etc. For example, cookies related to targeted advertisement actions, social networks markers generated by sharing buttons on social networks like Facebook, Twitter, Pinterest, YouTube, Google+, Instagram (Social Plugins).
Partnership cookies: These cookies located on the terminal by partners companies allow to identify the articles visited or bought on the WEBSITE and to collect browser data in order to personalize the advertising offer towards the USER out of the WEBSITE. In the scope of advertisement partnership, Chemins Blancs may transfer to the partners some data related to products visited by the USER when browsing on the WEBSITE as well as the nature of his/her purchases. The USER may refuse these cookies at any time by selecting appropriate parameters in his/her browser. As a consequence, this refusal will prevent from the access to some functionalities proposed by Chemins Blancs partnership companies.
Social networks buttons: Chemins Blancs makes available to USERS sharing buttons like Facebook, Twitter (Please refer to « Social networks Plugins » below).
9.4 Management of cookies
For the purpose of the management of cookies as well as your choice, the setting of each browser is different. It is described in the Help menu of your browser, which will allow you to know how to change your wishes regarding cookies.
Deactivation of cookies via the main browsers:
1) In the Menu « Tools », select « Internet Options »
2) Then click on tab « Confidentiality »
3) Then click on the button « Advanced » to shift to the window « Advanced confidentiality Parameters».
4) Then Tick the box « Ignore automated cookies management », then select « Refuse » and save your preference by clicking on « OK ».
1) In the menu on top of the page click on « Tools », then « Options »
2) Select on tab « Privacy »
3) Parameter the « Conservation rules », Click on « Use personalized parameters for historical».
4) Un-tick « accept third cookies » and save your preference by clicking on « OK ».
1) In the Menu « Parameters » then on « Display advanced parameters».
2) Select tab « Confidentiality » then the menu « Content parameters».
3) Tick the box « Block the cookies and data on third party website » and save your preference by clicking « OK ».
1) In the menu on top of the page click on « Safari », then « Preferences »
2) Select on tab « Confidentiality »
3) Un-tick « Accept cookies » et save your preferences.
9.5 Web beacons
Chemins Blancs is using web beacons on certain pages of the WEBSITE allowing to account the number of visitors on web pages. These web beacons may be used with some commercial partners, especially to measure and improve the efficiency of some advertisings. The information gathered via these web beacons are anonymous and allow to know the flow of visitors on web pages and this in order to bring better assistance to the USERS of the WEBSITE.
9.6 Social Networks Plugins
The WEBSITE is using social networks plugins like Facebook, Twitter (hereafter « Social Networks »). For example, if the USER is connected to Facebook when browsing the WEBSITE, Facebook will be able to directly link his/her visit to his/her Facebook account, even if the USER has not used the sharing button. If the USER interacts with plugins, for example by clicking on the “like” button or if he/she leaves a comment, the corresponding information will be transferred and registered on a Facebook server. They will be published on the USER’s Facebook account.
Chemins Blancs does not manage data collected via social networks buttons. The USER must review the policy of personal data processing and confidentiality published by the concerned Social Networks, and this in order to know the terms for processing and using the data gathered by these Social Networks as well as the possible setups available to protect his/her private life. Should the user refuse that the Social Network links the information gathered through the USER account of Chemins Blancs to his/her Social Network user account, he must disconnect this Social Network before browsing the WEBSITE.
X - SECURITY MESURES TAKEN BY MAISON LENER TO SECURE PERSONAL DAT PROTECTION
10.1 – Personal Data Protection
Chemins Blancs takes all possible technical measures pursuant to the professional standards to maintain the integrity, security, confidentiality of data and more specifically to prevent them from being distorted, damaged or accessible to unauthorized third parties.
Our WEBSITE set all appropriate security measures in order to prevent any risk of loss, unauthorized use or access to your personal data. All data that you provide are saved on secured servers. Chemins Blancs set procedures in order to manage any personal data breach.
In particular, when placing the order, no bank data is collected and registered by Chemins Blancs. Chemins Blancs uses service providers with a « PCI-DSS » certified platform in order to secure payments.
All service providers work within the European Economic Area (EEA) and abiding by the same legislation in force.
10.2 - Preventing and combatting fraud
Data collected are also used in prevention and fight against fraud and more specifically against card fraud. Chemins Blancs reserves the right to check the personal data provided by the CUSTOMER when placing the order and take all measures deemed necessary to check that the identity of the person placing the order corresponds to the identity of the credit card owner, in order to prevent from any fraudulent payment. This check may include the requirement of identity and/or address proof.
In lack of negative answer from the CUSTOMER, Chemins Blancs reserves the right to cancel the order placed by the CUSTOMER.
In case of account creation, you have chosen a password. We recommend to choose a password with a high level of efficiency and we remind you that you are responsible for the confidentiality of this password.
We recommend you to connect exclusively on secured and preferably private servers. Keep in mind of risks involved with public WIFI networks.
Should you receive an email pretending being our brand and requiring personal information or an update of these information, please do not answer and transfer this email to us so that we can take the appropriate actions.