Welcome to EMILIE COUSTEAU’s Privacy Policy.

Your privacy is important to us,
and we are committed to protecting your personal data.

Last updated:  29th November 2020

1. Introduction

This privacy policy tells you how Emilie Cousteau uses your personal data when you visit our website, when we welcome you as a client or you otherwise interact with us. It also tells you your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy notices we may show you from time to time, so that you are fully aware of how and why we are using your personal data. Thank you.

This website is not intended for children under 13 and we do not knowingly collect data relating to children.

This privacy policy was last updated on November 29th 2020.

If you have any questions, please contact Emilie Cousteau.

2. Who we are

Emilie Cousteau (owner of the brand ‘Croquembouche SAS’) is the data controller responsible for this website and the handling of any personal data. When we mention Emilie Cousteau or Croquembouche SAS, “we”, “us” or “our” in this privacy policy, we are referring to Emilie Cousteau. 

Our full details are:
 
Full name of legal entity: Emilie Cousteau (Owner of the brand Croquembouche SAS) 
  
Email address: emilie.cousteau@gmail.com
 
Postal address: 200 Rue de Rivoli, 75001, Paris.
 
3. What data do we collect about you, for what purpose and on what ground do we process it

Personal data means any information capable of identifying an individual. It does not include anonymized data. 
We may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

  • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

  • We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests, which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

     

4. Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.

5. If you choose not to give us your personal data

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

6. 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. For more information on this please email us at emilie.cousteau@gmail.com

If we need to use your personal data for an unrelated purpose, we will let you know and explain how the law allows us to do this.

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.

We do not carry out automated decision making or any type of automated profiling.

7.  How we collect your personal data

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details below.

We may receive data from third parties such as  advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

8. Marketing communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (1) you made a purchase or asked for information from us about our goods or services or (2) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

If a third party outside Emilie Cousteau wants to use your personal data for their own direct marketing, we will always get your express opt-in consent first.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

9. Disclosures of your personal data

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, accountants, auditors and insurers

  • Members of our virtual team

  • Government bodies that require us to report processing activities.

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

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

10. International transfers

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

  • We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

  •  If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

11.  Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

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

12.  How long we keep your personal data for

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) between six and ten years (depending on the legal implications) after they stop being customers.

In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

13. Your legal rights

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

For an English and French Version where you can see more about these rights:
https://www.cnil.fr/en/rights-and-obligations

See below to find out more about these rights:

  • Request access to your personal data

    This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of your personal data

    This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data

    This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data

    This enables you to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing your personal data

    This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request transfer of your personal data

    We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Right to withdraw consent

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please email us at emilie.cousteau@gmail.com

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 may refuse to comply with your request in these circumstances.

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 shared with anyone who doesn’t have the right to receive it. We may also contact you to ask you for more information in relation to your request to speed up our response.

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

 

14. How to contact us about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please don’t hesitate to email us at emilie.cousteau@gmail.com.

For any other general questions about our services or website, please contact us here.

If you have any complaints, we will always do our best to help with your concerns, so please do not hesitate to contact us first of all. Alternatively, you have the right to make a complaint at any time to the Commission Nationale de l”informatique et des Libertés (CNIL),

the French supervisory authority for data protection issues (https://www.cnil.fr/en/home).

 

15. 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 notice of every website you visit.

 

16. Changes to this privacy policy

If anything changes in this privacy policy in future, we will post the details on the page or send you an email if appropriate.

17. Cookies

What are cookies?

Our website uses cookies to distinguish you from other users of our website. A cookie is a small file of letters and numbers that we store via your device. We explain below how we use cookies and how you can use controls on your device (e.g. your browser settings) to set your cookie preferences.

Cookies help us to provide you with a good experience when you use our website and also allows us to improve our website and services. We use the following categories of cookies:

  • Strictly necessary cookies. These are cookies which are needed to make the website work properly. For example, cookies enable you to log in, make a booking or buy a gift, and make secure payments.

  • Functionality cookies. These are used to recognise you when you return to our website. This helps us to personalise our content for you and remember your preferences.

  • Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. This forms part of Tacking Data and we may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, and we have no control over this. These cookies are likely to be analytical/performance cookies or targeting cookies.

We can use strictly necessary and functional cookies without consent. We gain your consent for other cookies via the banner that you see the first time you visit our website. You can choose not to consent. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

However, if you do not consent, or use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

Please be aware that if you delete your cookies we will no longer know that you’ve opted out of online behavioural advertising, so our adverts can still appear to you on other websites.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

17. Finally, a small request

To help you get the most from your Emilie Cousteau experience, it’s important that your personal data is accurate and up to date. If anything changes during your relationship with us, please let us know. Thank you.

8. Language / langue

Because our services are only available for Business to Business in English, all of our polices and terms are equally only available in English. If you would like to translate any of our terms or policies to another language, you are welcome to use free external translation services to translate our terms /policies to your preferred language. You may for example use services such as  https://translate.google.com/ where you can simply copy-paste the link of the relevant page for translation. We can under no circumstances whatsoever accept any and all liability as for the accuracy of the translation nor for any and all consequences that may arise from your usage of the listed translation service.

*Nos services n'étant disponibles qu'en anglais, toutes nos politiques et conditions ne sont disponibles qu'en anglais. Si vous souhaitez traduire l'une de nos conditions ou règles dans une autre langue, vous pouvez utiliser des services de traduction externes gratuits pour traduire nos conditions / règles dans la langue de votre choix. Vous pouvez par exemple utiliser des services tels que https://translate.google.com/ où vous pouvez simplement copier-coller le lien de la page concernée pour la traduction. Nous ne pouvons en aucun cas accepter aucune responsabilité quant à l'exactitude de la traduction ni aux conséquences pouvant découler de votre utilisation du service de traduction répertorié.