PRIVACY POLICY

Last update : September 8th 2022

What is the purpose of this Privacy Policy? 

The General Data Protection Regulation (GDPR) as well as the French Data Protection Act of 1978 (amended in 2018) requires professionals to provide concise, clear, understandable, user-friendly information about the processing of personal data pertaining to them, for the purpose of ensuring that they understand how their personal data are processed.

 

*Definition: The “Customer” - “you”: Any customer of the www.lilliputiens.com  site as defined by Article 1 of the site’s general terms and conditions of sale. 

Who is the data controller for the personal data collected and processed via the www.lilliputiens.com ?  

JURATOYS

Simplified joint-stock company with share capital of €1,600,000,

located at 13 rue de l’Industrie – 39270 ORGELET, France

Registered with the Registry of Commerce and Companies of Lons de Saunier under number 453 389 660

What personal data concerning you do we collect?

JURATOYS is careful to only collect data that is strictly necessary for the purpose of the processing implemented.

Each time JURATOYS collects personal data, it will use an asterisk (*) to clearly indicate whether an answer is required or optional. If you do not complete the required fields, JURATOYS will not be able to proceed with processing. Any optional information helps us to better manage and improve processing.

In practical terms, www.lilliputiens.com site collects the following categories of data concerning you: 

Identification data

First name, last name, salutation

Contact information

Email and mailing address, phone number. 

Professional experience

CV

Furthermore, some data are automatically collected by the www.lilliputiens.com site by cookies or other trackers, specifically:

Categories of Data

Connection and navigation data

Examples of data

Date et heure de visite, adresse IP, appareil, navigateur, système d’exploitation, données de configuration système, pages consultées.

Purposes

These data are required for the proper technical operation of the Site, as well as to measure site usage. For more information on cookies and other trackers, please review the Cookie Management Policy  for de www.lilliputiens.com

For what purpose(s)/objective(s) are your personal data collected and on what basis?

(Purposes of processing and legal basis)

Processing done by JURATOYS meets specific, explicit and legitimate purposes.

In practical terms, for the www.lilliputiens.com site, the purposes and legal bases are as follows:

Creating and managing your Customer account

If you create a customer account without making an order: Fulfilment of the contract.

If you create a customer account and make an order: Fulfilment of the contract and consent for data which are not strictly required for fulfilment of the sales contract.

Managing your order and after-sales service.

Fulfilment of the contract.

Processing your contact request and/or information

JURATOYS has a legitimate interest in processing contact requests sent to it and providing you with information on its activities.

Direct marketing

Consent 

Processing your job application

Pre-contractual measures 

Legitimate interest (CV-tech)

Improvement of the www.lilliputiens.com site, as well as enhancing your user experience

The legitimate interest of JURATOYS in improving its website, as well as enhancing your user experience. 

Managing litigation and pre-litigation

The legitimate interest of JURATOYS to defend its rights.

Compliance with legal and regulatory obligations

Legal and regulatory obligations required of JURATOYS

When your consent is the legal basis, it is important to note that you have the right to withdraw your consent at any time, specifically by contacting our Data Protection Officer (DPO) (see below, “how can I exercise my rights”?).

Who are the recipients of personal data?

(Recipients)

JURATOYS only communicates your personal data to specific, authorised personnel.

Data may be sent to providers of technical services selected for their expertise and reliability who operate on behalf of, and according to documented instructions from JURATOYS (IT subcontractors, etc.). These providers pledge to comply with the GDPR principles set forth in national and European Union legislation.

In practical terms, with respect to the www.janod.com  site’s processing of data, the recipients of your personal data are as follows:

Creating and managing your Customer account

Internal recipients: personal data intended for employees of JURATOYS responsible for customer relationships.

Managing your order and after-sales service.

Internal recipients: personal data intended for employees of JURATOYS responsible for customer relationships.

Processing your contact request and/or information

Internal recipients: personal data intended for employees of JURATOYS responsible for customer relationships.

External recipients: Data may be sent to providers of technical services selected for their expertise and reliability who operate on behalf of, and according to instructions from JURATOYS.

Direct marketing

Internal recipients: personal data intended for employees of JURATOYS responsible for direct marketing.

External recipients: Our service provider for managing email campaigns.

Processing your job application

Internal recipients: personal data intended for employees of JURATOYS responsible for recruitment.

Improvement of the www.lilliputiens.com site, as well as enhancing your user experience

Internal recipients: personal data intended for employees of JURATOYS responsible for IT and website management.

External Recipients: data may be sent to providers of technical services selected for their expertise and reliability who operate on behalf of, and according to instructions from JURATOYS (in particular, the IT maintenance provider).

Managing litigation and pre-litigation

Internal recipients: personal data intended for employees of JURATOYS responsible for legal affairs.

External recipients: administrative or legal authorities (Only in the scenario of an explicit request and with them having provided a reason or in the event of a proven violation of the legal or regulatory provisions) and/or external consultants (Only in the context of managing any disputes or other legal subjects, as the case may be). 

Compliance with legal and regulatory obligations

Internal recipients: personal data intended for employees of JURATOYS responsible for legal affairs.

Internal recipients: external consultants

How long does JURATOYS store your personal data?

(Period of time)

JURATOYS only stores your data for the period strictly necessary for the operations for which it was collected as well as to comply with legislation in effect.

In practical terms, with respect to the www.lilliputiens.com site’s processing of data, the storage periods are as follows: 

Creating and managing your Customer account

If you create a customer account without making an order: The period in which your account is open (active basis).

If you create a customer account and make an order: The period in which your account is open (active basis). Then, for 5 years (archival basis) from deletion of your account as evidence in the event of litigation or pre-litigation.

Managing your order and after-sales service

The period of the contractual relationship (active basis). Then, for 5 years (archival basis) from the end of your contractual relationship as evidence in the event of litigation or pre-litigation.

Processing your contact request and/or information

The time period necessary to transmit the information requested (concerning the product and/or company) (active basis). 

Direct marketing

The period for which you have granted your consent (active basis, then for 3 years from the last contact (archival basis).

You can unsubscribe from the newsletter at any time, and thereby revoke your consent, by clicking here  or clicking on the unsubscribe link in each email.

Processing your job application

If your application is not selected, your personal data is deleted immediately.

Connection and navigation data

This refers to data collected by cookies and other trackers - consult the table above concerning cookies.

These data are kept for 13 months

Improvement of the www.lilliputiens.com site, as well as enhancing your user experience

The data are stored strictly for the time required for the improvement measures.

Managing litigation and pre-litigation

The data are stored strictly for the time required to manage the litigation.

Therefore, in general, the limitation for most actions is 5 years. They may be subject to specific limitations with shorter periods.

Compliance with legal and regulatory obligations

The data are stored in accordance with legal obligations.

Therefore, in general, accounting documents and supporting documents are stored for 10 years.

What are my rights with respect to my personal data?

(Rights)

In accordance with the General Data Protection Regulation (GDPR) as well as the French Data Protection Act of 1978, you have the following rights with respect to your personal data:

The right to access - GDPR Article 15

“The exercise of your access rights allows you to know if data concerning you was processed and to obtain the communication in an understandable format. It also allows you to control the accuracy of the data and, if need be, to have it rectified or erased” (definition from the CNIL’s webpage).

Right to object – GDPR Article 21

“Does your personal data appear in an non-mandatory file and you would like it to no longer appear there? The right to object enables you to object to your data being used by an organisation for a specific purpose. You must propose “reasons related to your specific situation”, except in the case of direct marketing, to which you may object without justification.” (definition from the CNIL’s webpage / When this processing is based on JURATOYS legitimate interest.

Right to Rectification – GDPR Article 16

The right to rectification allows you to correct inaccurate data about you (incorrect age or address) or to add to the existing data (address without an apartment number) in connection with the purpose of the processing” (definition from the CNIL’s webpage).

Right to erasure (“right to be forgotten”) – GDPR Article 17

This right enables you to have the data controller erase personal data concerning you as quickly as possible. “You can have the data erased if at least one of the following situations applies:

             your data are used for marketing purposes;

             the data are not needed or no longer needed for the purposes for which they were initially collected or processed;

             you withdraw your consent to use your data;

             your data are subject to unlawful treatment (for example, by publication of pirated data);

             your data was collected when you were a minor in the information society environment (blog, forum, social network, website, etc.);

             your data must be erased to comply with a legal obligation;

             you object to the processing of your data and the controller of the file does not have legitimate or compelling grounds not to act upon your request.”

(definition from the CNIL’s webpage).

Right to restriction of processing – GDPR Article 18

“If you dispute the accuracy of the data used by the organisation or you object to how the data are processed, the law authorises the organization to verify or review your request for a certain period of time. During this period, you can request the organisation to free use of your data. In practical terms, it should no longer use the data, but still store it” (definition from the CNIL’s webpage).

 

Thus the right to a temporary limitation of the processing of your data applies specifically for the purpose of conducting the verifications, namely:

             when you dispute the accuracy of your information, the time JURATOYS has to verify its accuracy;

             if the processing is unlawful, rather than request its erasure, you would prefer to limit its use

             if JURATOYS no longer needs the data for processing, but they still need to retain it so you can establish, exercise or defend a right in a legal claim.

             if you object to the processing pursuant to your right to object, during the verification period intended for verifying if JURATOYS’ legitimate reason prevails over yours.

Right to data portability – GDPR Article 20

“The right to portability provides the opportunity to retrieve some of your data in a machine-readable format. You are furthermore free to store this portable data or transmit it easily from one system to another, in order to reuse it for other purposes.” (definition from the CNIL’s webpage).

This right does not apply under all circumstances. It only applies subject to it fulfilling all of the following conditions:

•             it applies only to your personal data, excluding all anonymous data and that of third parties;

•             it does not apply to infringements of JURATOYS’ rights and liberties (in particular, business secrets) or that of third parties (specifically intellectual property rights);

•             it concerns personal data processed automatically (therefore, paper files are not concerned);

•             the processing is based on your consent or the fulfilment of a contract concluded with JURATOYS.

The right to establish directives - Article 85 of the French Data Protection Act

You may send general or specific instructions regarding your personal data in the event of your death (for example, that the data be deleted or sent to any person of your choice). You may revoke your directives at any time.

To learn more of the exact content of your rights, please review the aforementioned GDPR Articles or refer to the following link:https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles (“your rights to control your personal data”).

How do I exercise my rights?

You can contact JURATOYS’ Data Protection Officer to exercise your rights:

  • To the following email address:dpo@juratoys.com 
  • By mail to the following address: 

Data protection officer

JURATOYS

13 rue de l’Industrie

39270 ORGELET

As an exception, the data protection officer could ask you to provide signed proof of identification if the officer has serious doubts as to the author of the request’s identity. This will be the case especially when the request was not sent directly from your Lilliputiens.be customer account (https://www.lilliputiens.com/fr/nous-contacter).

 

When you exercise your rights, the data protection officer processes your personal data in order to handle your request. These data are stored for one month (with the exception of the copy of your proof of identity (if requested), which is kept during the verification period) as JURATOYS has an obligation to reply within this time. Nevertheless, this deadline can be extended to 3 months in consideration of the complexity of the request.

Your right to file a complaint with the CNIL: 

You also have the right to file any complaints with the French Data Protection Authority (la Commission Nationale de l'Informatique et des Libertés – CNIL), 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07, related to the way in which JURATOYS collects and processes your data.

How does JURATOYS ensure the security of your personal data?

JURATOYS takes all useful and suitable organizational and technical measures to preserve the security, integrity and confidentiality of your personal data, specifically to avoid it being altered or damaged or allowing unauthorised third parties access to it.

Who do I contact if I have a question or misunderstanding regarding this privacy policy? 

All requests for information regarding the privacy policy implemented by JURATOYS can be sent to dpo@juratoys.com.

JURATOYS reserves the right to modify this policy at any time, in particular according to the legal and regulatory environment and CNIL doctrine.