Privacy Policy

Effective Date of Privacy Policy: 09/10/2024

LES HÉRITIÈRES, as publisher of the site https://www.les-heritieres.com/ , whose legal information appears in the “Legal Notices” tab, pays particular attention to the protection of personal data. This is an essential condition of the relationship of trust that LES HÉRITIÈRES wishes to establish with all users of the Site.

LES HÉRITIÈRES is required to collect and process personal data on users accessing or using the services of the website accessible at the URL https://www.les-heritieres.com/ (hereinafter referred to as " Users ” or “ you ").

This privacy policy (hereinafter the “ Privacy Policy ”) sets out the terms and conditions under which LES HÉRITIÈRES collects and processes your personal data , in order to provide you with complete information on the subject.

Personal data is defined as any information relating to an identified or identifiable natural person, that is to say any natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity, as this term is defined by the regulations in force (hereinafter the " Personal Data”).

Data relating to a legal entity is not Personal Data. The collection and processing of this type of data is not covered by this Privacy Policy or by applicable legislation.

1. DATA CONTROLLER

The entity that collects and processes your Personal Data is the company LES HÉRITIÈRES, a simplified joint-stock company registered with the Nanterre Trade and Companies Register under number 951 482 025, with a share capital of €15,000, whose registered office is located at 31 avenue de Ségur - 75007 Paris, France, intra-community VAT number FR24951482025, represented by its President Mrs. Amélie Vincent (hereinafter “ LES HÉRITIÈRES ” or “ we ”).

LES HÉRITIÈRES operates the website accessible at the URL https://www.les-heritieres.com/ (hereinafter referred to as the “ Site ").

As such, LES HÉRITIÈRES undertakes to comply with the applicable national and European legislation in force, including in particular the General Data Protection Regulation No. 2016/679 of April 27, 2016, the amended law of January 6, 1978, as well as any other applicable regulations.

2. MEANS OF COLLECTION OF PERSONAL DATA

Depending on how you interact with LES HÉRITIÈRES, it may collect your Personal Data in the manner described as follows:

• Your Personal Data is collected directly from you when you complete a pre-valuation form for your jewelry(s) on the Site;
• Your Personal Data is collected directly from you when you complete a membership application form for our member community on the Site;
• Your Personal Data is collected directly from you when you contact us via any means of exchange and communication, including social networks, such as Instagram or instant messaging applications such as WhatsApp.

3. PERSONAL DATA COLLECTED AND PROCESSED

When collecting your Personal Data, you expressly undertake to communicate only complete, accurate and up-to-date information, and not to prejudice the interests or rights of third parties.

If your Personal Data is collected through a form on the Site, the information that LES HÉRITIÈRES requires to provide its services to you is marked with an asterisk. Other information is optional.

The Personal Data that may be collected are as follows:

• Processing, management and monitoring of pre-estimate requests : Your name, first name, email address and telephone number;
• Processing, management and monitoring of community membership and Community Management : Personal data appearing on your national identity card or any official identity document, your telephone number, your email address and any other Personal Data that you provide to us spontaneously;
• Processing, management and monitoring of communications : Personal data relating to your profile and publicly accessible (profile photo, pseudonym, etc.), your telephone number and any other Personal Data that you spontaneously provide to us in the context of communications.

The companies that provide the social networking and instant messaging application services used by LES HÉRITIÈRES and Users also act as controllers of the Personal Data processing carried out on their platforms. Users are therefore advised to read the privacy policy of each of these platforms, over which LES HÉRITIÈRES has no control.

4. LEGAL BASES AND PURPOSES FOR COLLECTING YOUR PERSONAL DATA

4.1 The collection and processing of your Personal Data is justified by different legal bases depending on our use.

LES HÉRITIÈRES thus ensures that it has one of the following legal bases:

• pre-contractual measures and the execution of a contract : the collection and processing of your Personal Data is necessary for the conclusion of the envisaged contract and then for the execution of the contract that we have concluded with you;
• Consent : the collection and processing of your Personal Data is expressly accepted. This consent can be withdrawn at any time;
• legitimate interest : LES HÉRITIÈRES has an interest in collecting and processing your Personal Data that is justified, balanced and does not infringe on privacy, as part of the management and monitoring of its commercial relationships with its customers, prospects and more generally its contacts. It is possible to object to this type of processing with us, except for exceptions;
• legal obligation : the collection and processing of your Personal Data is mandatory under a law.

4.2 On the basis of one or more of these legal bases, LES HÉRITIÈRES collects and processes your Personal Data for the purposes of:

• Provide you with a pre-estimate of your jewelry;
• Allow you to join our community of members after having verified your identity and to benefit from the associated advantages, in particular the benefit of preferential rates, the presentation of jewelry in preview, the sending of a monthly newsletter dedicated to the world of jewelry, access to our showrooms or even a jewelry appraisal;
• Promote our products and services and communicate via social media and instant messaging applications.

5. DURATION OF STORAGE OF YOUR PERSONAL DATA

LES HÉRITIÈRES retains your Personal Data for a period that does not exceed the period necessary for the purposes set out in the Privacy Policy. Thus, the retention periods for your Personal Data depend on the purposes for which they are collected and processed.

Personal data is kept for the durations corresponding to the following phases:

- Active base : your Personal Data is kept for our current usage period, i.e. the period necessary for us to achieve the purposes. These periods are as follows:

• Management of pre-estimate requests : retention for the period necessary to process the request or for a period of three years from the request, the end of the commercial relationship or from the last contact from the User or the person concerned (online request, email or post, click in an email sent by LES HÉRITIÈRES);
• Community membership management (identity verification) : retention for the time necessary to process the request, then deletion of the identity card as soon as the identity verification has been carried out;
• Community animation (newsletter, communication of preferential rates, presentation of exclusive products) : retention until withdrawal of consent or for a period of three years from the request, the end of the commercial relationship or from the last contact from the User or the person concerned (online request, electronic or postal mail, click in an email sent by LES HERITIERES);
• Communication via social networks and instant messaging applications : retention for the period necessary to process the request or for a period of three years from the request, the end of the commercial relationship or from the last contact from the User or the person concerned (online request, email or post, click in an email sent by LES HERITIERES).

- Intermediate archiving : this phase occurs when the purpose of processing Personal Data is achieved, but the retention of your Personal Data is necessary, for example to meet a legal obligation or to constitute evidence during the limitation period (commercial, civil, consumer law limitation period in particular). In this case, access is restricted to only authorized persons who have an interest in knowing it due to their functions.

After the deadlines set out above, your Personal Data will either be deleted or anonymized (without us keeping a copy). You are reminded that deletion or anonymization are irreversible operations and that we will no longer be able to restore them thereafter.

6. RECIPIENTS OF YOUR PERSONAL DATA

Your Personal Data is mainly processed by LES HÉRITIÈRES.

Where applicable, your Personal Data may be transmitted:

• to our subcontractors, service providers and their limited authorized personnel, with regard to the specific services entrusted to them and which they must carry out on behalf of LES HÉRITIÈRES in strict compliance with obligations, in particular those of security and confidentiality,
• to public bodies (tax and social security bodies), to competent authorities (judicial authorities and legal auxiliaries in the context of legal proceedings), as well as to ministerial officers,
• to any other entity which should be considered a recipient under applicable regulations.

7. TRANSFER OF YOUR PERSONAL DATA

7.1 Your Personal Data is mainly processed within the European Union and we endeavour, as far as possible, not to transfer it outside this territory.

7.2 However, we may need to transfer some of your Personal Data outside the European Union.

Only Personal Data strictly necessary for carrying out the processing in question are concerned.

In this case, the transfer of your Personal Data is carried out, depending on the situation, in one of the following alternative ways:

• either your Personal Data is transferred to a country benefiting from an adequacy decision from the European Commission, i.e. considered to offer a level of protection adequate to that provided in the territory of the European Union: in this case, the provisions of the GDPR apply without any other legal instrument;
• either your Personal Data is transferred to a country whose level of protection of Personal Data has not been recognized as adequate to the applicable regulations, in this case we supervise the transfer by one of the following legal instruments offering appropriate guarantees, within the meaning of the GDPR: standard contractual clauses of the European Commission or approved by it, internal company rules (Binding Corporate Rules, BCR), a code of conduct, or a certification mechanism;
• or, as an exception and as a last resort, in the absence of an adequacy decision or appropriate guarantees, your Personal Data may be transferred pursuant to Article 49 of the GDPR, provided that the required conditions of the applicable paragraph are met.

Regardless of the alternative used, any transfer of your Personal Data outside the European Union is for the sole purposes detailed in this Privacy Policy.

8. PROTECTION OF YOUR PERSONAL DATA

8.1 In order to preserve the confidentiality and security of your Personal Data and in particular to protect it against unlawful or accidental destruction, accidental loss or alteration, or unauthorized disclosure or access, we take appropriate technical and organizational measures, in accordance with applicable legal provisions. To this end, we have implemented technical measures (such as firewalls) and organizational measures (such as a username/password system, physical protection measures, etc.).

LES HÉRITIÈRES takes all necessary precautions to preserve the security and confidentiality of your Personal Data in order, in particular, to prevent it from being distorted, damaged, disclosed and accessed by unauthorized third parties.

The computer systems used to store your Personal Data are equipped with a software protection device. Physical and electronic backup procedures for your Personal Data are also implemented.

We will do our best to protect your Personal Data. If you suspect any unauthorized use, damage, or loss of your Personal Data, please notify us immediately using the contact details provided in Section 11 “For More Information” below.

8.2 In the event of a breach of your Personal Data, we undertake to notify the competent authority (the National Commission for Information Technology and Civil Liberties, known as CNIL) under the conditions prescribed by the applicable regulations. If said breach results in a high risk, particularly in terms of privacy, we will notify you and provide you with the necessary information and recommendations.

9. YOUR RIGHTS OVER YOUR PERSONAL DATA

You have the following rights over your Personal Data collected and processed by us:

• right of access to your Personal Data : this is the right to obtain confirmation that your Personal Data is being processed, and if so, to access it,
• right to rectify your Personal Data : this is the right to obtain the modification of your inaccurate or incomplete Personal Data,
• right to limit the processing of your Personal Data : this is the right to obtain limited processing of your Personal Data, in the following cases: when you object to the processing of your Personal Data, when you contest the accuracy of the Personal Data or when you believe that their processing is unlawful, or when the deadline for deleting your Personal Data expires, but you wish to retain them to exercise your rights. This right does not apply to your Personal Data which would be necessary for the execution of an order,
• right to erasure of your Personal Data : this is the right to obtain the deletion of your Personal Data in certain cases (your Personal Data is no longer necessary with regard to the purposes for which it was initially collected, is subject to unlawful processing, etc.), and subject to legal or legitimate retention obligations,
• right to portability of your Personal Data : this is the right to receive your Personal Data at any time in a structured and commonly used format, in order to transmit them to another data controller. The right to portability only concerns processing carried out on the basis of your consent or the performance of the contract binding us,
• right to object to the processing of your Personal Data : this is the right to refuse the processing carried out by us for processing based on our legitimate interest and for commercial prospecting purposes, except in particular in the case of a compelling legitimate reason for the processing, if a contract binds us, if you have given your consent (you must then withdraw your consent and not object), or if a legal obligation requires us to process your Personal Data,
• right to define instructions regarding the fate of your Personal Data (including retention, deletion or communication) after your death. You can modify these instructions at any time. If you provide us with such instructions, you agree that your Personal Data will be stored, transmitted and executed. In the absence of a specific designation, your heirs will be entitled to take note of your instructions upon your death and request their implementation.

When the collection and processing of your Personal Data is based on your consent, this consent may be withdrawn at any time. Only processing based on this legal basis will be affected and suspended. This withdrawal does not affect the lawfulness of processing carried out before the withdrawal. All processing carried out on another legal basis will continue under the terms and conditions described in the Privacy Policy.

You also have the right to lodge a complaint with the competent national authority, in this case the National Commission for Information Technology and Civil Liberties (CNIL), without prejudice to any other recourse before the competent courts.

You can exercise these rights:

• By post to the following address (PO Box): LES HÉRITIÈRES – 31 avenue de Ségur - 75007 Paris, France or
• By email to the following address: contact@les-heritieres.com

In the interests of confidentiality and protection of your Personal Data, we must be able to verify your identity in order to respond to your request. To do this, you must attach, in support of any request to exercise the rights mentioned above, a photocopy of an identity document stating your date and place of birth and bearing your signature, in accordance with the provisions relating to the protection of individuals with regard to the processing of personal data and the free movement of such data.

We will process your request within a maximum of one (1) month from receipt.

10. CHANGES TO THE PRIVACY POLICY

LES HÉRITIÈRES may modify the Privacy Policy depending on the evolution of its activities, security standards and current legislation.

Any modification by LES HÉRITIÈRES will result in an update of the said Privacy Policy. In this case, the new version of the Privacy Policy will be notified to you by any means at our disposal (via our website or by email in particular), within a reasonable period of time prior to the entry into force of the new provisions of the Privacy Policy.

If you do not agree with the terms of the new Privacy Policy, you can notify us by exercising one of your rights, as detailed above.

If any of the clauses of this Privacy Policy is declared null or contrary to the regulations, it will be deemed unwritten but will not result in the nullity of the other clauses of the Privacy Policy.

11. FOR MORE INFORMATION

If you have any questions regarding our management of your Personal Data, you can contact us by one of the following means:

• by sending an email to the address: contact@les-heritieres.com
• by sending a letter by post to the following address (PO Box): LES HÉRITIÈRES 31 avenue de Ségur - 75007 PARIS