PRIVACY POLICY
Updated on 01/11/2023
1 - Definitions
Data or Personal Data : any information enabling Visitors and Users to be identified directly or indirectly.
Persons Concerned : Visitors, Users and Customers of the Site within the meaning of the GTC accessible on the Site. The terms Samples, User Account and Order are defined in the GCS.
Service provider : professional who provides PRO-NUTRITION with a service, and his employees, legal representatives and agents.
Applicable Regulations: Regulation n°2016/679 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such Personal Data [or RGPD] and Law n°78-17 of January 6, 1978 relating to data processing, files and freedoms [or LIL].
Data Controller: the person (natural or legal) who, alone or jointly with others, determines the purposes (why Personal Data is processed) and means (how it is processed) of the Processing.
Site : le site web <www.pro-nutrition.net> édité, géré et animé par PRO-NUTRITION.
Sub-Contractor : person (natural or legal) who processes Personal Data on behalf of a Data Controller.
Processing : all operations that may be carried out on Personal Data, such as collection, recording, access, consultation, backup, restoration, use, transmission and deletion.
PRO-NUTRITION : SOPRAL, a société par actions simplifiée (simplified joint-stock company), with capital of 7125,000 euros, registered in the RENNES trade and companies register under number 679 200 741 00065, with registered office at Cesson-Sévigné, 3 rue de Paris - Immeuble Atalis 2 - Bâtiment E - 35577 CESSON SEVIGNE CEDEX.
2 - Introduction
2.1 General information
Aware of the importance of ensuring the security and confidentiality of Personal Data, PRO-NUTRITION is strongly committed to the protection of Personal Data.
This Personal Data Use Policy_ PUDP (hereinafter the "Policy") informs the Data Subject of the commitments and measures taken by PRO-NUTRITION to ensure the protection of Personal Data.
PRO-NUTRITION's approach is in line with the Personal Data protection system:
- The General Data Protection Regulation n°2016/679 of the European Parliament and of the Council of April 27, 2016,
- Directive 2002/58/EC of the European Parliament and of the Council of July 12, 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (Directive on privacy and electronic communications),
- French Data Protection Act no. 78-17 of January 6, 1978, as amended,
- Decree n° 2019-536 of May 29, 2019 taken for the application of the law n° 78-17 of January 6, 1978 relating to data processing, files and freedoms,
- Law no. 2016-1321 of October 7, 2016 for a Digital Republic,
- Recommendations and guidelines from the European Data Protection Committee (EDPS) and the Commission Nationale de l'Informatique et des Libertés (CNIL).
The Policy may evolve according to the legal and regulatory context, the decisions of competent judges and the doctrine of the EDPS and the CNIL.
2.2 Objectives
The purpose of the Policy is to centralize in a single document clear, simple and precise information concerning the Processing of Personal Data of Data Subjects operated by PRO-NUTRITION.
The Policy enables Concerned Persons to understand:
What Personal Data | For what purpose(s)? | What rights do they have to their |
It sets out the general principles and organization put in place by PRO-NUTRITION to ensure the proper application of Applicable Regulations.
3 - Scope of application
The Policy applies exclusively to Concerned Persons as defined in Article 1 of the PUDP.
4 - Person responsible for processing
The Data Controller is SOPRAL (PRO-NUTRITION).
SOPRAL
679 200 741 00065 R.C.S. RENNES
3 rue de Paris - Immeuble Atalis 2 - Bâtiment E - 35577 CESSON SEVIGNE CEDEX
contact@pro-nutrition.fr
5 - Data Protection Officer
In order to ensure that its practices comply with the Applicable Regulations, PRO-NUTRITION has appointed a Personal Data Protection Officer (hereinafter the "Officer").
The Data Protection Officer is the Data Subject's main point of contact with PRO-NUTRITION regarding the protection of Personal Data.
The Data Subject may contact the Data Controller with any questions relating to the Processing of his or her Personal Data and the exercise of his or her rights in relation thereto (see article 13).
DATA PROTECTION OFFICER
Mail: contact@pro-nutrition.fr
6 - Personal data protection principles
6.1. Legitimate and specific purposes
PRO-NUTRITION collects and processes Personal Data for a specific, explicit and legitimate purpose.
The objectives pursued by PRO-NUTRITION are set out in an inventory available in section 10 of the Policy.
The Data may not subsequently be used in a manner incompatible with these purposes.
6.2. Data minimization
PRO-NUTRITION takes care to limit the collection of Data to that which is strictly necessary for the objective pursued.
However, if PRO-NUTRITION invites the Data Subjects to communicate only the Personal Data that are strictly necessary to process their request, the Data Subjects remain free to communicate the Personal Data of their choice.
PRO-NUTRITION may not be reproached for collecting Data which it has not requested to be communicated.
6.3. Fair and transparent data collection
PRO-NUTRITION informs the Data Subjects of each Processing that it implements through :
- the information on its Site, and
- to this Policy.
Data is collected fairly: it is not collected without the knowledge or consent of the Data Subject.
6.4. Data protection taken into account by default and right from the design stage
PRO-NUTRITION undertakes, when implementing its Processing and in particular when using technologies, including those supplied by Service Providers or Subcontractors, to ensure that they and PRO-NUTRITION take into account the following principles:
- The Processing of Personal Data must be limited to what is necessary;
- Access to Personal Data is restricted to those who need to have access to it;
- Data is kept for no longer than is legally required or recommended for the purpose of the Processing;
- Applicable regulations concerning the protection of Personal Data are complied with.
7 - Legal basis for Processing
In accordance with Applicable Regulations, Processing is only carried out if a legal basis has been identified.
Depending on the purpose for which the Personal Data is used, the legal basis for the Processing of Personal Data may be :
- the consent of the Person Concerned ;
- PRO-NUTRITION's legitimate interests (e.g. customer loyalty);
- the execution of pre-contractual measures or GTCs concluded with the Data Subject;
- to comply with a legal obligation if current legislation requires the Data to be processed (e.g. the retention of User Account connection logs).
PRO-NUTRITION has identified the legal basis for each Processing operation (see article 10).
8 - Recipients of Personal Data
The Data collected by PRO-NUTRITION is processed internally by employees authorized to do so and subject to an obligation of confidentiality.
The Data of Concerned Persons may also be communicated to trusted Service Providers, chosen by PRO-NUTRITION, and who process said Data specifically in the name of and on behalf of the latter (e.g. IT service providers: messaging provider, online chat solution, hosting, maintenance of IT tools, etc.).
They may also include service providers who provide consulting services (e.g. safety auditors, legal advisors, statutory auditors, chartered accountants, etc.).
PRO-NUTRITION ensures that all Service Providers it uses offer sufficient guarantees in terms of Data protection, particularly with regard to confidentiality and security.
Finally, PRO-NUTRITION may communicate Data Subjects' Data to authorized third parties such as the judicial authorities.
9 - Data retention periods
PRO-NUTRITION keeps Data Subjects' Data only for as long as is necessary to achieve the objective pursued at the time of collection and in compliance with Applicable Regulations.
PRO-NUTRITION may keep certain Data for a longer period in order to fulfil its legal or regulatory obligations, and to enable it to exercise or prove a right.
10 - Treatment details
PRO-NUTRITION also processes the Personal Data of Data Subjects by depositing cookies. For further information, Data Subjects are invited to refer to PRO-NUTRITION's Cookies Policy, accessible on the Site.
11 - Security of Personal Data
PRO-NUTRITION implements organizational and technical measures to ensure the security of Data Subjects' Data, in particular by protecting them against loss, alteration, disclosure and unauthorized access.
12 - Transfer of Personal Data outside the EEA
Wherever possible, PRO-NUTRITION endeavours not to transfer Data Subjects' Data outside the EEA.
Nevertheless, in certain cases, Data may be transferred to or accessed and/or stored in countries outside the EEA. It may, for example, be processed by Subcontractors operating outside the EEA.
PRO-NUTRITION transfers Data outside the EEA only in a secure manner and in compliance with Applicable Regulations.
In accordance with the provisions of Articles 44 et seq. of the RGPD, PRO-NUTRITION chooses Service Providers or Subcontractors established outside the EEA who, depending on the case:
- comply with the conditions set out in the Policy;
- have regulations ensuring an adequate level of protection;
- include in their contracts, or agree to sign, standard contractual clauses adopted by the European Commission.
Identity of subcontractor | Role / missions | Processed data | Warranties adopted |
STRIPE | Online payment service. | Payment information (card number or bank details, amount and date of purchase). | Adoption of standard contractual clauses. https://stripe.com/fr/privacy#Transferts-internationaux-de-donnees |
TAWK TO | Online chat solution. | Data collected via Site chat (name, email, message). | Adoption of standard contractual clauses. |
TYPEFORM | Online form creation tool. | Data collected via the Sample request form. | Adoption of standard contractual clauses. https://admin.typeform.com/to/dwk6gt/ |
CREDIT AGRICOLE (Transaction module) | Online payment service. | Payment information (card number or bank details, amount and date of purchase). |
For further information, the Data Subject may contact PRO-NUTRITION and its Data Protection Officer at contact@pro-nutrition.fr or write to him at Pont Réan, 74 rue de Redon 35580 GUICHEN.
13 - Rights of Persons Concerned
In accordance with the Applicable Regulations, the Data Subject is entitled to the following rights in respect of his or her Personal Data, which may be exercised by contacting PRO-NUTRITION using the contact details set out below:
Information | She is informed in a clear, transparent, understandable and easily accessible way about how PRO-NUTRITION processes her Personal Data and about her rights. |
Access | It may be provided with a copy of its Personal Data. PRO-NUTRITION may require payment of a fee for any request for an additional copy. |
Rectification | The Data Subject may ask PRO-NUTRITION to rectify his/her Personal Data if it is inaccurate or out of date, or to complete it if it is incomplete. |
Opposition | Unless there is a compelling reason to the contrary, he or she may object to the Processing of Personal Data for the purpose of fulfilling PRO-NUTRITION's legitimate interests. |
Deletion | It may request the deletion of its Personal Data. In certain cases, PRO-NUTRITION must nevertheless retain Data for legal or legitimate reasons. |
Limitation | In certain cases, the Data Subject may request the suspension of the Processing of his/her Personal Data. |
Portability* | It may request PRO-NUTRITION to retrieve its Personal Data in order to dispose of it. This only applies to Data provided when Processing is based on consent or on a contract and is carried out using automated processes. |
Withdrawal of consent | The Data Subject may withdraw his/her consent at any time, when the Processing of his/her Personal Data is based on consent. |
Post-mortem instructions | You also have the right to formulate specific and general directives concerning the conservation, deletion and communication of your post-mortem Data. |
Claim | The Data Subject has the right to lodge a complaint with the data protection authority of his/her country (the CNIL for France) to contest a decision taken by PRO-NUTRITION concerning his/her Data. The Data Subject is nevertheless invited to contact PRO-NUTRITION before lodging any complaint. |
* The Person concerned, provided they have a personal space on the Site, can access and download their Personal Data from their space by clicking on the "My Personal Data" tab.
PRO-NUTRITION undertakes to respond to requests to exercise rights as quickly as possible and in any event within the legal time limits. PRO-NUTRITION may ask the Data Subject for proof of identity if it is unable to identify him or her.
Contact: contact@pro-nutrition.fr / 3 rue de Paris - Immeuble Atalis 2 - Bâtiment E - 35577 CESSON SEVIGNE CEDEX
