Sunn CGV

Privacy Policy 

PRIVACY POLICY

Manufacture Française du Cycle/Sunn offers a service to individuals for the sale and distribution of sporting goods for on the website which is accessible via the internet at https://www.sunn.fr (hereinafter the “Website”).

While you use the Website as a Customer, User or Visitor, Manufacture Française du Cycle may collect and process certain Personal Data of yours. Out of concern for your privacy, Manufacture Française du Cycle has implemented the necessary measures to protect your Personal Data and minimise the amount of Personal Data that it collects and processes.

The purpose of this policy (hereinafter the “Privacy Policy”) is to inform you about:

  • How Manufacture Française du Cycle collects and processes your Personal Data;
  • The commitments made by Manufacture Française du Cycle in order to ensure the security of your Personal Data;
  • Manufacture Française du Cycle’s obligations as well as your own obligations, with a view to maximising the protection of your Personal Data.

All terms beginning in uppercase letters, such as “Personal Data”, “Customer” and Users” refer to the definitions provided in Article 14 of this Privacy Policy.

  1. DATA CONTROLLER IDENTITY AND CONTACT INFORMATION

This Privacy Policy is a commitment made by Manufacture Française du Cycle, a simplified corporation with a sole shareholder (SASU) with a capital of €6,000,000, registered with the Nantes Trade & Companies Register under SIRET business registration number 791 771 223 00017, whose head offices are located at 27 rue Marcel Brunelière, 44270 Machecoul-Saint-Même, France (hereinafter “Manufacture Française du Cycle”). [Legal Notice]

You may submit any questions, requests for information or complaints that you may have to Manufacture Française du Cycle, as laid down in Article 6 below.

  1. WHAT PERSONAL DATA ARE COLLECTED AND HOW

– Personal data that Manufacture Française du Cycle collects directly from you:

Manufacture Française du Cycle mainly collects identification data (your name and email address), which it uses to determine who are in order to provide for optimal management of the business relationship it has with you, or more simply so it can manage the Website and its Customer Accounts.

  • To create your Customer Account, Manufacture Française du Cycle collects the following information: your title, full name, email address, password, date of birth, landline number, mobile phone number, postal address and the shop you have chosen as closest to you.
  • To create your rewards card, Manufacture Française du Cycle assigns you a rewards card number that is specific to you and collects the same information as for the creation of your Customer Account, along with data that are subsequently collected as and when you use your rewards card.
  • When you write a review on the Website, Manufacture Française du Cycle collects your email address and your satisfaction rating.
  • When you use the “Contact” form to contact Manufacture Française du Cycle, it collects your full name and email address.
  • When you contact Manufacture Française du Cycle by telephone, it collects your identification information (depending on the reason for your call).
  • When you decide to contact Customer Service using the Website’s tools, such as the “Contact” form, Manufacture Française du Cycle uses the information you previously entered on the Website, particularly the information used to create your Customer Account, in order to provide you with personalised service. If you do not want this to happen, you can log out before using those tools.
  • When you place an order, Manufacture Française du Cycle collects your billing address (and your shipping address if different), your telephone number and your debit/credit card information.
  • When you sign up for the newsletter, Manufacture Française du Cycle collects your email address.

As a general rule, if you do not complete any of the required fields marked with an asterisk (*), you will not be able to benefit from some or all of the Website’s Services and features, and your requests may not be processed and handled.

All other fields are optional and are designed to improve the quality of the Services offered to you by the Website.

If a form (review, contact, etc.) has a free text field, it is recommended that you do NOT enter any personal information there but only provide information that is strictly necessary to the handling of your request. Manufacture Française du Cycle may delete any non-essential information.

– Data that Manufacture Française du Cycle automatically collects when you use the Services:

Manufacture Française du Cycle collects the following information when you use the Services:

  • Technical data: your IP address, internet connection, browser type and information about the Device you are using;
  • Data gathered by cookies: for more information, see the Cookie Policy.

– Personal data that Manufacture Française du Cycle collects indirectly:

Manufacture Française du Cycle collects the following data from third parties like its partners for direct marketing purposes:

  • Your email address and telephone number;
  • Your full name and addresses.

 

  1. WHY MANUFACTURE FRANCAISE DU CYCLE COLLECTS AND USES YOUR PERSONAL DATA

Manufacture Française du Cycle may process your Personal Data on several grounds:

  • On the legal grounds of performance of a contract or pre-contractual measures taken at your request, such as picking and shipping your order, recording an e-reservation or creating a personalised gift card;
  • On the grounds of your consent;
  • On the grounds of the legitimate interests of Manufacture Française du Cycle. The legitimate interests pursued by Manufacture Française du Cycle include:
    • sharing personalised recommendations and promotions from Manufacture Française du Cycle with you,
    • sending the Manufacture Française du Cycle/Sunn newsletter to the email address you provided for that purpose,
    • managing your requests for information and your online reviews, especially in order to improve your User experience,
    • setting up and enhancing online sales tools and continuously improving the purchasing experience,
    • managing and administrating the Website;
  • On the grounds of a legal obligation.

The reasons why Manufacture Française du Cycle processes your Personal Data are as follows:

  • To manage and administrate the Website;
    • To manage responses to your requests submitted via the “Contact” form;
    • To manage your requests submitting via the “Contact form” requiring a response from the Gift Cards Service;
    • To manage the reviews you submit to Manufacture Française du Cycle;
  • To process your requests to exercise your rights (access, rectification, objection to processing, erasure, restriction of processing, data portability and instructions for your Personal Data in the event of your death);
  • To manage your registration for a Customer Account and to verify that you meet the necessary conditions;
  • To manage access to your Customer Account and use of the Website;
  • To give you access to the Services defined in the Terms & Conditions;
    • To allow you to place and track orders and see your order history;
    • To allow you to personalise your preferences in your Customer Account;
    • To send you direct marketing if you have consented to receive it;
  • To send you the Manufacture Française du Cycle newsletter;
  • To analyse connection and browsing data for the targeted advertising of the Website’s Services;
  • To manage cookies under the conditions set forth in the Cookie Policy;
  • To conduct surveys or analyses as part of sales operations organised by Manufacture Française du Cycle, its subsidiaries, its sales and affiliates network and/or any company offering a service on behalf of Manufacture Française du Cycle.


  1. DATA ACCURACY

As a User of the Website or a Customer of Manufacture Française du Cycle/Sunn, you acknowledge that you have been informed of the importance of the accuracy of your Personal Data which you provide via the Website or through your interactions with Manufacture Française du Cycle.

Consequently, you agree to only provide accurate Personal Data in your interactions, when entering into contractual agreements with Manufacture Française du Cycle, when requesting Services or when otherwise using the Website, and to update your Personal Data immediately if they should change over the course of the contract between you and Manufacture Française du Cycle or simply over the course of your use of the Website.

To that end, you may make a request to access and rectify your Personal Data, or to object to their processing, as stipulated (amongst others) under Article 5 (“Your rights”) below.

  1. YOUR RIGHTS

Your rights of access, rectification, erasure, restriction of processing and data portability

Pursuant to the provisions of Articles 15 to 21 of the European General Data Protection Regulation (GDPR) and Articles 38 to 40 of the French Data Protection Act, you, as a data subject, have the right to access, rectify and erase your Personal Data and restrict their processing by Manufacture Française du Cycle.

Further, for processing based on the legitimate interests of Manufacture Française du Cycle, you have the right to object, on grounds relating to your particular situation, to the continued processing of your Personal Data. It is understood that you may object to the processing of your Personal Data where these are processed for direct marketing purposes, at any time and free of charge.

Where the processing of your Personal Data by Manufacture Française du Cycle is based on your consent, you may withdraw your consent at any time by sending an email to contact@sunn.fr.

Last, you have the right to data portability for the Personal Data you provide to and that are processed by Manufacture Française du Cycle.

These rights are free to exercise (unless the request is manifestly unfounded or excessive), which you may do as follows:

  • By email stating the subject matter of the request, sent to contact@sunn.fr;
  • By letter stating the subject matter of the request, sent to Manufacture Française du Cycle, Service Juridique, 27 rue Marcel Brunelière, 44270 Machecoul-Saint-Même, France.

Your request must be signed and accompanied by a copy of an official form of photo identification and must specify the address to which we should send our response. You will receive a response within one (1) month of receipt of your request, which timeframe may be extended to two (2) months in view of the complexity or number of requests.

Personal Data after death

In accordance with the provisions of Article 40-1 of the French Data Protection Act, Manufacture Française du Cycle hereby informs you that, as a natural person:

  • You have the right to provide instructions to Manufacture Française du Cycle concerning the storage, erasure and disclosure of your Personal Data after your death;
  • You may change or revoke those instructions with Manufacture Française du Cycle at any time;
  • You may designate a person who will be responsible for the fulfilment of those instructions and who will be empowered after your death to review those instructions and demand their implementation by Manufacture Française du Cycle.

You are also informed that, in the absence of transmitting any specific instructions to Manufacture Française du Cycle on what to do with your Personal Data, following your death your heirs may exercise the rights relating to the storage, erasure and disclosure of your Personal Data where necessary to the organisation and settlement of your estate and to the acknowledgement of your death by Manufacture Française du Cycle.

  1. COMPLAINTS AND REQUESTS FOR INFORMATION

To request information about the processing of your Personal Data, you may contact Manufacture Française du Cycle by email sent to contact@sunn.fr. Further, pursuant to the GDPR, you have the right to lodge a claim with the French Data Protection Authority (CNIL).

Comprehensive information about the protection of personal data is available on the CNIL website.

  1. STORAGE PERIOD

Your collected Personal Data are stored for as long as necessary for the achievement of the purposes as described in Article 3 WHY MANUFACTURE FRANCAISE DU CYCLE COLLECTS AND USES YOUR PERSONAL DATA plus the legal limitation period.

Consequently, the storage periods are as follows:

  • For Personal Data relating to Website connections: the maximum statutory retention period of one (1) year beginning on the data of the concerned connection;
  • For Personal Data relating to Customers: the duration of the business relationship, plus three (3) years for the purposes of activation and direct marketing;
  • For Personal Data relating to leads: a period of three (3) years from the date of the last inbound contact with Manufacture Française du Cycle from the lead;
  • For Personal Data relating to accounting documents and records: ten (10) years, in the name of accounting evidence;
  • For Personal Data relating to past transactions and payment methods used: one (1) year from the date on which the invoice or payment was issued, on condition that you have indicated that you want Manufacture Française du Cycle to remember you and your information;

For Personal Data relating to the rewards programme: Facebook undertakes to automatically delete the data transferred to it by Manufacture Française du Cycle once the matching process is complete and to retain no copies or backups of the concerned Personal Data.

Your collected Personal Data are deleted after the occurrence of any of the following events (subject to the applicable legal limitation periods):

  • Expiration of the defined storage period;
  • Exercise of your right to erasure, in accordance with the French Data Protection Act and the conditions laid down in Article 5 (“Your rights”) above;
  • End of publication of the Website by Manufacture Française du Cycle for any reason whatsoever, save in the case of special instructions provided by you (on condition that those special instructions are reasonable and feasible for Manufacture Française du Cycle);
  • In the event of your death, expiration of the applicable storage and limitation periods or a request from a beneficiary with proof of your death and their status as your beneficiary.

These requests may be made by email sent to contact@sunn.fr.


  1. RECIPIENTS

Your Personal Data collected by Manufacture Française du Cycle may be transmitted to:

  • Third parties for the operation of the Website and for the purposes described in Article 3 (“Why Manufacture Française du Cycle collects and uses your personal data”);
  • Technical service providers delivering services that contribute to the achievement of the aforementioned services, namely including service providers that are responsible for:
    • processing, managing and/or fulfilling Services, reservations and orders,
    • processing payments and/or handling of security measures relating to the transmission of payment information,
    • sending direct marketing emails, invitations to register for an account and any other informational emails;
  • Electronic gift card recipients whose details you provided when purchasing an e-gift card;
  • Facebook, which undertakes as a processor not to transfer the data that it processes, once matching is complete, to any partners (including business partners), for any reason whatsoever.

If you do not want your Personal Data to be transmitted in these ways, you may exercise your rights to access, rectify, erase, object to or restrict the processing of your Personal Data, as outlined in Article 5 (“Your rights”).

You agree that Manufacture Française du Cycle may also be compelled to disclose any and all information about you in order to be in compliance with the Applicable Regulations or in response to a judicial or administrative request.

These requests may be submitted as follows:


  1. PERSONAL DATA SECURITY

Manufacture Française du Cycle takes appropriate technical and organisational measures to protect your Personal Data against accidental or unlawful destruction and against their unauthorised alteration, disclosure or access.

To that end, Manufacture Française du Cycle hashes Personal Data before transferring them to Facebook.

However, Manufacture Française du Cycle cannot control all the risks associated with the internet and so draws your attention to the existence of such risks which are inherent to the way the internet functions.

Manufacture Française du Cycle ensures that its service providers process your Personal Data with sufficient safeguards in terms of the implementation of appropriate data security measures.

Should you identify a security breach affecting the Website, you agree to confidentially communicate the relevant information about that breach to Manufacture Française du Cycle.


  1. CROSS-BORDER FLOWS OF PERSONAL DATA

In connection with your use of the Website, Manufacture Française du Cycle may need to transfer your Personal Data to partners located outside the European Economic Area, more specifically to the United States.

In those instances, the processing of your Personal Data is covered by the guarantees provided by the European Commission’s adequacy decision in respect of the EU-U.S. Privacy Shield. The Privacy Shield is a system of self-certification for companies established in the United States. The European Commission has recognised that this mechanism offers an adequate level of protection of Personal Data transferred from a European company to a company located in the United States. CNIL considers that this mechanism offers sufficient legal safeguards for such data transfers. More information about the Privacy Shield is available on the CNIL website.

All Personal Data transfers outside the European Economic Area carried out by Manufacture Française du Cycle comply with the requirements of the Applicable Regulations, thanks in particular to the appropriate safeguards implemented by Manufacture Française du Cycle, such as signature of the European Commission’s standard contractual clauses with the Personal Data recipient or the use of binding corporate rules.

  1. MODIFICATIONS

Manufacture Française du Cycle may make changes to this Privacy Policy, which will then be published online. When this happens, the previous Privacy Policy will automatically be replaced by the new version, which will be binding with immediate effect. Use of the Website is subject to the Privacy Policy in effect at the time of use.

To keep abreast of any such changes and updates, we recommend that you regularly review the active Privacy Policy. Manufacture Française du Cycle may choose to display a message on the Website about changes or updates to the Privacy Policy although it has no obligation to do so.

  1. RESPONSIBILITY

You agree to review the Website’s Terms & Conditions (hereinafter the “T&Cs”) and any other contractual documents that you may enter into with Manufacture Française du Cycle when using the Website and the Services. Collectively, the aforementioned documentation and this Privacy Policy constitute the entirety of the contractual agreement that is binding upon you.

You agree to strictly adhere to the terms of this Privacy Policy and of the Website’s T&Cs when using the Website.

Manufacture Française du Cycle shall not be held responsible in the event of (i) use of your Personal Data, particularly those that can identify you, by a third party, either through negligence or through you own actions; (ii) the inaccuracy of your Personal Data or the fact that you have not updated them; (iii) non-compliance with your obligations in connection with the Applicable Regulations, this Privacy Policy, the T&Cs and/or any other contractual documents that apply to you.

You will bear the cost of any financial penalties that may be ordered against Manufacture Française du Cycle, namely by a French judicial or administrative decision or by an independent administrative authority like the French Data Protection Authority (CNIL), as a result of a breach of your obligations under this Privacy Policy.

  1. GENERAL INFORMATION

If any of the clauses of this Privacy Policy are nullified, namely as a result of a change in legislation or in the Applicable Regulations, or by a court ruling, this shall in no way affect the validity and requirement of compliance with the Privacy Policy’s other clauses.

This Privacy Policy and the documents to which it refers are all governed by French law.

  1. DEFINITIONS

To ensure the proper understanding of this document, the terms defined below and beginning with uppercase letters, whether in singular or plural form, will have the following meanings:

 

Applicable Regulations:

All existing and future regulations and standards that apply to the Users and the Website, namely including, legislation and regulations that apply to web platforms like the Website and that concern the protection of Personal Data, such as the French Data Protection Act and the European General Data Protection Regulation.

 

Customer:

A legal entity or natural person with a Customer Account who is registered or resides in France and/or abroad and who makes use of the Website.

 

Customer Account:

The section of the Website that is available to Customers after registration on the Website, under the conditions stipulated in the Terms & Conditions. Customer Accounts are strictly personal, individual and non-transferable to third parties. Customer Accounts can be accessed by means of the Customer’s username and personal password, and contain all the Customer’s Personal Data.

 

Device:

The different hardware that Users may use to access the Website. In particular, Devices may include smartphones, Apple and Android tablets, personal computers and any smart objects or objects that can be connected to another object or to the internet.

 

Personal Data:

According to Article 4 of the European General Data Protection Regulation, “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one 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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

For example, data that allow you to be identified, such as your title, full name and email address are considered to be Personal Data.

 

Service:

The services offered to Customers by Manufacture Française du Cycle via the Website, as defined in the Terms & Conditions.

 

User:

Any natural person accessing the Website on their own behalf or on behalf of a legal entity, with the capacity and/or power to enter into a contractual agreement via the Website, whether they are a Visitor or a Customer.

 

Visitor:

Any natural person using the internet to view the Website on a Device, without being a Customer.