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Privacy Policy

Last Updated 06/09/2022

1. PURPOSE OF THE PRIVACY POLICY

The content of this privacy policy (hereinafter the “Privacy Policy”) is published by RelevanC, société par actions simplifiée (a simplified joint stock company under French law) with a sole shareholder entered on the Saint-Etienne Trade and Companies Register under number 824 155 824 represented by Cyrille Geffray in his capacity as Chief Executive Officer, whose registered office is located at 1, cours Antoine Guichard 42000 Saint-Etienne (hereinafter “RelevanC” or the “Company”).

The purpose of this Privacy Policy is to define the terms and conditions under which the Company processes personal data relating to natural persons who are customers and/or prospects of the Casino Group brands or of companies outside the Casino Group.

 

2. DEFINITIONS

« Advertiser »: means any company, whether a Brand or a third party company, on behalf of which advertising activities are carried out by RelevanC.

« Cookie(s) »: means a text file placed on a user's hard disk by the server of the website visited or by a third party server, containing information relating to the user's browsing.

« Data »: means any personal data (such as surname, first name, email address, postal address, etc.) within the meaning of the applicable Regulations.

« Brand(s) »: means any subsidiary of the Casino Group within the meaning of Article L. 233-1 of the French Commercial Code (Code de Commerce).

« Casino Group »: Means Casino, Guichard Perrachon, a société anonyme (public limited company under French law), whose registered office is at 1 Cours Antoine Guichard, 42 000 Saint-Etienne, identified under number 554 501 171 with the Saint-Etienne Trade and Companies Register, and its Brands.

« Data Subject(s)» or « You »: means any natural person whose Data is processed by RelevanC.

« Advertising Space Sales Agency »: means a company whose business consists of managing and selling advertising space on one or more media to Advertisers.

« Applicable Regulations »: means the domestic and European laws and regulations relating to the protection of personal data, including (i) French Law No. 78-17 of 6 January 1978 as amended relating to information technology, data and freedoms, (ii) Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 (iii) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and (iv) any other future applicable legislation that may supplement or replace them.

« Regulation »: means Regulation (EU) No. 2016/679 of 27 April 2016 on the protection of personal data.

« RelevanC Website »: means the RelevanC website at the following address: www.relevanc.com

« Brand Website(s)»: means the website of one or more Casino Group Brand(s).

« Website(s) »: refers indifferently to the RelevanC Website and/or the Website(s) of one or more Brands.

 

3. RESPONSABILITIES OF RELEVANC

Within the meaning of the applicable Regulations, certain Data processing is carried out under the responsibility of RelevanC, or under the joint responsibility of RelevanC and one or more Brands and/or third-party companies.

Upon simple request by registered letter with acknowledgement of receipt sent to the following address: Service Juridique 35, boulevard de Sébastopol 75001 Paris, any Data Subject may obtain the outline of the joint liability agreement between RelevanC and the Brand that has collected their Data.

For other processing, RelevanC acts as a processor for the Brands, or as a processor for other Casino Group companies or third-party companies.

 

4. THE DATA PROCESSED BY RELEVANC

4.1 Nature of Data processed

RelevanC processes the following Data:

  • Identity data and contact details such as: last name, first name, date of birth, gender, postal address, telephone number and email address;
  • Transactional data such as: date and time of a transaction (collection), point of sale of the Brand in which the transaction was carried out, product(s) or service(s) covered by the transaction, quantity of products or services purchased, amount of discounts or rebates (if applicable);
  • Browsing data, in particular on the websites of the Retailers, such as: IP address of the device used, identifiers associated with the device used, type of browser and operating system used, date, time and duration of browsing, pages searched and/or consulted, browsing duration, reference URL (if applicable);
  • Behavioural data related to in-store or online purchases such as: purchasing habits and preferences, average basket, product categories, etc.

4.2 Data collection methods

The Data is collected by the Brands from which the Data Subject purchases online or in physical stores, and communicated to RelevanC.

Data may also be communicated by the Data Subject directly to RelevanC, for example by completing a contact form via the RelevanC Website.

Prior to any communication of Data, the Data Subject is informed of the mandatory or optional nature of such Data, the consequences of a refusal to communicate mandatory Data, its rights and the purpose.

When the Data Subject visits or uses the RelevanC Website, the Brand Websites, as well as certain third-party websites of which RelevanC is a partner, trackers (cookies and similar technologies) automatically collect information from the device used. The Data Subject may accept or refuse cookies that are not essential for the proper functioning of these Websites.

 

5. PURPOSES OF PROCESSING

RelevanC processes the Data for the following purposes:

  • Administering the RelevanC Website (corrective and upgrade maintenance, fraud detection, etc.);
  • Make audience measurements on the Websites in aggregated and anonymised form;
  • Communicating with the Data Subjects in the context of a request for information on RelevanC products and services;
  • Communicating with the Data Subjects in the context of a request to exercise rights;
  • Managing RelevanC pages on social media related to the RelevanC recruitment policy (such as, but not limited to: LinkedIn™, Welcome to the Jungle™)
  • Managing RelevanC pages on social media in connection with the improvement of RelevanC customer knowledge and RelevanC institutional communication (Facebook™, Twitter™, Instagram™)
  • Carrying out targeted commercial canvassing with loyalty card holders on behalf of Advertisers, Retailers or Advertising Space Sales Agencies;
  • Carrying out targeted commercial canvassing with people who do not have a loyalty card;
  • Carrying out statistical studies related to changes in consumer trends in aggregated and anonymised form;
  • Allowing RelevanC to comply with its legal obligations;
  • Allowing RelevanC to comply with security and audit requirements;
  • Allowing RelevanC to defend its interests, including in court;
  • Displaying the most appropriate advertisement for the profile of Data Subjects using online behavioural advertising and programmatic advertising techniques, and determining whether the Data Subject is a member of a social media platform in order to display advertising there and/or to identify consumers with similar interests and characteristics.

6. LEGAL BASES FOR THE PROCESSING

RelevanC processes the Data either on the legal basis of the consent of the Data Subject or on the legal basis of the legitimate interest of RelevanC while preserving the interests and fundamental rights of the data subjects.

Where RelevanC bases its processing on the legal basis of consent, the Data Subject is asked to accept or refuse such processing by ticking an appropriate box. The Data Subject is informed that he or she has the option to withdraw this consent at any time.

Where RelevanC bases such processing on the lawful basis of the legitimate interest, they are informed that they have the option to object to such processing

 

7. RECIPIENTS OF THE DATA

The Data is primarily intended for processing by persons who are RelevanC personnel.

Where necessary, RelevanC may disclose Data to persons other than the aforementioned persons.

This may include:

  • RelevanC service providers, contractors and other partners such as: social media platforms, search engines, advertising agencies, credit institutions, IT development and maintenance companies, website hosting and management companies, legal, accounting, auditing and other professional service providers related to RelevanC’s activities;
  • third parties involved in a sale, merger, consolidation, change of control, transfer of substantial assets, financing, restructuring or liquidation of RelevanC; 
  • agents of a public or judicial authority, governmental agencies, regulatory agencies or other third parties to comply with applicable law, or to detect, protect or defend the interests of RelevanC.

8. LOCATION OF DATA

Data is in principle processed by RelevanC in the EEA (European Economic Area).

By way of exception, the Data may be located outside this territory, for example for storage or maintenance purposes. In such an event, RelevanC ensures that the Data is located either in a territory benefiting from an adequacy finding, or that such Data is transferred by means of appropriate transfer instruments provided for by the Regulation (in particular by means of standard contractual clauses or binding corporate rules).

Any request for information concerning the location of your Data must be sent to the following contact details:

  • By email: mes-droits@relevanc.com
  • By traditional mail: RelevanC – For the attention of the DPO – 35, boulevard de Sébastopol 75001 Paris

 

9. DATA SECURITY

Data security is one of RelevanC’s priorities.

To this end, RelevanC undertakes to implement appropriate technical and organisational measures to ensure a level of data security appropriate to the risk to the rights and freedoms of natural persons in the context of the aforementioned processing.

These measures take into account the state of knowledge, the nature and intensity of the risks, as well as the implementation costs.

You are invited to consult the RelevanC Data Security Charter at the following link:

 

10. COOKIES

RelevanC uses Cookies.

You are invited to consult the RelevanC Cookie Policy by clicking on the following link:  https://www.relevanc.com/en/cookies-policy/

 

11. RIGHTS OF THE DATA SUBJECTS

Data Subjects are informed that they have the following rights over their Data, under the conditions and limits provided for by the Applicable Regulations:

  • the right to withdraw their consent at any time when the Data processing is based on consent;
  • the right to object to the processing of all or part of the Data;
  • the right to request the limitation of certain Data processing;
  • the right to access the Data and to receive a copy of said Data in a structured, commonly used and machine-readable format;
  • the right to request the deletion of the Data;
  • the right to request any rectification of the Data;
  • the right to give instructions on how to deal with the Data post-mortem;
  • the right to lodge a complaint with the Commission Nationale Informatique et Libertés (French Data Protection Agency “CNIL”) or any supervisory authority under the conditions set out hereinafter.

Any complaint may be submitted to the CNIL (information available at www.cnil.fr).

However, before making any complaint, You should contact RelevanC at the following address:

  • By email: mes-droits@relevanc.com
  • By traditional mail: RelevanC – For the attention of the DPO – 35, boulevard de Sébastopol 75001 Paris

 

12. DATA STORAGE PERIOD

RelevanC undertakes to ensure that the Data are retained for no longer than the period necessary for the purposes for which the Data are collected and processed.

Administering the RelevanC Website: The time required for corrective and upgrade maintenance and fraud detection operations. .

Performing audience measurements on the Websites in aggregated and anonymised form: 25 months from the collection of the Data by means of Cookies.

Communicating with the Data Subjects in the context of a request for information on RelevanC’s products and services: 12 months from the last exchange with the Data Subject

Communicating with the Data Subjects in the context of a request to exercise rights: 5 years from the Data Subject’s request to exercise a right

Managing RelevanC pages on social media related to the RelevanC recruitment policy (such as, but not limited to: LinkedIn™, Welcome to the Jungle™): Job application data are retained for a period of 2 years in the current database and then 3 additional years in archiving.

Carrying out targeted commercial canvassing on behalf of Advertisers, Retailers or Advertising Space Sales Agencies: Contractual term (attached to the Data Subject’s loyalty card with the Brand) extended by twelve (12) months from the last activation of the card, except in the event of a request to delete the account or card.

Carrying out statistical studies related to changes in consumer trends in aggregated and anonymised form: A period of five (5) years from the date of the transaction in question (in concrete terms: the date on the receipt).

Allowing RelevanC to comply with its legal obligations and security and audit requirements: Duration of the legal obligation in question.

Allowing RelevanC to comply with security and audit requirements 

Allowing RelevanC to defend its interests, including in court: For the duration of the relevant statutory limitation period.

 

13. CONTACT DETAILS

Any request for information relating to this Privacy Policy must be sent to the following contact details:

  • By email: mes-droits@relevanc.com
  • By traditional mail: RelevanC – For the attention of the DPO – 35, boulevard de Sébastopol 75001 Paris

 

14. UPDATING

This Privacy Policy may be updated in line with changes in the applicable Regulations.

Please check it regularly.

 

15. APPLICABLE LAW

This Privacy Policy is subject to French law.