The Château Lascombes company undertakes to collect and use your data in observance of the regulations relating to the protection of personal data, namely the European regulations relating to the protection of private persons in regard to the processing of personal data (GDPR) and to ensure its security and confidentiality.

This policy (“hereafter “the Policy”) aims to inform you of the reasons for which we are caused to process your personal data, in the manner that we do so and your rights in the matter.

The Policy covers the processing that we carry out in the context of offering those products and services provided by Château Lascombes.

For ease of reading, here are various clarifications relating to the terminology used in the Policy in the matter of personal data.

What is personal data?

Personal data is any information or data allowing the direct or indirect identification of a natural person (especially the surname, first name, telephone number, email address, ID number, IP address, licence plate, etc.).

What is sensitive data?

Sensitive data is any data revealing the racial or ethnic origin, political opinions, religious or philosophical convictions or union membership, as well as genetic data, biometric data in order to identify a natural person in a unique manner, data relating to health or data concerning the sex life or sexual orientation of a natural person, as well as data relating to criminal sentences or offences.

What is processing of data?

Data processing is any operation or group of operations whether carried out or not using automated processes relating to personal data, which especially includes the collecting, recording, organisation, conservation, adaptation, modification, extraction, consultation, use, communication via transmission, dissemination or any other form of otherwise making available, alignment or combination, limitation, erasure or destruction.

What is a data controller?

A data controller is any natural or legal person, who determines, solely or jointly, the purposes and means of the processing.

Why do we collect personal data?

We are caused to collect – in a relevant and proportionate manner – and process your personal data for the following purposes:

• The processing and delivery of your order via our internet website.
• Management of your personal space via our internet website, including your connection management, implementing appropriate measures to ensure your account’s security;
• Operations relating to commercial management and commercial prospecting.

These operations especially include those linked with customer loyalty programmes, the dispatch of promotional and commercial offers likely to interest you, as a function of your profile.

• The carrying out of legal, regulatory and administrative requirements in force;
• The managing of your various complaints and enquiries (for example, a request for information relating to our products and services;
• The managing of your requests for right of access, rectification, objection or any other right relating to the use of your personal data.

When we are caused to collect and process data relating to you for particular purposes, which is to say, for other aims than those described above, we shall inform you via a specific information notice at the time of the collection of the said data.

Who is the data controller for my personal data?

The data controller for your personal data is the following entity:

CHATEAU LASCOMBES SA
Head Office: 1 cours de Verdun
33460 MARGAUX
SIREN No. 344 388 848 – SIRET No. 442 783 1630 0011

With whom might we share your data?

Within the strict limits of processing carried out for the stated purposes in this Policy, we are caused to communicate certain data of yours:

• To staff authorised by Château Lascombes in the context of the carrying out of their tasks (e.g. authorised staff in charge of receipt and processing of your order, etc.);
• To subcontractors – for example, we may be caused to entrust certain technical operations, linked with the maintenance of our IT systems and delivery, to outside companies;
• To persons authorised in their capacity of authorised third parties (e.g. supervisory authorities, statutory auditors, auditors, etc.).

All of your personal data is retained within the European Union. We do not transfer your data to any countries outside the European Union.

Château Lascombes does not transfer personal data that you provide us to third parties for uses which would be specific to them.

What are the legal grounds for processing your personal data?

The legal grounds which form the basis of us being able to process your personal data are:

• the requirement to fulfil a contract or pre-contractual measures for the purposes of;
• complying with a legal obligation;
• the legitimate interests of the data controller.

The table below indicates, by purpose, the legal basis upon which we rely for the processing of your data.

How long do we keep your data?

Your personal data is kept for the time necessary for the carrying out of the purposes described in this Policy. They are then archived to comply with the legal or regulatory requirements, or in order for Château Lascombes to establish proof of a right or a contract (periods applicable to limitation). Here are some examples:

What are your preferences regarding commercial prospecting?

We carry out communications in the context of our relationship with you to offer you new products likely to correspond to your requirements.

If you consent to this (excluding cases in which the applicable regulations so authorise us), we are likely to send you our commercial offers by email.

You may withdraw your consent at any time and/or object to receiving commercial communications from us and contact us according to the ways described in the section, “What are your rights?”

What are your rights?

In accordance with the applicable regulations, you have those rights as below relating to the use of your personal data. These rights may be subject to certain legal conditions, limitations and exceptions.

• Right of access: you have the right to obtain a confirmation that the personal data affecting you is being processed, to obtain a copy of it, as well as certain information linked to its processing.
• Right of rectification: you have the right to obtain the rectification of personal data affecting you, that is inaccurate, as well as supplementing it.
• Right of deletion: you may, in certain cases, obtain the deletion of personal data affecting you. This right particularly applies when your personal data is unnecessary in regard to the purposes for which they were collected.
• Right of objection: you may object, for reasons relating to your particular situation, to the processing of your personal data.
• Right of limitation of processing: under certain circumstances, you have the right of obtaining a limitation upon the processing of your personal data.
• Right to the portability of your data: in certain cases, you can request to receive the personal data affecting you that you have provided to us, or, when that is possible, for us to send it directly to another data controller.
• Right to withdraw your consent: for processing requiring consent from you, you have the right to withdraw your consent at any stage. Exercising this right does not infringe the legality of processing based on the consent given before the withdrawal of same.
• Right to give instructions relating to the treatment of your data post-mortem: you have the right to give instructions relating to the conservation, deletion and communication of your personal data after your death.

For any procedure relating to the exercise of your rights, you may convey your request in the following ways:

– By email: contact@chateau-lascombes.fr

– By post: CHATEAU LASCOMBES- 1 Cours de Verdun 33460 MARGAUX

You also enjoy the right to lodge a complaint to the National Commission for Data Protection and Liberties (CNIL). For further information, we invite you to visit the CNIL’s website. Furthermore, we have set in place various relevant technical and organisational measures, aiming to ensure the security of your data and avoid the risks linked with its being violated. We undertake to inform you, as soon as possible, in the event of data affecting you being compromised which is liable to bring about a heightened risk to your rights and liberties.

How can we be contacted for any request relating to the processing of your personal data?

For any questions relating to the processing of your personal data and the exercise of your rights, you may contact the château by using the following details: contact@chateau-lascombes.fr or by post, CHATEAU LASCOMBES, 1 Cours de Verdun 33460 MARGAUX.