Registered Office: SAS Gérard Tremblay 12 rue de Poinchy - 89800 CHABLIS

Tel: +33 (0)3 86 42 40 98 - Email: gerard.tremblay@wanadoo.fr

RCS AUXERRE 338 646 748 VAT No.: FR 86338646748

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Publication Directors: Eléonore Tremblay, General Manager, and Vincent Tremblay, President

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Graphic Design: Elodie Schaller Communication

Photo Credits: BIVB, BIVB/A. Ibanez

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Hosting: Gandi 75013 Paris, France, 63-65 boulevard Masséna

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REPRODUCTION RIGHTS

In accordance with the Law of March 11, 1957 (Art. 41) and the Intellectual Property Code of July 1, 1992, all texts, illustrations, photographs, plans, drawings, animations, videos, and content on this website may not be used or reproduced without obtaining authorization from SAS Gérard Tremblay.

For any requests regarding the reproduction or use of elements contained on the website www.chablis-tremblay.com, please contact: gerard.tremblay@wanadoo.fr

 

PERSONAL DATA PROTECTION POLICY

SAS GERARD TREMBLAY is committed to protecting the personal data of its clients, anyone who accesses its website, and, more generally, any individual whose personal data it may process. SAS GERARD TREMBLAY is also aware of the need to ensure that individuals retain control over their personal data. The purpose of this Personal Data Protection Policy is to provide the individuals concerned with important information regarding how SAS GERARD TREMBLAY processes their personal data, and how they may exercise their rights. It is also intended to meet the requirements of regulations concerning the protection of personal data (notably Regulation No. 2016/679).

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1. Who is responsible for the processing of personal data?

The data controller is: SAS GERARD TREMBLAY Simplified Joint-Stock Company (Société par Actions Simplifiée) with a capital of 128,970.00 euros 12 Rue de Poinchy, 89800 Chablis, France Registered with the Auxerre Trade and Companies Register (RCS) under number 338 646 748 gerard.tremblay@wanadoo.fr Telephone: +33 (0)3 86 42 40 98

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2. For what reasons/purposes and on what legal basis is personal data processed?

SAS GERARD TREMBLAY processes your personal data for various reasons/purposes—for example, to manage customer relations (purchases, warranties), or to keep you informed about product news or the latest commercial offers via email or postal mail. Depending on the purpose, the processing of your personal data is based on the performance of a contract (or pre-contractual measures), your consent, the legitimate interests of SAS GERARD TREMBLAY, or compliance with a legal obligation (such as the management of product recall campaigns). For further details, please refer to the sections below.

SAS GERARD TREMBLAY may process personal data for the following purposes:

Processing based on the performance of a contract (or pre-contractual measures) concluded between SAS GERARD TREMBLAY and an individual:

- Customer relationship management: contracts, orders, deliveries, invoices, and accounting;

- Management of warranties, complaints, and after-sales service;

- Management of outstanding payments and legal disputes;

- Management of product recalls.

Processing based on consent:

- Commercial solicitation via email for SAS GERARD TREMBLAY products, directed at individuals who have provided their consent and have not previously shared their personal data in connection with a product purchase from SAS GERARD TREMBLAY;

- Placement of cookies to enable or facilitate website navigation, save browsing preferences on the website, and compile statistics on visits to and interactions with the website.

Processing based on the legitimate interests pursued by SAS GERARD TREMBLAY:

- Responding to contact requests made by individuals to SAS GERARD TREMBLAY, including requests to be contacted by SAS GERARD TREMBLAY. The legitimate interest pursued by SAS GERARD TREMBLAY is the ability to respond to requests from individuals who have contacted the company.

- Execution of a contract concluded between SAS GERARD TREMBLAY and a legal entity. The legitimate interest pursued by SAS GERARD TREMBLAY is to ensure the performance of the contract, which encompasses the following purposes:

o management of customer relations: contracts, orders, deliveries, invoices, and accounting;

o management of warranties, complaints, and after-sales service;

o management of outstanding payments and legal disputes;

o management of product recalls.

- Commercial prospecting directed at individuals who have provided their personal data in the context of a purchase of a product from SAS GERARD TREMBLAY, regarding similar products. The legitimate interest pursued by SAS GERARD TREMBLAY is to continue or renew an existing commercial relationship with individuals who have already demonstrated an interest in its products. You may easily object to receiving these offers at any time by clicking the unsubscribe link provided in each email communication, or by sending a letter to SAS GERARD TREMBLAY – Personal Data Protection Department, 12 RUE DE POINCHY, 89800 CHABLIS, or an email to the following address: gerard.tremblay@wanadoo.fr.

- Commercial solicitation by mail or telephone regarding SAS GERARD TREMBLAY products, directed at individuals who have requested information via the SAS GERARD TREMBLAY website or who have engaged with commercial activities related to SAS GERARD TREMBLAY products.

- Distribution of the SAS GERARD TREMBLAY newsletter to individuals who have requested to receive it and have registered for this purpose on the SAS GERARD TREMBLAY website.

- Preparation of commercial statistics. The legitimate interest pursued by SAS GERARD TREMBLAY in this context is to maintain a commercial relationship with individuals who have shown interest in its products, to better understand their needs, to promote its products and services, and to organize commercial campaigns.

- Fraud detection. The legitimate interest pursued by SAS GERARD TREMBLAY in this context is to identify potential fraud.

Processing based on a legal obligation: -

Handling requests from data subjects regarding their rights of access, rectification, and objection;

- Managing complaints and legal disputes.

 

3. What categories of personal data are processed?

SAS GERARD TREMBLAY may process personal data relating to your identity. The term "personal data" refers to any information relating to an identified or identifiable natural person. For further details, please refer to the sections below.

SAS GERARD TREMBLAY may process personal data relating to:

- Individual identity (including title, surname, first names, and date of birth);

- Contact information (such as postal address, landline and/or mobile phone number, fax number, and email address);

- Products purchased and the management of the commercial relationship (such as requests for documentation, products purchased, quantity, amount, frequency, delivery address, purchase history, product returns, the origin of the sale or order, and correspondence with the customer or after-sales service).

- to the transaction and payment methods (such as the transaction number, details of the purchase or of the good or service subscribed to; the type of payment method (PayPal, bank card) and related information);

- to the connection to servers and the internet (such as digital login identifiers, IP address, connection logs).

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4. Cookies

The SAS GERARD TREMBLAY website uses "cookies" (small files, typically consisting of letters and numbers, sent by a web server to the cookie file in the browser on your computer's hard drive) to enable or facilitate navigation, save your browsing preferences on the website, and compile statistics on visits and interactions with the site.

You will be provided with clear and comprehensive information before any "cookie" is installed, allowing SAS GERARD TREMBLAY to obtain your consent—unless the cookie’s sole purpose is to enable or facilitate electronic communication, or it is strictly necessary for the provision of an online communication service that you have expressly requested. To ensure you can provide consent independently and specifically for each distinct purpose, you have the option to consent to each purpose individually, or to provide consent on a global basis. You may object to the use of cookies and configure your web browser to reject them. For guidance on how to adjust your cookie settings, you can consult the CNIL website, depending on the browser you use, at the following address: https://www.cnil.fr/fr/cookies-les-outils-pour-les-maitriser. In any event, in accordance with applicable regulations, you have the right to access, object to, rectify, or delete any personal data that may be collected through these cookies. These rights are further detailed in Article 8 of this Personal Data Protection Policy.

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5. To whom may personal data be disclosed?

Your personal data is shared with internal departments at SAS GERARD TREMBLAY that require such data for the purposes mentioned above, as well as with SAS GERARD TREMBLAY’s subcontractors and service providers. For further details, please refer to the sections below. SAS GERARD TREMBLAY may disclose personal data to various categories of recipients:

- SAS GERARD TREMBLAY’s sales, logistics, production, IT, customer service, administrative, and marketing departments: personal data is shared with internal departments at SAS GERARD TREMBLAY that need to process it for the purposes previously outlined.

- Partners: personal data may be shared with partners for the purpose of carrying out tasks (such as transport, delivery, or payment processing) entrusted to them by SAS GERARD TREMBLAY as part of its business operations.

- Technical and IT service providers responsible for managing the SAS GERARD TREMBLAY website: the SAS GERARD TREMBLAY website is managed and hosted by IT service providers, and personal data—specifically data related to website access—is processed by these providers.

All these recipients are located within the European Union. SAS GERARD TREMBLAY undertakes not to transfer personal data to third parties whose business or purpose involves acquiring new prospects for the purpose of sending commercial solicitations, without the express consent of the data subject. SAS GERARD TREMBLAY may be required to disclose personal data in order to comply with a legal obligation, in response to a request from an administrative or judicial authority, or for the pursuit of a legitimate interest, such as the defense of its legal rights.

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6. How is personal data collected?

Personal data may be collected directly by SAS GERARD TREMBLAY—for example, when an individual contacts SAS GERARD TREMBLAY via its website, calls or writes to the company directly, or places an order on its website.

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7. How long is personal data retained?

Your personal data is retained for the period necessary to fulfill the purposes for which it was collected, and is archived beyond that period to comply with legal obligations or to assert legal claims. For further details, please refer to the sections below. Your personal data is kept in an active database and used for varying durations depending on the purposes described above—specifically:

- Personal data required for your order is stored and used for a period of 10 years from the date of your order on the SAS GERARD TREMBLAY website.

- Personal data in the form of cookies is stored and used for a period of 13 months from the date it is placed on your computer or the device used to access the site.

- Without prejudice to your right to object to or withdraw your consent for this processing at any time, personal data processed for the purpose of commercial solicitation regarding SAS GERARD TREMBLAY products is stored for a period of 10 years from the date of your last activity on the SAS GERARD TREMBLAY website. Personal data may be archived beyond the retention periods described above in order to comply with legal retention obligations or to assert legal claims.

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8. Security

SAS GERARD TREMBLAY implements all necessary technical and organizational measures to ensure the security and confidentiality of the processing of your personal data. To ensure the security of your personal data—specifically to prevent it from being altered or damaged, or accessed by unauthorized third parties—SAS GERARD TREMBLAY takes all appropriate precautions, taking into account the nature of the data and the risks involved in its processing (including, for example, physical security and surveillance of premises, and the implementation of authentication procedures requiring secure, personal access via confidential usernames and passwords).

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9. What are your rights regarding the processing of your personal data?

In accordance with applicable regulations, you have the right to access your personal data, to rectify it, to object to its processing, or to request the restriction, erasure, or portability of your data, where applicable. Furthermore, you may withdraw your consent at any time for any processing based on such consent. You may also opt out of receiving communications regarding our offers, news, or events by using the hyperlink provided for this purpose in every email sent to you by SAS GERARD TREMBLAY, or by writing to: SAS GERARD TREMBLAY – Personal Data Protection Department, 12 rue de Poinchy, 89800 CHABLIS, France, or by sending an email to: gerard.tremblay@wanadoo.fr. If you believe that your rights have not been respected, you may lodge a complaint with the CNIL (the French Data Protection Authority). Finally, you may also, if you wish, provide us with specific instructions regarding the handling of your personal data after your death. For further details on your rights, please refer to the sections below. Depending on the nature of the processing, you have the following rights:

– Right to object: You have the right to object, at any time, to the processing of your personal data:

o For direct marketing purposes, without needing to provide any specific justification;

o For any other purpose based on the legitimate interests of SAS GERARD TREMBLAY, for reasons relating to your particular situation—unless SAS GERARD TREMBLAY can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

– Right of access: you have the right to obtain confirmation as to whether or not your personal data is being processed by SAS GERARD TREMBLAY, and, where it is, to obtain access to the information concerning you that is processed by SAS GERARD TREMBLAY.

– Right of rectification: you have the right to obtain the correction of any inaccurate or incomplete information concerning you that is processed by SAS GERARD TREMBLAY.

– Right to withdraw your consent: for processing activities based on consent, you may withdraw the consent you have provided at any time.

– Right to restriction of processing: you have the right to request the suspension of the processing of your personal data while a verification is carried out (e.g., verifying the accuracy of the information, the legal basis for the processing, or the legitimate grounds relied upon by SAS GERARD TREMBLAY when you have objected to the processing), or in cases where the processing is unlawful but you oppose the erasure of the data.

– Right to provide instructions regarding the fate of your personal data after your death: you have the right to issue instructions concerning what should happen to your personal data after your death. In the absence of such instructions, your heirs may exercise these rights regarding your personal data following your death.

– Right to erasure (or "right to be forgotten"): you have the right to obtain the erasure of your personal data by SAS GERARD TREMBLAY if one of the following grounds applies: (i) the data are no longer necessary for the purposes for which they were collected; (ii) you withdraw your consent for the processing and there is no other legal basis for such processing; (iii) you object to the processing of your personal data and there are no overriding legitimate grounds for the processing; (iv) the data are being processed unlawfully; (v) the data must be erased to comply with a legal obligation.

– Right to data portability: you have the right to receive the personal data you have provided to SAS GERARD TREMBLAY in a structured, commonly used, and machine-readable format so that you may transmit them elsewhere, or you may request that SAS GERARD TREMBLAY transmit them directly to another data controller. This right applies when the processing is based on your consent or on the performance of a contract, and is carried out using automated means.

– Right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL): You have the right to lodge a complaint with the CNIL if you believe that SAS GERARD TREMBLAY is not complying with the obligations set out in the regulations regarding the protection of personal data (for more information, please visit: https://www.cnil.fr/).

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10. How can you exercise your rights regarding your personal data?

In general, to exercise your rights, or if you have any questions or encounter any difficulties concerning the processing of your personal data or your rights, you may contact SAS GERARD TREMBLAY: By mail: SAS GERARD TREMBLAY – Personal Data Protection Department, 12 RUE DE POINCHY - 89800 CHABLIS

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