ARTICLE 5 - Protection of personal data
As an exception, this article indicates the specificities applicable to each user (hereafter referred to as "Member") subscribing to the loyalty program Green Addict.
5.1 Means of collection
The personal data of the Member is collected directly from him/her, at the time of his/her subscription to the program Green Addict on the Internet site www.Manucurist.com.
The Member is solely responsible for the quality of the personal data he/she transmits to Manucurist.
5.2 Data collected
The following personal data are collected on a mandatory basis as part of the program membership Green Addict name, surname, first name, email address, postal address. This data is necessary to Manucurist to ensure the authentication of the Member. The absence of such data, their irrelevance or their non-updating is likely to cause a delay in the processing of the Member's request, or even its refusal.
Other personal data collected by Manucurist in the context of a membership is optional, in order to get to know the Member better and send him/her communications adapted to his/her profile.
For information purposes only, Manucurist processes the Member's purchase history and website usage (e.g. by collecting browsing data via cookies, subject to consent). This processing is not in itself necessary for the creation of a Member's account, but becomes necessary when it comes to managing the Member's eligibility for the various benefits of the program Green Addict.
5.3 Purposes and legal basis
As a Member, your personal data may be processed for the following purposes and on the following legal bases
- Management and animation of the loyalty program and communities: informing the Member about the loyalty program or the services available, managing the Member relationship, card benefits and card operations.
- Commercial prospecting by electronic means: establishment of customer profiles, prospecting by email and/or SMS, data collection via cookies.
- This processing is based on the Member's consent. By exception, commercial prospecting by post may be based on the legitimate interest of Manucurist.
- Carrying out satisfaction surveys and customer studies: surveys, product tests, sales statistics and organization of competitions.
- This processing is based on the legitimate interest of Manucurist consisting in the continuous improvement of its service and its products.
- Exercise by the Member of his/her individual rights: management of requests to exercise the Member's rights concerning the use of his/her personal data.
- This processing is based on a legal obligation.
- Management of pre-litigation and litigation.
- This processing is based on the legitimate interest of Manucurist to establish the proof of a right or a contract.
5.4 Retention periods
Manucurist keeps the Member's personal data until the purposes for which they were collected have been fulfilled, i.e. for the duration of the membership in the program Green Addict plus the applicable legal limitation periods, in order to keep proof of transactions.
In some cases, a longer retention period is imposed on Manucurist by a legal obligation.
Please note that data collected for commercial prospecting purposes can only be kept until you withdraw your consent, and up to 3 (three) years from the last commercial contact with Manucurist (e.g. when the Member clicks on an offer sent to him/her).
Manucurist will transmit the Member's personal data only to those recipients who have a strict need to process them in accordance with the purpose of their collection.
In this context, the service providers involved in the management of the program are concerned Green Addict.
5.6 Data transfers outside the European Union
Some of the personal data we collect may be transferred outside the European Union, mainly to Canada and the United States, where there are service providers of Manucurist.
In case of transfer, Manucurist ensures that it is (i) made to a country subject to an adequacy decision of the European Commission under Article 45 of the GDPR, or (ii) supported by appropriate safeguards under Article 46 of the GDPR, including the European Commission's standard contractual clauses, as well as technical and organizational measures to ensure a high level of security and confidentiality of data, similar to that required by the GDPR.
5.7 Individual rights of the Member
The Member has individual rights over his or her personal data: right of access, right to rectification, right to erasure, right to limitation, right to opposition, right to portability.
The Member can exercise his rights by sending his request to
- by e-mail: firstname.lastname@example.org.
- by mail: Customer Service Manucurist - 19, rue d'Enghien 75010 Paris, France.
Moreover, the Member may at any time rectify his or her own personal data by going to the "My account" page of the Manucurist.
The request must indicate the right(s) that the Member wishes to exercise. In accordance with Article 12.6 of the GDPR, when Manucurist has reasonable doubts as to the identity of the person exercising his/her rights, identification may be requested.
Finally, the Member has the right to lodge a complaint with the supervisory authority, the Commission Nationale de l'Informatique et des Libertés (CNIL), in the event that he or she feels that he or she is unable to exercise his or her rights or wishes to report a breach of personal data protection rules.