Confidentiality policy
Preamble
The company Lucky cart is attentive to the protection of the privacy of its Interlocutors, and, in particular, to the protection, confidentiality and security of their Data that it collects, in compliance with the General Protection Regulation 2016/679 and the Data Protection Act No. 78-17 as amended (the” Regulation ”).
Through this privacy policy, Lucky cart wishes to bring to the attention of all its Interlocutors:
- the characteristics of the processing of Data collected and processed under its responsibility;
- the commitments it makes to respect the Data and allow its Interlocutors to exercise the rights conferred on them by the Regulations, if applicable.
Definitions
The terms and expressions identified by a capital letter in the privacy policy have the meaning set out below, whether they are used in the singular or the plural:
- ” Customer ”: refers to the contact within the legal entity, a major retailer (brand or distributor) who enters into a contract with Lucky cart in order to benefit from the services offered by the latter;
- ” Cookie ”: refers to the practice of registering and/or reading information on digital terminals (computer, smartphone, tablet, etc.);
- ” Data ”: refers to the personal data of the Interlocutors, namely information allowing them to be identified, directly or indirectly, collected and processed in particular when using the Site for the contact request, and/or when participating in a promotional campaign organized by Lucky cart;
- ” Prospect ”: refers to the contact of the legal person, a major retail player (brands and retailers) identified as being able to be interested in Lucky cart's services, and who does not or no longer have the status of Customer;
- ” Interlocutor”: refers equally to Participants, Customers, Prospects, Internet Users, and Candidates;
- ” Data controller ”: refers to the Lucky cart company which determines alone or jointly the purposes and means of the Data processing described in this privacy policy;
- ” Site ”: refers to the website www.luckycart.com published by Lucky cart;
- “Internet user”: refers to any person who browses the Site;
- ” Supplier ”: refers to the natural or legal person providing Lucky cart with goods or services;
- ” Participant ”: refers to the natural person of legal age residing in mainland France with a valid personal email address who participates in a promotional campaign organized by Lucky cart and which allows them to win a prize by an instant draw.
Methods for collecting personal data
Lucky cart can collect Data from its Interlocutors directly:
- through the contact form posted on its Site;
- through the Distributors' websites when it comes to Participants.
Characteristics of treatments
As a Data Controller or Joint Data Controller, Lucky cart collects and processes Data relating to its Interlocutors according to the characteristics listed below. When the treatment is based on consent, the Interlocutors have the right to withdraw it at any time.
NO. 1
Purpose of the treatment: Organization and management of the game (participation in the game, information and management of winners, allocation and delivery of prizes, announcement of results)
Person (s) concerned: Participants
Legal basis: Enforcement of game rules
Data retention period*: 3 years from the end of the game organized by Lucky cart
Data controller (s): Lucky cart and the Distributor concerned Information relating to this processing has been provided in the game rules accepted by the Participant
NO. 2
Purpose of the treatment: Establishment of consumption profiles based on the Participant's purchase histories and promotion preferences in order to offer personalized promotions
Person (s) concerned: Participants
Legal basis: Legitimate interest of Lucky cart and the Distributor, namely to optimize the performance of promotional investments
Data retention period*: 3 years from the end of the game organized by Lucky cart
Data controller (s): Lucky cart and the Distributor concerned Information relating to this processing has been provided in the game rules accepted by the Participant
NO. 3
Purpose of processing: Management of disputes or complaints, fraud checks, including the calculation of the risk of fraud, and compliance with this regulation, management of cancellations and management of registrations on a special list allowing promotions to be no longer displayed to fraudsters
Person (s) concerned: Participants
Legal basis: Legitimate interest of Lucky cart and the Distributor, namely to limit the risks of fraud
Data retention period*: 3 years from the date of registration on the “banlist” when proven fraud has been detected. The data processed as part of the calculation of the risk of fraud for the detection and management of abusive behavior is kept for a period of fifteen (15) months.
Data controller (s): Lucky cart and the Distributor concerned Information relating to this processing has been provided in the game rules accepted by the Participant
NO. 4
Purpose of the treatment: Elaboration of analyses, statistics and performance of reporting operations
Person (s) concerned: Participants
Legal basis: Legitimate interest of Lucky cart and the Distributor, namely to analyze participation in the game
Data retention period*: 3 years from the end of the game organized by Lucky cart
Data controller (s): Lucky cart and the Distributor concerned Information relating to this processing has been provided in the game rules accepted by the Participant
NO. 5
Purpose of processing: Management of requests for information sent by mail as well as via the form on the Site
Person (s) concerned: Interlocutors
Legal basis: Execution of pre-contractual measures taken at the request of the person concerned
Data retention period*: For the time necessary to manage requests
Data controller (s): Lucky cart
NO. 6
Purpose of the treatment: Management of contracts concluded with Customers
Person (s) concerned: Customers
Legal basis: Legitimate interests of the data controller, namely the execution of the contract concluded with the legal person
Data retention period*: Duration of the contractual relationship
Data controller (s): Lucky cart
NO. 7
Purpose of the treatment: Commercial prospecting
Person (s) concerned: Customers
Legal basis: Legitimate interests of the data controller, namely the promotion of its services when messages are sent (i) by post or telephone or (ii) to Customers in compliance with article L.34-5 of the CPCE
Data retention period*: For a period of 3 years from the last contact or the end of the contractual relationship
Data controller (s): Lucky cart
NO. 8
Purpose of the treatment: Supplier Management
Person (s) concerned: Supplier or contact of the natural person within the Supplier
Legal basis: Lucky cart's legitimate interests, namely the monitoring of its commercial relationship
Data retention period*: Duration of the contractual relationship
Data controller (s): Lucky cart
NO. 9
Purpose of processing: Examination and processing of applications
Person (s) concerned: Candidates
Legal basis: Legitimate interests of Lucky cart, namely the management of recruitments
Data retention period*: Maximum duration of 2 years from the last contact from the Candidate
Data controller (s): Lucky cart
NO. 10
Purpose of the treatment: Pre-litigation and litigation management
Person (s) concerned: Interlocutors
Legal basis: Lucky cart's legitimate interest, namely the defense of its interests in court
Data retention period*:
Pre-litigation: for the duration necessary for the amicable settlement of the dispute, or, failing that, as soon as the corresponding action is prescribed.
Litigation: for the duration necessary for the procedure and until the expiry of the ordinary and extraordinary appeal periods.
Data controller (s): Lucky cart
(*) At the end of these retention periods, the Data will be archived securely for the necessary retention and/or prescription periods resulting from applicable legislative or regulatory provisions. At the end of these periods, the Data will be deleted, in accordance with the regulations in force.
Treatments carried out jointly between Lucky Cart and distributors
In accordance with article 26 of the RGPD, the purpose of this clause is to bring to the attention of the Participants the main lines of the agreement that Lucky cart has made with the Distributors concerned concerning treatments 1 to 4, when they are carried out jointly.
Each of the Distributors is in charge of informing the Participants and brings to the attention of the Participants the game rules corresponding to the promotional campaign, by means of their website, and before the Participant registers to participate in the game.
Lucky cart is the contact point for Participants to exercise their rights and to deal with complaints relating to treatments 1 to 4. Requests for rights that would be exercised directly with the Distributor, are sent by the latter to Lucky cart.
If the request concerns a treatment carried out under the exclusive responsibility of the Distributor, Lucky cart will send it to him as soon as possible.
This privacy policy does not apply to treatments carried out exclusively under the responsibility of Distributors.
Data recipients
The Data is mainly intended for the competent internal services of Lucky cart, for specifically authorized technical staff, and this in accordance with the purposes listed in the article “Characteristics of treatments”.
Lucky cart may also be required to communicate some of the Data to its subcontractors, in particular IT and accounting. These subcontractors are required to respect the confidentiality, integrity and security of the Data communicated to them and to use them only in the context of the execution of their service mission.
In particular circumstances, Lucky Cart may be required to disclose the Data, when it is required by judicial and administrative authorities justifying the need to know it.
Computer rights and freedoms
In their capacity as “person concerned” by the treatments implemented by Lucky cart, alone or jointly, and in compliance with the Regulations, all Interlocutors have the rights listed below:
- Of a right of access, i.e. to obtain confirmation that the Data is or is not being processed and, when they are processed, access to said Data, as well as various information including the purposes of the processing, the category of Data, the recipient (s) of the Data, etc.
- of a right of correction, as soon as possible, Data that is inaccurate, incomplete, incomplete, outdated or equivocal, or whose collection and processing are prohibited;
- of a right of opposition to the processing or transfer of Data, unless there are legitimate and compelling reasons that prevail over the interests of the Interlocutors;
- of a right to erasure Data for the following reasons:
- The Data is no longer necessary for the purposes for which it was collected or processed;
- The consent on which the processing was based has been withdrawn, and there is no other legal reason for processing the Data;
- The processing of the Data has been opposed and there is no overriding interest justifying the processing;
- The Data has been processed unlawfully;
- The Data must be deleted in order to comply with the legal obligation to which Lucky Cart may be subject;
- The Data was collected when the person concerned was a minor.
- of a right to limitation Data processing for the following reasons:
- For a period of time allowing the data controller to verify the accuracy of the Data, when they are the subject of a dispute by the person concerned
- The processing is unlawful and the person concerned objects to their deletion and instead requires the limitation of their use;
- The data controller no longer needs the Data for the purposes of processing, but they are still necessary for the person concerned to establish, exercise or defend legal claims;
- During the verification whether the legitimate reasons pursued by the data controller prevail over those of the Interlocutors when they opposed the processing
- Of a right to organize in advance and during his lifetime, the conditions under which the Data will be stored and communicated, after death;
- of a right to portability and the recovery of Data allowing to receive the Data transmitted in a structured format, commonly used and readable by a machine, and to transmit them to another data controller.
In the event that one of these rights is exercised electronically, the answers provided will, where appropriate, be provided electronically when possible, unless the interlocutor has specifically requested otherwise.
In the event that the answers provided by Lucky Cart are deemed unsatisfactory or incomplete, all of its Interlocutors have the possibility of filing a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés), the national supervisory authority in charge of compliance with obligations concerning the protection of personal data.
Lucky cart contact details
The head office of Lucky cart is located at 159 rue Montmartre 75002 Paris.
Requests for the exercise of Interlocutors' rights can be sent to the following addresses:
- by email to the address: contact@www.luckycart.com
- by post to the following address: Lucky cart, For the attention of the data protection officer, 159 rue Montmartre 75002 Paris.
The exercise of one of these rights may be refused if the Interlocutor's request does not meet the conditions set out in the Regulations. In this case, the Interlocutor concerned will be duly informed.
Cookies
- Strictly necessary Cookies (“Technical Cookies”)
Some Cookies have the exclusive purpose of allowing or facilitating electronic communication or are strictly necessary for the provision of online communication services at the express request of each Internet user.
In practice, these cookies allow the main services of the Site to function optimally. In accordance with article 82 of the LIL, the Internet User's consent is not requested for the use of these cookies, which generate Data processing necessary to pursue our legitimate interest, namely the proper technical management of the Site.
The Internet user can technically block technical Cookies using their browser settings but their experience on the site may be degraded.
The technical Cookies used by Lucky cart are the following:
- iconCaptcha, which aims to ensure the security of our contact form by limiting robotic sending attempts;
- Qtrans that allows us to translate the pages of the site into English at your request.
The data collected using these cookies is not stored.
Access to social networks
The Site allows access to social media pages by clicking on certain tabs on the Site.
When Internet Users click on these links, Data concerning them is automatically transferred to the social networks concerned. Consequently, Internet Users must read their respective privacy policies in order to know their characteristics, and if necessary exercise their rights, by clicking on the links below:
- Facebook privacy policy: https://fr-fr.facebook.com/privacy/explanation;
- Linkedin privacy policy: https://fr.linkedin.com/legal/privacy-policy?
In addition, we inform you that browsing Lucky cart's Facebook pages involves the processing of Data for statistical purposes under the joint responsibility of Lucky Cart and Facebook Ireland Limited, the latter ensuring the main responsibility for such processing in accordance with the addendum published by the latter and available at the following address: https://fr-fr.facebook.com/legal/terms/page_controller_addendum.