Château de Poncié, a simplified joint stock company with a single partner (SASU), registered in the trade and companies register of VILLEFRANCHE-TARARE under number 504 521 360, whose registered head office is located at Château de Poncié in FLEURIE (69820) (hereinafter referred to as "Château de Poncié") takes the protection of your personal data very seriously and is committed to complying with the applicable regulations in this area, in particular the principles arising from the European General Data Protection Regulation no. 2016-679 of 27 April 2016, which came into force on 25 May 2018 ("GDPR").

This privacy policy aims to provide you with all the information on how your personal data is collected and processed by Château de Poncié, in its capacity as data controller, from the site accessible at the following address: chateaudeponcie.fr (hereinafter the "Site").

Users are reminded that the Site is intended for adults only.

Are you looking for information on other specific processing that we carry out? We invite you to consult our Cookie Policy.


1. Definitions from the RGPD

Personal data

Any information relating to an identified or identifiable natural person (also referred to as "data subject"). An "identifiable natural person" is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

Château de Poncié

Château de Poncié, a simplified joint stock company with a single partner (SASU), registered in the trade and companies register of VILLEFRANCHE-TARARE under number 504 521 360, whose registered head office is located at Château de Poncié in FLEURIE (69820)

Recipient

The natural or legal person, public authority, department or any other organization that receives communication of Personal Data, whether or not it is a third party.

Regulations

All of the regulations in force applicable to the Processing of Personal Data and in particular the General Data Protection Regulation (RGPD), which came into force on May 25, 2018, which introduces new concepts in relation to the law "relating to data processing, files and freedoms" of January 6, 1978 as amended (known as the Data Processing and Freedoms Act) and modifies the obligations of the actors involved in the Processing of Personal Data.

Data Controller

The natural or legal person, public authority, service or other body that, alone or jointly with others, determines the purposes and means of Processing.

Website

This Website is published and operated by Château de Poncié and is accessible from the following URL: chateaudeponcie.fr.

Subcontractor

The natural or legal person, public authority, department or any other organization that processes Personal Data on behalf of the Data Controller.

Processing

Any operation or set of operations carried out or not by means of automated processes and applied to Personal Data or sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, deletion or destruction


2. What Personal Information is collected and how do we collect it?

Through its Site, Château de Poncié may collect and process the following Personal Information:

  • Personal Information that you provide directly to us:

The Personal Information that is collected is that which you provide to us directly through the collection forms available on the Site (contact request, opening a customer account, etc.) or by e-mail sent directly to our e-mail address.

The Personal Data that you communicate directly to us are collected in the following cases:

When you wish to bring information to our attention or request information through our contact form:

  • title (Mr. / Mrs.) ;
  • name, first name ;
  • address ;
  • Postcode / City; Country;
  • e-mail address;
  • telephone number.

When you place an order online (customer data):

  • title (Mr. / Mrs.);
  • name ;
  • address ;
  • Zip code / City ;
  • country ;
  • e-mail address ;
  • telephone ;
  • your bank details (credit card number, expiration date, CVC).

Please note that for your purchases by credit card, we use the services of an intermediary who will have access to the Personal Data exclusively necessary to process your payment.

When you wish to create a customer account:

  • title (Mr. / Mrs.) ;
  • name, first name ;
  • address ;
  • Zip code / City ;
  • country ;
  • telephone ;
  • e-mail address;
  • password.

When you book an activity offered by Château de Poncié:

  • last name, first name ;
  • telephone number;
  • e-mail address.

When you subscribe to our newsletter:

  • e-mail address.

And more generally when you send us an e-mail directly:

  • information transmitted by you and most probably :
    • name, first name ;
    • e-mail address;
    • telephone. 
       
  • The Personal Data that we collect during our commercial relationship:

This includes, in your capacity as a customer:

  • Information relating to the history of your commercial relationship with Château de Poncié (orders, billing and payment),
  • requests made or incidents reported to our customer service department.

 

  • Personal Data that we collect automatically:

When you visit the Site, data (including Personal Data) known as browsing data is automatically recorded either :

  • by means of cookies,
  • directly by the Château de Poncié computer system,
  • indirectly by the IT service provider in charge of managing the Site.

Some of this data is collected in order to ensure that the Site is fully available, to improve it and to maintain a secure environment. Other data may be used to analyze your user behavior and traffic and/or to increase the interactivity of our Site.

This may include:

  • Data about your use of the Site:

This usage data may include information such as your computer's IP address, browser type, browser version, the pages of our Site you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

  • Data about the equipment that allows you to access the Site:

Depending on the equipment you are using and the settings activated, the following data may be collected, among others: the type of equipment (cell phone, tablet, PC, MAC, etc.) and operating system you are using and their settings.

This information can be obtained either directly from the server's event logs (log files) or via cookies or similar tools.


3. Why do we process your Personal Information?

We use your Personal Information to carry out the Purposes set out in the table below.

This Personal Data is collected in one of the cases provided for by the Regulation, namely

  • the execution of a contract we have concluded with you, and/or
  • the respect of a legal obligation, and/or
  • your consent to the use of your Personal Data, and/or
  • our legitimate interest in using your Personal Information, it being specified that the legitimate interest is a combination of business reasons and/or security reasons that justify the use of your Personal Information by Château de Poncié.

You will find all this information in the table below.

Order Take into account and execute the order (or service reservation); Invoice; Supply the ordered products Contract; Legal or regulatory obligation Customer data
Payment Execute payment of your order; Manage rejected bank transactions Contract Banking data (collected and processed by a third party provider in case of card payment or by the bank in case of transfer)
Claim on payments Handle any complaints from the holder of the credit card used to pay for the order Law (L. 133-24 of the Monetary and Financial Code) Banking data outside CVC (collected and processed by a third party provider)
Customer relationship follow-up Complaints management; Customer relationship management following an order; Refund management Execution of the contract Customer data; Banking data outside CVC (collected and processed by a third party provider)
Bookkeeping Accounting and tax obligations Compliance with a legal obligation to retain data Data customer
Customer account To allow the customer to access the customer area and to benefit from the functionalities of the Site Execution of the contract to which you agreed by validating the General Conditions of Use when you registered on the Site (creation of an account). Customer data; Bank data (excluding CVC)
Management of lead requests Respond to the request made via the contact form or more generally via an email address found on the Site Respond to the request made via the contact form or more generally via an email address found on the Site Title (Mr. / Mrs.) ; Name, first name ; Address ; Zip code / City ; Country ; E-mail ; Phone
Newsletter Execute the newsletter subscription Consent Customer/prospect email address
Château de Poncié's commercial offers by electronic means Carry out direct prospecting campaigns on similar products or services within the meaning of Article L. 34-5 al 4 of the Code des postes et des communications électroniques Depending on the case : Consent or Legitimate Interest Prospect data; Customer data
Other Château de Poncié commercial offers Send commercial offers Consent Prospect data; Customer data
Functioning and optimized provision of the Site Making the Site available in an optimized and faultless manner; Ensuring the proper functioning of the Site Consent or legitimate interest (to provide users with an optimized and fluid site) Cookies & Trackers
Analysis of your behavior on the Site Measurement of audience and frequentation; Behavioral analysis; Establishing commercial and frequentation statistics of the Site Establishing statistics of use of the Site in order to develop new features Consent or legitimate interest (to provide users with an optimized and fluid site) Cookies & Trackers
Social networks Improve the interactivity of the Site and help promote Château de Poncié through sharing Consent Cookies & Trackers
Video sharing Enrich the site with multimedia content and increase its visibility Consent Cookies & Trackers

For more information about cookies, we refer you to our Cookie Policy.


4. Who are the recipients of your Personal Information?

Château de Poncié only communicates your Personal Information to authorized and designated recipients, in accordance with the provisions of the applicable Regulations.

In strict compliance with the purposes set out above, your Personal Data is processed first and foremost by Château de Poncié's internal departments in the course of their usual duties.

It is also communicated to certain of our subcontractors and service providers (website manager, host) who are bound by the same security and confidentiality obligations as Château de Poncié.

We require all of these third parties to apply at least the elementary security ruleś defined by the CNIL both on the administrative, technical and organizational aspects in order to protect your Personal Data against any unlawful disclosure, use, modification and destruction.

To do this, we have rigorously selected our Subcontractors according to the security of the hosting they provide (at the level of the standards among the strictest), reinforced the infrastructures used and hardened the contracts concluded with them. In this respect, we have signed strict security clauses with our subcontractors, in accordance with the regulations.

Your Personal Data may thus be transmitted to the following Service Providers and/or Subcontractors:

  • Technical subcontractors:
    • OVH, which handles the hosting of our Site;
    • the IT service provider who takes care of the development of our Site, namely : Pure Illusion (108 route de Chavanne - 74330 POISY);
    • the service provider SARL SOLUMATIC (3 allée Rigny Ussé - 37170 CHAMBRAY LES TOURS - SIRET No.: 798992970 00037), which enables Château de Poncié to benefit from a commercial wine management tool.
       
  • the Château de Poncié transport company (LOGIVIN - ZA les pièces-bourgeoises, 71640 Givry).

Your Personal Information may also be shared with third-party companies in accordance with the conditions set out in the article "Use of social networks via sharing buttons" below.

The Personal Information you may provide to us may also be disclosed in response to legal or administrative proceedings of any kind or to law enforcement actions requested by the appropriate authorities.

Château de Poncié undertakes not to transmit your Personal Information to third parties unless:

i.  you have given your prior consent to the sharing of your Personal Information with third parties
ii.  the sharing of your Personal Information with such third party is necessary to provide the requested services
iii.  a competent judicial or administrative authority requires Château de Poncié to disclose your Personal Information as described above.

5. How long is your Personal Information kept?

Your Personal Information is kept for the time necessary to fulfill the purposes described above and in compliance with applicable law.

If you are a customer of our company, we keep your Personal Information for the time necessary to follow up on your relationship with us, and then for a period of 3 years from the end of the commercial relationship.

However, Personal Information that is necessary to establish proof of a right or contract, or that must be retained to comply with a legal obligation, will be retained for the period of time required by the applicable law.

Connection data (IP address, date and time of connection, pages consulted) are kept for a maximum period of 6 months.

The details of the retention periods are shown in the table below:

Category of Personal Data Treatment name Shelf life in active base
Customer data Ordering Duration of the contractual relationship
Customer data Customer relationship follow-up Duration of the contractual relationship
Customer data Bookkeeping In the form of an intermediate archive: legal retention period (10 years).
Customer data Customer account The client's Personal Information is kept until: deletion of the account by the client or by Château de Poncié; 2 years from the client's last connection in case of inactivity
Customer data Newsletter Until you unsubscribe from the newsletter
Customer data Château de Poncié's commercial offers by electronic mail For a period of 3 years from the end of the commercial relationship (e.g. from the end of a contract from the last contact from the customer)
Customer data Other Château de Poncié commercial offers For a period of 3 years from the end of the business relationship (e.g. from the end of a contract or the last contact from the customer)
Complete payment data (except CVC). For the visual cryptogram of the bank card (CVC), it is not kept. Payment Until full payment of the transaction
Complete payment data (except CVC). For the visual cryptogram of the bank card (CVC), it is not kept. Claim on payments 13 months from the date of debit or 15 months from the deferred date (L. 133-24 of the Monetary and Financial Code)
Complete payment data (except CVC). For the visual cryptogram of the bank card (CVC), it is not kept. Customer service Until the expiry of the period for which we undertake to reimburse you for an order
Prospect data Château de Poncié's commercial offers by electronic mail For a period of 3 years from the date of collection by Château de Poncié or the last contact from the prospect
Prospect data Other Château de Poncié commercial offers For a period of 3 years from the date of collection by Château de Poncié or the last contact from the prospect
Prospect data Newsletter Until you unsubscribe from the newsletter
Data from all users Managing your rights The data is kept until Château de Poncié responds to the request. The response provided may be retained for evidentiary purposes, within the applicable limitation period, from the time Château de Poncié responds to the request. In the event of the collection of proof of identity, this data is in principle deleted as soon as your request has been granted. Château de Poncié may be required to retain these documents for the purpose of establishing proof in certain exceptional cases where Château de Poncié identifies a strong risk of litigation, based on a case-by-case, duly documented analysis. In such cases, the period for which the documents are kept is determined in accordance with the statute of limitations for public action set forth in the Code of Criminal Procedure.
Cookies & Trackers Operation and availability of the Site 6 months from the date of collection depending on the type of cookie / tracker (except for third party cookies whose duration is indicated in the cookie policy
Cookies & Trackers Video sharing 6 months from the date of collection depending on the type of cookie / tracker (except for third party cookies whose duration is indicated in the cookie policy
Cookies & Trackers Social networks 6 months from the date of collection depending on the type of cookie / tracker (except for third party cookies whose duration is indicated in the cookie policy
Cookies & Trackers Analysis of your behavior on the Site and statistics 6 months from the date of collection depending on the type of cookie / tracker (except for third party cookies whose duration is indicated in the cookie policy

At the end of these periods, your Personal Information is then archived (to meet a legal obligation or administrative interest of Château de Poncié), anonymized or deleted in accordance with our archiving policy.


6. Transfer of your Personal Information outside the European Union


We strive to keep your Personal Information within the European Union. However, your Personal Information may sometimes be transferred outside the European Union through our partners, subcontractors and/or service providers or third party platforms (META, Linkedin).

Some recipients may be located in countries that have been the subject of an adequacy decision (total or partial) by the European Commission, which considers them to provide an adequate level of protection for Personal Data.

For other countries that are not considered to provide an adequate level of protection, Château de Poncié makes every effort to implement the necessary and sufficient safeguards to ensure the level of protection required by the Regulations (in particular, on a case-by-case basis, through the regularization of standard contractual clauses based on the European Commission's model, or any other mechanism that complies with the Regulations).
 

7. Use of your Personal Information by third party platforms

The Site may contain links to other sites. Similarly, other sites may reference or link to our Site. We have no control over these other domains and websites. We encourage our users to read the privacy policies of each website and application with which they may interact. We do not endorse, verify or approve of, and are not responsible for, the privacy practices or the content of such websites or applications. If you visit such other websites or applications, you do so at your own risk and are subject to their privacy policies.

You may also visit the Château de Poncié Site using the private browsing mode.

8. Use of social networks through "sharing buttons"

In order to provide you with the most comprehensive services, we offer you the possibility to easily share the pages you visit on your favorite social networks.

Our Site uses "plug-ins" or social modules on its various pages ("share" buttons on third-party social networks). When you visit a page of our Site containing such social plug-ins, a connection is automatically established with the servers of the social networks, which may then be informed that you have accessed the corresponding page of our Site. If you wish to limit the information published or known by these social networks concerning your actions on the Site, we advise you to disconnect from your social networks before visiting our Site.

The use of the buttons allowing access to social networks is indeed likely to lead to a collection and an exchange of certain Personal Data between the social networks and the Site.

In order to protect your privacy, however, we have limited the information that is automatically transmitted through this means.

In this context:

  • Château de Poncié only collects the information according to which you are connected to the social network in question;
  • the social network in question collects the information specified in its own personal data protection policy, which we invite you to consult, and which you can influence in the settings of each social network.

Château de Poncié is not responsible for the use that is made of your Personal Information by these social networks on their own behalf.

Finally, we inform you that the information transmitted to the various social networks in accordance with the above conditions may be transmitted and processed by these companies via their servers located in several countries around the world, including the United States, in accordance with their own privacy policies, which you will find at the following links and which we invite you to read.

Other Google services:

This Site uses several features offered by Google. As such, some of your Personal Data and in particular your browsing data may be transferred to this company whose servers may be located outside the European Union and in particular in the United States.

Google's use of your personal data is subject to its terms of use. We advise you to read them carefully in order to be able to fully exercise your rights towards Google.

The services concerned include Google Analytics. Google Analytics uses cookies to analyse your use of the website on the basis of your consent.

You can prevent the storage of cookies by making the appropriate settings in your browser; however, we would like to point out that in this case you may not be able to use all the functions of the Website.

In addition, by downloading and installing the Browser Plugin which is available under the following link: https://tools.google.com/dlpage/gaoptout?hl=fr, you can prevent:

  • the collection by Google of personal data generated by the Google Analytics cookies relating to your use of the Site (including your IP address),
  • the processing of this data by Google.

By doing so, an opt-out cookie will be installed and will prevent the capture of your Personal Data during future visits to the Website.

You can find more information about the use of personal data by Google Analytics in the privacy statement of Google: https://support.google.com/analytics/answer/6004245?hl=fr.


9. Security

We constantly strive to protect your Personal Information. Upon receipt of your Personal Data and throughout its life cycle, we apply strict procedures and security measures to ensure its availability, integrity and to prevent unauthorized access.

As a Data Controller, we implement appropriate technical and organizational measures, in accordance with applicable legal provisions, to protect your Personal Data against alteration, accidental or unlawful loss, unauthorized use, disclosure or access, including

  • raising awareness of the confidentiality requirements of our employees who have access to your Personal Information;
  • securing access to our premises as well as physical and logical access to our IT systems and platforms;
  • securing the access, sharing and transfer of Personal Information;
  • a high level of personal data protection requirements when selecting our subcontractors and partners.

SSL or TLS Encryption

For security reasons and to protect the transmission of confidential content, such as orders or requests you send to us, this Site uses SSL or TLS encryption. An encrypted connection can be identified by the browser address line changing from "http://" to "https://" and the padlock symbol on that line.

When SSL or TLS encryption is enabled, the Personal Information you transmit to us cannot be viewed by third parties.
 

10. What are your rights?

We will endeavour to allow you to exercise your rights with respect to your Personal Information:

  • you may access and obtain a copy of the Personal Data that Château de Poncié collects and processes about you;
  • you may request that your Personal Information be rectified, updated or corrected;
  • you may request the deletion of your Personal Data as soon as possible where any of the following grounds apply:
    •  (a) the Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed;
    • b) you withdraw your consent on which the Processing is based and there is no other legal basis for the Processing concerned. The withdrawal of consent is valid for the future;
    • c) you exercise your right to object and there is no compelling legitimate reason for the Processing;
    • d) the Personal Data has been unlawfully Processed;
    • e) the Personal Data must be erased to comply with a legal obligation.

The right to erasure may not apply if the Processing is necessary:

  • to comply with a legal obligation,
  • to establish, exercise or defend legal claims.

You may request the restriction of the Processing of your Personal Data when any of the following apply:

  • (a) a verification of your Personal Data is necessary after a challenge by you to the accuracy of your Personal Data ;
  • b) the Processing is unlawful and you object to the deletion of your Personal Data and request instead that their use be restricted;
  • c) Château de Poncié no longer needs your Personal Data for the Processing but the Personal Data is necessary for you to establish, exercise or defend legal claims;
  • d) you have objected to the Processing and Château de Poncié verifies whether the legitimate reasons pursued by it prevail over your legitimate reasons.

 

  • you may object at any time, for reasons relating to your particular situation, to the Processing of your Personal Data based on a legitimate reason;
     
  • you may withdraw your consent to the Processing of Personal Data at any time, provided that the Processing is based on consent (this concerns in particular the Processing of cookies);
     
  • you have a right to portability allowing you to receive the Personal Data you have provided to Château de Poncié in a structured, commonly used and machine-readable format when, cumulatively:
    • the Processing is based on consent or on a contract;
    • the Processing is carried out using automated processes.

In exercising this right, you have the right to obtain from Château de Poncié that your Personal Data be transmitted directly by Château de Poncié to another Data Controller where technically possible.

The right to portability must not infringe the rights and freedoms of third parties.

  • In accordance with French law, Château de Poncié gives you the opportunity to decide in advance what will happen to your Personal Data after your death.

Any correction or deletion of your Personal Data or any limitation of the Processing carried out at your request will be communicated by Château de Poncié to each Recipient to whom your Personal Data may have been transmitted in accordance with these provisions, unless such communication proves impossible or requires disproportionate effort.

In the event that your Personal Data is inaccurate or out of date, you may inform Château de Poncié so that the required corrections and/or updates can be made.
 

11. How to exercise your rights?

To exercise your rights, please contact :

  • electronically, at contact@chateaudeponcie.com;
  • by post, to the attention of Château de Poncié - 69820 FLEURIE.

If Château de Poncié has reasonable doubts as to the identity of the individual making the request, it may ask him or her for additional information necessary to confirm his or her identity (e.g. a copy of his or her identity card).

To assist you in exercising your rights, you will find a model letter prepared by the Commission Nationale de l'Informatique et des Libertés (CNIL) at the following link: https://www.cnil.fr/fr/modele/courrier/exercer-son-droit-dacces.

Château de Poncié has a period of one (1) month to respond to your request from the date of receipt. This period may be extended by two (2) months due to the complexity of your request and the number of requests received. Château de Poncié will inform you within one month of your request.

If you feel that your rights are not sufficiently respected, you have the right to file a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés).
 

12. Changes

Château de Poncié may update this Privacy Policy at any time to reflect any new practices and service offerings. In this case, the date on which the Privacy Policy was updated will be updated and will indicate the day on which the changes were made. If Château de Poncié makes changes that it considers important, you will be notified by means of a notice on our Site.


13. Use of cookies

You are informed that, during your visits to our Site, cookies may be installed on your browser to allow you, in particular, optimal navigation. Cookies are data stored in the user's terminal equipment. They are used by our Site to send information to the user's browser and allow the browser to send information back to the originating site (e.g., a session identifier, language choice or date). Other types of cookies, such as pixel tags, may also be used.

Please see our Cookie Policy for more information.