Privacy policy of the Groupe STERENN

Data updated on 05/03/2024

The Groupe STERENN and its subsidiaries undertake to ensure the confidentiality of the data collected, and to implement all appropriate technical and organisational measures to preserve their security and integrity, in particular against accidental loss, alteration, distribution or unauthorised access. It is important that we inform you of the personal data collected when you use our Digital Platforms, how it is processed and what rights you have in this respect.

In this Privacy Policy, we explain our policies and practices regarding the manner in which we collect, maintain, use, protect and disclose personal data that we collect on our Digital Platforms at trade shows, events, or otherwise.

We recommend that you read this Privacy Policy carefully as it contains important information about your personal data.

This policy complements the legal notice and the Terms of Use available online.

Please contact us if you have any questions or comments about this Privacy Policy (see section 9 "How to contact us" below).

1- Who are we?

The terms "The Groupe STERENN", "the Group", "subsidiaries", "we" and "our" refer to the Groupe STERENN as the controller of your personal data, unless otherwise specified in this Privacy Policy.

The person responsible according to art. 4 par. 7 of the EU General Data Protection Regulation (GDPR) is :
Groupe STERENN
Za de Beaucé – Route de Saint Malo
35520 La Mézière – France

Questions regarding data protection can be addressed to our data protection officer :
Groupe STERENN
Za de Beaucé – Route de Saint Malo
Tel. +33 2 99 13 05 00
35520 La Mézière – France
Mail : service.web@groupe-sterenn.com

The purpose of collecting data on our various sites is to create a management file of prospects and customers, or suppliers, or candidates of our companies. Our file is used and optimised for statistical purposes, to contact and/or propose relevant and quality content to those who wish to receive it. The purpose of our forms is either to request contact, to create an account, or to register for an event or our newsletter.

Our websites :
www.groupe-sterenn.com
www.fournial.fr
www.centradis.fr
www.sterennmotoculture.fr
www.sterennbtpenergie.fr
www.sterennequipements.com
www.sterennpolska.pl
www.sterenniberica.es
www.agriest.fr

2- What personal data do we collect and how is it collected?

Personal data is information relating to an identified or identifiable natural person. It includes, for example, a person's name, address and gender.
We may collect personal data directly from you (e.g. when you order a product over the telephone) or indirectly (e.g. from your electronic devices that interact with our websites, electronic forms or social networks (the "Digital Platforms").

2.1 Data you provide directly to us
You may provide us with data :
- When you create an account online or by phone;
- When you subscribe to our newsletter;
- When you use our Digital Platforms;
- When you purchase products or services on our Digital Platforms or by phone;
- When you attend one of our events (trade fairs, open days, etc.)

Depending on what you provide to us, such information may include:
- Your identity (including your first name, last name, gender, nationality, marital status);
- Your contact details (including postal address, email, telephone numbers);
- Your purchases and after-sales service (including purchase history, order details, delivery location);
- Your preferences (including favourite products);
- Certain payment data (including billing data, type or method of payment);
- Other information you may provide by filling in forms or contacting us (including your comments or other communications to us).

We will inform you when your information is needed to process your request, to respond to your enquiries or to provide our products and services to you. If you do not provide this information, it may delay or make it impossible to process your request, respond to your queries and provide products or services.
We endeavour to ensure that the personal data we hold is accurate at all times. We therefore encourage you to update your data should any changes occur. We may also ask you to update your data from time to time.

We recommend that you only provide the data requested or necessary for your request, with the exception of sensitive data relating to race, ethnic origin, political opinions, religious or philosophical beliefs, and data concerning health, sex life or sexual orientation. The STERENN Group and its subsidiaries do not collect sensitive data.

2.2 Indirectly collected data
We may collect data when you use our Digital Platforms, including your IP address or other navigational, communications data (including browser, operating system, device model, traffic data), through cookies or similar technologies placed on your device. Some cookies are necessary for the proper functioning of our Digital Platforms and others are used for analytical purposes that help us provide you with more personalized services and a better digital experience. For more information about cookies and how to change your preferences, please read our {{cookie_policy}}

If you provide us with personal data about someone else, you must ensure that you have the right to disclose that data to us and that, without us taking any further steps as required by data protection law, we can collect, use and disclose that data for the purposes described in this Privacy Policy. For example, you must ensure that the data subject is aware of the various matters set out in this Privacy Policy. The individual must also give the consents set out in this Privacy Policy as to how we process their personal data.

2.3 Minimum age
We remind you that we do not collect, directly or indirectly, personal data from persons under the age of 16, without prejudice to any local law setting a different minimum age. We therefore ask you not to provide us with personal data of persons who do not meet this criterion.

3- Why do we collect your personal data and how do we use it?

We collect and use your personal data on one or more of the following legal bases:
- We have obtained your prior consent (for example when you subscribe to our newsletter). Please note that with this particular legal basis, you have the right to revoke your consent at any time (see below paragraph 8 "What are your rights to your personal data?") ;
- The processing is necessary in the context of a contract between the Groupe STERENN and its subsidiaries and you, for example when you place an order;
- We have a legitimate interest in carrying out the processing and this legitimate interest is not overridden by your interests, fundamental rights or freedoms;
- We have to process your personal data in order to comply with applicable laws and regulations.

Depending on the context, we may use your personal data to:
- Provide you with the products or services you have requested;
- Carry out checks to identify you and verify your identity;
- Send you marketing communications, with your prior consent (see paragraph 4 "Communication and Marketing");
- To provide you with after-sales service and manage credit notes/refunds;
- Handle your after-sales service requests, credit notes and refunds;
- Respond to your questions, suggestions and requests, including requests to exercise your rights;
- To manage complaints and disputes;
- To manage the events you have registered for and/or attended;
- To detect, prevent and combat fraudulent or illegal activity, including protecting your transactions from fraud, acting against counterfeiting and resale of our products in breach of our terms and conditions;
- Protect you and our employees;
- To manage the stock of certain types of scarce products;
- Monitor and improve our Digital Platforms;
- Perform statistical analysis, including to tailor our product and service offerings (including the use of nationality on an anonymous basis);
- To improve our products and services;
- To comply with our legal obligations, which includes providing information to regulatory bodies where required by law, in particular to comply with our legal obligations to prevent and combat fraud, money laundering and terrorist financing.

4- Communication and marketing

The Groupe STERENN and its affiliates use and disclose your personal information only for the purposes for which you provided it to us, as defined at the time of collection or through your subsequent consent, including :
- To evaluate and improve products and services and the user experience (in particular to develop new products and services, analyse the customer base; carry out data analysis, accounting and auditing), profiling (shopping basket saving, personalisation of the display of content accessible to you...) ;
- To send newsletters and special offers, provided that the user ticks the box expressing his acceptance, provided for this purpose, when registering for the Services;
- To analyse visits to the various digital platforms and their frequencies, audience measurements, studies, statistics, surveys (cookies) and improve the user experience on the website;
- To recruit.

In order to optimally design the presence of the Group and its subsidiaries, we maintain company pages in various social networks. We want to inform interested parties about our services and communicate with you via these channels.

These channels are used for the following purposes:
- Provision of information about our company and products;
- Statistical evaluations for management analysis and the development of services and products, as well as for the improvement of management processes; Communication with prospects, customers, candidates, suppliers and interested parties.
- We rely on your consent to process the personal data you provide to us for these purposes. Therefore, if you no longer wish to receive such information, you may withdraw your consent at any time (see below paragraph 8 "What are your rights over your personal data?").

We may ask you to confirm or update your marketing preferences if you ask us to provide other products and/or services in the future, or if there are changes in law, regulation or our corporate structure.

5- How long do we keep your personal data?

Your personal data is processed for the period necessary for the purposes for which it was collected, to comply with legal and regulatory obligations and for the duration of any period necessary for the establishment, exercise or defence of legal claims.
In order to determine the most appropriate retention periods for your personal data, we have specifically considered the amount, nature and sensitivity of your personal data, the purposes for which we have collected your personal data, the service you deserve and expect from us and the applicable legal requirements.

For example:
- With respect to our prospects (potential customers): your data is retained for three years from your last action, and then deleted or archived to comply with legal retention obligations;
- With regard to our customers: your data is kept for the duration of our commercial relationship and up to ten years, then deleted or archived in order to comply with the legal obligations of conservation;
- With respect to cookies used on the Digital Platforms: they are stored for up to 13 months from the time they are installed on your device.

6- How do we disclose and transfer your personal data?

We may only disclose your personal data to the parties named below and for the following reasons:

- We disclose your personal data to employees of the Groupe STERENN and its subsidiaries who need to have access to your personal data and who are authorised to process it for the aforementioned purposes and who undertake to keep it confidential.

- We may disclose your personal data to departments within the Groupe STERENN companies responsible for customer relations, retail, e-commerce, communications, legal, finance, internal audit, IT management and security for the purposes set out in this Privacy Policy and to provide you with a consistent level of service across all Groupe STERENN companies. This may include providing you with the products and services you have requested, improving the services provided and, with your consent, sending you marketing communications regarding offers, services, products or events (for this purpose, you may revoke your consent at any time. See paragraph 8 "What are your rights regarding your personal data" below).

- We may also communicate personal data to third parties acting on behalf of the Groupe STERENN and approved by the Groupe STERENN. All such processing is based on our prior instructions set out in a binding contract that complies with the requirements of applicable law. Such disclosures are made for different reasons, including :
* IT development and support;
* Hosting and conducting marketing research and marketing campaigns;
* Delivery services...
These service providers are committed to respecting confidentiality and are not authorised to use your personal data for any other purpose.

- We may be required by mandatory provisions of applicable law or in connection with legal proceedings or other legal requests, to disclose your personal data to authorities or third parties.

- We may also disclose or process your personal data in accordance with applicable law to defend our legitimate interests (for example, in civil or criminal proceedings). For example, we may disclose such personal data if necessary to identify, contact or bring legal action against a person or entity that is violating our Terms and Conditions of Sale and Use or is causing distress or harm to other users of our Digital Platforms.
Please note The Groupe STERENN & its subsidiaries do not sell personal information to any third party.

7- How do we protect your personal data?

All your personal data are strictly confidential and will only be accessed on a need-to-know basis by duly authorised Groupe STERENN staff and independent service providers acting on our behalf under appropriate technical and organisational security measures.

The Groupe STERENN has implemented security measures to protect your personal data from unauthorised access and use. We follow appropriate security procedures in the storage and disclosure of your personal data to prevent unauthorised access by third parties and to prevent accidental loss of your data. We restrict access to your personal data to those who have a genuine business need to access it. The persons who access your data will be subject to a duty of confidentiality towards the Groupe STERENN.

We also have procedures in place to deal with any suspected data breach. We will notify you and any relevant supervisory authority of a suspected data breach where we are required by law to do so.

We also require those to whom we transfer your personal data to comply with the above. Unfortunately, the transmission of information via the Internet is not completely secure. We therefore cannot guarantee the security of your personal data transmitted to us via the Internet. Any such transmission is at your own risk and you acknowledge and agree that we will not be liable for any unauthorised use, distribution, damage or destruction of your data, except to the extent that we are required by law to assume such liability. Once we have received your personal data, we will apply the above security measures.

8- What are your rights regarding your personal data?

In accordance with applicable data protection law, you may at any time request access to, rectification of, deletion of and portability of your personal data, or restrict or object to its processing.

A summary of these rights is set out below:
- Your right of access: the right to receive a copy of your personal data.
- Your right to rectification: the right to ask us to rectify any errors in your data or to complete it.
- Your right to be forgotten: the right to ask us to delete your personal data in certain situations.
- Your right to restrict processing: the right to ask us to restrict the processing of your personal data, in certain circumstances, for example if you dispute the accuracy of the data.
- Your right to data portability: the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and/or to transmit that data to a third party, in certain situations.
- Your right to object to processing: the right to object: at any time during the processing of your personal data for direct marketing purposes or in certain other situations, to our further processing of your personal data, for example processing on the basis of our legitimate interests.

Where the processing of your personal data is based on your consent, you may at any time decide to withdraw it. If your consent is withdrawn, this will not affect the processing of your personal data based on other legal grounds, such as the fulfilment of your orders and the retention of your order data in accordance with applicable law.

If you no longer wish to receive our advertising or promotional information, please note that you may revoke your consent to direct marketing at any time directly from the unsubscribe link included in each advertising email we send you. If you do so, we will promptly update our databases and take all reasonable steps to respond to your request as soon as possible, but we may continue to contact you to the extent necessary in connection with any product or service you have requested.

You also have the right to lodge a complaint with your local data protection authority in the event of an alleged breach of the data protection rules applicable to you.

To exercise any of these rights, please contact us using the details below (see paragraph 9 "How to contact us").

Please note that if you exercise any of the above rights, you will be asked to inform us of which right you wish to exercise and to provide us with certain information (copy of an ID card, passport or other legally recognised identification) for identification purposes in order to process your request and to protect you against fraudulent requests from third parties.

9- How to contact us?

If you have any questions about your account, to revoke your consent, to ask general questions or to make a complaint, please contact our customer service:
- By e-mail : contact@groupe-sterenn.com
- By phone : +33 (0)2 99 13 05 00
- By post : Groupe STERENN - Za de Beaucé – Route de Saint Malo - 35520 La Mézière – France

For questions specifically related to advertising emails, we remind you that you can unsubscribe directly at any time via the "unsubscribe" link contained in all advertising emails we have sent you.

If you have any questions or concerns about our Privacy Policy or data processing, you can contact the Group's Data Protection Officer at the following address: service.web@sgroupe-sterenn.com

10- Changes to this Privacy Policy

This Privacy Policy reflects our current practices and may be changed and updated from time to time. When we post changes to this Privacy Policy, we will change the "Effective Date" at the top of this Privacy Policy to indicate when such changes are effective.

If we change this Privacy Policy in a material way, we will notify you by posting a change notice at the top of this Privacy Policy.