Privacy Policy

PREAMBLE

The purpose of this Privacy Policy is to inform you about:
• the means implemented by STURGEON to collect and process your personal data when browsing our e-commerce site https://sturia.com/ (the "Site") or the use of online sales services which are offered there;
• the cookies that we deposit on your navigation device; And
• the rights you have in this respect,
in accordance with the laws and regulations in force, in particular with regard to the General Data Protection Regulations (“GDPR”).

The Privacy Policy applies to visitors to the Site in addition to the General Conditions of Sale and may be modified or supplemented at any time by STURGEON to take into account legal and regulatory developments and STURGEON's practices. We invite you to consult it regularly.

PERSONAL DATA

1- Data controller

STURGEON, Société Civile d'Exploitation Agricole, with a share capital of 1,000,000 euros registered with the RCS of SAINTES under number 401 692 801, whose registered office is located at 102, route de Beauval, CS 60007 Saint Sulpice et Cameyrac, 33452 Saint Loubes Cedex.

2- Processing of personal data

In accordance with the GDPR, the personal data we collect will be used for the fulfillment of the purposes for which it was collected in accordance with the table below:

Purpose	Legal basis
Creation of the customer account	Performance of the contract
Order management, delivery and invoicing	Performance of the contract Legitimate interest
Payment management	Performance of the contract Legitimate interest
Customer relationship management and customer follow-up	Performance of the contract Legitimate interest Legal obligation
Collection and publication of customer reviews	Legitimate interest Consent
Organization and management of contests	Performance of the contract
Commercial prospecting by e-mail, subscription to the newsletter	Consent
Management of requests for the right of access, erasure, portability, limitation, rectification and opposition	Legal obligation
Personalization of the shopping experience and communication	Legitimate interest Consent
Site management, ensuring the proper functioning and improvement of the site	Performance of the contract Legitimate interests Consent

3- Duration of data retention

STURGEON undertakes not to keep your personal data beyond the time strictly necessary for the purposes of use for which they were collected, in order to meet your needs or to fulfill our legal obligations.

To establish the retention period of your data, we apply the following criteria:

• If you create an account, we keep your personal data for 3 years from the end of the commercial relationship if you are a customer or from your last contact if you are not yet a customer;
• If you buy products, we keep your personal data for the duration of our contractual relationship and for a period of 5 years from the end of it; Invoices and accounting data are kept for 10 years;
• If you participate in a competition, we keep your personal data for 3 months from the end of the competition concerned;
• If you contact us as part of a request, we keep your personal data for the duration necessary to process your request and for 3 years from your last contact;
• If you have consented to receive commercial prospecting messages, we keep your personal data until you unsubscribe or until you ask us to delete them or at the end of a period of inactivity of 3 years.

Nevertheless, personal data may be archived beyond the periods provided for as evidence in the event of a dispute or for other storage obligations, in particular for accounting or tax purposes.

The maximum retention periods defined in the table above apply , unless you request the erasure or the cessation of the processing of your personal data before the expiry of these periods.

4- Data recipients

To achieve the purposes described above and within the limits necessary for the pursuit of these purposes, your personal data may be transmitted:
• the relevant STURGEON departments (marketing, sales, logistics, etc.);
• has service providers (logistics, IT, etc.);
• to administrative or judicial authorities where applicable.

5- Are your data processed outside the EU?

The data collected is likely to be processed outside the European Union. In this case, STURGEON makes the necessary arrangements with its subcontractors and partners to guarantee an adequate level of protection for your data, in full compliance with the applicable regulations.

6- What are your rights?

Pursuant to Articles 14 to 22 of the GDPR, you have the right to exercise the following rights:
• Right of access;
• Right of rectification;
• Right of opposition and erasure to the processing of your data;
• Right to oppose profiling;
• Right to restriction of processing;
• Right to the portability of your data;
• Right to define directives relating to the fate of your personal data after your death.

To exercise your rights, you can contact our GDPR Manager using the following means of contact:
- via the contact form on the Site,
- by e-mail to the following address: caviar-sturia@kaviar.com ,
- by post to the following address: STURGEON, 102, route de Beauval, CS 60007 Saint Sulpice et Cameyrac, 33452 Saint Loubes Cedex,
by indicating your contact details (surname, first name, address) and a legitimate reason when this is required by law (in particular in the event of opposition to processing).

To find out more about your rights, you can also consult the website of the Commission Nationale de l'Informatique et des Libertés, accessible at the following address: http://cnil.fr .

7- SECURITY

STURGEON undertakes to implement all physical security measures (security of access to premises, management of authorizations, security of equipment, etc.) and logic (antivirus, security of passwords, security of flows, anonymization, encryption , data traceability, etc.) necessary to ensure the security and confidentiality of the personal data processed.

COOKIES

When using the Site, information relating to navigation may be saved in text files called "Cookies" installed on your browser, subject to the choices you have made regarding Cookies and which you can modify at any time.

1- What are cookies?

Cookies are text files placed on your computer, smartphone, tablet, etc. during your visit to our Site. They are used to allow us to operate and analyze its use by users.

2- Cookies used on the Site

Several types of cookies are placed on our Site:

2.1 Functional cookies

These Cookies are intended to improve the functioning of the Site. For example, cookies that remember the content you have previously seen on this website or the e-mail address and password you provided when registering. Cookies can also remember the items placed in your shopping cart when visiting the Site.

2.2. Statistical cookies

These Cookies allow us to measure the audience on our Site (number of visitors, browsing time, etc.) in order to improve its operation and the services offered.

3- Manage cookies

When you browse the Site, you have the possibility, at any time, either to accept or refuse all cookies, or to personalize your choices according to their purposes.

Your preferences are recorded and kept for a period of 6 months. Once this period has expired or the addition of a new purpose requiring your consent, we will ask you again for your choices regarding the deposit of cookies.

Simply continuing to browse the Site does not constitute acceptance on your part.