Personal Data

Personal Data and Cookie Management Policy

Last updated on 9 December 2025

1. Cookies

When you visit a website, data may be stored in or retrieved from your browser, usually in the form of cookies. This information may be about you, your preferences, or your device, and is mostly used to ensure that the website works properly. The information does not usually identify you directly, but it can enable you to enjoy a personalised web experience. Because we respect your right to privacy, we give you the option to not allow certain types of cookies. However, if you block certain types of cookies, your browsing experience and the services we are able to offer you may be impacted.

1.1 Strictly necessary cookies

Some cookies are necessary for our website to function. For example, when you log in to your account or create an account, a cookie will help us recognise you as an existing user. These cookies cannot be disabled, as certain aspects of the website cannot function without them.

1.2 Tracking cookies

Google Analytics

The Website uses Google Analytics to analyse how users use the site. The tool uses cookies to collect anonymous information about the visitor's Internet connection and behaviour. The information generated by cookies about your use of the website (including your IP address) is transmitted to Google. This information is then used to evaluate visitors' use of the site and compile statistical data about the Site's activity.

We will never use (or permit any third party to use) the statistical analysis tool to track or collect Personally Identifiable Information (PII) from visitors to our site. Google will not associate your IP address with any other data held by Google. We will not connect or attempt to connect an IP address to the identity of a computer user.

We will not associate the data collected from this site with personally identifiable information from other sources, unless you explicitly provide us with this information. To learn more about Google Analytics privacy:https://support.google.com/analytics/?hl=fr#topic=10737980

If you refuse tracking cookies, we have chosen to anonymise Google Analytics IP addresses by replacing the last digits of the IP address. In this case, the full IP address is never transmitted to Google.

Google Tag Manager (GTM)

The Website uses Google Tag Manager («GTM»), a tag management system that allows various scripts and audience measurement or marketing tools to be deployed and managed without directly modifying the Website's code. GTM does not collect any personal data as such; it serves solely as a technical interface for activating other tags (such as Google Analytics 4, Meta Pixel or Sirdata).
The use of tags loaded via GTM may be subject to your consent depending on their nature.

Google Analytics 4 (GA4)

The Google Analytics 4 solution is also implemented via GTM. It allows us to measure the Site's audience and improve its functioning. The data collected is anonymised when you refuse tracking cookies. Information relating to your browsing may be transmitted to Google in accordance with the terms described above.

Meta Pixel (Facebook/Instagram)

The Site uses Meta Pixel in order to measure the performance of our advertising campaigns on Meta platforms (Facebook and Instagram) and to potentially offer personalised content. This tracker collects information about your browsing and interactions with the Website.
The Meta Pixel may only be stored with your prior consent where required by applicable regulations.

Sirdata (advanced consent management and advertising targeting)

The Site also uses the services of Sirdata, which enable, in particular:

to condition the triggering of cookies according to your choices expressed in the consent banner,
to offer personalised advertising campaigns when you have consented to this.

Sirdata may place cookies for behavioural analysis or advertising targeting purposes. These trackers are only activated after you have given your explicit consent via the preference management module.

To learn more about Sirdata and its practices:https://www.sirdata.com/vie-privee/

1.3 Disable cookies

You can disable the use of personal cookies when you arrive on the site, and at any time by clicking on the «Manage cookies» link in the footer of the site.

Furthermore, most browsers allow you to refuse cookies. You can also delete cookies that have already been stored on your computer. All cookies have a default expiry date, but you can manage this and clear your storage. Different browsers may use different methods to disable cookies.

We recommend that you configure your cookies directly on the website, without changing your browser settings.

2. Personal data

We respect your concerns about the protection of your privacy and personal data. This Personal Data and Cookies Management Policy (the «Policy») sets out what information is collected and how your personal data and cookies are processed when you browse the Website.

2.1 Identity and contact details of the data controller

The Website is operated by the Publisher, whose contact details are provided in the Website's Legal Notice (or «we»), acting as data controller within the meaning of applicable personal data regulations, including the General Data Protection Regulation («GDPR») of 27 April 2016.

Finally, in the cases mentioned below, some of our partners, such as social networks, may act as independent data controllers: in such cases, we invite you to consult their Personal Data Charter.

2.2 How is your personal data collected and used?

We collect your personal data directly from you when you use the Website and place an order for our products, or automatically when you access the Website.

We may collect and process personal data from the following categories:

2.2.1. Information you provide to us:

Your identification details such as your first name, surname, title, nationality, date of birth, postal address, country of residence, email address and telephone number;
Your preferences and interests;
Information provided via the «Contact us» form;
Bank details such as your payment details.

2.2.2. Information collected automatically:

Connection data such as your IP address, your device specifications, and your connection logs.

We may also indirectly collect personal data about you from other sources, for example if your data is sent to us by one of your contacts or through one of our partners such as social networks (including the fact that you use these networks and your associated advertising identifiers).

We may also collect your personal data when you participate in advertising campaigns with which we are associated, but which are primarily managed by a third party. If we receive additional information about you from a third party, we will take steps to ensure that you are informed of this collection of personal data and the circumstances surrounding it.

Finally, we may also collect information that you provide about other people, for example when you decide to purchase and send products to someone, or when you participate in a game on our Site and wish to invite friends to play as well. In this context, you agree to inform these third parties of the content included in this Policy. We use this information solely to respond to your requests and will not send marketing communications to your contacts unless they choose to receive communications from us.

2.3. Basis and purposes of processing your personal data

We collect and process your personal data when we have a legal basis for doing so:

2.3.1. Your consent (Article 6(1)(a) GDPR), in order to:

Using a number of cookies
To send you information about our offers, news and events (newsletters, invitations and other publications) as well as offers, news and events concerning other entities of the Clarence Dillon group, either by e-mail, SMS, MMS, notifications, telephone or post. If you receive such information from us and no longer wish to receive it, please contact us at [email address] and request to be removed from our mailing lists, or use the unsubscribe methods indicated and/or included in our communications. ;
Showing you targeted advertisements and finding other people like you on social media (by downloading and comparing your personal data – for example, your email address – with the information you have provided on social media) (for internet users residing in countries where consent is required); ;
Customise the content of the Website; ;

And/or

2.3.2. Performance of a contract with you or pre-contractual measures taken at your request (Article 6(1)(b) GDPR), in order to:

Create an account on the Website and then manage it
Purchase of products;

And/or

2.3.3. Legitimate interests (Article 6(1)(f) GDPR):

To ensure the security of our Site and its users and compliance with our Legal Notice(insert as a link);
To improve our products and customer relations by sending you information about our offers, news and events (newsletters, invitations and other publications) on similar products and/or services following a transaction.
Compile statistics and gain a better understanding of your preferences and interests.
Responding to your enquiries submitted via the «Contact Us» form or other similar forms; ;
To show you targeted advertisements and find other people like you on social networks, for users in countries where your consent is not required.
Create your profile based on your information, order history, and preferences.
Conduct satisfaction surveys, subject to consent as required by the regulations in your country.
Detecting and preventing fraud

And/or

2.3.4. Compliance with our legal obligations (Article 6(1)(c) GDPR), in order to:

Process any complaints, fulfil our legal obligations and defend our interests in the event of a dispute or legal action.

When we ask you to provide personal data, we clearly indicate whether the information is mandatory or optional and the consequences if you refuse to provide it (for example, the fact that we will not be able to process your request).

2.4. Recipients of personal data

In accordance with current regulations, we may share your personal data with:

our hosting providers
our support and marketing service providers (customer service, email service, statistical analysis service)
social media
any authority, court or other authorised third party, where the disclosure of personal data is required by law, a regulatory provision or a court order, or where such disclosure is necessary to ensure the protection and defence of our rights
all purchasers in the event of restructuring of the Publisher, including the total or partial disposal of assets, merger, takeover, acquisition, demerger and, more generally, any reorganisation operation.

The Website may contain links to other websites for reference purposes only. We are therefore not responsible for the content, processing of personal data or practices of third-party websites. Please contact them directly for further information.

2.5. Transfers of personal data

We may transfer personal data to countries outside the European Economic Area («EEA»), including countries that have different data protection standards than those applicable in the EEA. Any transfer of your Data outside the EEA is carried out with appropriate safeguards in accordance with applicable personal data protection regulations. A copy of the applicable safeguards can be obtained on request (by contacting us as indicated below).

For any questions regarding the transfer of personal data outside the European Economic Area, you may contact us at the address indicated below (Article 2.8 «Your rights»).

2.6. Retention period for personal data

Your personal data is retained for as long as necessary for the purpose for which it was collected (see table below), unless you request its deletion from the Publisher (Article 2.8 «Your rights»), you revoke your consent, or there is a legal obligation to retain it for a longer period. It will be destroyed at the end of this period or within one month of any request for erasure.

The data retention periods are listed in the table below.

Data processing	Shelf life
Respond to enquiries submitted via the «Contact us» form»	Duration of treatment and then three (3) years after treatment.
Complaints management and compliance	Duration of the claim plus five (5) years from its resolution. In the event of legal action: duration of the proceedings until full enforcement of the court decision or settlement agreement.
Sending information about the Publisher's offers, news and events	Unless you unsubscribe, three (3) years from your last contact with the Publisher.
Display advertisements on your social media accounts and those of other individuals like yourself.	Three (3) years from your last contact with the Publisher
Security and integrity of the Website	Three (3) to six (6) months depending on the security and integrity operations performed.
Fraud prevention and detection	Three (3) to six (6) months depending on the investigations carried out and the duration of legal proceedings (if any).
Geolocation	No data retention.

2.7 Changes to our Personal Data and Cookie Management Policy

We may occasionally amend this Policy. We encourage you to check this page regularly to ensure that you agree with any changes.

You will be informed of any changes either by a special notice on our Website (in particular by updating the date at the top of this Policy) or by email notification.

We may also seek your consent if necessary.

2.8 Your rights

You have the right to access and rectify your data, as well as the right to request its deletion, to object to its processing and to obtain its restriction or portability within the limits provided for by law, subject to compelling legitimate grounds that we may justify for retaining your personal data.

In order to respond to your request, we may ask you to provide proof of identity. We may also ask you to provide us with additional information or supporting documents. We will endeavour to respond to your request as soon as possible.

You may opt out of receiving communications about our offers, news and events at any time. by using the hyperlink provided for this purpose in each email sent to you or by sending a letter or email to the addresses below.

You also have the right to give us specific instructions regarding the fate of your data after your death.

To exercise your rights, you must contact the appointed data controller, who can be reached at:

By email to the following address:info@closdecaille.com

By post to the following address: Clos de Caille, 2861 Chemin de Mousteirol 83570 Entrecasteaux, France

The modification will take effect within one month of receipt of the User's request.

You also have the right to refer any complaint regarding the way in which we collect and process your Data to the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés, CNIL), 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.