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Privacy Policy – Cookies

Last update May 22, 2022


The Privacy Policy - Cookies (hereinafter "PDCC") of Cultural Enterprise Limited (hereinafter "CE") aims to inform users of the website (hereinafter "Website"), whether or not they are customers of CE (hereinafter "User" or "Users"), of CE's practices and commitments with respect to the collection and processing of Users' personal data. 


CE is a limited liability company registered in Hong Kong under the registration number 2896441, whose head office is located at N5, 17F, Strand 50, 50 Bonham Strand, Sheung Wan, Hong Kong SAR and represented by its Director, M. Patrick Foret, domiciled in this capacity at the said head office.


CE is legally committed herein to apply and comply with French legal requirements related to Privacy Policy and the collection and processing of Users’ personal data.


CE is responsible for the collection, processing, use, disclosure, retention and protection of Users' personal data. 


Users should read the PDCC to be fully informed of the manner in which and the purpose for which CE collects and processes their personal data. 


The PDCC may be regularly updated. Changes to the PDCC will be effective when first posted and will be binding on Users.


If any provision of the PDCC is invalidated by any Law, Regulation or final decision of a competent court, the remaining provisions shall remain in full force and effect.


CE's failure to enforce any provision of the PDCC against any User shall not be construed as a waiver of CE's right to enforce such provision against any other User, nor shall it be construed as a waiver of any other provision of the PDCC. 


Article 1: Scope of the PDCC


The PDCC describes our practices for collecting, using, disclosing, storing and protecting Users' personal data in accordance with the General Data Protection Regulation (hereinafter "GDPR") and the French Data Protection Act (n°78-17 January 6, 1978). 


It applies to all visits and browsing by Users on the Website, to all orders placed by a User in accordance with our general terms and conditions of sale accessible via this link [ajouter le lien] and to any contact of the User with CE, either by means of the contact form on the Website, by post, e-mail or telephone.

Article 2: Definitions


Personal data shall mean any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier (surname, first name, identification number, location data, etc.) or to elements specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.


CE collects the following personal data: 


  • Creating a customer account: last name, first name, gender, date of birth, postal address,                  e-mail address and telephone number, 

  • Placing an order on the Website (via the shopping cart or the contact form): last name, first name, date of birth, e-mail address and telephone number. 

  • Use of the form for a simple request for information: name, first name, e-mail address. The User is free to communicate any personal data that he/she may wish and that may be necessary for the processing of his/her request,


CE also collects connection information such as statistics on page visits by Users, traffic to and from websites, referral URLs, advertising data, and the browsing history of Users.  


No banking data or information is collected by CE, since at the time of payment, Users are redirected to a secure third-party payment module of the banking organization that collects and processes only Users' banking data and information. 


If Users choose to interact with CE through one of its social networks, CE will collect and process personal data voluntarily provided by Users in order to process their requests. 


Users warrant the authenticity and accuracy of all personal data they provide on the Website, either when creating a customer account, placing an order, or using the contact form on the Website, and that they shall be tantamount to proof his/her identity.


A "cookie" is a file sent to the User's hard drive via their browser. This term covers all traces deposited and/or read, in particular when consulting the Website, reading an e-mail, installing or using software or a mobile application, whatever the medium used.


CE uses the following cookies: 


  • Technical cookies: navigation or session, required to ensure the proper functioning of the Website and to enable Users to enjoy certain content and services they wish to access, 

  • Functional cookies, which are used to enable specific features of the Website and a set of selected criteria (such as language or items Users wish to purchase) and to optimize the quality of the services offered,

  • Analytical cookies, including from third parties, to understand how users, including Users, use the Website,

  • Advertising cookies, also from third parties, intended to create profiles of the user and used to offer Users advertising messages in relation to the preferences indicated during the User's online navigation. 


Functional cookies, analytical cookies and advertising cookies will only be activated and used on the Website if Users give their prior consent to their use.


Article 3: Purposes     


Users are informed that their personal data is mandatory and essential to achieve the following purposes: 


  • To manage the accounts created on the Website by the Users,

  • To manage, process and track orders placed on the Website by Users,

  • To manage, process and follow up all requests and complaints from Users, of any nature whatsoever,

  • To provide Users with customer service, 

  • To manage and follow up the subscriptions to the Newsletter voluntarily subscribed by the Users of the Website,

  • To send communications related to the Website and CE's business, including announcements and administrative messages such as order confirmation,

  • To send the CE Newsletter to Users who subscribe to it, 

  • To send marketing communications about CE and other third-party partners that may be of interest to Users, where CE has a legitimate basis for doing so,

  • To conduct market research as part of CE's ongoing efforts to improve the services it provides to its Users, 

  • To conduct credit checks, prevent fraud and other prohibited or illegal activities, and to maintain the security of the Website,

  • To improve the Website's services and CE's offerings.


Users are informed that without the provision of their personal data, CE will not be able to fulfill their request. 


CE also uses "cookies" and/or "Web beacons" in order to adapt and optimize the display of the Website in consideration of the browsing preferences indicated by the Users of the Website (country, language, time zone, etc.), but also in order to ensure the proper functioning (functional cookies), to analyze and measure the traffic on the Website (audience cookies) and to provide personalized advertising and marketing.


The functional cookies used by CE are essential to the operation of the Website and to the navigation of the Users since they allow the Users to use the main functionalities of the Website and to secure their connection.


Users are informed that they can oppose to the recording of "cookies" and "web beacons" by configuring their computer in accordance with the information provided on the CNIL website, "cookies" section.

Links on the Website may allow access to or interaction with certain social networks (Facebook, Instagram, Youtube, LinkedIn, etc.) which may use "cookies" and/or "web beacons" through the Website and thus collect personal data. CE does not participate in the deposit or analysis of these "cookies" and/or "web beacons" and does not collect or have knowledge of the information collected via these "cookies" and/or "web beacons". CE recommends that Users consult the terms of use, privacy policies and legal notices of these social networks.


Article 4: Legal grounds - legal bases


CE only collects necessary personal data, proportionate to the legitimate and determined purposes defined above and voluntarily submitted by Users, and only implements legal personal data processing on the basis of legal sources provided by the regulations: 


  • Consent of Users (subscription to the Newsletter, various requests via the contact form voluntarily and beforehand by Users, creation of a customer account, placing an order, etc.), 

  • Compliance with legal obligations (claims, litigation, etc.), accounting and tax, 

  • Legitimate interests of CE (protection and development of its business and the Website, etc.) as long as the processing does not infringe the rights of individuals, 

  • Combating fraud, money laundering and financing of terrorism.


Users are informed that they can withdraw their consent at any time.


Article 5: Recipients and transfer


The personal data collected on the Website is intended for CE and may, if necessary, be temporarily communicated to third parties performing services on behalf of CE, in the context of the operation and management of the Website (computer scientist, webmaster, etc.) or the processing of Users' orders (packer, carrier, accountant, etc.).


CE does not rent, sell, disclose or share Users' personal data with any other person or company other than those mentioned in the first paragraph, including for marketing purposes.


Personal data collected and processed by CE is hosted and stored on servers located in France and will not be transferred outside the European Union. 


However, should personal data be transferred outside the European Union, CE will take all necessary measures to ensure that the countries receiving the personal data provide an equivalent level of personal data protection to those of the European Union and France.


The transfer will then be limited either to countries listed by the European Commission as providing adequate personal data protection or to recipients that comply with the European Commission's standard contractual clauses applicable and in force on the day of the transfer of personal data.


Article 6: Data retention period


Personal data are collected, recorded and retained in accordance with the GDPR and the French Data Protection Act (n°78-17 January 6, 1978) in its latest version in force, and are kept for limited periods determined according to the purpose of the processing and the legal and regulatory provisions in force. 


When Users contact CE but do not place an order with CE, their personal data is retained for a period of 3 years after the first contact with the prospect who did not follow up, or after the last contact with this User. 


When Users place an order with CE, their personal data will be retained for the duration of the execution and completion of the order and, thereafter, for the duration of the legal statute of limitations. 


Personal data related to any fraud or money laundering is kept for 5 years after the order is completed and accounting personal data is retained for 10 years. 


In the case of legal proceedings, Users' personal data is retained until a final court decision is made.


If you request that we no longer send you direct marketing communications, we will keep a record of your request and contact information to ensure that your request is honored.


These retention periods may be modified in the event of changes in French and European laws and regulations, which will then be immediately enforceable against Users. 


At the expiration of these retention periods, CE will delete the Users' personal data in order to comply with the legal provisions in force without the need to obtain Users' express and prior approval.


Article 7: Security


According to current knowledge, it is technically impossible to guarantee the unfailing security of data exchanged on the open Internet network. However, CE has taken all reasonable measures to ensure the utmost confidentiality and security of personal data collected or communicated by Users and to protect the actions done on the Website (antivirus, restricted access to the back office of the Website, etc.) in order to prevent data theft, used without authorization, distortion, etc. 


These personal data are only visible to authorized personnel who is aware of the issues of personal data protection. 


In the event of a personal data breach, CE will notify the CNIL in the forms and deadlines provided for by the GDPR and the French Data Protection Act (n°78-17 January 6, 1978) in its latest version.


Article 8: Users’ Rights


In accordance with the GDPR, Users have the following rights: 


  • Right of access: to confirm their personal data, and, where applicable, to gain access to their personal data and obtain details on the nature of the processing carried out, 

  • Right to request the rectification: to obtain the rectification of their inaccurate personal data,

  • Right to erase: to obtain the erasure of their personal data,

  • Right to portability: to receive their personal data from CE, in a structured, commonly used and computerized format in order to transfer them to another platform,

  • Right to be forgotten: to delete their personal data, 

  • Right to limitation of processing: to effectively block their personal data, to store them and to interrupt their processing, 

  • Right to object: to object to the way their personal data is processed.


The Users wishing to assert one of these rights must send their request, with a copy of their identity card, by post to the following address Marie Piselli, 3 Rue de Turbigo - 75001 Paris - France or by e-mail to CE will send a reply to this request within a maximum of thirty (30) days from the receipt by CE of the request from the User concerned.


Users also have the right to refer any claims or complaints to the CNIL.


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