Data Protection Policy

Our personal data protection policy is designed to establish a relationship of trust between you and our services, in order to offer you a positive experience in a completely transparent manner.

Through this policy, we are able to take your requirements into account and meet your expectations.

In order to respect your trust, A&G Retail Group SAS guarantees above all the protection of your personal data and the confidentiality of our customers (hereinafter "Your Data").

For complete transparency, and to guarantee you secure use of our website Wynhaven in all its available versions and related applications (hereinafter the "Wynhaven Site"), we make available the way in which we process your data, so that our services are always in accordance with the respect of your rights. In this way, we ensure the security, confidentiality and non-alteration of your privacy and your data, across all of our platforms.

Our policy and we ourselves guarantee that all necessary precautions are taken to protect all of your data against disclosure, loss or alteration. This is why we provide you with all the elements allowing you to easily understand how we process your data. This data will only be kept for the time necessary for the management and processing determined. You will of course, at any time, have access to your data and be able to modify it, as it will be available in your personal spaces on the Wynhaven site.

To this end, we strive to take all necessary measures in order to comply with applicable law regarding data protection.

Wynhaven hereby commits, through this personal data protection policy, to respect the essential principles of the UK GDPR and the Data Protection Act 2018, by making available to you information concerning the existence and modalities of the data processing applied here (paragraph 3), the rights you have regarding your data, as well as by applying these rights ourselves (paragraphs 6 and 10). Any information relating to possible transfers to a third country or recipients is also made available, as well as the retention period of collected data (paragraph 5) and security measures (paragraph 9).

WHO ARE YOU?

When we refer to "you" in this Personal Data Protection Policy, it is because it is directly linked to you and concerns you as a customer of Wynhaven, if you have placed an order on the Wynhaven site, if you have created a customer account but have not ordered products or services, or if you have browsed as a visitor on the Wynhaven site without having created a customer account or placed an order.

FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?

3.1. When do we collect your personal data?

Your personal data may be collected if you visit the Wynhaven site using cookies, if you create a customer account on the Wynhaven site, if you place an order for one of our products or services, or if you have agreed to be a member of our newsletters (SMS, emails).

Your personal data is used to streamline your navigation on the Wynhaven site, as well as to offer you a more personalised experience. We can thus process your orders as efficiently as possible, prevent fraud, process necessary refunds, and manage your customer reviews.

3.2. Your navigation on the Wynhaven Site

In order to allow you to navigate on the Wynhaven site, we process your data with your consent as the legal basis.

3.3. Processing of your orders

In order to handle and process your orders, we use your data.

The use we make of it serves to manage mediation, customer relations (including through social networks), our after-sales and remote sales service, our marketing and commercial prospecting management actions for the Wynhaven site, as well as the management, deliveries and transport of orders.

The performance of the contract between the two parties (you and us) is the legal basis for the processing of this data.

A&G Retail Group SAS's legal obligation is the legal basis for processing with regard to the management of product recalls. Your consent or our legitimate interest are, depending on the case, the legal basis for processing for marketing and commercial prospecting actions.

3.4. Customer reviews

In order to share your reviews with our customers and visitors and allow you to leave your review on the Wynhaven site, we use your data on the legal basis of your consent or legitimate interest.

3.5. Payment recovery and fraud prevention

In order to enable payment recovery and fraud prevention, we use your data.

Through this, we can also guarantee the security of payments.

The performance of the contract between the two parties as well as the legitimate interest of A&G Retail Group SAS, as data controller, are the legal bases for this processing.

3.6. Advertising management operations for Wynhaven

Wynhaven's advertising management operations are managed through the use of your data.

This allows us to grow our customer and prospect data, manage technical maintenance and prospect activities, commercial statistics and advertising campaign studies, and implement any promotional operations, excluding online gambling and games of chance.

The legal bases for the above are the user's consent or the legitimate interest of A&G Retail Group SAS.

WHERE DOES YOUR DATA GO?

Your data is transmitted to several internal departments of Wynhaven.

It is not sent to third parties, except in the situations specified below:

In order to process your orders, your personal data may be transmitted to several service providers whose specialisations include banking transactions, customer relations, after-sales service, delivery, IT development, site management or the provision of guarantees or insurance.

Your data may be shared with service providers such as payment and transaction centres (banks, etc.), call centres for the management of business processes or customer experience, or, for customer reviews, a customer review collection and processing manager.

Wynhaven's advertising management is handled, using your data, for advertising clients and advertisers.

DATA RETENTION

The data collected by A&G Retail Group SAS is kept only for the time necessary for the implementation and completion of the operations mentioned in paragraph 3 of our personal data policy.

We retain certain data collected by Wynhaven for a certain period of time.

For prospects, data is retained for 3 years from the last customer contact. Where data represents an administrative interest for certain purposes, such as litigation, retention periods are set by applicable limitation rules.

Regarding orders, your data will be archived for 5 years from the end of the use of the customer's orders, then in intermediate archives for 5 years. The same applies to customers.

Regarding banking data, it is archived for the entire period of validity of the bank card (plus one day). There is no intermediate archiving of banking data.

Cookies and their use and duration are detailed in paragraph 7 of our policy.

EXERCISING YOUR RIGHTS

6.1. You have the right to request access, modification and rectification of your Data.

6.2. You have the right to request the restriction of the processing of your Data. To do so, you must contest the accuracy of your personal data for the period required to allow us to verify its compliance; or, where you believe our use of your personal data is unlawful and you request a restriction of its use rather than erasure; or where we no longer need to use your data for the purposes mentioned in paragraph 3 but your data is still necessary for the establishment, exercise or defence of your legal rights.

6.3. You have the right to request the deletion of your Data. If you request the deletion of your personal data, A&G Retail Group SAS may still retain it in intermediate archive format for the time necessary to fulfil its legal, accounting and tax obligations.

6.4. You have the right to object to processing used for commercial prospecting purposes.

For prospecting by email, you may request modification or unsubscription from newsletters by clicking the "unsubscribe" link available in all newsletters, or by navigating directly to the contact page of the Wynhaven site.

For prospecting by SMS, you may unsubscribe by replying "STOP" by SMS, or by navigating to the contact page of the Wynhaven site.

6.5. You have the right to transmit post-mortem instructions concerning the retention, erasure and communication of your personal data. In the absence of such instructions, your successors and heirs may contact Wynhaven to access the uses of this data, to organise and settle the deceased's estate, to close the account, and/or to request the discontinuation of the processing of personal data. You may also request that your data not be communicated to a third party in the event of death.

6.6. You have the right to data portability.

6.7. You have the right to withdraw your consent regarding processing based on that legal basis. If you withdraw your consent, this does not affect the lawfulness of the uses made before your withdrawal.

6.8. You have the right, at any time, to lodge a complaint with the competent supervisory authority. In the United Kingdom, this is the Information Commissioner's Office (ICO): www.ico.org.uk.

In order to exercise your rights, please send your request (accompanied by your email, last name, first name, a copy of your identity document and postal address) by email to contact@trywynhaven.com and/or by post to A&G Retail Group SAS, 47 Rue Vivienne, Paris.

Within a maximum of one (1) month after the date of receipt of the request, we will send you a response.

COOKIES

7.1. What is a cookie?

When you browse a website such as the Wynhaven site, it may, depending on your choice, insert a text file on your device (computer, phone or tablet) through your browser.

This text file is called a COOKIE. This cookie allows the website, such as Wynhaven, during the prescribed validity or registration period of the cookie, to identify your device when you make another visit.

Only the issuer of a cookie can read or modify the information contained in that cookie.

7.2. What are cookies used for on Wynhaven?

Different types of cookies can be classified into categories. Some are issued directly by Wynhaven and its service providers, but some come from third-party companies.

7.2.1. Cookies issued by Wynhaven and its service providers

There are several categories of cookies that may be found on your device when you browse our website:

7.2.1.1. "Essential" Cookies

In order to access our site, "essential" cookies are necessary; they are used, for example, to place orders. Without them, you might encounter navigation problems and be unable to place an order. "Essential" cookies also allow Wynhaven to monitor its activity. They may be inserted on your device by Wynhaven or by its service providers.

7.2.1.2. "Analytics and Personalisation" Cookies

"Analytics and personalisation" cookies are not mandatory; they allow us to facilitate your searches, optimise your experience with us, better target your expectations, adapt our offers and maximise the organisation of our site.

7.2.1.3. "Advertising" Cookies

Advertising cookies appear in the advertising spaces of our site. The benefit for you is that your browsing time is improved through the presentation of relevant offers and advertisements. To do this, "advertising" cookies target your expectations in real time and offer you advertising content adapted to your interests, through your recent browsing history on other sites. The advertising content offered may contain cookies issued by Wynhaven, its service providers, or by third parties.

7.2.2. Cookies issued by third-party companies

Third parties using cookies on our site use their own privacy policy for this purpose. These cookies are not necessary for the use of our site.

7.2.3. Cookies issued by third-party applications integrated into our site

During your browsing on our site, we may include applications from a third party, in order to offer you the possibility of sharing content and/or your opinion from our site with other people, for example when you click on the "share" or "like" buttons that come from social networks.

These social networks may then identify you through these buttons even if you have not used them during your browsing on the site. They can do this if, during your navigation, you were simultaneously connected or active on your social network on your device. We have no control over the uses they employ, nor over the data they access.

To find out more about the use of your data, you can consult the personal data protection policies of these social networks and manage your settings according to your preferences.

7.3. Browser options

Your browser software contains many options that you can set according to your preferences. Through these, you can accept or reject cookies on your device. You can also choose to activate a reminder asking whether you accept or refuse cookies before their potential recording, or refuse each time.

Please note that the choices you make may modify or alter your browsing on certain sites or services that require the use of these cookies (such as placing an order on our site). If you prefer to refuse these cookies or delete those already recorded, we decline all responsibility for the consequences of the alteration of the functioning of our services.

To find out how to set your options according to your browser, consult its help menu.

TRANSFERS OUTSIDE THE UNITED KINGDOM

Most of the time, your data is kept within the United Kingdom or the European Economic Area.

However, when our service providers are located in countries outside the UK/EEA, we may share some of your data in third countries, including countries that have not been the subject of a UK adequacy assessment.

In this case, we take the necessary steps to ensure that this data sharing is done in compliance with the relevant regulations and that the protection of your privacy and fundamental rights is guaranteed (for example, through the use of the UK International Data Transfer Agreement or standard contractual clauses).

We can, upon your request, provide you with more information about data transfers.

SECURITY MEASURES

Through the technical and organisational measures we take, we guarantee a level of security commensurate with the risks to the rights and freedoms of natural persons. To do this, we take into account the origin, scope, context, costs and state of knowledge, the purposes of the processing, and the identified risks.

In addition, we comply with the PCI DSS payment card industry security standard, which reflects our commitment to security.

PROFILING AND AUTOMATED DECISION-MAKING

We may use automated processing (such as profiling) in connection with fraud prevention and customer identification. Where such processing produces legal effects concerning you or similarly significantly affects you, you have the right to obtain human intervention, to express your point of view, and to contest the decision.

POLICY UPDATE AND REVISION

Our personal data policy will be updated whenever necessary in order to remain in accordance with the regulations applicable to the protection of your data (every three (3) years at minimum).