PRIVACY POLICY

1. GENERAL

LPG SYSTEMS attaches great importance to the protection of your personal data and to respect for your privacy.

This Privacy Policy aims to :

•  Inform you of the conditions under which LPG SYSTEMS collects, exploits, stores, shares and protects your personal data;
•  Guarantee you an effective exercise of your rights on your personal data
• Respect the provisions of the French law n ° 78-17 of January 6^th modified, relative to the protection of personal data called  « Loi Informatique et Libertés », the standards enacted by the French  Supervisory Authority called “la CNIL” and the Regulation (EU) n ° 2016/679 of April 27, 2016, called « GDPR ».

We invite you to read carefully these provisions to know and understand our practices regarding the processing of your personal data that we implement.

2. IDENTITY OF THE DATA CONTROLLER

LPG SYSTEMS (hereinafter « LPG »), as Data Controller, is responsible for the processing of personal data collected within the framework of our relationships.

LPG SYSTEMS is a simplified joint stock company organized under the laws of France, registered in the Trade and Companies Register of Romans (FRANCE) under number B 335 183 836, located at Technoparc de la Plaine, 30 rue du docteur ABEL, Valence (26902) Cedex 09, FRANCE.

Phone : +33 (0)4 75 78 69 00 / Fax : +33 (0)4 75 42 80 85

Email address : contact@lpgsystems.com

Intra-community VAT number: FR 50 33 51 83 836

3. COLLECTED DATA

We collect and use your personal data (Hereafter “Data”), which is any information that identifies you directly or indirectly, to the extent necessary in the context of our activities, and to offer you personalized and quality products or services.

Depending in particular on the type of product or service we provide to you, we collect different types of personal data about you, including:

– Data relating to your identity: name, first name, civility, date of birth etc.

– Professional data: profession; information on your professional background (if you provide your CV and / or cover letter to apply for a job at LPG) etc.

– Contact details: postal address (address, city of residence and postal code), telephone number, e-mail address etc.

– Commercial data: customer number (if you are already an LPG customer), purchase history, etc.

– Technical IT data: login, password, connection data, browsing history, etc.

– Bank details: bank details, credit card number etc.

When paying for your orders online on our websites, we use a secure payment system, in order to guarantee maximum security. At the time of payment, you are redirected to the bank’s platform via the secure https protocol. Only the bank data necessary for the completion of the transaction will be collected by the bank, namely the number and expiration date of the bank card, as well as the visual cryptogram

The mandatory or optional nature of the communication of this data is indicated at the time that it is collected (notably on the collection forms). However, failure to provide information that has been identified as mandatory will technically prevent LPG from responding to your request.

The data collected by LPG depends on your relationship and interaction with the organisation.

We collect these Data directly from you, whether you are a customer, prospect or candidate (when you contact us, visit our websites, use our products and services, participate in a survey or any other operation that we organize), but also indirectly from our business partners or through the use of cookies and / or other tracers on our websites

4. DURATION OF STORAGE OF YOUR DATA

Your Data are intended in particular to LPG which keeps them only for the time necessary for the operations for which they have been collected and in compliance with the regulations in force without prejudice to the conservation obligations or limitation periods:

Data relating to the customers are retained for the duration of the contractual relations, increased by three (3) years from the end of the contractual relations,

Bank Data is only kept for the time necessary to complete the transaction, i.e. until full collection of the sums due to LPG or expiry of the withdrawal period (only in the event of an online sale to a particular).

Data relating to the prospects are kept for duration of three (3) years from the last with contact LPG.

Data relating to applicants for our job offers are kept for 1 year from their transmission to LPG.

5. HOW AND WHY WE USE YOUR DATA:

Your Data is collected by LPG for, depending on the case:

• comply with our various legal or regulatory obligations (in particular accounting and tax)
• perform any contract to which you are a party
• serve our legitimate interests
• respect your choice when we have asked for your consent for a specific treatment

And for the following purposes:

• Processing of your request (s) by the competent service
• Processing of your LPG® product orders
• Management of our customer file
• Management of our directory of professional customers equipped with LPG® devices and / or resellers of LPG® slimming and anti-aging products
• Prospecting by sending marketing, advertising and promotional messages that correspond to you
• Monitoring of the operation and geolocation of our professional devices
• Prospecting by sending newsletters relating to our products or news from our company
• Prospecting through the organization of thematic commercial operations and / or contests
• Customer relationship monitoring operations such as carrying out satisfaction surveys or polls
• Organization of workshops to present the interest and benefits of using LPG® devices
• Establishment of statistics Recruitment

6. WHO IS YOUR DATA INTENDED FOR?

Your Data is mainly intended for LPG except your Banking Data collected as part of an online sale which is intended solely for the Bank

However, we may disclose your Data to third parties:

• As part of our partnerships with Leasing companies
• In the context of service contracts with subcontractors within the meaning of Article 28 of the GDPR subject to national and European provisions on the protection of personal data;
• When we have a legal obligation to do so or if we believe, in good faith, that it is necessary to (i) respond to any claim against LPG, (ii) comply with any legal request, (iii) or enforce any contract entered into with our customers, such as the Terms of Use and this Data Protection Policy;
• In the event that we sell or acquire a business or assets, in which case we reserve the right to share your Data with the potential seller or buyer of that business or those assets.INTERNATIONAL DATA TRANSFER

As part of these activities, LPG may be required to transfer all or part of your data to a country that does not belong to the European Economic Area.

If you reside in Belgium, Luxembourg, Italy, Spain, Germany, the United-Kingdom, Switzerland, the United States or China your Data is intended for LPG’s subsidiaries, LPG BENELUX, LPG ITALIA, LPG ENDERMOLOGIE ESPAÑA, LPG DEUSCHTLAND GMBH, LPG SYSTEMS UK LTD, SHENZHEN JIANDA TRADING et LPG SWITZERLAND and ENDOSYSTEMS LLC.

As such, it may be transferred to Italy, Belgium, Spain, Germany, the United-Kingdom, Switzerland, The United States or China.

If you reside abroad, in a country where LPG has an official distributor, your Data may be transferred to that distributor so that it can respond to your request.

If your Data is transferred to a country outside the EEA, LPG will take appropriate measures to ensure that your Data enjoys a level of protection equivalent to that which it enjoys within the EEA.

Thus, the transfer of your Data can take place:

– on the basis of a decision issued by the European Commission, when the latter has recognized that the country to which your Data will be transferred provides an adequate level of protection

Or

– by being framed by specific mechanisms to ensure a sufficient and appropriate level of data protection in accordance with the provisions of Article 46 of the GDPR

7. WHAT RIGHTS DO YOU HAVE?

In accordance with the applicable legislation, you have:

• a right of access, rectification, objection and erasure of your personal data,
• a right of restriction of processing
• a right to object to processing
• a right to data portability,
• a right to withdraw your consent at any time
• a right to set guidelines for the processing of your data after your death
• a right to lodge a complaint with a competent Supervisory Authority.

If you are a consumer, you have a right to object to the use of your phone number for the purposes of commercial prospection

You can exercise any of your rights by following the procedure fixed in article 9 below. We will endeavor to comply with your request within a reasonable time and, in any event, within the time limits set by law.

All requests must be accompanied by a photocopy of an identity document bearing your signature.Before responding to your request, we may (i) verify your identity and (ii) ask you to provide us with more information to respond to your request.

8. AMENDMENT OF OUR PRIVACY POLICY:

We may occasionally modify this Privacy Policy.

We advise you to regularly check this page to be aware of any changes or updates to our Privacy Policy.

9. CONTACT:

If you have any questions regarding our Privacy Policy or any request about your data, you can contact us :

• By email at the following address: dataprivacy@lpgsystems.com
• By mail to the following address: LPG SYSTEMS, Délégué à la Protection des Données, Technoparc de la Plaine, 30 rue Dr Abel, CS 90035 – 26000 VALENCE (FRANCE)

Updated 01/06/2023