At LE VADROUILLEUR, personal data that we collect about you is only the necessary data in order to identify you and validate your orders.
No intrusive data or sensitive data is collected about you.
On www.levadrouilleurspirits.com, the personal data processing controller is Mr Theo Arnulf.
All your requests concerning your personal data can be sent to him to the following email address: email@example.com
You can also download and fill the privacy form by clicking here.
See Legal Notices.
LE VADROUILLEUR attests to implement in good faith all necessary means to respect your privacy, to carry out the data collecting and processing in a licit, loyal and transparent way, as well as to act in compliance with the whole applicable regulation.
Article 1. Definitions
The Site: the website accessible via the following address www.levadrouilleurspirits.com, as a whole, including both consultative and applicative parts, and including all potential subdomains.
LE VADROUILLEUR: refers to the company Maison LC 1901 SAS, owner, editor and sole representative of the Site, business name and brand « LE VADROUILLEUR », as designated in the in the Legal Notices.
Users: refers to all natural or legal person with full legal capacity who consults the Site and uses its functionalities.
The Client: refers to any User, natural or legal person with full legal capacity, who purchases validly at least one Product on the Site.
The Parties: refers to, together, LE VADROUILLEUR and the Users and/or LE VADROUILLEUR and the Clients, who agreed the Terms & Conditions.
Third party: refers to any person who is not party to the Terms & Conditions.
The Terms: the whole and indivisible agreement that governs entirely and exclusively the User’s registration and use of the Site, as well as all orders by all Clients. This agreement may also be named “Contract” or “Terms and Conditions”, and is accessible by clicking here.
The Services: refers to the entirety of the services, free or payable, provided by LE VADROUILLEUR via the Site.
The Products: refers to any type of product, physical or dematerialised, that can be purchased on the Site.
The Information: designates all information published on the Site by LE VADROUILLEUR.
The Content: designates all content entered by the Users, that are destined to fill their account and/or to be published on the Site (testimonies, comments, etc.).
The Data: designates all management data, entered by Users/Clients in order to be able to use the Site and its functionalities.
Article 2. Acknowledgement of Accountability
. The collection and processing of personal data, executed as part of the use of the Site, necessary to undertake the good execution of the common contractual purposes, and for LE VADROUILLEUR to respect its obligations as part of its commercial distance activities, is executed in compliance with the applicable regulation in European Union (GDPR) as well as (French) “Loi Informatique et Libertés modifiée”, under the responsibility of Mr Theo Arnulf, designated in the Legal Notices.
Article 3. Object and purpose of data collection
Article 3.2. Object and purpose of the data processing
. The collection and processing of personal data executed on or via the Site is limited to that which is strictly necessary, and in accordance with the principle of “privacy by default”.
. Data collecting and processing on or via the Site is executed for the following purposes:
- ensure technical effectiveness and safe use of the Site, which can include in particular the consultation, the subscription and/or registration (personal account, webinars, events, etc.), written communication, the publication of comments and reviews, the execution of orders, contact making, right execution of the Services, the download and/or upload and archiving of specific contents, management of accounts and personal data, notifications, invitations, solicitations and miscellaneous communications from LE VADROUILLEUR;
- allow LE VADROUILLEUR to know its audience better in order to optimize and manage its relationship with the Users, via analysis and Site’s audience measurement, as well as the compilation of anonymous statistics;
- allow LE VADROUILLEUR to send Users and Clients newsletters destined to, in particular, inform them about the use and evolutions of the Site, the launching of future Products or Services, specific advice from LE VADROUILLEUR, etc.);
- allow LE VADROUILLEUR to send Users and Clients solicitations, commercial or not, concerning corresponding offers (similar to those offered on the Site), and to enhance the Site as well as its commercial offers.
This purpose includes management of LE VADROUILLEUR relationship with the Users and of clients and User’s reviews about products, Services, or contents; it also includes potential participation to special events (such as game contests, random draw, offers, etc.) and to retention programs, exclusive of gambling and game of chance that are subject to approval from (French) “Autorité de Régulation des Jeux en Ligne” (ARJEL), as well as prospecting and/or specific information, including prospect reminder follow-up messages, management of technical operation for prospecting, selection of Users for customer retention, commercial prospecting, surveying, products tests, discounts and all solicitation operations.
- allow LE VADROUILLEUR to ensure the right execution of its obligations towards Clients and Users, via diverse Services and products, which implies by definition to provide voluntarily personal data, which can include: identifying persons using the Site in order to purchase Products and/or Services; perform operations related to data management concerning contracts, purchases, deliveries, bills, countability and commercial relationship follow-up; allow the right execution of payments, as well as prevention and fight against fraud and payment methods fraud, and in particular card fraud; manage arrears, losses, and disputes; resolve potential claims, and treat requests concerning rights of access, rectification and opposition;
- NOTE: LE VADROUILLEUR does not transfer any of your personal data to any commercial partner whatsoever.
Article 4. User’s consent
. In accordance with article 6 of the GDPR, LE VADROUILLEUR can perfectly collect and process data, in order to execute its obligations as part of the purchase of its products and Services, to protect its legitimate interests, in accordance with the Terms and Conditions.
. LE VADROUILLEUR shall request your explicit consent unless these two aforesaid cases make it unnecessary, or if the Law provides an obligation to collect your consent.
. For purposes of transparency, respect of the rights of individuals on their personal data, and also optimisation of the use of the Site, LE VADROUILLEUR has set up a compliance process concerning the automatic use of basic cookies upon entering the Site, so that nor the User neither LE VADROUILLEUR needs to take specific action to ensure the compliance of such process. No cookie on the Site allows to collect personal data.
. The Parties agree that the names of the buttons on the Site can be replaced by other names with an equivalent meaning, that attests the User’s consent.
Article 4.2. Explicit consent to use specific cookies when using the Site’s functionalities (Opt-in)
. User’s consent is systematically and explicitly collected with a physical or digital signature, and/or the filling of a checkbox and/or any other way of collecting the consent, understood as the manifestation of a clear and unambiguous will (optin), in particular in all cases that imply by definition to collect and use some provided/collected data.
. In all cases of collection of a required consent, LE VADROUILLEUR allows the Users to effectively withdraw their consent (optout) to actual or future data collecting and processing, by any adequate means (such as in particular: “optout” and email unsubscription link, written formal request, etc.).
Article 5. Content of data collection
Article 5.1. Data collected with cookies
Article 5.2. Data explicitly provided by Users
. The exact content of the data collection operated when the Users use the Site’s functionalities and/or Services, vary according to such specific use, and may gather the following information:
Ordering data and accounts data (accounts are automatically created when validating your first order):
- Name and surname
- Valid email address
- Date of birth (in accordance with (french) Loi Evin on minor protection and alcohol consumption)
- Postal billing address and shipment address
Billing information and commercial relationship:
- Billing and delivery/shipping addresses (email and postal);
- Bank details in order to execute payments, via the third party provider MyPOS, an electronic payments software (card number + expiration date + security cryptogram);
LE VADROUILLEUR cannot technically access to payment data, which are entirely managed by MyPOS.
In case of potential reimbursement, and if the Client does not explicitly require to use another payment method, LE VADROUILLEUR will use the same payment details via its administrator dashboard, with no possibility of visualising such data.
When the Client requires to use new payment details, such data is collected by LE VADROUILLEUR for the strict purpose of the concerned payment or reimbursement, and deleted once such payment is entirely processed.
Clients management data:
- Identification and password (User’s passwords are never stocked in plain text, but as a computer footprint, and are destined to future security verifications concerning future connexions to the Site);
- Basic connexion logs (with IP address, date and time of connexion;
- Complementary and supporting data and documents when LE VADROUILLEUR executes a legitimate security verification that implies provision of such data.
- Information provided voluntarily by Users in surveys, with the purpose of knowing better their degree of satisfaction with Products and Services, of their needs, of their personal and professional path or career, of their means and purchase habits, of their goals, of their potential obstacles, and their suggestions for improvement;
- Complementary information potentially provided by Users/Clients during events, may they be online or not;
None of such data is used for direct prospection.
Data provided in order to receive the newsletter:
- Name and valid e-mail address.
Article 5.3. Users defaults in providing data
. Whether the providing of an information is compulsory or not, varies according to the use of the Site, and is always specified explicitly and clearly online or in the concerned documents
. Users commit without reserve to provide exclusively complete, exact and valid information, and waive LE VADROUILLEUR from all responsibility for any damage resulting from their own fault in this field.
. Likewise, Users admit that their own potential defaults in providing compulsory data allow LE VADROUILLEUR to suspend or cease any Service and/or purchase of products, eventually based on such data.
. Under its moderation and control capacity over the whole Site’s activities, LE VADROUILLEUR reserves the right to perform any useful verification concerning all data provided by the Users, including asking supplementary supporting data and/or documents.
Article 6. Data collection via Cookies
Article 6.1. Cookies utility
. Cookies can be used for statistics purposes, in order to optimize the Site and the Services by processing data concerning frequency of access, performed operations and consulted information.
. The collected information will never be used for another purpose than following navigation habits, volume, type and configuration of the traffic transiting through the Site, developing its conception and layout, and more generally enhancing the Site’s use.
. None of such cookies is used for prospection purposes.
Article 6.2. Acceptation of cookies and quality of navigation
. Nevertheless, all the cookies that are not strictly necessary are specified by LE VADROUILLEUR.
. Statistics cookies don’t collect personal information allowing to identify Users, neither on hard drive nor online, and the collected data is anonymous or anonymized.
. The necessary cookies are destined to allow LE VADROUILLEUR to execute its obligations, and give access only to connexion data.
Article 6.4. Exact list of cookies used by LE VADROUILLEUR
1. Imperative cookies for the Site’s functioning in any case:
Connexion and identification cookies: allowing to access the User’s IP address, date and time of connexion, operating system, browser and device type;
Specific cookie made to check that the informative banner has been approved (management of consents on the banner itself, allowing not to display it with every page loading).
2. Imperative cookies for the Site’s functioning in case of payment:
MyPOS cookies to allow the right functioning of this service, as the case may be (read this page to know more about MyPOS solution).
3. Non imperative cookies for the Site’s functioning:
No non-essential cookie is deposited on the User’s device for audience measuring, which is done via the tool Plausible, which is totally compliant with GDPR requirements, for it does not use the system of cookies to ensure the data collection.
Users can learn more about such solution by visiting this page.
° Plausible software for standard audience measuring purposes
No data found in this software allows to identify persons.
LE VADROUILLEUR never crosses data collected in this field with other collected data, and cannot use them alone to identify persons.
The technical process used by Plausible does not imply any cookie strictly speaking. No cookie is thus used in order to access the audience measuring anonymous data.
(even though this topic is treated in this section, in order to inform Users the most clearly as possible)
° Specifications about Plausible cookies:
During navigation on the Site, LE VADROUILLEUR collects by default only the data that allows audience analysis and measurement: data concerning IP address (identification of the internet connexion and the terminal), consulted pages, as well as various types of data, regarding possible interactions between Users and the Site:
- Number of viewers
- Bounce rate
- Origins of the traffic
- IP address and operating system
- Visits data: number of unique viewers, total number of visits, number of viewed pages, number of views per visit and duration of visits, date and time of visit)
- Places of consultation (geo-tracking is not more precise than the city)
. None of such data, processed separately or together, allow any kind of identification of any person, and is consequently considered as anonymous or anonymized data.
Article 7. Interactivity with third party Websites and Apps
. Users can interact with the Site by clicking on third party websites and applications buttons (via social networks buttons, LE VADROUILLEUR diverse websites).
. Users are aware that when they connect their account to such other third service’s account, such as a social network, this service shall lawfully communicate to LE VADROUILLEUR their connexion and profile information, as well as any other information thus been authorized.
. In no way LE VADROUILLEUR shall bear responsibility of any damage resulting from the use of this process towards the Users and Clients as well as such third parties and is accountable exclusively for the data processing under its responsibility.
. LE VADROUILLEUR also excludes its responsibility for the use by Users of the files and documents that are exchanged in any way by the latter, and for any damage that could result from it (in particular, loss, hijacking, destruction, etc.).
Article 8. Security of data processing
Article 8.1. General security obligations
. LE VADROUILLEUR commits to take all necessary or useful caution measures to preserve the safety of the data collection and processing, with respect for physical and logical safety standards (offices, devices and servers protection, etc.) that are under its authority, concerning navigation, subscription and use of the Site in general, not excluding all security obligation placed under the web host's responsibility (OVH).
. Security measures are adapted to the effective risk of accidental, unauthorized or illegal access, and to effective risks of personal data divulgation, alteration, loss, or destruction.
. Any information accessible on the Internet via an outbound link from the Site, except LE VADROUILLEUR other websites, is not placed under the responsibility of the latter, who excludes its responsibility concerning such contents and potential IT security holes or risks, as well as any consequence that could result from them (the specific IT security conditions concerning the Site are specified in the Terms&Conditions > CGUV).
Article 8.2. Security measures
- IT Security ensured by LE VADROUILLEUR:
° ID (unique e-mail) and password (never displayed in plain text and not accessible to administrator; password recovery process in case of loss or theft
° Separation of data tables
° Prestashop system dedicated to security (protection against computer hacking)
° Implementation of protection for professional devices (encryption and passwords security policy)
° Regular backups (done directly by LE VADROUILLEUR, daily and under safe conditions, in order to ensure the restoration of the Site in case a problem its security, its integrity, or its existence.)
° Encryption of the data transiting between the server and the User/Client
° Encryption of the code and the cookies.
° Log and events filing
° Regular modification of administrator passwords
° Disaster recovery system and process, as the case may be
. LE VADROUILLEUR takes security measures in order to avoid damage on and/or distortion of the processed data, and to prevent access from third parties, in particular by controlling and securing potential access and communication of such data.
. Users admit that they are responsible for their own ID and password, which they can create and modify in case of loss or oblivion, via the specified process on the Site. Users exclude seeking responsibility of LE VADROUILLEUR in such cases of oblivion, loss, theft, hijacking of this ID and password. LE VADROUILLEUR attests that it even has no access to the User’s password in plain text and therefore can not even read them.
- IT Security ensured by the hosting company (OVH) :
° Log and events filing
° Encryption through the HTTPS protocol on every page of the Site
° Limitation of connections and IP addresses filtering
° Management of administrators accesses
. management of certificates
° Real time detection and analysis of security threats
° Management and rating of databases repertories
° Management of storage files
° Pooling of resources and knowledge in the field of IT security
The commitments of OVH concerning personal data security are accessible by clicking here.
- IT Security ensured by MyPos:
. The third party service provider who’s in charge of payments on the Site (MyPos) fully takes over banking details encryption for every payment made on the Site.
The commitments of MyPos concerning personal data security are accessible by clicking here.
Article 8.3. Information obligations in case of security holes
. LE VADROUILLEUR commits to the fullest transparency of communication concerning its Users and Clients personal data security.
. May the case arise when LE VADROUILLEUR would know about an unauthorized or illegal access to its Users personal data, and especially if such access brings or involves consequences on security risk realization or aggravation, LE VADROUILLEUR commits to:
- Notify the incident to the Users forthwith, especially if such notification is mandatory;
- Examine the causes of the incident;
- Take any necessary and reasonable measures in order to lessen negative effects and damages that could result from the aforesaid incident.
. In no case the fact that LE VADROUILLEUR commits to inform promptly its Users in such specific cases should be understood as an admission or acknowledgement of fault or liability concerning the occurrence of the concerned incident.
Article 9. Data processing privacy
Article 9.1. Legitimate communication of data
. LE VADROUILLEUR does not communicate the personal and confidential data collected through the use of the Site, to no third party and in no way or form whatsoever, except to the legitimate persons cited below:
- LE VADROUILLEUR potential staff (including trainees or interns);
- The potential technical services provider who is in charge of the creation and/or maintenance of the Site, as well as data hosting;
- The persons who are potentially in charge of countability, administrative and/or legal aspects of the LE VADROUILLEUR company, including as external services providers;
- Potential providers, subcontractors and/or subsidiary companies, in order to fully execute the purchases that imply the latter, who can only access the necessary data, and for the right execution of the contract(s) that bound them to LE VADROUILLEUR, and subject to respect of their contractual obligations that binds them to LE VADROUILLEUR;
- Legally authorized third parties (in particular on explicit and motivated request of public, judicial, or regulating authorities, etc.); in particular, customs offices shall be recipients of personal data as part of international deliveries;
- Potential assignees in case of LE VADROUILLEUR participation to a merger or acquisition operation, or any other form of asset sales, subject to commitment to guarantee the same level of personal data protection and privacy to the Users, who shall be informed before such transfer or submission to new privacy rules.
. In such cases of communication of personal data to third parties, LE VADROUILLEUR ensures that the latter is accountable for applying privacy conditions that are the same or equivalent to its own commitment.
. In such cases, LE VADROUILLEUR commits to guarantee that the concerned third parties offer sufficient contractual warranties in order to implement appropriate technical and organisational measures, and for the processing to meet GDPR requirements.
Article 9.2. Data collected for users and clients testimonials
. LE VADROUILLEUR commits to collect potential anonymous testimonials from Users and Clients in accordance with the terms of the CGUV.
. In cases when such testimonials are not anonymous and include the concerned User’s image, an image rights authorization is systematically proposed to the concerned User or Client, in order to guarantee the latter the respect of such right and the option to withdraw his consent if he wishes to delete his testimonial from the Site or discontinue its exploitation by LE VADROUILLEUR.
Article 9.3. International transfer of personal data (outside E.U)
. In accordance with regulation applicable to data transfers with countries outside the European Union, LE VADROUILLEUR commits to transfer, as the case may be, collected personal data only and exclusively to countries acknowledged to offer an equivalent level of protection.
. LE VADROUILLEUR commits to refrain from transferring personal data outside countries acknowledged by the (french) CNIL for offering a sufficient level of protection, unless LE VADROUILLEUR has been duly authorised by the CNIL in order to process such transfer.
. The User accepts that the use of the Site in general can involve automatic transfer of several connection data (pages views, operating system, language, country, etc.), to third party services providers who are in charge of providing the services that allow LE VADROUILLEUR to collect and process its own data (in particular Plausible), with no possible intervention of LE VADROUILLEUR on such transfer). The User can consulter article 6 of the present for more information on cookies.
Article 10. Data conservation and time limits
Article 10.1. Renewal of the User’s consent
. The collected data are saved validly for the entire duration of the commercial relationship between the Parties, and as long as they are necessary to the purpose for which they have been legitimately collected initially and for which they continue to be processed, and as long as this purpose continues to be legitimate, proportionate, and accepted by the concerned User (when consent is required).
. The specified time limits for conservation of the data vary according to the type of data, which can be subject to legal and regulatory different requirements (which can authorise a longer saving or on the contrary require their deletion).
. In some cases the User’s/Client’s consent can be renewed when the time limit of conservation is reached. Should this consent not be renewed, the concerned data shall be anonymized and saved for statistics purposes, or for reasons of proof of the commercial activities of LE VADROUILLEUR.
. As a consequence, the Users admit that the potential deletion of their account, as the case may be, results in immediate purge of all data contained in their profile or account, except contractual and purchase data that are destined to archiving by LE VADROUILLEUR.
Article 10.2. Time limits of conservation applicable to different data
. Data is saved for the purpose of enhancing the use of the Site, optimizing commercial relationship, as well as ensuring security of navigation and finally for reasons of proof of the commercial activities of LE VADROUILLEUR.
. The time limits (except for management data) are:
- fifteen (15) months for banking data and bank details, when there are collected and saved by LE VADROUILLEUR (in principle, banking details necessary for the validation and processing of the purchases are not saved by LE VADROUILLEUR – they are fully managed by the third party service provider for payments – MyPos);
- five (5) years concerning billing and contract data, for amounts under 120 euros, and 10 (10) years concerning amounts above 120 euros;
- maximum three (3) years for the other types of data;
This time limit of three years starts from the end of the contract that links them to LE VADROUILLEUR, or the last active contact for the Users.
. More precisely, shall the User fail to identify or to have an active behaviour (for example, by clicking on a link) within a period of three years, the latter may receive an email inviting him/her to connect to his/her account on the Site forthwith, otherwise his or her data may be completely deleted from LE VADROUILLEUR database.
Article 10.3. Record keeping
. All data that have not been validly deleted after the limits have been reached in accordance with article 10.2 of the present, can be recorded as archives on a separate computer device, for reasons of proof and in a strictly limited access, except in case of request for personal data deletion procedure, prone to result in definitive deletion of such data under legal requirement.
. In such case, the deletion of data is effective when the time limit for data conservation, or necessary or imposed recording limit, is reached, and/or as soon as valid and formal request from the User is received and treated (see article 11).
. In such case, the Users admit that their personal data can be purged from LE VADROUILLEUR IT system with no possibility of recovery.
Article 11. Rights of persons on their personal data
Article 11.1. Rights of persons’ content
. The Users have right of access, query, rectification, limitation, portability, opposition and/or deletion of the data that concern them.
. The Users also have the right to oppose, at any time and for reasons that depend from their particular situation, to the processing of personal data on legal legitimate basis by LE VADROUILLEUR, as well as a right to oppose commercial prospecting. The consent to process can be withdrawn with no effect on such processing legal validity, based on initial consent.
. The Users can also set general and particular guidelines that define the way they wish their above mentioned rights to be applied after their death.
. The Users can always lodge a complaint before the (french) CNIL if answers provided by LE VADROUILLEUR is deemed unsatisfactory.
Article 11.2. Rights of persons exercise
. Users requests concerning their rights relative to their personal date can be made:
- either by e-mail on the following address: firstname.lastname@example.org
- either by regular mail (see details in Legal Notices)
We recommend Users to use the dedicated form, for all requests concerning privacy and personal data, which is accessible by clicking here.
. LE VADROUILLEUR commits to make effective all motivated requests concerning personal data, by notifying its reception forthwith, and by answering it formally within a period of thirty (30) business days, starting from the reception of the request.
. For security reasons, and in order to avoid fraudulent requests, LE VADROUILLEUR can validly require that the request shall be accompanied with identity credentials, which shall be deleted or destroyed after the demand is fully processed, and subject to the application of a legal disposition requiring its recording.
. The Users admit without reserve that in case they submit a motivated request to delete their personal data, such data can be purged without any possibility of recovery, and that this deletion may prevent the right execution and continuation of their contractual relationship as well as the benefit of the Services, as they may be imperative to use some parts of all of the Site. As a consequence, should these rights be exercised at the same time with a purchase or subscription of products or Services, such purchase or subscription could not be executed.
Article 12. Applicable law, disputes and litigation
. The User who does not reside in France is informed that he can also bring his case to a court of the Member State of the European Union in which he has his main residence.
Do not reproduce – Last update 02/06/2023