PRIVACY AND PERSONAL DATA PROCESSING POLICY

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Contact details of the Data Protection Officer (DPO) for MARKETING CRÉATION :

Email: dpd@marketingcreation.com

Telephone: 04 42 26 23 07

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The Peluche Création website is owned and operated by Marketing Création

The company MARKETING CREATION, a simplified joint-stock company with a capital of 100,000 euros, registered with the Trade and Companies Register of Aix-en-Provence under number 530 796 861, having its registered office at 1 via Aurelia 13100 Le Tholonet (hereinafter the "Company" or "MARKETING CREATION"), represented by Mr. Frédéric Martz, its President, collects and processes the personal data (i) of its clients' customers in the event of intervention as a subcontractor but also (ii) of the persons who represent its clients in the context of the sale of online products and the provision of services by MARKETING CREATION to its own customers.

As a consumer customer using a web page hosted by MARKETING CREATION or as an employee or representative of one of MARKETING CREATION's customers or prospects, you are one of MARKETING CREATION's contacts (hereinafter the "Contact" or "You") and MARKETING CREATION must collect and process some of your personal data to interact with you and/or its customer/prospect for whom you work.

By participating in a competition organized by MARKETING CREATION, you (hereinafter the "Player" or "You") communicate your personal data so that MARKETING CREATION (or its client) may possibly communicate the results to you or even send you a prize to the address provided.

MARKETING CRÉATION is committed to protecting the privacy and personal data of its clients and players. Therefore, it ensures that it adopts and adheres to a personal data processing policy that complies with current regulations, and in particular with the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (the " GDPR ") and the French Data Protection Act of 1978, as amended.

Thus, the purpose of this policy relating to the confidentiality and protection of personal data (the “ Policy ”) is to set out the terms and conditions of the processing of personal data by the Company concerning the Interlocutors and Players in the case of competitions.

MARKETING CRÉATION reserves the right to modify the Policy at any time and undertakes to inform Interlocutors and Players of these changes via a notification when using the services.

1. The data controller

MARKETING CREATION is the data controller of the personal data collected and processed under the conditions of this Policy applicable to Interlocutors and Players.

MARKETING CREATION is a data processor when it acts as a service provider for a client, organizing a contest or providing the client with a dedicated webpage to host the contest. In this case, MARKETING CREATION's client is the data controller.

You can contact MARKETING CREATION using the contact details provided in the preamble or in Article 9 "Contact" of this Policy.

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The data controller is the person, in this case the Company, who determines the methods and purposes of the processing of personal data. They assume responsibility for the personal data processing they implement and are the user's main point of contact for exercising their rights under this processing.

2. Sources and categories of personal data

2.1. Source and collection of personal data

MARKETING CREATION collects your personal data in order to communicate with its clients and prospects, with the aim of facilitating the sale of its products and services. Specifically, MARKETING CRÉATION collects and processes your personal data when:

• from the initial contact between the client or prospect and MARKETING CRÉATION ;
• of creating a user account;
• from the use of or browsing on our website (including through cookies);
• from your subscription to our newsletter, to events organized by MARKETING CRÉATION
• of your participation in a survey organized by or for MARKETING CRÉATION.
• from your participation in a survey or contest organized by or for MARKETING CREATION. We may also collect information about you obtained from authorized third parties. These sources may include, for example, business partners (physical or online stores, consumer service providers, etc.), advertising agencies, distributors, or data analysts.

We may also collect information about you from authorized third parties. These sources may include, for example, business partners (physical or online stores, consumer service providers, etc.), advertising agencies, distributors, or data analysts.

MARKETING CRÉATION also processes all personal data communicated spontaneously and voluntarily, in particular when a Contact or a Player contacts MARKETING CRÉATION such as, for example, in the context of a trade fair or during a competition.

2.2. Categories of personal data

MARKETING CRÉATION collects and processes the following categories of personal data:

⇨ Information needed to make contact and identify the Interlocutor: Personal data : name, first name, title, telephone number and professional email address of the Interlocutor.

⇨ Information needed to contact and identify the Player : Personal data : name, surname, title, age and date of birth, and postal address and personal email of the Player.

2.3. The mandatory nature of providing the data

The information provided is mandatory for

• The process of connecting MARKETING CRÉATION with clients/prospects and presenting your services to them MARKETING CRÉATION . Failure to provide this mandatory information will prevent us from connecting you with our clients.
• Participation in competitions and, more specifically, the delivery of any prizes. If you fail to provide this mandatory information, we will be unable to consider your participation valid as we will be unable to deliver any prize you may have won.

2.4. Data Accuracy

MARKETING CRÉATION makes every effort to maintain accurate and complete personal data. To ensure we have up-to-date information, you can notify us of any changes to your contact details or any other data by contacting MARKETING CRÉATION using the contact details provided in Article 9 "Contact" below, or by regularly updating your Profile.

2.5. Location of personal data

The personal data collected for which MARKETING CRÉATION is responsible is hosted in France on MARKETING CRÉATION 's servers which are hosted by the company 1&1 Ionos Internet.

Further details regarding the safeguards taken for data transfers outside the European Economic Area are given in Article 6.

3. Purposes and legal bases of processing

Personal data is processed by MARKETING CRÉATION for the following purposes:

As part of the execution of the contract between MARKETING CRÉATION and the client, and in the context of legitimate interest, this also allows for:

• Managing the relationship between MARKETING CRÉATION and its clients/prospects;
• Manage debt collection;
• To detect, investigate, prevent or take action regarding illegal activities, abuses, suspicions of fraud or situations involving potential threats to the safety or rights of a person or entity and to use them as evidence in the event of litigation;
• To investigate, prevent and stop violations of this Policy; and
• To protect and defend our rights and interests, including our intellectual property rights, before the competent courts or jurisdictions.

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For the above purposes, the Company's legitimate interest is to enforce and execute its rights and to prevent fraud and any prohibited or illegal activity.

The Company also seeks to enable the training of its employees and the performance of compliance and safety audits.

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Thus, the Company's legitimate interest is to maintain the level of competence and enrich the knowledge of its teams.

Finally, the data is collected to comply with legal obligations:

• To comply with the legal and regulatory obligations to which MARKETING CRÉATION is subject, such as the tax declaration related to transactions and the retention of invoices,
• To train our teams, in accordance with the legal obligations to which MARKETING CRÉATION is subject as an employer,
• Manage User requests regarding their rights concerning personal data.

4. Communication of personal data

The personal data collected and processed may be transmitted:

• To the authorized persons of the relevant departments within MARKETING CREATION;
• In the event of a claim, theft or other breach of the Terms and Conditions or the law, personal data may be transmitted to our insurance company and/or our brokerage firm, which is required to maintain the confidentiality of the transmitted data and, where appropriate, to the police and judicial authorities.
• To administrative and judicial authorities, and more generally to public bodies, in order to comply with our legal obligations or to allow us to defend our rights and interests,
• As needed, consult our legal advisors and lawyers
• If we sell or transfer our business or part of it and your personal data relates to that sold or transferred part, or if we merge with another company, we will share your personal data with the new owner of the business or our merger partner, respectively.

5. Personal data security

MARKETING CRÉATION implements organizational, technical, software and physical security measures to protect personal data against loss, unauthorized access, disclosure or alteration.

6. Data transfer outside the European Economic Area

Your personal data may be transferred to countries outside the European Economic Area (hereinafter " the EEA "), in particular to our business partners.

In order to ensure protection equivalent to that offered in the EEA, a territorial area outside of which the GDPR standards do not apply, data transfers outside the EEA are governed by contractual clauses based on the standard clauses of the European Commission.

7. Data retention

MARKETING CRÉATION retains your personal data for the time necessary to fulfill the purposes for which it was collected, plus any applicable legal retention periods for archiving, data retention, and statutes of limitations. Once processing is complete, the personal data will either be deleted or anonymized by MARKETING CRÉATION.

For more information regarding the retention period of your personal data, please contact us using the contact details provided in Article 9 "Contact" below.

8. User Rights

As a user, you have, under the conditions of the GDPR and applicable French laws, a right of access, rectification, erasure and portability of your personal data, as well as a right to limit and object to the processing of this data.

You also have the right to organize the fate of your personal data in the event of death, as well as the right to lodge a complaint with the CNIL, whose website is accessible at the following address: http://www.cnil.fr and whose headquarters are located at 3 Place de Fontenoy, 75007 Paris.

For processing based on your consent, this consent may be withdrawn at any time, without affecting the lawfulness of the processing prior to its withdrawal. The User may exercise their rights free of charge with MARKETING CRÉATION using the contact details provided in Article 9 "Contact" below, except in the case of manifestly excessive requests, in which case fees may apply.

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In addition to the information below, MARKETING CRÉATION invites you to consult the CNIL website:

• Right of access : You have the right to obtain from MARKETING CRÉATION confirmation as to whether or not your personal data is being processed and, where that is the case, access to the data and information regarding the purposes of the processing (Article 15 of Regulation 2016/679 on the protection of personal data (“GDPR”)). Requests that are manifestly unfounded, excessive, or repetitive may not receive a response or may incur a fee.
• Right of rectification : you have the right to obtain from MARKETING CRÉATION , as soon as possible, the rectification of those of your personal data which you consider inaccurate (art. 16 of the GDPR).
• Right to erasure : you have the right to obtain from MARKETING CRÉATION the erasure of your personal data, under the conditions provided for in Article 17 of the GDPR.
• Right to data portability : you have the right to receive, or to request the sending to a third party, personal data concerning you provided to MARKETING CRÉATION , in a structured, commonly used and machine-readable format (art. 20 of the GDPR).
• Right to restriction of processing : you can obtain from MARKETING CRÉATION restriction of the processing of your personal data under the conditions of Article 18 of the GDPR.
• Right to withdraw consent : You have the right to withdraw your consent to the processing of your data if that processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Right to object : you have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data, where such processing is based on legitimate interest and under the conditions of Article 21 of the GDPR.
• Right to organize the fate of your personal data in the event of death : you can define general or specific directives relating to the retention, erasure and communication of your personal data after your death (law 78-17 of 6 January 1978 as amended, art. 40, II).
• Right to lodge a complaint with a supervisory authority : without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you constitutes a violation of the regulations applicable to personal data (Art. 77 of the GDPR).

9. Contact

For more information on the processing of your personal data or to exercise your rights, you can contact us using the following contact details:

MARKETING CREATION
29 Allée Saint Jean, ZAC de la Barque,
Arteparc Building C, 13710 Fuveau – France

Email: dpd@marketingcreation.com

Telephone: 04 42 26 23 07