PRIVACY AND PERSONAL DATA PROCESSING POLICY

Contact details of the personal data protection officer of MARKETING CRÉATION (DPD):

Email: dpd@marketingcreation.com

Telephone: 04 42 26 23 07

The Peluche Création website is owned and operated by Marketing Création

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 530796861, having its registered office at 29 Allée Saint Jean, ZAC de la Barque , Arteparc Bâtiment C, 13710 Fuveau (hereinafter the " Company " or " MARKETING CRÉATION "), represented by Mr. Frédéric Martz, its President, collects and processes the personal data of the people who represent its customers in the context of the sale of online products and services provided by MARKETING CRÉATION to its customers.

As an employee or representative of one of MARKETING CREATION's clients or prospects, you are one of MARKETING CRÉATION (hereinafter the " Interlocutor " or " You ") and MARKETING CRÉATION must collect and process some of your personal data to interact with you and their client/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 CRÉATION can possibly communicate the results to you or even send you a prize at the address informed.

MARKETING CRÉATION is concerned about the protection of the privacy and personal data of its Interlocutors and Players. Thus, it ensures that it adopts and complies with a personal data processing policy in accordance with the regulations in force and in particular with the General Data Protection Regulation n° 2016/679 of April 27, 2016 (the "GDPR " ) and the 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 for the processing of personal data by the Company concerning Interlocutors and Players in the case contests.

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 controller

MARKETING CRÉATION is responsible for the processing of personal data collected and processed under the conditions of this Policy applicable to Interlocutors and Players. You can contact MARKETING CRÉATION using the contact details provided in the preamble and article 9 “Contact” of this Policy.

Learn more

The controller is the person, in this case the Company, who determines the methods and purposes of the processing of personal data. He assumes responsibility for the processing of personal data that he implements and he is the main contact for the user to assert his rights under the 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 exchange with its customers and prospects, in order to facilitate the sale of products and its services. In particular, MARKETING CRÉATION collects and processes your personal data when:

• contacting the client or prospect with MARKETING CRÉATION ;
• the creation of a user account;
• the use of or navigation on our website (in particular by cookies);
• of your subscription to our newsletter, to events organized by MARKETING CRÉATION
• your participation in a survey organized by or for MARKETING CRÉATION .

We may also collect information about you obtained from authorized third parties. These sources may, for example, be 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 an Interlocutor or a Player contacts MARKETING CRÉATION such as, for example, within the framework of a trade show or during a contest.

2.2. Categories of personal data

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

⇨ Information necessary for contacting and identifying the Interlocutor: Personal data : surname, first name, title, telephone number and professional email address of the Interlocutor.

⇨ Information necessary to contact and identify the Player : Personal data : surname, first name, title, age, and personal postal address of the Player.

2.3. The mandatory nature of the provision of data

This information is required for

• the connection between MARKETING CRÉATION and the client/prospect and the presentation of MARKETING CRÉATION services to its clients/prospects. Failing to provide this mandatory data, we will not be able to implement the connection with our customers.
• participation in competitions and more particularly the delivery of any prizes. Failing to provide this mandatory data, we could not consider your participation as valid because we would be unable to deliver the prize that may have been won.

2.4. Data Accuracy

MARKETING CRÉATION makes its best efforts to maintain accurate and complete personal data. To ensure that we have up-to-date information, you can inform us of any change in your contact details or any other data, by contacting MARKETING CRÉATION at the contact details mentioned in article 9 "Contact" below, or by putting regularly update your Profile.

2.5. Location of personal data

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

More details concerning the guarantees 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 to achieve the following purposes:

As part of the performance of the contract between MARKETING CRÉATION and the client and as part of the legitimate interest also allows:

• Manage the relationship between MARKETING CRÉATION and its customers/prospects;
• Manage collection;
• Detect, investigate, prevent, or take action regarding illegal activities, abuse, suspected fraud, or situations involving potential threats to the security or rights of any person or entity and to act upon it evidence in the event of litigation;
• Investigate, prevent and deter violations of this Policy; And
• Protect and defend our rights and interests, including our intellectual property rights, before the competent courts or jurisdictions.

Learn more

For the above purposes, the legitimate interest of the Company is to enforce and execute its rights as well as 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 security audits.

Learn more

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

Finally, the data is collected to meet legal obligations:

• Satisfy the legal and regulatory obligations to which MARKETING CRÉATION is subject, such as the tax declaration relating to transactions and the retention of invoices,
• Train our teams, under the legal obligations to which MARKETING CRÉATION is subject as an employer,
• Manage User requests regarding their personal data rights.

4. Communication of personal data

Personal data, collected and processed, may be transmitted:

• To the authorized persons of the departments concerned within MARKETING CREATION;
• In the event of a claim, theft or other violation of the T&Cs or the law, personal data may be transmitted to our insurance company and/or our brokerage company, which is required to maintain the confidentiality of the data transmitted and, where appropriate, to the police and justice services.
• To administrative and judicial authorities and more generally to public bodies in the context of compliance with our legal obligations or to enable us to defend our rights and interests,
• As needed, to our legal advisers and lawyers,
• If we sell or transfer our business or part of it and your personal data relates to that part sold or transferred, or if we merge with another business, we will share your personal data with the new owner of the business. or our merger partner, respectively.

5. Security of personal data

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

6. Transfer of data 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 are not applicable, 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 pursued, if necessary increased by the legal periods of archiving, retention of certain data and prescription. At the end of the processing, the personal data will be either deleted or anonymized by MARKETING CRÉATION .

For more information concerning the retention period of your personal data, we invite you to contact us using the contact details indicated in article 9 “Contact” below.

8. User Rights

As a user, you have, under the conditions of the RGPT and the laws applicable in France, a right of access, rectification, erasure and portability of their personal data, as well as a right to limitation and opposition 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 the head office is located at 3 Place de Fontenoy, 75007 Paris.

For processing based on your consent, this may be withdrawn at any time, without affecting the lawfulness of the processing prior to such withdrawal. The User may exercise his rights, free of charge, with MARKETING CRÉATION at the contact details indicated in article 9 “Contact” below, except in the event of a manifestly excessive request, in which case charges may be applied.

Learn more

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 that your personal data is or is not being processed and, when it is, access to said data as well as information relating to the purposes of the processing ( 15 of Regulation 2016/679 on the protection of personal data (“GDPR”)). Manifestly unfounded, excessive or repeated requests may not receive a response or incur charges.
• Right of rectification : you have the right to obtain from MARKETING CRÉATION , as soon as possible, the rectification of those of your personal data that you consider inaccurate (art. 16 of the RGPD).
• 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 portability : you have the right to receive, or request the sending to a third party, of the personal data concerning you provided to MARKETING CRÉATION , in a structured, commonly used and machine-readable format (art. 20 of the RGPD ).
• Right to limitation of processing : you can obtain from MARKETING CRÉATION limitation of the processing of your personal data under the conditions of article 18 of the PGD.
• Right to withdraw consent : you have the right to withdraw your consent to the processing of your data if such processing is based on consent. The withdrawal of consent does not affect the lawfulness of the processing based on the consent given before its withdrawal.
• Right of opposition : you have the right to object at any time, for reasons relating to your particular situation, to the processing of your personal data, when it is based on the legitimate interest and under the conditions of the 21 GDPR.
• Right to organize the fate of personal data in the event of death : you can define general or specific directives relating to the storage, erasure and communication of your personal data after your death (law 78-17 of the 6 January 1978 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 concerning 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 at the following coordinates:

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