Last update: Novembre 23, 2020
1 – Protection of personal data
Commonwealth Cigar Co, the drafter of this agreement, performs processing of personal data.
The following describes how this data is collected and the detail of how it is used. The personal data which is collected varies depending on how the services are used. Personal data collected or held is directly communicated by the person themselves, browsing the website, or comes from third parties, or is collected from the activity on the website and the use of the services.
2 – Sales and marketing prospecting
The following information is collected and processed: contact details, such as surname, first name, home address, country of residence, landline and/or mobile telephone number, e-mail address, reference to social network connections.
The purpose of using this information as personal data is:
To send communications about products and services for business development purposes. Such communications may take the form of e-mail, postal mail, SMS, telephone calls or targeted online advertising. This data is kept for prospecting purposes for a maximum period of three (3) years.
When data has been collected in connection with the provision of a service or requests for information, information on similar or targeted services may be sent on the basis of previous requests, unless the data subject requests to stop receiving such commercial communications or chooses not to receive them. This data is kept for prospecting purposes for up to three (3) years after the data collection.
Each time an electronic communication for commercial prospecting purposes is sent, the recipient has the possibility to choose not to receive any more in the future through an unsubscribe link. In addition, it is possible at any time to send an e-mail to the following address: firstname.lastname@example.org to request that the sending of these commercial communications be stopped.
The use of data and information as described above is authorized by the regulations applicable to the protection of personal data. In most cases, this processing of personal data for business development purposes is based on the legitimate interest of Commonwealth Cigar Co.
In addition, when the data subject has given his/her consent directly to Commonwealth Cigar Co partners (such as insurance companies, comparison sites, social network platforms, marketing agencies and affiliation platforms, search engines, online property ad sites etc., without this list being exhaustive), Commonwealth Cigar Co may receive personal data. The use of this information by Commonwealth Cigar Co is then possible in order to promote its services under the conditions described above.
3 – Online questionnaire
The following information is collected and processed: IP address, post code, landline and/or mobile phone number, and if applicable the information provided in the online questionnaire. This information is used solely to establish contact with the person who completed the online questionnaire and offer them an exchange or an appointment with an authorized person of Commonwealth Cigar Co to draw up a personalized quotation without obligation and to ensure its follow-up at the end of the contact. This contact will be made by telephone and/or e-mail. The data collected when sending the completed online questionnaire is kept for a maximum period of three (3) years.
The use of the information as described above is authorized by the regulations applicable to the protection of personal data. The processing of such personal data in this case is based on the consent of the data subject.
4 – From the use of the website
The Commonwealth Cigar Co website uses cookie technology to improve navigation and the experience of website users. When you consult it, these cookies can be stored on the browsers of the medium used, regardless of the device (computer, tablet, smartphone). They are used in particular for identification purposes for analyses of the use of the site’s elements.
The cookie has a validity period which varies according to the type of cookie and allows the visitor to be recognized the next time they use the website. In any event, this period shall not exceed thirteen (13) months.
Visitors can decide whether or not to accept cookies when browsing the website. To this end, Commonwealth Cigar Co displays on its website a banner of prior information inviting the visitor to accept cookies. As long as the visitor has not given their consent to the collection of cookies, no cookies may be placed on their terminal, with the exception of cookies exempt from the collection of consent insofar as they are strictly necessary for the provision of a service expressly requested by the user.
5 – In the context of the services provided
The following information is collected and processed: surname, first name, address, landline and/or mobile telephone number, e-mail address.
▪ for the performance of pre-contractual measures or the contract with Commonwealth Cigar Co, when it implements a processing operation for the purpose of:
prospecting, production, management, follow-up of customer requests and files,
the drafting of deeds on behalf of its clients;
▪ as well as in the context of compliance with legal and regulatory obligations when it implements a processing operation for the purpose of:
the prevention of money laundering and terrorist financing and the fight against corruption,
all elements necessary for these purposes are collected and processed.
This information is used to perform the tasks related to the services and services requested.
Such processing is authorised by the regulations applicable to the protection of personal data, and in all cases is based on the legal basis of the contract between the data subjects and Commonwealth Cigar Co or that of the legitimate interest. Unless otherwise specified, the information referred to above is necessary in order to fulfil our contractual obligations.
6 – Retention of information
Personal data is stored for the purposes listed in this policy.
Unless otherwise specified in the previous paragraphs, the data is kept as long as the data subject has a contractual relationship with Commonwealth Cigar Co.
In the event of termination of the contract between the data subject and Commonwealth Cigar Co, such as at the end of the service or service requested, and if there is no other reason to continue processing, the information will be kept for the periods necessary to comply with the regulations and rules of prescription in force – in particular contractual, accounting and tax rules, or of applicable to process any claim or request relating to the services provided.
Customers’ personal data is kept for the duration of the contractual relationship increased by three (3) years for the purposes of animation and prospecting, without prejudice to retention obligations or limitation periods. With regard to the prevention of money laundering and terrorist financing, data is kept five (5) years after the end of the relationship with Commonwealth Cigar Co.
7 – Rights related to personal data
the right to access one’s personal data,
the right to correct any errors in the files,
the right to have one’s personal data deleted, to limit its processing or to object to it.
the right to withdraw consent,
the right to object to the receipt of business development documents in the future,
in certain circumstances, the right to ensure that such information is transferred to the data subject or to a third party.
the right to define general and specific guidelines defining the way in which the data subjects intend to exercise, after their death, the rights mentioned above by e-mail to the following address: email@example.com, accompanied by a copy of a signed identity document.
8 – Contact and complaints
All questions raised in this policy and requests for the exercise of the data subject’s rights are handled by the Data Protection Officer, who may be contacted as follows: firstname.lastname@example.org.
Any request to exercise the rights of access, rectification, deletion or restriction of processing must be accompanied by a copy of an identity document from the applicant.
We reserve the right to modify it at any time in order to provide up-to-date information on how we collect and process personal data.