Updated: December 2024

Protecting your personal data is one of our priorities. On our website https://thebradery.com/
(THE " Site " ) and our mobile application (the " Application ") we apply this privacy policy
( Privacy Policy This allows us to inform you about the use and protection of your
data.
Within the framework of the Privacy Policy, the expression " Personal Data" » Or " Data "
refers to any information that identifies you directly or indirectly, including from the terminal you
use, that is to say from your computer, tablet, smartphone, etc.
By using our Site and our Application, you acknowledge that you have read our Privacy Policy.
Confidentiality. In the event of any changes to the conditions under which your data is processed, we will update our
Privacy Policy and we will inform you about it.

Table of Contents

1. Data Controller
2. DPO contact details

3. What data are we likely to process?

4. Why and how do we process your Data?

5. Who are the recipients of your Data?

6. Transfer of your Data outside the European Union

7. What are your rights and how can you exercise them?

8. Management of cookies, SDKs, and other trackers.

1. Data Controller

The company SYMMETRIC, known under the trade name THE BRADERY, a simplified joint-stock company (SAS) with a capital of 1,395.60 euros, of which
The head office is located at 23 rue du mail – 75002 Paris, registered with the Trade and Companies Register (RCS)
from Paris under number 839 442 258 (“The Bradery”, “we”) is responsible for the processing of the Data
Personal data concerning you, under the conditions described in this Privacy Policy.

2. Contact details of the DPO

We have appointed a Data Protection Officer (DPO) to ensure compliance with personal data processing regulations.
You can contact him for any questions or to exercise your rights at the following address: dpo@thebradery.com or by mail to The Bradery – GDPR, 23 rue du mail – 75002 Paris.

This email address is dedicated exclusively to requests related to the protection of personal data rights . Therefore, only messages concerning data protection will be processed via this address. For any other requests or questions, please write to care@thebradery.com .

3. What data are we likely to process?

When you use our Site or our Application, we may collect the categories of
The following data concerns you:

- Civil status and identity (e.g. : contact details) ;

- Data relating to the customer relationship (e.g. orders placed; communication preferences; use of the referral system);

- Economic and financial data (e.g., order amount, payment method used);

- Connection data and data relating to your behavior on the Site and the Application (e.g., language chosen);
- Location data (e.g., country of connection to the Site);
- Data that you freely provide to us.

When data is collected via forms, we indicate its mandatory nature with an asterisk.

4. Why and how do we process your Data?

The collection and processing of your Data pursues several objectives which we detail below.

a) Creation and management of your member account
b) customer relationship management
c) Customer satisfaction management
d) managing your requests
e) Implementation and operation of the sponsorship program
f) prevention and combating of fraud and management of unpaid invoices
g) security, operation and improvement of the Site and the Application
h) display of advertisements
i) sending commercial communications
j) participation in competitions
k) use of social networks
l) applications
m) exercising your rights
n) Management of partnership requests

 

a) Creating and managing your member account

We process your Data to allow you to create a member account on the Site and
the Application and to manage this account.
This processing is necessary for the purposes of our legitimate interests, which consist of providing you with a personal space.
allowing you to order the products and services offered for sale on the Site and the Application.

With the exception of data that is linked to orders you have placed from your account
(member (see b) Customer Relationship Management), your data is kept until you delete your
account. If your account is inactive for 2 years, we will delete it in accordance with the
recommendations from the CNIL. We will inform you beforehand so that you can tell us about
your wish to keep your member account.

b) Customer relationship management

We process your Data in order to carry out all operations related to the management and

Customer relationship management. When you place an order on the Website or the Application, we process your
Data to verify that the order has been paid for, prepare it, deliver it, provide after-sales service, manage
your complaints and the exercise of your right of withdrawal where applicable. When your order concerns
For travel offers, our partners will handle the execution of your orders and are responsible
of the processing of your Data for this purpose.
This processing is necessary for the performance of the contract concluded with us (our General Terms and Conditions).
We also process your Data to perform statistics and analyses in order to identify the
sales performance and improving our understanding of our customers. This processing is based on our interests
legitimate goals which consist of optimizing our product and service offerings
Your data is kept for the entire duration of our contractual relationship. At the end of our relationship
Contractually, we may retain the Data that is necessary to assert a right or defend our interests.
interest during the statutory limitation period of 5 years.
The data processed for the purpose of performing analyses and statistics is retained for the entire duration
necessary for achieving the objective pursued by the analyses and statistics, and within a maximum timeframe
3 years after our last interaction with you, unless you object before the end of this period.
Accounting data and supporting documents are also archived for a legal period of 10 years.
to be counted from the financial year to which they relate for accounting evidentiary purposes.
Your bank details are processed by our payment service providers who manage payments on the
Website and Application. In accordance with regulations and CNIL recommendations, they may be
stored by them in encrypted and secure form for a period of 13 months following the date of
debit (15 months in the case of payment by deferred debit cards) for evidentiary purposes in the event of a possible dispute
of the transaction when this retention is necessary for the management of any potential claims from
payment card holders. This allows, in particular, for the refund of your order in case of
exercising your right of withdrawal. Your bank card's security code is never stored.
On the Application, we offer you the option to save your bank card details to facilitate payment for your
subsequent orders. Your bank card will only be registered if you have consented. Again, these are
Our payment service providers who process your Data. Your Data will
deleted as soon as you withdraw your consent or upon expiry of your bank card.
The data necessary for the implementation of the conformity guarantees for products ordered on the Site
and the Application are deleted after the applicable legal periods have expired.
Finally, the data needed to manage pre-litigation and litigation is deleted once the
The procedure is definitively closed, subject to the data allowing a legal right to be established (example:
transactional agreement) whose preservation is necessary

c) Customer satisfaction management

We process your Data when you provide us with feedback on our products and
services during surveys or polls that we organize.
This processing is necessary for the purposes of our legitimate interests, which consist of improving our understanding of our
to customers and optimize our product and service offerings in light of our customers' expectations.
Your data is kept for a maximum of 3 years from the date of the survey or the
survey.

d) Handling your requests

We offer several ways for you to send us your requests or questions (emails,
chatbots, social networks, etc.).
On this occasion, we process your Data in a manner necessary for the purposes of our interests.
legitimate interests consisting of offering you a personalized consumer experience and creating or enriching our relationship
with you.
When you are a customer of The Bradery, your Data is kept for the entire duration of our relationship
contractual.
When you are a prospect of The Bradey, your Data is kept for 3 years from the last contact you had with us.

e) Implementation and operation of the sponsorship program

We have implemented a referral program that allows both referrers and sponsored individuals to benefit
promotional benefits. Participation in the referral program is not mandatory but results from a
active approach on the part of both sponsors and sponsored individuals.
The management of this referral program involves the processing of data from both referrers and sponsored individuals.
is necessary for the purposes of our legitimate interests in implementing marketing operations with a view to
to promote our business.

f) Prevention and combating of fraud and management of unpaid invoices

We process your Data for the purposes of fraud prevention and detection and management of
unpaid bills.
This processing is based on our legitimate interests, which consist of verifying the authenticity of transactions and
to recover our debts.
Regarding data processed for the purposes of preventing and combating fraud, it is kept for as long as
The member account is active. Regarding the data processed for the purpose of managing unpaid invoices, it is
kept until the debts are recovered.

g) Security, operation and improvement of the Site and the Application

When you access and browse the Site and the Application, we process your data.
Data to prevent and detect security incidents on the Site and the Application, and to personalize
displaying the Site and the Application and carrying out traffic measurements in order to optimize the Site and
the Application and to improve its features.
These processing activities are based either on your consent or on our legitimate interests, which consist of offering a
secure, personalized and optimal experience of the Site and the Application.
Some of your data may be collected through cookies.
When collected via cookies, pseudonymized data is retained for a maximum of 25
months from the date of their collection.

h) Display of advertisements

When you accept advertising cookies, we may process your Data in order to display ads on the Site and

The Application or on third-party sites will display personalized advertisements about our products and services or those of
brands we work with. Personalized ads allow us to offer you content
tailored to your profile and interests. To do this, we also process your Data
for profiling purposes in order to create audience categories (people with the same profile or the same
interests are grouped together).
This data processing is based on your consent to cookies and, with regard to profiling, on our
legitimate interests consisting of offering personalized content to internet users who wish it.
Your data is kept for a maximum of twenty-five months.
We also process the Data in order to produce statistics and analyses relating to
the performance of advertisements. Some of the data may be shared with the brands for which
We display advertisements so they can check the performance of their ads. This processing is
based on our legitimate interests, which consist of evaluating the relevance of the advertisements we display and the
improve in relation to the expectations of internet users.
The data processed in this context is kept for a maximum period of 3 years from the date of its collection.
collection.

i) Sending commercial communications

We process your data in order to send you marketing communications by email.
(ex (information on our current or upcoming sales, newsletter).
This processing may be based on your consent or on our legitimate interests pursuant to Article L34-5
of the Postal and Electronic Communications Code. In this case, you can object to any
at any time and easily by clicking on the unsubscribe link provided in each email.
Some communications may be personalized based on your profile and interests. For
In doing so, we process your Data for profiling purposes in order to create categories
audience (people with the same profile or interests are grouped together).
This processing is based on our legitimate interests in adapting our communications to our customers' expectations.
members. You can object at any time.
We also process the Data in order to produce statistics and analyses relating to
the performance of our communications (e.g. (e.g., email open rate, click-through rate on redirect links, email reading time). This processing is based on our legitimate interests, which consist of evaluating the relevance of our
commercial communications and improve them in relation to the expectations of internet users.
Your data is kept for 3 years from the last contact we had with you.
If you unsubscribe from our mailing list, you will no longer receive our marketing communications.

j) Participation in competitions

We regularly organize competitions giving participants the chance to win
endowments.
We process participant and winner data as necessary for the purposes of
our legitimate interests in organizing competitions, managing participation in these competitions and delivering the
endowments.
The Data is kept for the duration of the Game and the time necessary for the distribution of prizes to
winners and until the end of the claim period when we implement one. Certain related data
The winners' information may be retained to assert a right or defend our interests during the period of
Legal statute of limitations of 5 years.
k) Use of social networks
We have pages on social media (e.g. Instagram, Facebook, LinkedIn, X, TikTok).
You can access these pages from your search engine. You can also click on the
buttons for these social networks on the Site and the Application.
Viewing our social media pages and interacting with our posts may result in
processing of your Data in accordance with what is specified in d) Management of your requests. We will
We inform you that social networks will also process your Data, particularly when you
Access our pages using the buttons on these social networks. To learn more, we invite you to
Consult their privacy policy.
Furthermore, your Data is processed jointly with the relevant social networks for the purposes
social networks assume responsibility for establishing statistics on interactions on these pages.
primary responsibility for this processing
These processing operations are based on our legitimate interests, which consist of using existing communication tools.
in order to promote our business, offer you a personalized experience, and create or enhance our relationship
with you.
Your data is retained as long as your user account on the social network in question is active, except
exercising your right to object or your right to erasure with the social network.

l) Applications

When you send us an unsolicited application or respond to our job offers, we carry out a
processing of your Data for the purpose of managing your application.
This processing is necessary for the purposes of carrying out pre-contractual measures.
Your data is deleted after a period of 2 years from the date of collection.

m) Exercising your rights

We process your Data when you exercise one of the rights you have over your
Data.
This processing is necessary for the performance of our legal obligations.
Your data is retained until your request to exercise your rights has been definitively processed.
data whose retention is necessary to demonstrate compliance with our legal obligations may be retained
for the entire duration of the statutory limitation period of 5 years, which begins to run from the date on which the claim was awarded
your request or the date on which we refused you.

n) Management of B2B partnership requests on the Site

When you submit a partnership request through our site, we collect and process the data that
you provide us (for example, your professional contact details, the name of your company, and details
of your request) in order to review and respond to your partnership request and assess opportunities for
collaboration.
This processing is based on our legitimate interest (Article 6.1.f of the GDPR), which consists of developing relationships
relevant commercial matters and responding to requests received.
Your data will be kept for the time necessary to assess and follow up on your request. If
No partnership is established; your data will be deleted or anonymized no later than one year after the last transaction.
contact with you.

5. Who are the recipients of your Data

Your data may be shared with various recipients.
The recipients of your Personal Data are as follows:

• Our authorized personnel when their duties justify access to the Data
  
  
• Our subcontractors, who assist us in providing you with our services by taking charge, under our control and instructions, of all or part of the processing operations of your Data.
  
  
  We use subcontractors for, among other things:
  
  - Hosting of the Site and the Application;
  - The management of payment services;
  - The use of software that facilitates our business (customer service, accounting, CRM tool, etc.);
  - The storage, preparation, delivery of our products and the management of returns of these products;
  - The display of personalized advertising;
  - Managing cookie storage;
  -Managing applications via recruitment platforms.
  
  
• To third-party entities that do not act as subcontractors but carry out processing in their own name and on their behalf, namely:
  
  - To administrative, financial or judicial authorities whose missions justify access to the data;
  - To entities whose access to the data is justified (examples: entities involved in audits, lawyers, accountants, etc.);
  - To banking institutions in order to process the payment of your orders;
  - To the carriers for the delivery of your orders;
  - To our business partners such as travel providers, installment payment services, brands when they ensure the shipment of the products you have ordered, brands with which we organize co-branded competitions;
  - To advertising agencies and advertisers involved in the distribution of personalized advertising.

We may also sell or transfer all or part of our business or assets, for example in
within the framework of a merger or sale. Transactions of this nature may legitimately involve the implementation
prior audits by professionals and subject to the implementation of safeguards and security measures
appropriate measures to ensure the confidentiality of the Data they access. In the event of
upon the effective completion of a transfer or sale of our assets containing your Data, we
will implement information procedures to guarantee the exercise of your rights on
Your Data.

6. Transfer of your Data outside the European Union.

Data may be transmitted to recipients located in countries outside the European Union, which have a different level of protection than the European Union.

In the absence of a suitability decision, we contractually require these
recipients that they implement the measures required to ensure the same level of protection as that
required by European regulations on personal data such as.
- The signing, between the entity receiving the data entrusted to it located outside the EU and The Bradery, of
standard contractual clauses adopted by the European Commission or adopted by a
supervisory authority and approved by the European Commission in accordance with Article 46.2.
c) and d) of the GDPR;
- Binding corporate rules approved by a supervisory authority in accordance with
Article 46.2(b) of the GDPR; or
- Any other instrument listed in Article 46 of the GDPR.
The Bradery acknowledges, however, that the aforementioned appropriate safeguards will not be mandatory.
when the transfer outside the EU falls within one of the derogations provided for in Article 49 of the GDPR.

7. What are your rights and how can you exercise them?

In accordance with applicable personal data regulations, you can exercise the following rights with The Bradery:

- Access your Data, request its rectification or portability;
- Request the deletion of your account and your Data;
- Withdraw your consent at any time for the future; without this affecting the lawfulness of the processing based on consent carried out before its withdrawal.
- To object to the processing of your Data or to request its limitation;
You also have the right to issue instructions regarding the retention, erasure and
communication of your Data after your death.

You can exercise your access and deletion requests by sending us an email to Dpo@thebradery.com and specifying:

This email address is dedicated exclusively to requests related to the protection of personal data rights . Therefore, only messages concerning data protection will be processed via this address. For any other requests or questions, please write to care@thebradery.com .

-Your name, surname, email address;
-The purpose of your request;
-The address to which the reply should be sent;
We may also ask you to provide proof of identity if we have legitimate doubts about it.
If you believe your data protection rights are not being respected, you have the right
to lodge a complaint with the competent supervisory authority, the National Commission for Information Technology
and Freedoms (CNIL), accessible via its website: www.cnil.fr.

8. Management of cookies, SDKs and other trackers

We use Cookies, SDKs and other tags on the Site and the Application (collectively referred to as " Cookies "). The cookies put in place are installed by us (cookies " first party " or issued by our partners (cookies) " th
IRD party ".
Cookies come in several types and serve different purposes. :

Necessary Functional Cookies These are cookies that allow the Site to function, to use the services of our Site, and to remember information entered on our Site (for example, access to your
account or shopping cart contents) and secure your transaction;

Cookies Personalization These are cookies that allow you to benefit from a browsing experience.
personalized based on your usage. They allow us to personalize the Site's display based on
products and services you have previously viewed, and thus tailor the displayed content to your
areas of interest ;

Advertising cookies These are cookies that allow us and our partners (for example, social networks) to...
social media) to offer you personalized advertisements tailored to your interests and profile, by
real-time, while you browse the internet and social media. They also allow for diversification
the advertisements that are targeted to you. If you choose no, you will still receive advertisements, but these will be...
will not be personalized based on your profile.

Analytical cookies These are cookies that allow for the analysis of browsing activity in order to measure
the audience of the site and the services and products offered, to conduct studies and analyses on our customers and to
These cookies allow us to improve the Site and its relevance. They allow us to understand the volumes, the
traffic and measuring the Site's performance (for example, to know which private sales attract the most visitors)
of Members, the most viewed products etc).

Geolocation These are cookies that allow us to know your location when you log in and...
Confirmation of your order allows us and our partners to send you targeted advertising.
tailored to your location.
We invite you to consult the cookie and personal data policies of our Partners,
on their respective websites.
You have control over cookies (excluding necessary functional cookies). During your registration, you have
The option to accept or reject advertising, analytical, personalization, and geolocation cookies.
Furthermore, in accordance with regulations, we periodically collect your consent regarding cookies.
(excluding necessary functional cookies).
You can also configure your cookie preferences at any time directly on the tool.
present on the Site.

You can also configure your cookie preferences via your browser. : Below you will find the different ways to manage your cookies depending on your browser. The configuration of each
The browser is described in your browser's help menu. Some examples :

• For Internet Explorer

™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies

In the Internet Explorer menu, go to "Internet Options";
In the "Privacy" tab, click the "Advanced" button;
Check the box "Ignore automatic cookie management";

Then select: "Accept" for first-party cookies, and "Reject" for third-party cookies;
Save the changes by clicking "OK".

• For Safari

™: http://docs.info.apple.com/article.htlm?path=Safari/3.0/fr/9277.htlm

In Safari's menu, select "Preferences";
Go to the "Security" tab;
When choosing "Accept cookies", select "Only from sites I visit".

• For Chromium

™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlmr=en&answer=95647

In the Chrome menu, select "Settings";
Click on "Show advanced settings";
Go to the "Privacy" section;
Click on the "Content settings" tab;
In the "Cookies" section (first section) check the box "Block third-party cookies and site data";
Save the changes by clicking "OK"

• For Firefox

™: http://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies

On the Firefox homepage, click on the "Settings" tab;
Select the "Privacy" table;
In the "History" section, for the "Retention rules" option, select "Use custom settings".
for the historical context”;
On the "Accept third-party cookies" dropdown menu, select "Never";
Save the changes by clicking "OK".

For other browsers and mobile devices, please visit the official webpage.
from the browser or device manufacturer or consult the provided documentation.
For more information on cookies and trackers: https://www.cnil.fr/fr/cookies-et-autres-traceurs.