PRIVACY AND USE OF PERSONAL DATA POLICY

Definition of terms used in the privacy policy

We will then designate:

• "Personal data": is defined as "any information relating to an identified natural person or which can be identified, directly or indirectly, by reference to an identification number or to one or more elements specific to him/her", in accordance with the French Data Protection Act of 6 January 1978.
• "Service" means the https://v2.my4spirits.com service and all of its contents.
• "Publisher" or "We": Bertholet Benoît, the legal or natural person responsible for the publication and content of the Service.
• "User" or "You": the Internet user visiting and using the Service.

Article 1 - Introduction and Role of the Privacy Policy

The purpose of this policy is to inform you of the Service's commitment to your privacy and to the protection of your Personal Information collected and processed in connection with your use of the Service. It is important that you read this Privacy Policy so that you are aware of why and how we use your data. By registering with the Service, you agree to provide us with true information about yourself. Providing false information is contrary to the terms and conditions on the Service. Please note that this Privacy Policy may be modified or supplemented at any time, including for the purpose of complying with any legislative, regulatory, case law or technological developments. The date of its update will be clearly indicated, if applicable. These changes are binding on you as soon as they are posted online and we therefore invite you to consult this Privacy Policy regularly in order to be aware of any changes. You will also find a description of your privacy rights and how the law protects you. If you have any questions regarding this Privacy Policy or if you wish to exercise your rights as described in Article 10 of this Privacy Policy, please contact us by e-mail at: benoit@v2.my4spirits.com or by mail at Grand'Route de ciney, 104 5503 Sorinnes.

Article 2 - Data collected on the Site

The Data collected and subsequently processed by the Service is that which you voluntarily transmit to us by filling in the various forms present within the Service. For certain operations on the contents, you may be led to transmit Data concerning you to third party partners through their own services, more specifically when you make payments. We will not have the said data at our disposal, their collection and processing being governed by the conditions specific to these parties. We invite you to consult their conditions before communicating your Data in this context.

Your IP address (the identification number assigned to your computer on the Internet) is collected automatically. You are informed that the Service may implement an automatic tracking process (Cookie), which you can prevent by modifying the relevant settings of your Internet browser, as explained in the general conditions of this Service. In general, you can visit the https://v2.my4spirits.com Service without providing any personal information about yourself. In any case, you are under no obligation to transmit this information. However, if you refuse, you may not be able to take advantage of certain information or services. We also collect, use and share aggregate data such as statistical or demographic data for any purpose. Aggregate data may be derived from your personal information but is not legally required to be so because it does not directly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users who access a specific feature of the Service. In order to provide better content and services, the https://v2.my4spirits.com Service uses the Google Analytics service. Google Analytics does not track your browsing habits on third-party services. The information about you that Google Analytics has access to does not contain any personal data about you. We do not collect so-called "sensitive" data. The contact information of the Users of the Service who have registered on the Service will be saved in accordance with the provisions of the French Data Protection Act of 6 January 1978. In accordance with this law, they have the right to access, withdraw, modify or rectify the Data they have provided. To do so, they just have to send a request to the following e-mail address: benoit@v2.my4spirits.com, or by mail: Grand'Route de ciney, 104 5503 Sorinnes.
The collection of Users' Personal Data by the Publisher does not require any declaration to the Belgian Data Protection Authority (DPA).

Article 3 - Identity of the controller

The data controller is Mr Bertholet Benoît.

Article 4 - Purpose of the Data Collected

The Data identified as mandatory on the Service's forms are necessary in order to benefit from the corresponding functionalities of the Service, and more specifically the operations on the content offered within it.

• The Service is likely to collect and process the Data of its Users:
• For the purpose of providing you with the information or services to which you have subscribed, in particular: newsletter.
• For the purpose of collecting information that allows us to improve our Service, products and features (including through the use of cookies).

Article 5 - Recipients and use of the Data collected

The Data collected by us are processed for the purpose of carrying out operations on the contents of the Service. You may receive electronic mail (emails) from our Service, in particular in the context of newsletters that you have accepted. You can ask to no longer receive these e-mails by contacting us at benoit@v2.my4spirits.com or by clicking on the link provided for this purpose in each of the e-mails sent to you. Only Bertholet Benoît is the recipient of your personal information. This information is never transmitted to a third party, notwithstanding the subcontractors that Bertholet Benoît uses. Neither Bertholet Benoît nor its subcontractors market the personal data of visitors and users of its Service. Your personal data may be shared with the parties indicated below for the purposes defined in this privacy policy. We require that all third parties ensure the security of your personal data and treat it in accordance with the law. We do not allow our third party service providers to use your data.

Article 6 - Legal basis for data processing

In accordance with the General Regulations on Data Protection (RGPD), Bertholet Benoît only processes personal data in the following situations:

• with your consent ;
• when there is a contractual obligation (a contract between Bertholet Benoît and you) ;
• to meet a legal obligation (under EU or national legislation).

Article 7 - Data Security

You are informed that your Data may be disclosed pursuant to a law, a regulation or a decision of a competent regulatory or judicial authority or, if necessary, for the purposes of the Publisher to preserve its rights and interests. We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without your permission. In addition, access to your personal data is subject to a defined and documented security procedure.

Article 8 - Data retention period

The Data is stored by the Service host, whose contact details appear in the Service's legal notice, and is kept for the duration strictly necessary to achieve the purposes referred to above and may not exceed 24 months. Beyond this period, they will be kept for exclusively statistical purposes and will not be used for any other purpose whatsoever.

Article 9 - Authorised service providers and transfer to a third country of the European Union

Bertholet Benoît informs you that it uses authorized service providers to facilitate the collection and processing of the data you have communicated to us. These service providers are located exclusively in the European Union. Bertholet Benoît has previously ensured that its service providers have implemented adequate guarantees and that they comply with strict conditions in terms of confidentiality, use and data protection. These service providers are also subject to the General Regulations on Data Protection (RGPD).

Article 10 - Computer rights and freedoms

In accordance with the legislation on the protection of personal data, you have the rights detailed below which you may exercise, as indicated in Article 1 of this Privacy Policy, by writing to us at the postal address mentioned at the top of this page (Grand'Route de ciney, 104 5503 Sorinnes) or by sending an e-mail to benoit@v2.my4spirits.com :

• The right to information: we have an obligation to inform you about how we use your personal data (as described in this privacy policy).
• The right of access: it is your right to make a request for access to the data concerning you in order to receive a copy of the personal data we hold. However, due to the obligation of security and confidentiality in the processing of personal data incumbent on Bertholet Benoît, you are informed that your request will be processed on condition that you provide proof of your identity, in particular by producing a scan or a photocopy of your valid identity document.
• The right of rectification: the right to ask us to rectify any personal data concerning you that is incomplete or inaccurate. Under this right, the legislation authorises you to request the rectification, updating, blocking or deletion of data concerning you that may be inaccurate, erroneous, incomplete or obsolete.
• The right to erasure, also known as the "right to forget": in some cases, you may ask us to delete personal data we have about you (unless there is a compelling legal reason for us to retain it).