PRIVACY POLICY
§1 Definitions
This privacy policy (hereinafter the "Privacy Policy") governs the manner in which MYBEST collects, processes and retains data collected from its Customers and from users of its services, in particular from users of its online sales platforms.
The term "MYBEST" refers to the Luxembourg company MYBEST Sàrl, whose registered office is located at L-5495 Wintrange, 4, Dentzescheck and which is registered in the Luxembourg Trade and Companies Register under number B263755.
The term "User" or "Customer" refers to any individual who uses MYBEST's services and sales or its online sales platforms.
The term "Personal data" means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to identity of that natural person;
This privacy policy may be adapted or supplemented freely at any time, but always within the limits permitted by law. The Client or User is invited to refer to it as often as possible and to consult the privacy policy on a regular basis in order to take note of any changes.
§2 Compliance with data protection regulations
MYBEST is committed to ensuring the protection of natural persons in relation to the processing of personal data as a fundamental right.
MYBEST is committed to complying with all applicable national laws and European regulations governing the processing of personal data. In particular, MYBEST undertakes to comply with REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter "GDPR").
MYBEST also adopts appropriate security measures and practices in data collection, storage and processing to protect against unauthorized access, alteration, disclosure or destruction of personally identifiable information. MYBEST takes these measures in accordance with its responsibilities, noting that certain specific services may be provided by third parties (e.g., payment service providers, delivery service providers).
§3 Identity and contact details of the data controller
MYBEST is the data controller within the meaning of Article 24 et seq. of the GDPR. MYBEST has not appointed a data protection officer.
For any request relating to the processing of personal data, MYBEST is represented by its manager and can be contacted either by post at the address of its registered office at L-5495 Wintrange, 4, Dentzescheck, or by e-mail at the following address: ingrid@mybest.wine
§ 4 Purposes of the processing for which the personal data are intended
MYBEST processes personal data only for the purposes indicated in this privacy policy or when you enter your data. The collection of personal data is required in the event of a purchase on the online sales platforms and in the event of the User's registration on the site. It is therefore primarily for the processing of purchases and the provision of its services. Personal data is used within the strict limits of the rules of Luxembourg and European data protection law. It may also be used by MYBEST to optimize its business processes and to adapt and improve its services.
Users' personal data is also used in connection with the provision of MYBEST’s services and the proper functioning of its online sales platforms.
In this context, MYBEST may collect and use personal data to ensure the operation of the Services (when making a purchase, where MYBEST collects the buyer's contact details and address; when creating a User account, where the use of an e-mail address and password are required to create an account).
In addition to the management of Customer purchases and orders, the collection and use of personal data is also required to receive and send text messages or notifications to customers.
§ 5 Types of data collected
MYBEST collects and processes the surnames, first names, addresses, e-mail addresses, passwords, telephone numbers, IP addresses, connection data and navigation data, order history, preferences, products consulted, delivery incidents and complaints or requests from Users.
Some data is collected automatically as a result of the User's activity on its online sales platforms.
For the execution of purchases, the payment information (name and surname of the holder, number, expiry date and security code of the payment card) of the Users will be requested by the payment provider. This data is not collected and processed by MYBEST, but by the payment service provider(s).
§ 6 Personal data falling under special categories as defined in Article 9 paragraph 1 of the GDPR
MYBEST does not request or collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
§ 7 Accuracy and data minimization
MYBEST undertakes to apply reasonable measures to ensure that Users' personal data is accurate and, where necessary, updated. Similarly, MYBEST will only collect personal data from Users for the purposes set out in this Privacy Policy. Personal data will not be used for any other purpose, unless the User has expressly agreed to the use of such personal data for another purpose.
§ 8 Sharing of personal data
MYBEST undertakes not to transfer Users' personal data to third parties without their express consent.
Users agree that their personal data may be passed on in the course of providing the Services to suppliers or subcontractors, if any, that MYBEST may use to provide its goods and services, including payments and deliveries, provided that such parties agree to treat such information in accordance with MYBEST's instructions and in full compliance with applicable laws regarding the protection of personal data.
§ 9 Transfer of data to MYBEST
MYBEST shall adopt appropriate measures to protect personal data from unlawful or unauthorized processing.
Customers and Users bear the responsibility for ensuring that any personal data they provide to MYBEST is transmitted securely.
§ 10 Length of data retention
Unless the right to erasure is exercised previously, the retention period for personal data is 10 years.
In the event that the User requests the closure of his account, the account will be deleted along with all personal data contained therein.
MYBEST may retain any data which it renders anonymous by means of an irreversible process and which will be used exclusively for internal purposes.
§ 11 Legal basis for the processing
The processing of personal data by MYBEST is based on point (f) of Article 6(1) of the GDPR.
§ 12 Rights of the data subject
At any time and free of charge, each User shall benefit, under the RGPD and the conditions defined therein, from the following data protection rights: right of access (Article 15 RGPD), right to erasure (Article 17 RGPD), right to rectification (Article 16 RGPD), right to restriction of processing (Article 18 RGPD), right to data portability (Article 20 RGPD), right to lodge a complaint with a supervisory authority (Article 77 GDPR), right to withdraw his consent (Article 7, paragraph 3 GDPR), as well as right to object to certain data processing measures (Article 21 GDPR).
To exercise these rights, the User may send a request to MYBEST.
Each User also has the right to withdraw their consent to this Privacy Policy at any time and free of charge. To do so, the User must close his or her account, if applicable.
The User may file a complaint with the Luxembourg supervisory authority, namely the Commission nationale pour la protection des données https://cnpd.public.lu/fr.html
§ 13 Acceptance of this Privacy Policy
The User's explicit acceptance of this Privacy Policy is a condition for using MYBEST services. Consent is evidenced by acceptance of the terms and conditions either when creating a user account or when making a purchase on MYBEST's online sales platforms.
