Personal data and Cookies Policy
Last update : 15/04/2022
When you visit a website, data may be stored in or retrieved from your browser, usually in the form of cookies. This information may be about you, your preferences or your device and is primarily used to ensure that the website functions properly. The information generally does not directly identify you, but may provide you with a personalized web experience. Because we respect your right to privacy, we give you the option of not allowing certain types of cookies. However, if you block certain types of cookies, your browsing experience and the services we are able to offer you may be impacted.
1.Cookies strictly necessary
Some cookies are necessary for the operation of our site. For example, when you log in to your account or create an account, a cookie will help us recognize you as an existing user. These cookies cannot be disabled, as some functionalities of the site cannot function without them.
We will never use (nor allow any third party to use) the statistical analysis tool to track or collect Personally Identifiable Information (PII) from visitors of our site. Google will not associate your IP address with any other data held by Google. We will not connect or seek to connect an IP address to the identity of the user of a computer.
We will not associate data collected from this site with personally identifiable information from any other source unless you explicitly provide us with that information. To learn more about Google Analytics privacy: https://support.google.com/analytics/?hl=fr#topic=10737980
In case you refuse the tracking cookies, we have chosen to anonymize the IP addresses of Google Analytics, replacing the last IP information. In this case, the complete IP address is never transmitted to Google.
You can deactivate the use of personal cookies when you access the site: click here to make your choice.
We recommend that you configure your cookies selection directly on the site, without changing your browser settings.
We respect your concerns about the protection of your privacy and your personal data. This Personal Data Guideline (the “Guideline”) sets out what information is collected and how your personal data is processed as well as the cookies collected when you browse the Site.
1.Identity and contact details of the data controller
The website https://www.haut-brion.com (the “Site”) is operated by Domaine Clarence Dillon SAS, whose head office is located in France, 31 avenue Franklin D. Roosevelt 75008 PARIS, registered under the number 572 179 026 RCS Paris, (“SAS Domaine Clarence Dillon” or “we”) having the quality of data controller within the meaning of the regulations applicable to personal data, which includes the General Data Protection Regulation (“GDPR”) of 27 April 2016.
Finally and in the cases mentioned below, some of our partners, such as social networks, may have the quality of independent data controller: we invite you to consult their Personal Data Charter.
2.How are your personal data collected and used?
We collect your personal data directly from you when you use the Site and our services or automatically when you access the Site.
We may collect and process personal data in the following categories:
Information you provide to us:
- Your identification data such as your first name, last name, title, nationality, date of birth, postal address, country of residence, e-mail address and telephone number;
- Your preferences and interests;
- Information entered via the “Contact Us” form;
- Banking data such as your payment details.
Automatically Collected Information:
- Connection data such as your IP address, terminal specifics and connection logs.
- We may also collect personal data about you indirectly from other sources, for example if your data is transmitted to us by one of your contacts or through one of our partners such as social networks (including your use of said networks and your related advertising identifiers).
- We may also collect your personal information when you participate in advertising campaigns with which we are associated, but primarily managed by a third party. If we receive additional information about you from a third party, we will take steps to ensure that you are aware of this collection of personal data and the circumstances surrounding it.
- Finally, we may also collect information that you provide to us about other people, for example, when you decide to purchase and send products to someone. In this context, you agree to inform these third parties of the content included in this Policy. We use such information only to respond to your requests and will not send marketing communications to your contacts unless they opt-in to receive communications from us.
3.Basis and purpose of processing your personal data
We collect and process your personal data where we have a lawful basis to do so:
Consent from you (Article 6 (1) (a) GDPR), in order to:
- Use a number of cookies.
- Send you information about our offers, news and events (newsletters, invitations and other publications) as well as offers, news and events concerning other entities of the Clarence Dillon Group either by e-mail, SMS, MMS, notifications, telephone or postal mail. If you receive such information from us and no longer wish to receive it, please contact us at [email address] and request to be removed from our mailing lists, or use the unsubscribe means indicated and/or included in our communications;
- Show you targeted ads and find others like you on social networks (by uploading and comparing your personal data – for example, your email address – with information you have provided on social networks) (for users in Germany, Poland and Japan, where consent is required);
- Personalize the content of the Site;
- Conducting satisfaction surveys (for users in Germany, Italy, Spain and Australia, where consent is required).
Performing a contract with you or pre-contractual measures taken at your request (Article 6 (1) (b) GDPR), in order to:
- Create an account on the Site and then manage it;
- Book a visit;
- Any other service, current or future, related to the services we provide and listed in the Terms and Conditions of Use.
Legitimate interests (Article 6 (1) (f) GDPR):
- To ensure the security of our Site and its users and compliance with the Terms and Conditions of Use.
- To improve our products and services and the relationship with our customers by sending you, following a transaction, information on our offers, news and events (newsletters, invitations and other publications) on similar products and/or services;
- To compile statistics and better understand your preferences and interests;
- To respond to your inquiries via the “Contact Us” form or other similar forms;
- Show you targeted advertisements and find other people like you on social networks, for users in countries where your consent is not required;
- Create your profile based on your information, order history and preferences;
- Conducting satisfaction surveys, subject to consent required under your country’s regulations;
- Detect and prevent fraud.
Fulfill our legal obligations (Article 6 (1) (c) GDPR), in order to:
- Handle any complaints, meet our legal obligations and ensure the defense of our interests in the event of litigation or legal action
When we ask you to provide personal data, we clearly indicate whether the information is mandatory or optional and the consequences of your refusal (for example, that we will not be able to process your request).
4.Recipients of personal data
In accordance with applicable law, we may share your personal data with :
- our affiliates, to provide you with relevant content and services
- our hosting providers;
- our support and marketing providers (customer service, ticketing service, e-mailing service, statistical analysis service);
- social networks;
- any authorities, courts or other authorized third parties, where the disclosure of personal data is required by law, regulation or court order, or where such disclosure is necessary for the protection and defense of our rights;
- all buyers in case of restructuring of SAS Domaine Clarence Dillon including the total or partial transfer of assets, merger, absorption, acquisition, split and more generally any reorganization operation.
The Site may contain links to other Internet sites for reference purposes only. Therefore, we are not responsible for the content, personal data processing or practices of third party websites. Please contact them directly for more information.
5.Transfers of personal data
We may transfer Personal Data to countries outside the European Economic Area (“EEA”), including to countries that have different data protection standards than those that apply in the EEA. Any transfer of your Data outside of the EEA will be subject to appropriate guarantees that comply with applicable data protection regulations. A copy of the applicable guarantees can be obtained upon request (by contacting us as set out below).
If you have any questions about transfers of personal data outside the European Economic Area, you can contact us at the address indicated below (section “Data Protection Officer (DPO) contact details”).
6.How long we keep your personal data
Your personal data are kept for the duration necessary to the purpose for which they were collected (see table below) unless you request their deletion to SAS Clarence Dillon (section ” Contact details of the Data Protection Officer (DPO) “), that you withdraw your consent or that there is a legal obligation to keep them for a longer period. It will be destroyed at the end of this period or within one month of any request for deletion.
The storage periods for data are listed in the table below.
|Data processing||Data storage period|
|Answering questions sent via the form “Contact us”||Duration of the treatment then three (3) years after the treatment.|
|Complaint management and compliance||Duration of the complaint plus five (5) years from its resolution.
In case of legal action: duration of the procedure until the full execution of the court decision or the settlement protocol.
|Sending information on the offers, news and events of SAS Domaine Clarence Dillon||Except unsubscription, three (3) years as from your last contact with SAS Domaine Clarence Dillon.|
|Displaying advertisements on your social networks and those of other people like you||three (3) years after your last contact with SAS Domaine Clarence Dillon|
|Security and integrity of the Site||three (3) to six (6) months depending on the security and integrity operations performed.|
|Prevention and detection of fraud||three (3) to six (6) months according to the investigations carried out and the duration of the legal procedures (if there are any).|
|Geolocation||No data storage.|
7.Modification to our Personal Data & Cookies Policy
We may change this Personal Data & Cookies Policy from time to time.
We encourage you to check this page regularly to ensure that you agree with any changes.
You will be notified of amendments either by a special notice on our Site (such as by updating the date at the top of this Policy) or by email notification. We may also seek your consent if necessary.
You have the right to access and rectify your data, as well as the right to request its suppression, to object to its processing and to obtain its limitation or portability within the limits specified by the law, subject to the imperative legitimate reasons that we could justify to keep your personal data.
In order to respond to your request, we may ask you to provide proof of identity. We may also ask you to provide additional information or proof. We will do our best to respond to your request as soon as possible.
You may at any time request to no longer receive communications from us regarding our offers, news and events by using the hyperlink provided for this purpose in each email sent to you or by sending a letter or email to the addresses below.
You also have the right to give us specific instructions regarding the disposition of your data after your death.
9.Protection of persons under the legal drinking age
As access to the Site is governed by the Site’s Terms and Conditions of Use, SAS Domaine Clarence Dillon does not collect any information or personal data relating to persons under the legal drinking and/or purchasing age according to the legislation in force in their place of residence.
10.Contact details of the Data Protection Officer (DPO) and right to lodge a complaint
In accordance with the law known as “Informatique et Libertés” (art. 34 of the law n° 48-87 of January 6, 1978), the user has the right to information, modification and erasure of personal data collected about him/her. To do this, the user should contact the person in charge of data processing who has been appointed and can be reached at
By e-mail to the following address [email protected]
By mail at the following address: Domaine Clarence Dillon 31, avenue Franklin Roosevelt 75008 PARIS
The modification will take place within one month from the receipt of the user’s request.
You also have the right to complain to the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, about the way we collect and process your Data.