DATA PROTECTION POLICY

WHO IS THE OWNER OF YOUR DATA?

As BIGBEN is the processing officer and publisher, it is the final Owner of the data processed and collected on the Site.

WHO PROCESSES YOUR DATA?

BIGBEN processes the data collected from the Customer since Bigben Lumin’US is a Bigben trademark. GAMES.FR, a company of the Bigben group, is responsible for the processing of orders placed on the website.

BIGEN is responsible for the processing of the Customer’s personal data in relation to the products and services offered on the Site. GAMES.FR uses the Customer’s personal data solely for the processing of orders.

THE PURPOSES FOR WHICH WE COLLECt AND PROCESS OUR CUSTOMERS’ DATA

In particular, the purposes for which we collect and process your data are:

management of customer relations;

optimization of the user’s experience;

satisfaction of our customer’s requests.

With respect to management of customer relations, we process your data to:

create a customer account;

enable you to have the benefit of services offered on the Site, and order products and services; monitor your orders and their billing; subscribe to newsletters, etc.;

receive your comments and opinions;

manage your consents and authorizations to use your personal data, for the sending of newsletters and commercial offers by electronic means;

manage the risk of fraudulent use of your data or services to which you have access via the Site, to enable us to take any necessary measures for the security of your data and our information systems that are used for the provision of products and services offered on the Site;

manage your requests related to the exercise of your rights in your personal data, particularly the right of access, rectification and opposition granted to you by virtue of the regulation regarding personal data;

  • manage any possible disputes, particularly those related to collection of payments you may owe us, and the management of defaults in payment;
  • manage the communications and monitoring of our exchanges, particularly in the context of disputes;
  • enable BIGBEN to provide proof of its compliance with legal or regulatory obligations, or for the management of litigation (e.g. proof related to your orders);
  • comply with the legal or regulatory obligations applicable to our Site’s activities, particularly those imposed by the public authorities;
  • manage product recalls initiated by suppliers.

With respect to commercial prospecting, we may use your data to carry out the following services, in compliance with the authorizations granted:

  • sending of promotion and advertising messages by post or electronic means, as well as by notification on mobile phones, depending on your profile;
  • analysis of your use of services (particularly your online surfing and your reactions to emails), in order to (to be completed) (e.g. Get to know the customer better: his interest in the services offered …Vis-à-vis the messages we send him …Make proposals that offer contents and services adapted to his profile);
  • For commercial prospecting related to customer profiling – refer to the confidentiality policy.

These analyses are conducted in compliance with the authorizations granted, particularly for the use of cookies or other tracers.

With respect to the carrying out of technical operations regarding the processing of your personal data:

the attribution of a digital identifier related to your data, to enable us to interact with you on various digital communication media, whether on websites, social networks or mobile applications;

  • the technical operations for the detection of abnormality and the security of our information systems on which your data are processed, and for organizational or cybersecurity purposes.

Your data collected in the context of services accessible via the Site may be processed with the merging of your data collected via the services offered by other entities of the BIGBEN Group or, possibly, their partners.

  • your identification data, your contact data, including your electronic data;
  • your purchasing data, the opinions you issue;
  • your customer profiles and your areas of interest.

The browsing data on the BIGBEN Group’s sites and mobile applications or sites and applications published by entities outside of the BIGBEN Group (e.g. sites visited, page views, or advertising banners addressed and/or clicked), with the help of the cookies technology and other tracers stored by BIGBEN or third parties, in compliance with the authorizations you may have granted.

Do we share data?

The sharing and merging of your data are for very specific purposes, namely:

  • facilitate your access to the services you have subscribed with various entities of the BIGBEN Group: for instance, spare you the trouble of entering, for each new account on a BIGBEN site, your surname, given names, email address or other standard data; or enable you to surf from a BIGEN site to another site without a need to enter your logins and password again;
  • Such services may be subject to specific conditions that require your agreement, as they are offered to you;
  • enable us to know you better in your relations with the various entities of the BIGBEN Group; analyze and build your profile, so we can send you personalized contents and commercial and advertising offers.

THE PROCESSING OF YOUR PERSONAL DATA

Your data may be processed for any of the following reasons:

  • to provide the services offered by the Site;
  • to enable us to communicate with you regarding our offers and products or those of third party advertisers.

COLLECTION OF DATA

The data collected in the context of services offered on the Site derive from:

  • your subscription to our newsletter, and the creation of your account;
  • the use of services offered on the Bigben Lumin’US.eu Site (purchases, newsletters, games, contests, and any collection of data at a particular time that may be developed);
  • sites and mobile applications published by entities outside of the BIGBEN Group: information related to surfing or the advertising that is sent to you;
  • social networks such as Instagram, Facebook, Ptinterest, …

Except for data derived from open data, the other data are not accessible to the public.

Data may be collected directly from you, via the use of services offered by the Site, or from other entities of the BIGBEN Group or our possible partners or third parties.

The collection of data is necessary to enable the Site, BIGBEN and our service providers and/or partners to provide the services offered by or via the Site, to enable us to know you better and facilitate your relation with BIGGEN, or to enable us or our partners to send you contents adapted to your profile and areas of interest.

THE ENTITIES AND PERSONS THAT MAY ACCESS YOUR DATA

To enable us to meet the aforesaid objectives, your data may be transmitted to the following addressees:

  • The authorized persons at the BIGBEN departments:
    • marketing department
    • digital customer department
    • legal department
    • accounting department
    • computer department
    • logistics department
    • The service providers and subcontractors that participate in the supply of services, such as:

the advertising management, advertisers or brand partners, to define the conditions for access to data by these third parties (use of these data at a particular time for a specific period without other entities having the right to use them for commercial activities other than for our account)The service providers and subcontractors of companies of the BIGBEN Group.

The administrative or judicial authorities in accordance with the applicable laws and regulations.

DURATION OF RETENTION OF DATA

Your collected data are retained for a period that is necessary for us to accomplish the aforesaid objectives, increased by the time prescribed by law.

Your data collected during your subscription are retained throughout the period of your membership. Thereafter, they may be retained and processed for 3 years following your most recent contact, to enable us to send you commercial offers.

Your data may be retained for a longer period of time if such is required by law or with regard to the applicable legal period of prescription.

DATA SECURITY POLICY

BIGBEN and the companies of the BIGBEN Group take into account the nature of personal data and the risks in the processing thereof, in the implementation of technical, physical and organizational measures that are appropriate to preserve the security and confidentiality of personal data and prevent the distortion or damage thereof, and the access thereto by unauthorized third parties.

BIGBEN and the companies of the Group select their subcontractors and service providers according to their ability to guarantee a sufficient and optimum level of quality, security and resources (processing security, technical measures, etc.).

LOCATION OF YOUR DATA PROCESSING

Your data collected and processed in the context of services offered by the Site may be transmitted to service providers located in countries outside of the EU, such as companies engaged in automated transmission of notifications via the Bigben Lumin’US application, even in the context of computer services or exploitation of data in liaison with social networks.

YOUR RIGHTS

In accordance with the regulation regarding protection of personal data, you have the right to access, question, rectify or delete your data (unless they are necessary for execution of our contract, for our compliance with the legal requirements, or for the assertion or exercise of our rights), as well as the right to give instructions regarding the disposition of your data after your death.

If we have a procedure implemented for partial or total withdrawal: mention it here.

To exercise your rights, you simply need to send a letter by post to: BIGBEN, Customer Relations Department / Rights regarding personal data, 396 rue de la voyette, CRT2 FRETIN, 59814 LESQUIN CEDEX, France, or contact it by mail at privacy@bigben.fr, indicating your surname, given name, email, address and, if possible, your customer reference.

You may also exercise your rights at this internet address: privacy@bigben.fr

In accordance with the applicable regulation, your request must be signed and accompanied by a photocopy of an identity card bearing your signature and indicating the address to which the response must be sent. You will receive a response as soon as possible.

If we are unable to respond to your requests in a satisfactory way, you may also file a complaint with a supervisory authority (in France the CNIL 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07. Tel : 01 53 73 22 22).