Privacy policy & data management

At Borrelly Spring Washers, the protection of the personal data of our customers, Internet users and partners is of paramount importance. We are therefore committed to respecting the regulations in force concerning the protection of privacy and personal data and, in particular, Law No. 78-17 of January 6, 1978 relating to information technology, files and freedoms, as amended by Law No. 2018-493 of June 20, 2018, and the European Regulation 2016/679 of April 27, 2016 on the protection of personal data.

In order to provide you with the most complete and transparent information possible on our use of your personal data, we have drawn up this privacy policy. Its purpose is to :

– allow you to communicate your personal information in confidence and in full confidentiality when you enter into a relationship with Borrelly Spring Washers, by any means and in particular when you use the websites borrelly.fr, borrelly.com and borrelly.de (hereafter the “Site”),

– inform you of the purposes for which data collected by Borrelly Spring Washers is processed,

– inform you of the measures taken to ensure the confidentiality and security of your personal data,

– and in general, to inform you of your rights with regard to personal data.

 

a. Who are we?

Your personal data is processed by Borrelly Spring Washers, a simplified joint stock company, registered with the Lyon Trade and Companies Register, no. 493 425 029, located at 448 rue du Moron 69440 Saint Laurent d’Agny.

 

b. What is personal data?

Personal data is information that allows you to be identified, either directly or indirectly. It may include your name, your first name, your telephone number or your e-mail address.

 

c. When do we collect personal data?

When you come into contact with Borrelly Spring Washers, by whatever means, in particular when you visit and use the Site, you may be asked to communicate a certain amount of personal data about yourself.

 

You may be asked to provide personal information to

– create your personal account or connect to it,

– browse the Site,

– any form you fill in on the Site,

– any correspondence with us by telephone, e-mail, social networks, forum or any other means,

– report a problem or request assistance, contact customer service.

 

Following the creation of your account and subject to your consent, you may receive information and commercial offers from Borrelly Spring Washers by electronic communication (newsletters, email, sms …). These emailings allow you to be informed of Borrelly Spring Washers news and possible advantages you may benefit from. We measure the opening rate of our electronic mailings in order to adapt them to your needs.

Some of the personal data you may be asked to provide is mandatory. The mandatory nature of the data collected is indicated by an asterisk, the other data is optional. Failure to provide mandatory personal data will result in the impossibility of accessing all services offered by Borrelly Spring Washers.

 

d. For what purposes do we collect your personal data?

We collect and process various categories of personal data in order to manage our business as well as our contractual and commercial relations with our customers and partners.

 

The processing of your personal data is carried out in particular for the following purposes

  • Contract management (management of orders, delivery, invoices and payments);
  • The management of after-sales service claims and guarantees attached to our products;
  • The management and follow-up of requests from prospective customers;
  • Sending commercial communications of a professional nature by post, telephone or email, with your consent;
  • The management of the satisfaction surveys that we offer you;
  • To comply with our legal and regulatory obligations and in particular to manage our accounts.
  • We may use data to better understand our customers or for statistical purposes to analyse the activity of the Site and improve the services we offer.

 

e. On what basis do we collect your data?

The legal bases on which we process personal data include processing that :

  • are necessary for the performance of the contract between you and Borrelly Spring Washers (management of orders, delivery, invoices and payments) ;
  • are necessary to comply with the legal and regulatory obligations imposed on Borrelly Spring Washers such as social and fiscal declarations and accounting obligations;
  • are necessary to respect our legitimate interests such as the development of Borrelly Spring Washers’ activities, the improvement of services, the search for new services, the administration, maintenance and improvement of the Site, the fight against fraud, the management of your customer account;
  • are based on the consent of our customers, which consent can then be withdrawn at any time for the purposes of, among other things, communicating with you about our services and providing you with information about our services.

In the interests of transparency, we have listed below the legal bases associated with each of our processing purposes:

  • Contract management: Contract.
  • Management of after-sales service claims and guarantees: Contract; Legitimate interest of our company to be able to establish proof of a right or contract.
  • Sending commercial communications: Consent.
  • Management and follow-up of requests from prospective customers: Consent
  • The management of satisfaction surveys that we offer you: Legitimate interest of our company; Consent.
  • Keeping the general accounts and auxiliary accounts as well as carrying out the related formalities: Legal and regulatory obligations.

 

f.  What categories of personal data do we collect?

In order to meet the purposes of the above-mentioned processing, we collect in particular:

Identification data:

  • your first and last name ;
  • your company and your function;
  • your postal address
  • your e-mail address;
  • your telephone number.

Connection / usage data:

  • IP address,
  • browsing history,
  • visit route,
  • operating system,
  • information on the devices from which you visit the Site.

 

g. Who has access to your personal data?

Your personal data will only be passed on within our departments to persons who are authorised to process it by virtue of their position. In order to carry out the management of your orders, we may transmit them to other service providers of Borrelly Spring Washers.

Your personal data may also be passed on to certain entities, namely

  • service providers, in particular those who perform certain services on our behalf, namely
  • our hosting provider: Mayflower
  • our delivery service provider: Cetup, DHL, Fedex, Kuehne Nagel, Rohlig, TNT
  • judicial and legal officers in the context of their mission to manage disputes and collect debts: in the event of a dispute, we may share your personal data to defend our rights;
  • the authorities for social and tax declarations in particular.

We reserve the right to disclose your personal data to other parties in cases where the law, a regulatory provision in force, a court order or a regulation requires or authorises it, or if this disclosure is necessary in the context of an investigation, or a procedure, on national territory or abroad.

In addition to the purposes listed above, we may disclose non-personal information to third parties, such as aggregated statistical data.

 

h. How long is your personal data kept?

Your personal data is kept for the period of time necessary to fulfil the purposes of the processing carried out.

Thus, the duration of the storage of your data corresponds to the duration of the commercial relationship between us.

This period may be increased by three years from the end of our business relationship for data that we use in the context of the performance of a contract.

This period may be increased by three years from the last contact we have had with you for data used for marketing purposes and data from prospective customers, except in the case of a withdrawal of your consent which implies that we do not retain your data after notification of such withdrawal.

After this period, we will either delete or anonymise your personal data.

In the event that we are required to keep track of some of your information by virtue of a legal obligation to which we may be subject or in order to prevent litigation, we may archive some of your data for legal prescription periods in accordance with the provisions of the Civil Code and the Commercial Code (e.g. 5 years in commercial matters or 10 years in accounting matters), before their definitive deletion or anonymisation. In this case, your data is stored in a separate database with secure access limited to strictly authorised personnel.

 

i. How is your personal information protected?

Borrelly Spring Washers is committed to ensuring the security of the data you provide. In order to prevent unauthorised access, use, modification, destruction, loss, damage or disclosure, appropriate technical and organisational measures have been taken to protect the data collected.

In particular, the security of your data is ensured

thanks to a protection by identifier and password ;
through traceability measures, by keeping the computers and servers used to store personally identifiable data in a secure environment
by limiting access to your data to authorised persons only.
To assist in this process of protecting your data, it is recommended that you avoid using an overly obvious login or password, as well as changing your password regularly and ensuring that you do not share your password with anyone.

Unfortunately, the transmission of information, especially over the Internet, is not completely secure. Although Borrelly Spring Washers is committed to doing everything in its power to protect your personal information, Borrelly Spring Washers cannot fully guarantee the security of any information you transmit to us.

In the event of a breach of your personal data that poses a risk to the rights and freedoms of data subjects, please be aware that Borrelly Spring Washers is obliged to notify the relevant supervisory authority and to inform you, as soon as possible, of any personal data breach that is likely to result in a high risk to your rights and freedoms, so that you can take appropriate action.

 

j. What rights do you have with respect to your personal data?

In accordance with the applicable regulations, you have the right to access, rectify and delete your personal data. You may also exercise your right to portability in order to obtain your personal data in a structured, usable and machine-readable format, so that it can be transmitted to a third party, if your request is eligible.

In addition, you have the right to request the restriction of the processing of your personal data as well as the right to object to their processing. In particular, you may object at any time and without giving any reason to our use of your personal data for sending commercial communications.

You also have the right to define specific or general directives concerning the post-mortem fate of your personal data, which may be registered with the data controller or a trusted third party certified by the CNIL.

In the event that you believe that your rights are not respected with regard to the protection of your data or that an action relating to the conditions of processing of your personal data is incompatible with the provisions of this policy or the applicable regulations, you may directly file a complaint with the CNIL.

You can contact us directly or exercise the rights referred to in the previous paragraph via the following email address: contact@borrelly.com

In order to enable Borrelly Spring Washers to respond quickly, please provide your full name, e-mail address and if possible your customer reference. Certain requests to exercise your rights (right of access) must be accompanied by a photocopy of an identity document bearing your signature in order to verify your identity and specify the address to which the reply should be sent.

A reply will then be sent to you, except in special cases, within one (1) month of receipt of the request.

 

k. Is your data transferred outside the European Union?

 

As a matter of principle, the personal data collected is not intended to be transferred outside the European Union. This personal data is hosted on a server located in the European Union.

However, in the event that Borrelly Spring Washers and/or its subsequent subcontractors are required to process personal data outside the European Union in connection with the provision of services, Borrelly Spring Washers will in any event take all necessary measures and guarantees to secure such transfers prior to the said transfer and undertakes to ensure that the transfer is covered either by :

  • an adequacy decision of the European Commission in accordance with Article 45 of the European Data Protection Regulation,
  • standard contractual clauses issued by the European Commission or a Supervisory Authority in accordance with Article 46 of the EU Data Protection Regulation
  • binding corporate rules approved by a competent Supervisory Authority under Article 47 of the EU Data Protection Regulation.

Should a transfer of data to countries not recognised by the European Commission as having an adequate level of protection be contemplated, Borrelly Spring Washers will inform you.

 

l. Cookie Management 

Cookies are small files stored on your device (computer, tablet, phone) that collect various data to enable exchanges with our system via your Internet browser.

Cookies allow us to facilitate your navigation (for example by pre-filling your login information), to improve the security of data processing and to offer a better user experience.

When you visit the Site, a banner informs you of the presence of cookies and their purpose, and invites you to indicate your choice. If you object to the use of these cookies and other cookies, you can disable them by following the instructions in the link in the “Personalise” banner.

In addition, you can at any time obtain clear and explicit information on the purposes for which cookies are used, information on how to object to the use of cookies and how to manage the use of each of these cookies, by clicking on the link in the said banner.
We draw your attention to the fact that refusing cookies may prevent you from accessing certain features of the Site. You can set your browser to allow you to accept cookies (see your browser’s help file for instructions).

Like most websites, the Site uses cookies which can be classified into several categories:

Type of cookie :

Strictly necessary – Maximum retention time 8H

These cookies are essential to enable you to browse our Website and use its features. The information collected by these cookies is related to the operation of our Site, for example, the Site’s scripting language and security tokens that help ensure the security of areas of our Site.

Performance/Analytics – Retention period 13 months

These cookies collect anonymous information about your use of our Site, for example, which pages you visit most often, whether you receive error messages and how you arrived at our Website. The information collected by these cookies is used only to enhance your use of our Site and never to identify you. Sometimes these cookies are placed by third party web traffic analysis service providers, such as Google Analytics.

Features – Retention period 13 months

These cookies remember the choices you make, for example, the country from which you visit our Site, your language, and any changes you make to the size of text or other parts of the web pages that you can personalise, in order to improve your experience on our Site and to make your visit more personal and user-friendly. The information these cookies collect may be anonymised and cannot be used to track your browsing activities on other websites.

Personalisation cookie – Retention period 13 months

These cookies allow the user to access the service with predefined characteristics on their terminal or defined by the user. For example, the language, the type of browser used to access the service, or the content display mode selected.

 

m. Changes to the Privacy Policy

Borrelly Spring Washers reserves the right to modify or otherwise update this Privacy Policy at any time without notice. Any material changes will be posted on the Site and/or, if applicable, by email. Please check this page regularly for changes to the Privacy Policy.

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