Version dated 23 December 2020.
For the purpose of this notice the words “we”/“us”/“our” are in reference to the data controllers defined below.
We are committed to safeguarding your privacy. This notice sets out how we will treat your personal data.
What information do we collect?
When you use Clos19 website and our services, we collect personal data directly from you or automatically.
We may process the following categories of personal data:
- Personal data collected directly from you:
- Identification data such as your first name, last name, gender, title, date of birth, postal address, delivery information, email address and phone number.
- Data regarding your consumption habits (such as your order history) and your preferences and interests.
- Content of the video you create (as the case may be).
- Banking data such as payment details or credit card number (for those who have a Clos19 account only).
- Information you may disclose when you contact us.
- Personal data automatically collected:
- Login data such as your IP address, your terminal specificities and your logs.
Personal data is collected directly from you, except when you are a gift recipient in which case source of collection of your personal data is the gift purchaser. In such case, the following information is collected indirectly: first name, last name, email address and delivery address. We may also collect indirectly from our social media partners the fact that you are using their social networks and your associated advertising identifiers.
If you provide us with personal data from third parties you confirm that you are authorized to do so. We will use this information only for the purpose of providing or fulfilling the respective service.
What about cookies?
For more information regarding cookies, please read our Cookies Notice.
How do you use my personal data?
We collect and process your personal data for the purposes listed below.
Based on your prior consent (legal basis: art. 6 (1) (a) GDPR):
- Use of certain types of cookies.
- Send you updates, newsletters and other special offers from Clos19 (unless we rely on derogations).
In order to perform a contract with you or in order to take steps at your request prior to entering into a contract (legal basis: art. 6 (1) (b) GDPR):
- Create an account on Clos19 website.
- Handle orders, deliver products, experiences and services such as video recording and sharing service, process payments and communicate with you about your orders.
In order to comply with our legal obligations (legal basis: art. 6 (1) (c) GDPR):
- Processing in connection with legal claims and compliance purposes (including disclosure of such information in connection with legal processes or litigation).
Based on our legitimate interests (legal basis: art. 6 (1) (f) GDPR), which are not overridden by your data protection rights, to:
- Ensure the security and integrity of Clos19 website and its users, and the compliance with our Terms & Conditions.
- Improve our products and services and the client relationship.
- Communicate with you via “Contact Us”.
- Produce general statistics and understand your preferences better.
- Run satisfaction surveys.
- Show you targeted advertisements and find other people like you within your social media networks (by uploading and matching your personal data - e.g. email address - you have provided to us with information you have supplied to the social media platform).
- Detect and prevent frauds.
When we ask you to supply us with personal data we will make it clear where there is a statutory or contractual (mandatory) requirement to provide personal data and the consequences of not providing the data (for example, that we will not be able to process your order).
Recipients of personal data
In accordance with law, we may share your personal data with:
- Our affiliates, to provide you with relevant content and services.
- Our processors providing us with hosting services.
- Our payment services providers.
- Our processors providing us with support and other marketing services (such as: emailing tools, video recording and sharing platform, customer care, ticketing services, statistical analysis services).
- Social networks (e.g. Facebook).
- Our processors providing us with logistic services.
- Travel related agencies.
- Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation, alleged or suspected illegal activity or any other activity that may expose us, you, or any of our other users to legal liability.
- The purchaser, or prospective purchaser, of any business or asset which we are, or are contemplating, selling.
- And their sub-processors.
The website may contain links to other websites for reference purposes only. We are not responsible for the content, privacy notices or practices of third party websites in these circumstances. Please contact them directly for more information.
We may transfer personal data to countries outside the European Economic Area ("EEA"), including to countries which have different data protection standards to those which apply in the EEA. In application of art. 46.2(c) of the GDPR, we have put in place European Commission approved standard contractual clauses to protect this data. You have a right to ask us for a copy of these clauses (by contacting us as set out below).
When we transfer your personal data to the U.S., we put in place appropriate guarantees that comply with applicable regulations relating to the protection of personal data.
For any questions regarding data transfers outside the European Economic Area, you can contacts us at the address set out below (“Controllers of personal data and questions” section).
Data retention periods are listed in the table below.
Please note however that appropriate data related to subscription of current services will be deleted one (1) month after you have notified us that you want to unsubscribe to such services.
|Data processing||Data retention period|
|Creation and management of your account on Clos19 website||Deletion after 3 years of inactivity|
|Handling of orders and delivery of products, experiences and services||10 years in archived after the validation of the order|
|Video recording and sharing||2 years from the date of collection|
|Online payment processing||Relevant banking data is accessible to us until transaction is completed. |
If you choose to save your credit or debit card details for future orders, these card details will be kept until expiration of the card (unless your consent is withdrawn at any time)
|Communication with you via contact form||Duration of the request resolution, then archived during 3 years starting from the resolve of the request|
|Legal claims management and compliance purposes||Duration of the claim and 5 years from the date of the resolution. If legal action : duration of the procedure until full execution of the Court decision or settlement agreement|
|Sending of updates, newsletters and other special offers from Clos19||3 years after the last contact from you|
|Show advertisements on your social network newsfeed and to other people like you||3 years after the last contact from you|
|Security and integrity of Clos19 website||Duration of security and integrity processes which may vary according to the operations carried out (3 to 6 months)|
|Fraud detection and prevention||Duration of the investigation (3 to 6 months) and then duration of the legal proceedings (if so)|
We may update this notice from time-to-time by posting a new version on our website.
You should check this page occasionally to ensure you are happy with any changes. We may also notify you of changes to our notice by email.
Under the GDPR you may have different data subject rights (art. 15-18 and 20-21 GDPR). You may ask us for a copy of your information, to correct it, erase it or to transfer it to other organisations at your request. You also have rights to establish instructions for the management of your data after death, to object to some processing and, where we have asked for your consent to process your data, to withdraw this consent. In particular, you have rights to object to direct marketing at any time. Where we process your data because we have a legitimate interest in doing so (as explained above), you also have a right to object to this. These rights may be limited in some situations (for example, where we can demonstrate that we have a legal requirement to process your data).
In order to respond to your request we may need to ask you to provide proof of identity or additional information. We will endeavour to respond your request as soon as possible.
We hope that we can satisfy queries you may have about the way we process your data. However, in application art. 77 of the GDPR, if you have unresolved concerns you also have the right to complain to data protection authorities.
Should you have any questions about this notice or our processing of your personal data, please write to us at the address set out below (“Controllers of personal data and questions” section).
Are children allowed to use our website?
We do not sell products or services for purchase by children. When placing an order you confirm you are aged 18 or over.
Updating information about myself
Please let us know if the personal data which we hold about you needs to be rectified or updated by contacting us as set out below (“Controllers of personal data and questions” section).
Controllers of personal data and questions
The data controllers are:
- Moët Hennessy UK Ltd, registered in England with company number 371236 and whose registered office is at 18 Grosvenor Gardens, London SW1W 0DH; and
- Moët Hennessy SAS registered in France with company number 338 228 414 RCS Paris and whose registered office is at 24-32 rue Jean Goujon, 75 008 Paris.
Should you have any questions about this notice or our treatment of your personal data, please:
- write to us at “Moët Hennessy UK Ltd, Clos19, 18 Grosvenor Gardens, London, SW1W 0DH”; or
- send us an email at: firstname.lastname@example.org.