Cromology” (representing individually and collectively the companies Cromology SAS, Cromology Services SAS, Couleurs de Tollens SAS, Zolpan Services SAS and Zolpan SAS) pays close attention to the protection of the personal data of users of its websites and/or mobile applications (hereinafter collectively referred to as the “Site”) and the clients of its shops trading under the names Tollens and Zolpan (hereinafter referred to as a/the “User(s)”). Cromology undertakes to ensure the highest level of protection for this data in accordance with the provisions of the French law no. 78-17 of 6 January 1978 relating to Data Processing, Files and Individual Liberties (the “Data Protection Act”) and the European Regulation 2016/79 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 (the “GDPR”).

This Charter informs you of the way in which your personal data may be collected, stored, used and processed by Cromology, in its capacity of data controller.

By using the Site, placing orders, making purchases in shops belonging to our Tollens, Zolpan and Districolor networks (hereinafter referred to as the “Shops”), contacting our Customer Service department, placing yourself on our list of prospective clients or applying for a job with Cromology, you acknowledge and declare that you have read and accepted the present rules governing the processing of your data and accordingly agree to its collection, storage, use and processing by Cromology under the conditions set out hereinafter.

These rules apply whenever we transmit your personal data and whenever we process it.

TYPE OF DATA COLLECTED BY CROMOLOGY

In the context of recruitment

In general, information and personal data concerning you that Cromology collects and processes are proportionate to the situation and to the job profile and limited to the personal data necessary to evaluate whether your job skills match the profiles of vacant posts.

To apply to an open position at Cromology, you fill out a form in which certain data is mandatory, and other data is optional.

The mandatory data may include:

  • Identification / Civil Status data: surname, first name, email address, gender (diversity-related question)
  • Personal life Data: geographical mobility
  • Professional career Data: targeted position for non-specific applications, previous experience (position and date), training

The optional data may include:

  • Identification / civil status: photo, postal address, phone number(s),
  • Professional career Data: salary expectation, availability, education, training, exam distinctions, diplomas, professional experience, skills, professional qualities
  • The data contained in the documents that you may enclose with your application: curriculum vitae, cover letter.

Under no circumstances will Cromology seek, collect or process any data that is considered ‘sensitive’ (racial origin, ethnicity, political, philosophical or religious opinions, health or sexual preferences) in order to fill a vacant post within the Cromology Group, unless the law of a country obliges it to do so. In this case, you will be informed of this and must give your express agreement.

In the context of the creation of a user account, the placing and follow-up of an order, the processing of a request and/or question and saving a simulation project via the Cromology Application

The data collected by Cromology is as follows:

  • Surnames, first names, phone number, postal address, email address and preferred Shop are the data collected in order to create a user account, which will enable the User to place orders online or in-store, and with their agreement, be kept informed of news concerning Cromology and the brand of the Site or Shop concerned and benefit from any promotional offers that our products may be the subject of. At any time, the User may request that no more commercial communications be sent to them by the Cromology Group, by clicking on the hyperlink present in each email sent to them by the latter at the email address that they provided when they created their account.
  • Names, first names, client account number, email address, postal address and phone number are the data collected in the context of any request for information and/or contact sent by the User to the Cromology Group via the form dedicated to that purpose and which enables the latter to reply to them.
  • Email address and postcode, which will enable the simulation project proposed by the Cromology Application to be saved.

PURPOSES OF THE PROCESSING CARRIED OUT BY CROMOLOGY

In its capacity of data controller, Cromology undertakes to comply with the two following principles:

  • You are the sole owner of your data that we collect and process in relation to you,
  • Your personal data is processed in a transparent, confidential and secure manner.

In the context of recruitment

Cromology collects, stores, uses and processes the personal data that you enter in the context of the management of its recruitment process and its CV library, and for you to be immediately informed of new opportunities if you have created an alert.

This same data may also be processed, in an anonymous form, for the purpose of reporting and statistical analyses, to evaluate in particular the frequency of visits to our Site and the recruitment cycle.

In the context of the creation of a user account, the placing and follow-up of an order, the processing of a request and/or question and saving a simulation project via the Cromology Application.

Cromology may also be led to process your personal data for the following purposes:

  • management of the creation and maintenance of the user account;
  • processing and fulfilling orders that you have placed on the Site, by phone or in the Shops, including the management of your payments;
  • handling and resolving all your claims or questions relating to orders that you have placed or future orders, your user account or our brands;
  • monitoring, developing and improving the Site and your use of the Site;
  • analysing your behaviour on the Site or in the Shops and your reactions to our marketing campaigns, in order to improve or personalise the products and services that we offer to you;
  • sending you information and commercial offers, concerning existing or new products and services related to Cromology’s brands;
  • offering you a personalised service and offers, by email, phone, on the Site or in a Shop;
  • offering you a service enabling you to save your simulation project via the Cromology Application.

If fields marked by an asterisk are not fully filled in by the User, their request cannot be processed.

RECIPIENTS OF YOUR PERSONAL DATA

In general, your personal data may also be communicated to service providers that Cromology works with. These service providers will have access to your data only to the extent strictly necessary for their missions, and undertake not to use your data for an objective other than that requested by Cromology in accordance with the present processing rules for your data. The latter will act solely in the capacity of subcontractors of Cromology and will not under any circumstances share this information with third parties or use it for other purposes.

You may object to this by exercising your rights described hereinafter. In this case, access to our services will be compromised.

Your data may be sent to public institutions or public authorities solely if the law requires this.

In the context of recruitment

In all cases, the recruitment process will be handled jointly by the Human Resources department, Recruitment Managers and the Managers of the departments in which there are vacant posts.

The latter Managers and the Recruiters may belong to different entities of the Cromology Group; your data may accordingly be transferred and used within the Cromology Group in Europe, but also worldwide, as the case may be.

The management system for our recruitment process and CV library is hosted within the European Union. Persons residing outside the European Union are informed that the processing of data linked to this hosting will be carried out in accordance with the French and European regulations.

In the context of the creation of a user account, the placing and follow-up of orders, the processing of a request and/or question and saving a simulation project via the Cromology Application.

Users’ data collected via the Site in the context of the creation of a user account or via the contact form, or via the Cromology Application is destined exclusively for Cromology’s sales and marketing departments.

Subject to their agreement, Users’ data may be transmitted to commercial partners of Cromology.

TRANSFER OF YOUR PERSONAL DATA

Cromology is a multinational. Our clients and activities are based worldwide. The collection and transfer of personal data by us therefore takes place at global level. We may therefore be led to transfer your personal data outside your country of residence.

In the case of the transfer of your personal data to a country located outside the EEA, we will take care to ensure that your data is protected and transferred in accordance with the legal requirements.

With regard to data transferred outside Europe, for example, this protection will be implemented by at least one of the following means:

  • the country to which we send your data has been approved by the European Commission as ensuring an adequate level of personal data protection;
  • the recipient has signed a contract incorporating “standard contractual clauses” which have been approved by the European Commission and impose an obligation to protect your personal data;
  • if the recipient is located in the United States, they may be certified under the EU-US Privacy Shield; or
  • in other cases, the law may authorise us to transfer your personal data outside Europe in another manner.

To obtain more information concerning the manner in which your personal data is protected in the case of its transfer outside Europe (and in particular a copy of the standard contractual clauses set in place with the recipients of your personal data), please contact us using the contact information provided in paragraph 9 hereinafter.

SECURITY OF YOUR PERSONAL DATA BY CROMOLOGY

We implement technical means and security measures to ensure the protection of your personal data and prevent its destruction, loss or alteration, unauthorised access or disclosure, and modification, whether by accident or as a result of illegal conduct.

Different protection is applied to client files depending on the sensitivity of the information that they contain. Adequate controls (e.g. restricted access) have been set in place on our computer systems. Only our authorised employees can access the premises used to collect, process or store personal data.

At the time of hiring, our employees undertake to comply with all the laws and regulations applicable, and in particular legislation concerning data protection. Access to sensitive personal data is limited to employees who need to have knowledge of it in order to perform their duties. Any unauthorised use or communication of Cromology’s confidential information by an employee is strictly prohibited and renders them liable to disciplinary sanctions.

In the context of recruitment, the transfer of data between your local browser and our online recruitment system is encrypted using the https protocol.

PERIOD OF STORAGE OF YOUR PERSONAL DATA BY CROMOLOGY

In the context of recruitment

We retain your personal data used in the context of our recruitment process and our CV library for the period necessary for the management of your candidature and within the limits provided for by the law if this permits a longer retention period.

In all cases the maximum period during which we will keep your personal data in order to enable us to recontact you and propose other posts that might be of interest to you will be two (2) years as from our last letter/email of reply.

Log data will be kept for a maximum period of one (1) year.

In the context of the creation of a user account, the placing and follow-up of orders, the processing of a request and/or question and saving a simulation project via the Cromology Application.

Once an online order has been placed, the client User’s data is archived for a period of five (5) years in the framework of a separate information system with restricted access, increased by the duration of any dispute/litigation procedure which may be initiated, where applicable. At the end of this timeframe, it is definitively deleted.

With regard to banking data in the context of online payment, the credit or debit card’s number and expiry date is subject to a retention period of fifteen (15) months following the date of the debit, and the security code of the card will be kept solely for the duration of the transaction.

However, the data of client Users used for the purpose of sales prospecting is kept for a period of three (3) years as from the last online purchase or the last contact emanating from the client User.

With regard to the data of prospective client Users, it is kept for a period of three (3) years as from the date of its collection by the Cromology Group via the account creation form or the last contact emanating from the prospective client User.

With regard to data collected in the context of the Cromology Application, it is kept for a period of three (3) years as from the date of its collection by Cromology.

With regard to User data collected via the contact form, it is deleted as soon as the request made by the User has been processed and an appropriate reply has been given to the User by Cromology.

THE RIGHTS HELD BY YOU WITH RESPECT TO YOUR PERSONAL DATA

In accordance with the European Regulation 2016/679 (GDPR) and the French “Information Technology and Civil Liberties” law of 6 January 1978, as amended, you benefit from a right to access personal information concerning you, in order to complete it, modify it, correct, remove it or oppose it for legitimate reasons to its processing.

All requests must:

  • include the surname, first name and email address of the User who is exercising their rights;
  • be signed;
  • specify the exact address to which confirmation that their request has been taken into account should be sent.

In principle, a reply will be sent to the User within a maximum timeframe of two (2) months following receipt of the request by Cromology.

For the part devoted to recruitment and the recruitment system and also that devoted to saving simulation projects via the Cromology Application.

The Site https://www.cromology.com via the site https://careers.smartrecruiters.com/Cromology/ and also via the forms to apply for different job opportunities within the Cromology Group or submit a spontaneous candidature and the mobile application “the Cromology Application” are under the responsibility of Cromology SAS, a French simplified joint stock company whose registered office is at 71, Boulevard du General Leclerc – 92110 Clichy, and which is registered in the Nanterre Trade and Companies Register under the number 434 266 722; Phone: +33 (0)1 41 27 62 00

In order to exercise this right, please send us proof of your identity and the subject of your request to the following address:

  • by email: info@cromology.com
  • by post: for the attention of Service Recrutement Cromology, 71 Boulevard du Général Leclerc, 92110 Clichy

For the part devoted to the creation of a user account, the placing and follow-up of orders, and the processing of a request and/or question

The Sites https://www.tollens.com/ and https://www.plasdox.com/ are under the responsibility of Cromology Services SAS, a French simplified joint stock company whose registered office is at 71, Boulevard du General Leclerc – 92110 Clichy, and which is registered in the Nanterre Trade and Companies Register under the number 592 028 294;

The Site https://www.zolpan.fr/ is under the responsibility of Zolpan Services SAS, a French simplified joint stock company whose registered office is at 17, Quai Joseph Gillet – 69004 Lyon, and which is registered in the Lyon Trade and Companies Register under the number 972 503 387;

The Site https://my.tollens.com/ and the Tollens Shops are under the responsibility of Couleurs de Tollens SAS, a French simplified joint stock company whose registered office is at 71, Boulevard du General Leclerc – 92110 Clichy, and which is registered in the Nanterre Trade and Companies Register under the number 306 289 307;

The Sites https://eboutique.zolpan.fr/ and https://www.districolor.fr/ and the Zolpan and Districolor Shops are under the responsibility of Zolpan SAS, a French simplified joint stock company whose registered office is at 17, Quai Joseph Gillet – 69004 Lyon, and which is registered in the Lyon Trade and Companies Register under the number 301 621 884

In order to exercise this right, please send us proof of your identity and the subject of your request to the following address:

  • by email: données.personnelles@cromology.com
  • by post: for the attention of Data Manager, Cromology, 71 Boulevard du Général Leclerc, 92110 Clichy

LINKS TO OTHER SITES

The fact that we enable you to access other websites via hyperlinks does not make us responsible for these sites’ practices concerning personal data.

COOKIES POLICY

What is a cookie?

A cookie is a small file (alphanumeric identifier) that is placed on your terminal (computer, tablet or mobile device)

containing information about the user of the site. It notably enables a link to be established between a device and other information about your utilisation of our services (such as the location, language, size of characters and other display preferences) during a limited period.

Why do we use cookies?

When you visit our Site or web page, cookies may be placed on your computer, mobile device or tablet, in order to facilitate and personalise your online experience, and provide you with more practical functionality in order to save you time.

When visiting our site or a webpage, cookies may be placed by us or our partners on your PC, mobile or tablet in order to optimise or personalise your experience online and to provide you with certain practical functionalities in order to save time, subject to the preferences expressed by you and which you may change at any time.

We may use the following three types of cookies:

  • technical cookies relating to site functionalities (mandatory):

These are mainly cookies that are indispensable to your utilisation of the site and its functionalities; without these cookies, certain site configurations may not function correctly.

  • cookies providing statistics on utilisation of the site:

These are cookies that enable us to track user browsing activity in order to produce statistics and monitor site performance. This data also enables us to improve the site and to optimise the user experience.

To benefit from these services, your express consent is required. By accepting these cookies, you help us to improve our website.

  • advertising cookies:

These cookies collect information about your browsing patterns to enable the Cromology group and its partners to offer you the most appropriate and relevant advertising in accordance with your interests.

To benefit from these services, your express consent is required. If you deactivate these cookies, advertising will continue to be displayed during your session but will not take account of your interests and will therefore be less relevant.

  • For how long do cookies remain on my device?

The cookies will be deleted within 13 months of their last having been placed on your device.

  • How do I accept or refuse the placement of cookies on my device?

The placement of cookies on your device depends on your choices, apart from functional and security cookies which are required to ensure that our site functions correctly.
You may accept or refuse cookies individually or in their entirety. We remind you that our site configuration may modify the conditions of access to our content, making the use of cookies mandatory. We remind you that deleting certain cookies may affect your conditions of access to our site.

Every web browser has its own cookie administration parameters. The procedures are described in the browser help menu:

You may at any time decide to configure acceptance or refusal, of your cookies at www.cromology.com/en/cookies provided at the bottom of every page of the site.

For further information about the use of cookies, visit the CNIL (the French Data Protection Authority) website at http://www.cnil.fr/vos-droits/vos-traces/les-cookies/ 

CONTACT

For all questions concerning our rules governing the processing of your personal data in the context of the activity of the Site or Shops, do not hesitate to contact the data controller concerned by sending them an email at the address specified in the Section entitled “The rights held by you with respect to your personal data”.

CHANGES TO THE CHARTER

Cromology reserves the right to modify at any time without notification all or part of these rules. Use of the Site will be subject to the rules in force at the time of your use, unless these modifications are substantial and relate to individual rights held by virtue of the application of laws relating to the protection of privacy and personal data.

To obtain any further information concerning the protection of personal data, any User may consult the website of the CNIL (the French Data Protection Authority) at the following address: www.cnil.fr.

Version revised on 03/05/2021