Respecting individuals' privacy is an important concern for DA Beverage Company. We are committed to complying with the provisions of Law No. 78-17 of January 6, 1978, as amended, relating to data processing, files, and freedoms, as well as those of Regulation 679/2016 of April 27, 2016, on data protection (GDPR).
This Privacy Policy is intended to exclusively manage the processing of data collected directly by the following websites (and their subdomains): www.devils-advocate.com.
The processing of personal data on behalf of corporate clients is subject to agreements directly concluded with them and is not covered by this Privacy Policy.
What is the status of DA Beverage Company?
DA Beverage Company is the data controller for the data collected via its website, blog, forms, or dedicated social media pages.
The contact details for DA Beverage Company are:
DA Beverage Company, 10 Avenue de la Grande Armée, 75017 Paris, France
Email: contact@devils-advocate.com
What is personal data?
According to Article 4, 1° of Regulation 679/2016 of April 27, 2016, personal data is defined as any information relating to an identified or identifiable natural person, either directly or indirectly, particularly by reference to an identifier, such as a name, identification number, location data, online identifier, or to one or more specific factors related to physical, physiological, genetic, mental, economic, cultural, or social identity.
We (DA Beverage Company) may collect personal data from you or receive it from you via our websites, blogs, forms, or dedicated DA Beverage Company social media pages. These data may include your name, surname, email, phone number, company information, or a free comment section.
You provide this personal data directly to DA Beverage Company, for example, when you make a contact request through the website’s form. In other cases, we collect data through cookies to understand how you use our websites. The cookie policy is described in a separate document from this Privacy Policy.
When we collect data, we identify by an asterisk (*) the information that is essential to process your request. This generally includes your name, surname, and email. If you do not fill in the fields marked with an asterisk, we will not be able to respond to your request.
Why do we process your personal data?
We process your personal data to:
- Handle your information requests;
- Operate the website;
- Analyze its audience;
- Set up and measure advertising campaigns;
- Manage your requests regarding your personal data.
With the exception of cookies strictly necessary for the website's operation, these personal data processing activities are based on your consent, meaning we will not process your personal data without first informing you and receiving a clear affirmative action from you, authorizing us to do so.
How long do we process your personal data?
In compliance with regulations, we retain your personal data in a form allowing your identification for no longer than necessary for the purposes for which they are processed. In this context:
- Personal data collected to respond to your information requests via our contact form will be kept for the necessary duration, which will not exceed six months from the last message received from you;
- Personal data collected for the purpose of website audience statistics (Google Analytics) will be retained for up to 13 months;
- Personal data collected to send you advertisements or measure their effectiveness (Facebook Pixel) will be retained for up to 90 days;
- Personal data collected to operate our website (SHOPIFY) will be kept for 30 minutes.
Who are the recipients of your personal data?
DA Beverage Company collects data intended for its marketing and customer relationship management services and will only be used for this purpose.
We share your personal data only with the following third parties:
- Website hosting providers (the website dedicated to activities in France is hosted in France);
- Marketing service providers for the development and management of our websites, contact forms, or advertising campaigns (e.g., email marketing).
We will only share your personal data with other third parties if we are legally obliged to do so or at the request of public authorities (e.g., judicial authorities).
We do not share your data with our partners without your consent.
Do we transfer data outside the European Union?
We carry out our processing within the European Union and do not transmit data to recipients outside the EU, except possibly to our offices in those countries if processing requires it (e.g., responding to a contact request by an expert based in the US). In any case, these processes will benefit from the guarantees described below (European Commission contractual clauses).
However, certain technical service providers who receive your personal data may be located outside the European Economic Area, such as the United States (Google services).
Therefore, your personal data may be processed in countries that are not recognized as offering an adequate level of data protection under Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016.
DA Beverage Company ensures that your data is protected to the same standard required by all applicable laws and regulations in the European territory and ensures that these providers are either bound by European Commission model clauses, subject to Binding Corporate Rules (BCRs) authorized by a data protection authority, or part of a recognized data protection program (e.g., Privacy Shield in the US).
WHAT SECURITY MEASURES HAVE WE IMPLEMENTED TO SECURE YOUR PERSONAL DATA?
We implement appropriate technical and organizational measures to ensure a level of security adapted to the personal data processing we conduct: automatic server updates, antivirus and firewall protection, limited access to dedicated IT folders, logging of access, security breach detection, management of retention periods, backup solutions, data encryption, etc.
WHAT ARE YOUR RIGHTS?
Under certain conditions, you have the right to request access to your personal data, rectification, or deletion of your data, or the right to limit its processing or object to the processing, as well as the right to data portability.
You also have the right to query and define general or specific directives on how you want your rights to be exercised after your death.
Some rights or their exercise may be subject to conditions. You can find more information by consulting the dedicated page of the CNIL (French Data Protection Authority) here.
HOW TO EXERCISE YOUR RIGHTS?
You can exercise your rights by emailing us at contact@devils-advocate.com or by sending a letter to DA Beverage Company, 29 Rue de Clichy, 75009 Paris.
You have the right to lodge a complaint with the supervisory authority in your country of residence. For example, if you reside in France and believe your personal data rights are not being respected, you can contact the CNIL at 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07 (Phone: 01 53 73 22 22, Website: www.cnil.fr).
You're right, the section on **Cookies and Trackers** wasn't fully translated. Here is the remaining part of the Privacy Policy in English:
Cookies and Other Trackers
What is a cookie or tracker?
Cookies or trackers are small files that record the visit and activity of individuals on connected websites or applications. They are typically associated with a terminal or browsing software and allow website and application publishers to collect quantitative and qualitative information on the use of their products. This activity, known as "tracking," is fundamental to continuously improving the features, ergonomics, personalization, and services offered online.
The term "cookie" broadly refers to (non-exhaustive list):
- HTTP & "flash" cookies;
- The result of fingerprinting (calculating a unique machine ID based on configuration elements for tracking purposes);
- Invisible pixels or "web bugs";
- Any other identifier generated by software or an operating system.
Why do we use cookies?
We (DA Beverage Company) may use cookies to collect browsing data from individuals (you) visiting our websites to improve your browsing experience. Cookies and trackers also help refine the precision of our advertising targeting on partner sites and measure the performance of our ads.
The data collected in this way is strictly anonymous and only used for performance analysis and advertising targeting purposes or, occasionally, for testing new functionalities of advertising or marketing technologies. In this case, the data is not used for commercial purposes and is immediately deleted after the test period.
How long do we store cookies?
The lifespan of cookies on our sites is 13 months, in line with the recommendation of the French Data Protection Authority (CNIL) on the validity period of consent for cookie placement. After this period, consent will be requested again before placing a new cookie.
How to control which cookies are installed on your devices?
- Cookie settings on this website: The settings are available in the information and configuration banner that appears during your first visit, and at any time during your navigation, in the "Cookies" tab at the bottom right of the website.
- Cookie settings in your browser software: You can configure the acceptance of cookies uniformly for all sites in your browser or customize it for each website. You can also configure your browser so that the acceptance or refusal of cookies is proposed before they are placed on your device.
How to manage cookies in your browser?
Each browser's configuration for managing cookies is different. It is described in your browser's help menu, which will explain how to change your cookie preferences. Here are links for major browsers:
- Internet Explorer™
- Safari™
- Chrome™
- Firefox™
- Opera™
More information about cookies?
If you want more information regarding cookies, you can consult the dedicated section on the CNIL website.