Policy on privacy and personal data processing and use of cookies

Version 0.3_2024-03-26

Download the rules of confidentiality specific to the MyPetzl Light mobile app.

I/ Policy on privacy and personal data processing

Users ("Users" or "you") of the "Petzl.com" application (hereinafter the "Website") acknowledge and accept that  PETZL Distribution (hereinafter "PETZL") processes some of their personal data in accordance with the terms and conditions of this Privacy Policy.

Personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online login, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.

In compliance with GDPR, personal data is:

a) Processed lawfully, fairly and transparently with regard to the data subjects;

b) Collected for specified, explicit and legitimate purposes and shall not be further processed in a way that is incompatible with these purposes;

c) Adequate, relevant and limited to what is necessary for the purposes for which it is processed;

d) Correct and, if necessary, kept up-to-date;

e) Stored in a form that permits identification of data subjects for no longer than is necessary for the purposes for which it is processed;

f) Processed in such a way as to ensure appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organisational measures.

What is this policy? What is its purpose?

The company, Petzl Distribution (hereinafter "PETZL" or "we/us"), cares about protecting your privacy and the use made of your personal data, and compliance with GDPR.

The aim of this policy is to describe and inform you about the processing of your personal data collected directly when you browse the Website. 

Your personal data is collected automatically via cookies, or via data entry forms on the Website. 

The current version of our data privacy  policy is the one published on the Website. It may be modified and updated by us, due to changes in applicable legislation or a change in our practice. We therefore invite you to regularly consult our policy to stay informed of any changes.

Who is responsible for processing the personal data collected?

PETZL Distribution is the data controller under (EU) Regulation 2016/679 of the European Parliament and of the Council 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 (hereinafter "GDPR"). 
Thus, as data controller, PETZL Distribution defines and limits the data to be collected in compliance with the purposes of processing.
The contact details for PETZL Distribution are:

Who is the Data Protection Officer appointed by us, and how can you contact them?  

We have appointed a Data Protection Officer (or DPO) who will be your point of contact for any questions concerning your data. 

You can reach them at the following address:
E-mail address: dataprivacy-eu@petzl.com 

Which personal data does PETZL collect? For what purpose? Can I refuse this collection and processing?

Through our Website, we collect a variety of personal data about you and process it for the purposes below:

 Purpose: Supply of products
When you buy products through our Website, we process your personal data, in particular to provide you with the products, to process your order, to ensure delivery and to answer your questions about your order.

 Legal basis
Execution of the contract made with you (ordering of products), legitimate interest of PETZL (to reply to your questions) and our legal obligations (for product recalls).

 Data collected
Identification data, payment data, administration data.

Storage period
3 years from delivery of the order (for questions concerning orders) or 10 years from when the data is collected.
15 years from sending you information alerting you to a safety risk concerning one of our products or a after-sales service claim. 

 Purpose: Supply of services
After-sales service or other services, such as technical questions concerning our products

 Legal basis
Execution of the contract (for the after-sales service), legitimate interest of PETZL and our legal obligation

 Data collected
Identification data, bank information where relevant, information on the product concerned and information concerning your activities  

Storage period
15 years from when the data is collected, with the exception of banking data, which is deleted once the purpose has been met.

 Purpose: Marketing and sales communication
Sending promotional products, news and other promotional, commercial and non-commercial information, informing you of various events in connection with PETZL and competitions), and proposing meetings with our sales staff to discuss your professional needs.

 Legal basis
Consent (for consumers) or legitimate interest of PETZL (for professionals)

 Data collected
Identification data and professional data

 Storage period
3 years from the last activity

 Purpose: Competitions
Selection of winners, sending prizes, receiving applications

 Legal basis
Execution of the competition rules

 Data collected
Identification data

 Storage period
5 years from the competition

 Purpose: Registration for PETZL events

 Legal basis
Legitimate interest of PETZL.

 Data collected
Identification data, activities practised, administration data.

 Storage period
2 years from the end of the event

 Purpose: Surveys
Such as satisfaction surveys and product orientation surveys

 Legal basis
Legitimate interest of PETZL.

 Data collected
Identification data, activities practised, interest for the brand and the products.

 Storage period
5 years from receiving responses

 Purpose: Employee recruitment
Receipt of applications, interviews, sending replies.

 Legal basis
Execution of pre-contractual measures and consent

 Data collected
Identification data, personality test and professional data 

 Storage period
The time it takes to examine the application and then, with your consent, 2 years from the application

 Purpose: Following social media, blogs, forums, websites
Measuring the brand's e-reputation, following the influence and activity of athletes and influencers, general monitoring of social media in connection with PETZL products and competitor products

 Legal basis
Execution of the contract or legitimate interest of PETZL

 Data collected
Identification data (last name, first name, pseudonym), information shared publicly (comments, photographs, likes)

 Storage period
13 months from collection 

 Purpose: Facilitation of subsequent purchases

 Legal basis
Consent

 Data collected
Type of card, PAN number, bank card validity start and end date

 Storage period
Data is kept until consent is withdrawn and/or the validity of the bank card data expires.

 Purpose: Claims management
Complaints management.

 Legal basis
Legitimate interest of PETZL

 Data collected
Type of card, PAN number, bank card validity start and end date

 Storage period
13 months from the debit date and 15 months for a deferred debit card. 

For personal data used within the framework of managing the Website (data collected via the use of cookies and other trackers), see our Cookie management policy (paragraph II of this document).

Is my data sent to third parties? Where are these third parties located? What is the need for these transfers?

Your personal data may be transferred to third parties located within the European Union, particularly to process transactions and payments after purchasing products on our Website. 

Additionally, we may have to use third parties located outside of the European Union, or which use sub-contractors located outside of the European Union. 

Any transfer of your data outside the European Union will be done using the appropriate guarantees, in accordance with the applicable personal data protection regulations. Please send an e-mail to dataprivacy-eu@petzl.com if you would like to receive a copy of the applicable guarantees.

These third parties are service providers that provide, for example, technical services (data hosting, Website functionalities), logistics services (delivery of products or promotional materials), social media (such as LinkedIn) or PETZL affiliate companies. 

In any case, your personal data shall not be transferred to third parties without any connection to PETZL, or who do not carry out any assignments or services for PETZL. However, it may be passed on if legislation or regulations require PETZL to do so, particularly in the event of legal proceedings or requests from legal or administrative authorities.

Which types of measures does PETZL put in place to ensure the security and privacy of my personal data?

Concerned about the security and privacy of your personal data, PETZL implements a series of organisational and technical security measures, in particular: 

• organisational measures:
  - we ensure that your data is processed by personnel and third parties who are bound by an obligation of confidentiality, written in a contract, so that they can only process your data for the purpose provided; and 
  - we adopt and apply a security policy within our organisation to ensure the security of your personal data and to counter any computer attacks efficiently and rapidly. 
   
• technical measures:
  - we implement secure access management, which in particular involves limiting access by IP address or dual authentication, so that only specifically identified persons can access your data and process it within the framework of their assignment;
  - we log of personal data access events; and
  - we use SSL certification, which ensures secure data connection and transmission between servers and your browser. Secure connection is symbolised by the acronym “HTTPS” (Hypertext Transport Protocol Secure) in our Website link.

Does the Website contain elements or links controlled by third parties? Is Petzl responsible for these elements?

Our Website may contain elements and links to other sites controlled by third parties. This concerns, for example, links to our retailers' websites or social media sites (such as Facebook, YouTube or other) (hereinafter "third parties").

There are two cases: 

• Reading content on the Website, hosted by third parties. You can accept or refuse third-party cookies. If you do not accept, this means that you will not be able to read the content on our Website (e.g.: video of one of our products on the Website, but hosted on YouTube)
• Consultation of links to third party sites. By consulting these different links, social media and other sites will have access to your data. This data will be processed by these sites and social media. 

PETZL does not have any access to or control over any content owned and operated by a third party to which the Website links. Likewise, we cannot control how or why these third parties process personal data.  For more information, we recommend you read the information published on the sites owned by third parties. 
In this context, PETZL and all PETZL Group companies decline all responsibility concerning these sites, elements, cookies or other, owned and operated by third parties.

What rights do I have over my personal data collected and processed by PETZL?

GDPR gives you a certain number of rights regarding your personal data:

• Right of access and in particular the right to obtain copies of all your personal data, as well as the essential details of how the data is processed;
• The right to obtain rectification of your personal data, as soon as possible, and the right to have any incomplete, inaccurate, ambiguous or out-of-date personal data completed;
• The right to have your personal data deleted if processing is no longer required, or if Petzl has withdrawn its consent or objected to processing, of if the collection, use, communication or storage of your personal data is prohibited;
• The right to limit the processing of personal data; 
• The right to portability of your personal data; and
• The right to object to the processing of your personal data (including the right not to be subject to a decision based exclusively on automated processing); 
• The right to withdraw your consent at any time.

To exercise your rights, you can contact us at any time, free of charge, at the following address: dataprivacy-eu@petzl.com. 

In the event of doubt concerning your identity when making a request to exercise your rights, proof of identity may be requested. 

How can I express my choices concerning the use of my personal data?

You can withdraw your consent at any time and free of charge by:

• clicking on the unsubscribe link at the bottom of our e-mails, or
• by contacting us at dataprivacy-eu@petzl.com,  particularly if the e-mail does not contain a link to unsubscribe. 

We may send service e-mails to inform you of product recalls or changes to our terms and conditions and/or our prices. Receiving these e-mails is not related to the choices you express to receive our news. 

These messages are necessary to fulfil our legal obligations, for the correct performance of our contracts or within the framework of our legitimate interest to inform you. 

Who can I contact if I notice that PETZL is in breach of its obligations?

If, after contacting our DPO, you consider that PETZL is in breach of its obligations in virtue of applicable laws and regulations pertaining to personal data protection, particularly concerning the security of your data or the exercise of your rights, you may make a complaint to the local control authority (for France: CNIL, 3 place de Fontenoy 75007 Paris, https://www.cnil.fr).

II/ Cookie management policy

Does PETZL deposit cookies when I visit the website?

Cookies are small computer files, or trackers, that are installed on your device (computer or mobile) and which make it easier to browse our Website, notably by storing preferences and by proposing personalised content. 

The Website uses cookies which enable it, in particular, to process statistics and information on traffic, facilitate browsing and improve the service for the comfort of the User.

Cookies are not malware files. These cookies do not damage or endanger your terminal. They do not download any viruses or malware, they do not run any software or programs and they do not make it possible to spy on the activities of your device.

This Policy informs the User that when they use the Website, a cookie may be automatically installed on their browser software.
The life span of the cookies is limited to 13 (thirteen) months.

How can I manage my consent to use cookies?

Some cookies require consent. Users can therefore accept or reject cookies.

Once these cookies have been accepted, your preferences are saved for your future visits on our Website, until you delete them from your device, or until their date of expiry as defined by national legislation and European Union regulations.

You can manage cookies concerning the Website at any time via the relevant link at the bottom of the page on the Website.

You can refuse the use of all cookies (including those required for the Website to work) by going to your browser settings, to the cookie management tab. Note, however, that deleting cookies may prevent access to certain parts of the Website or the provision of certain services during your visit.

Does PETZL process personal data collected via cookies? 

The personal data obtained automatically through browsing on the Website, particularly the IP address of your device, and/or by computer files stored on your device, called "cookies", is used in compliance with the stipulations below.  

The cookies used on our Website fall into several categories.

a) "Strictly necessary" cookies

These activate the essential functions, without which the Website cannot work. They do not collect personal data and cannot be disabled.

This category consists of the following groups of cookies:

• "Host" cookies: these provide the connection between the Website and the servers that host it. They are essential and necessary for the Website to work.
• Cookies related to e-commerce on the Website: they memorise the content of your basket and keep you informed of the availability of our products that interest you.
• "User Experience" cookies: these cookies offer a personalised experience of your visit to the Website. They record your preferences, notably in terms of Website language, location, product universes that you visit, mobile or computer version display on mobile devices.

b) "Functionality" cookies
They offer advanced functionalities to improve browsing on the Website. They do not collect personal data, except for your IP address, and can be disabled if you wish.

This category consists of the following groups of cookies:

• Video player cookies (such as YouTube, Vimeo, Dailymotion): Video player cookies allow you to view videos shared on YouTube, Vimeo or Dailymotion platforms on the Website. By watching these videos, you receive cookies from these platforms. 
• Google Maps cookies: they allow you to easily search PETZL retailers and distributors in the world and to use geo-location to display the retailers and distributors nearest to you.

c) Cookies "for targeted advertising"
They are put on our Website by our advertising partners. They can be used by these companies to draw up a profile of your interests and propose relevant advertisements on other websites. They do not directly store your personal data, but are based on the unique identity of your browser and your Internet device.

This category consists of the following groups of cookies:

• Social media cookies (such as LinkedIn, Facebook or Twitter): these cookies make it possible to show you relevant advertisements, both on the website of these social media and outside of these sites (advertiser's website, for example). 
• Google Tag Manager cookies: they measure user traffic and behaviour, and make it possible to understand the impact of on-line and social media advertising. In concrete terms, these cookies allow us to offer increasingly personalised content based on the elements in which you are interested.

d) "Statistics" or "performance" cookies
These cookies allow us to determine the number of visits and sources of traffic in order to measure and improve our Website's performances. They help us identify which pages are the least visited and to assess how visitors browse the Website. All information collected by these cookies is aggregated and therefore made anonymous.

These cookies consist of Google AnalyticsTM cookies. These cookies are a tool for analysing and measuring the Website's audience and make it possible to analyse use of the Website and to draw up statistics (distinction between different user sessions, particularly new visits).

Data collected by Google AnalyticsTM is transferred to Google and stored on servers based in the United States, to then be analysed to measure use of the Website, create reports and possibly provide services related to the Website's activity.

The way Google processes this data is detailed in its privacy policy, accessible via this link: https://www.google.com/intl/fr/policies/privacy/. 

III/ Miscellaneous provisions 

PETZL reserves the right to make changes to this Policy at any time, in accordance with this clause. 

If PETZL modifies this Policy, it will publish the new version on the Website and update the last update shown at the top of this Policy. 

PETZL invites Users to view this page regularly.

IV/ Contact PETZL

If the User has questions or complaints concerning PETZL's compliance with these stipulations, or if the User wishes to make any recommendations or comments to PETZL, they may contact PETZL by writing to: dataprivacy-eu@petzl.com.