PERSONAL DATA PROTECTION CHARTER

In accordance with the European Regulation 2016/679 of April 27, 2016
(known as the "General Data Protection Regulation" or GDPR)

GDPR CHARTER - RONDSON

This personal data protection charter (hereinafter: the "Charter") describes the commitment of the Website WWW.RONDSON.COM – RCS TOULOUSE – 5 RUE D’APOLLO – PARC D’ACTIVITE DE MONTREDON 31240 L’UNION – SIRET 690800644 - VAT N° FR 48 690 800 644 published by Mr SEGON as the data controller with respect to privacy and the protection of the personal data of its users. This Charter has been drafted to inform you of the practices and conditions under which WWW.RONDSON.COM collects, uses, and stores your personal data (hereinafter: the "Data").

You will find a description of the various Data that we may collect and process or that you may transmit to us when you access and/or use the site https://www.rondson.com (the "Site") on which our products are sold. The term "Site" refers only to the site https://www.rondson.com.

Given the constant evolution of laws and regulations relating to technology and personal data protection, it is likely that this Charter will be updated. If you are a user of the Site, you will be informed of any changes by email.

If any clause of this Charter is declared null or contrary to the regulations, it will be deemed unwritten but will not invalidate the other clauses of this Charter.

This Charter applies to the Data collected:

• Via simple browsing on the Site
• Via emails exchanged between WWW.RONDSON.COM and you, or any other electronic messaging tool
• When you create a user account on the Site
• When you place an order on the Site
• When you subscribe to the Site's Newsletter (the "Newsletter")

It does not apply to information collected by any third parties or through sites managed by them, including via applications or content (including advertisements) redirecting the user to the Site. We kindly ask you to carefully read the Charter regarding the processing of your Data and inform you that browsing our Site necessarily entails the acceptance of this Charter. If you do not agree with it, we invite you to leave our Site. It is your responsibility to verify that the Data communicated to WWW.RONDSON.COM is accurate. If necessary, you have the possibility to correct and update it from your "My Account" area.

1. WHAT DATA IS COLLECTED BY WWW.RONDSON.COM?

Depending on the nature and purpose of your interaction with WWW.RONDSON.COM (creation of a user account, subscription to the Newsletter, filling out contact forms, as well as during possible telephone conversations), we may collect the following Data:

• Your email address will necessarily be requested if you wish to create a user account, communicate with us via the contact forms and/or receive our Newsletter
• Data relating to your identity such as your surname, first names, email address, postal addresses, and telephone numbers may be requested
• Browsing Data: this refers to Data relating to how you use the Site, including: IP address, browser used, browsing duration, search history, operating system used, language, and pages viewed
• Data regarding your visits to the Site, including traffic data, log files, and other communication data or resources you use when accessing the Site
• Order Data: your postal address is necessary for issuing invoices. Similarly, your bank, PayPal, or other financial partner details must be provided to proceed with the payment of your order
• Data relating to the use of social networks when you use their features.

2. HOW IS YOUR DATA COLLECTED?

Data can be collected in different ways on the Site. Data can be collected directly when you transfer it to us using the contact and user account creation forms, Newsletter subscription forms available on the Site and/or communicated when you contact us by phone. When you contact us by these various means, a copy of your exchanges with WWW.RONDSON.COM, including email addresses, may be made and archived. WWW.RONDSON.COM also indirectly collects certain Data using cookies/trackers. We invite you to read our Cookie Policy, designed to help you better understand these technologies and the use we make of them on the Site and as part of our services, applications, and tools.

3. WHY IS YOUR DATA COLLECTED?

If you are a regular user, we collect your Data to:

• Send you our Newsletter and/or personalized commercial offers if you have consented
• Manage orders and execute the contract
• Ensure the security and traceability of purchases on the site
• Send you information regarding your account (in particular purchase invoices, order history)
• Manage your requests sent via the contact page
• Allow you to leave a review on products and/or the Site
• Inform you of changes concerning the Site or our product and service offering
• Respect our rights and obligations stipulated in contracts concluded with users as well as for any other legal purpose.

We may also use cookies or trackers:

• To secure your browsing and help improve your user experience, in particular by recognizing the username and password you have already provided so that you do not have to enter them on each page of the Site where they are required. Refusing these will prevent any order on the Site (Identification impossible).
• To analyze traffic and data on the Site in order to measure the number of Site users, to make it easier to use, and to ensure its capacity to respond quickly to your requests.

Refusing to properly fill out the Site's form(s) may block access to certain pages, particularly those concerning the ordering of products or services.

4. WHO PROCESSES YOUR DATA?

Your Data is processed by the staff and collaborators of WWW.RONDSON.COM in charge of:

• Site management (Orders and shipments)
• Support management, to answer all your questions
• Invoicing management.

Furthermore, within the framework of our activity, and for processing needs, your Data may be communicated to subcontractors, service providers, or other third parties, and in particular:

• Bank – Banque Populaire Occitane
• Emailing service: Mailjet
• Carriers (La Poste, Colissimo, ...)
• Accounting services
• Tax services
• Google Analytics

Each of these actors respects a confidentiality commitment regarding the use and processing of personal data.

For payment management and to facilitate the user experience, WWW.RONDSON.COM offers the following payment methods for purchases on the Site:

• Online payment by Credit Card (Carte Bleue, Visa, Eurocard / Mastercard) managed by Banque Populaire Occitane
• Payment by bank transfer
• Payment by check

WWW.RONDSON.COM has no access to your identifiers and credit card numbers. All transactions are secured using SSL encryption, guaranteeing you both the identity of the payment organization and the confidentiality of the data.

For the sending of our Newsletters, our e-mailing campaigns are managed through the services of MAILJET- RCS PARIS 524 536 992 00059 – 13-13 BIS, Rue de l’Aubrac – 75012 Paris - SIRET - VAT N° FR 675 245 369 92.

All of the aforementioned subcontractors, service providers, Partners, or other third parties are bound by contractual obligations to respect the confidentiality and protection of Data and to process them only for the purposes for which we transmit them.

Your Data may be transmitted to any buyer or other successor in the event of a merger, assignment, restructuring, reorganization, dissolution, or other sale or transfer of part or all of the assets of WWW.RONDSON.COM due to uncertainties or bankruptcy, liquidation, or other processes in which the Data of WWW.RONDSON.COM users is among the assets transferred.

Finally, we may also disclose your Data:

• to comply with any mandate required by applicable laws, including government and regulatory requests
• if we believe that disclosure is necessary or required for the protection of the rights, property, or safety of WWW.RONDSON.COM, its clients, or other stakeholders.

This possible disclosure includes exchanging information with other companies and organizations for fraud protection and anti-counterfeiting purposes.

The Site may contain links to various sites and social media platforms managed on third-party servers, by people or organizations over which WWW.RONDSON.COM has no control. Therefore, we can under no circumstances be held responsible for the way your Data will be stored or used on the servers of these third parties. We advise you to read the applicable personal data protection charter of each third-party website you access via the Site to assess how your Data will be used.

5. HOW LONG IS YOUR DATA KEPT?

WWW.RONDSON.COM only keeps your Data for the time necessary for the purposes set out in Article 3. This retention period is not the same depending on the Data in question, as the nature and purpose of the collection may cause this period to vary. Similarly, certain legal obligations impose a specific retention period.

When you are subscribed to the Newsletter, we keep your email address until you unsubscribe.

When you contact WWW.RONDSON.COM via the contact form or communicate with us by phone, your data may be kept:

• up to one (1) year from the last contact if you do not have a customer account or an order placed on the Site.
• up to ten (10) years (Legal duration) from the last order placed on the Site, if this information concerns this order.
• In all other cases, the retention period for this exchanged Data may not exceed one (1) year.

Regarding your user account, all your billing data is kept for ten (10) years from the date of purchase even if you have requested the deactivation of your user account.

If you request the deletion of Personal Data, your Site user account will be deactivated and anonymized, then completely deleted at the end of the aforementioned periods from the day you made the request. Finally, regarding Data collected via cookies or trackers, they will be kept for up to six (6) months for audience measurement cookies or trackers and up to thirteen (13) months for others. Beyond the aforementioned retention periods, your Data will be anonymized to be kept for exclusively statistical purposes.

6. HOW IS YOUR DATA PROTECTED?

Your Data is stored on a secure server protected by a firewall and antivirus software. We have implemented technical and organizational measures to ensure the security and confidentiality of your Data against accidental loss and unauthorized access, use, modification, and disclosure. Given the inherent characteristics of the Internet, it is however impossible for us to guarantee optimal security of information exchanges on this network. We strive to protect your Data, but we cannot guarantee the absolute security of information transmitted to the Site. You agree that you transmit your Data at your own risk. We cannot be held responsible for non-compliance with privacy settings or security measures in place on the Site. As such, you agree that the security of your information is also your responsibility. For example, you are responsible for keeping the password that allows you to access your user account secret. Do not disclose it to third parties under any circumstances. Likewise, be careful when disclosing information in the public sections of the Site, as these can be viewed by any user of the Site.

7. WHAT ARE YOUR RIGHTS?

You can choose how the Data you transmit to us is used:

• You can browse the Site without providing Data. In this case, you will not be able to use certain features of the Site and, in particular, make purchases (if you are a regular user) and/or downloads on the Site.
• You can refuse to provide your bank or PayPal details and/or your postal addresses. In this case, you will not be able to make a purchase on the Site.
• You can decide to no longer receive the Newsletter as well as our personalized offers: you simply have to log in to your user account on the Site or click on the link present in the email sent to you.

In any case, you have the possibility to access your user account at any time to consult or update your Data and unsubscribe from our Newsletter if you were subscribed to it. In accordance with the provisions of applicable personal data protection regulations, in particular the European Regulation 2016/679 on Data Protection (the "GDPR") as well as the law of January 6, 1978 n°78-17 known as "Informatique et Libertés" and its amendments, you have a right of access and a right of rectification over your Data.

In addition, subject to the conditions laid down by the said regulations for the exercise of these rights, you benefit from:

• A right to erasure of your Data (Excluding accounting data for which a 10-year retention is required by French law - article L123-22 of the Commercial Code)
• A right to restrict the processing of your Data
• A right to object to the processing of your Data for legitimate reasons, in accordance with Article 21 of the GDPR
• A right to portability of the Data you have provided (for automated processing based on consent or the execution of a contract)
• The right to withdraw consent, where it was requested from you. When the processing of your Data is based on your consent, you can withdraw it at any time.

However, you acknowledge that processing carried out prior to the revocation of your consent remains perfectly valid. You also have a right to object, without providing a reason, to WWW.RONDSON.COM analyzing your Data to share it for marketing purposes.

However, in accordance with Article 12.6 of the GDPR, for the exercise of these rights, WWW.RONDSON.COM, as the data controller, reserves the right to ask you to prove your identity. We inform you that the data used to prove your identity will be deleted once we have responded to your request. You can exercise these rights by sending an email in French to contact@rondson.com or to the following address:

RONDSON – 5 RUE D’APOLLO – PARC D’ACTIVITES DE MONTREDON 31240 L’UNION

We have a period of one month to respond to any request relating to the exercise of your rights. This period may be extended by two months due to the complexity or number of requests.

8. STORAGE OF DATA COLLECTED BY WWW.RONDSON.COM

The Data collected within the framework of the use of the Site is stored exclusively on a server located in Europe (FRANCE), hosted by the company OVH – RCS LILLE METROPOLE 424 761 419 00045 – 2 RUE KELLERMANN – 59100 ROUBAIX – France – VAT N°: FR 22424 761 419.