1 - Overview

1.1 - Aim of this policy

LESACA is determined to respect your privacy and protect your personal data.

This confidentiality policy is designed to inform you about our use of your personal data that we gather when you access the LESACA website www.lesaca.co, when you purchase any goods at LESACA points of sale or when you contact LESACA.

It will enable you to determine the origin and the use of the information that we gather, as well as your rights and options under the applicable data protection rules and regulations.

This Confidentiality Policy is therefore important for you and we ask you to read it carefully.

1.2 - Modification of this policy

LESACA may modify this policy from time to time depending on the legal and regulatory context, and to keep you informed about changes in our personal data processing practices.

LESACA therefore recommends that you always become acquainted with the latest version of this Confidentiality Policy whenever you plan on having any dealings with LESACA, by visiting this section or by clicking on the “Terms & Conditions” link at the bottom right of the home page of the website (see the first line of text in the link “Overview”).

1.3 - Role and responsibility of LESACA

Unless there are any other texts that provide otherwise with regard to certain specific instances of processing of personal data, the processing of your personal data that is described in this policy shall be performed by LESACA, a Canadian sole proprietorship; registered with the Ontario Business Services under the number 300 271 103 (“LESACA”), which publishes the www.lesaca.co web site and which is thus the “data controller” under the data protection laws. 

2 - Key points of this confidentiality report

The data that is gathered

• LESACA gathers your personal data when you use the website.
• In addition to the information that you actively provide (ex. registering for the newsletter), information is automatically gathered or generated by LESACA’s systems (ex. determination of your LESACA product reference numbers).

How your data is used

The data we gather enables us to:

• to perform the Services Provided by LESACA as requested.
• to send you information about LESACA’s products and events that we consider most likely to be of interest to you
• to understand how you may oppose such a use and withdraw your consent, please consult section 3.11.
• the use of Cookies on the website enables us to improve its performances and to send you targeted advertising. To deactivate the use of cookies for these purposes, please click here.
• checks are moreover carried out in order to ensure the security of the website and of the payments made on the website. For more information about these checks, please consult section 3.2.

Who receives your personal data, and to whom is it transferred

• Your personal data is only accessible to authorized personnel working at LESACA’s company and entities with which you are in contact.

How long is your data kept

• In general, your personal data will be kept by LESACA for as long as you remain a client and until the expiry of the applicable warranties. It will only be kept beyond that time with your permission or to meet our legal obligations.

Your rights and options

• Under the data protection laws and regulations, you have a right to access, amend and request the erasure and to exercise other rights over your personal data.
• You may review your decision as to whether to receive the LESACA newsletter at any point in time. For more information, please see section 3.11.

3 - Our policy in detail

3.1 - How LESACA uses your personal data

Your personal data is only gathered when LESACA has a legal basis for doing so. We therefore only process your personal data when this is necessary.

1 - To deal with your requests, ex.

• to send you information about our offers, news and events (newsletter, invitations and other publications via the channels that you will have specified beforehand – post, e-mail, telephone, SMS, instant messaging).
• to improve the operation of the website by generating statistics, to personalize the interface of the website based on your preferences, and for the purpose of targeted advertising or promotional material, in keeping with our cookies policy.

2 - To provide you with services and fulfil the orders that you place, and to comply with our contractual obligations, and in particular:

• to manage your orders and their delivery as well as the corresponding warranties.
• to manage any other service, whether current or future, in connection with the Terms & Conditions and registered in the corresponding Overview.

3 - To foster the legitimate interests of LESACA:

• to manage our relationship with you by keeping an up-to-date centralized database of our existing and potential clients, enabling us to proactively manage the monitoring of our commercial relationship.
• to create survey reports and statistics, after anonymizing the underlying data or after implementing processes designed to prevent the erroneous attribution of data to an identified person.
• to ensure the security of your transactions online, to prevent fraud and payment defaults.

For all these purposes founded on our legitimate interest, we take into consideration any potential impact that the gathering of this data may have upon you and upon the users of the website in general. Should we believe that your interests or your fundamental rights and freedoms transcend our legitimate interests, we will refrain from using your personal data on this basis and may ask you for your consent on a case by case basis.

3.2 - Note concerning the processing of personal data for purposes of presentation and management of payment defaults

In order to combat fraud over the Internet, information concerning your order and concerning the terminal used to place the order (such as the operating system used, the location of the machine, whether or not a proxy was used, etc.) is gathered automatically and used, subject to your consent, to analyze your transactions for purposes of fraud detection and prevention of payment defaults. The information may be transmitted to our payment service provider and to any third party that is duly authorized by law for the sole purposes of checking your identity, the validity of the order, of the payment method used and of the requested delivery address.

You may withhold or withdraw your consent at any point in time in accordance with the terms of our cookies policy. However, should you refuse to allow us to use cookies to secure the transactions, your order may not be approved automatically and will have to be reviewed manually. You may be asked for proof of identity in order to confirm your order.

3.3 Categories of data gathered by LESACA

The categories of personal data that we gather directly from you include:

• your identification and contact data (such as your family name and first name, e-mail address, telephone number, date of birth, mother tongue, preferred means of contact) needed to identify you or to contact you when you use one of the Services Provided by Lesaca.
• transaction related information needed to process your order (items chosen, delivery and billing address, telephone number, means of payment, including your bank card details in order to enable billing – account holder name, number and expiry date – in case of payment by bank card).
• data concerning the monitoring of our commercial relationship (your order number, the chronology of your purchases, your contacts and requests or your correspondence with our Customer Service unit).
• socio-demographic data (such as your age, your profession, etc).
• data concerning your preferences and your person (preferred style, size, favourite colours, etc).

The personal data that is indispensable for LESACA to fulfil the purposes described above is highlighted in the various pages of the website. Should you not disclose this data in the mandatory fields, LESACA may not be able to respond to your requests and/or supply you with the products and services that you want. All other data is merely optional and enables us to know you better and to improve the way in which we communicate with you and the services that we provide to you. 

Other data is gathered automatically when you access the Site, use our Services or perform a transaction with us:

• connection data concerning the terminal used: your IP address, the type of browser you use and various information about your browsing of our Site are also gathered for purposes of administration and/or to generate statistics, as detailed in our cookies policy.
• information about your browsing habits: we use cookies and other tracking technologies to gather information concerning you, such as your preferences and order history.

3.4 - Recipients of your personal data

Management of the Site and the Services:

• Your personal data is processed by LESACA. It will not be transferred or made accessible to any third party other than (i) LESACA’s subcontractors and service providers (for example, our Customer Service) who are involved in a purely technical or logistical capacity (carriers, providers of hosting and maintenance services to the Site, payment and fraud prevention service providers, etc.), and (ii) upon any reorganization of our company, including a total or partial disposal of our assets, merger, takeover, acquisition, de-merger, and in general any reorganization operation, in order to ensure the continuity of the services provided.

3.5 - Duration of retention

Lesaca shall not retain your personal data beyond the duration that is strictly necessary for the accomplishment of the purposes for which it was gathered.

• newsletter, contacts and complaints

The identification data of the client that is used with the client’s consent to send out newsletters and other LESACA publications shall be kept for a period of three years as of its gathering or as of the last contact initiated by the client.

Any personal data and general information about your requests (for example, opening date, closing date, subject of the request) that is gathered and processed under the section entitled “Contact” or pursuant to contact with the Customer Service unit will only be kept for 5 years in our unique customer repository.

• Data concerning orders and past purchases 

LESACA will keep the data concerning your orders for as long as you remain a client (i.e. have an active client account or are a regular contact of our Stores) and until the expiry of the applicable warranties. This data will only be kept beyond that time with your consent or for accounting and evidential purposes or to meet our legal obligations or, after having been anonymized, for purposes of studies and statistics.

• Payment data 

Your payment data will be kept securely for the duration that is needed to confirm your order and payment and will then be immediately destroyed. In case of a problem with payment, your data will be kept throughout the duration of the management of the incident, then for a period of three (3) to five (5) years, depending on the severity of the incident.

3.6 - Links

The website may contain links to third party web sites. LESACA has no control over the content, the Confidentiality Policy and the data protection policy or the actions of these third party web sites. The use of the information that you may provide to third parties on other sites or that these third parties may gather on those other web sites is not governed by this Confidentiality Policy. You should carefully examine the confidentiality and data protection policies of any third party web sites and contact the publishers of these web sites should you have any questions about the way in which they use your personal data. LESACA hereby disclaims liability for any failure by a third party to use your personal data in accordance with their confidentiality policy or in accordance with any contractual or legal obligation that is binding upon them.

3.7 - Modifications and updates of the confidentiality policy 

This Confidentiality Policy is in keeping with the prevailing practices at LESACA. It may be modified and updated to reflect the changes in LESACA’s practices, to provide more information or to ensure compliance with the applicable regulations.

In case of a modification or update, the revised Confidentiality Policy shall be put online on the Site, with a statement indicating the date of the latest update. You will also be informed by a message on the website urging you to read the updated Confidentiality Policy.

3.8 - Your rights and options

Access and rectification

You have the right to access your personal data and to request the rectification or the destruction of any data that should turn out to be inaccurate. Where applicable, you must ensure that you disclose to LESACA any updates or changes to your personal data, including your postal and/or e-mail address, in order to enable us to dispatch your orders to the right address and to contact you about your orders in case of need.

Other rights:

• Erasure. You may also request the erasure of your personal data provided that it is no longer necessary for LESACA to keep it.
• Opposition. You can also oppose the processing of your personal data or request the imposition of limitations on such processing, unless the processing is necessary for the management of the Services that you request.
• Withdrawal of consent. Where the processing of your data is based on your consent, you may withdraw this consent at any point in time.
• Portability. You may moreover exercise your right to portability, i.e. obtain, in a structured, machine-readable form, the personal data that you provided to us directly on the basis of your consent or of a contract drawn up and signed with you and that that is undergoing automated processing.
• Directives. You may also let us know your instructions regarding the preservation, erasure and disclosure of your personal data after your death, and modify these directives at any point in time.

These rights may be exercised directly with LESACA in accordance with the terms of the section 4 entitled “Contact us”. You may be asked for proof of your identity.

3.9 - Unsubscribing from our newsletters, requesting an end to targeted advertising 

You may withdraw your consent at any point in time and request to no longer receive correspondence from us regarding our offers, news and events, by using the hypertext link that is included for this purpose in each e-mail that we send you.

You may also oppose LESACA’s use of your personal data for purposes of marketing or drawing up a client profile; in that case, however, you will no longer benefit from customized offers or services.

4 - Contact us 

If you have any questions about this Confidentiality Policy and LESACA’s data protection practices, please do not hesitate to contact us via the “Contact” section on the website.