SA & CONSULTANTS Privacy Policy
This policy explains how SA & CONSULTANTS, operating under the Heritage Hub brand and the website heritagehub.fr, collects and uses the personal data of visitors, clients, prospects, and users of its services. It also outlines the choices and rights available to you.
1 Data Controller
The data controller is SA & CONSULTANTS, a simplified joint-stock company with a capital of 50,000 euros, registered with the Nanterre Trade and Companies Register under number 922 558 002, with its registered office located at 43 boulevard de Verdun, 92400 Courbevoie, France.
SIRET: 922 558 002 00015. Intra-community VAT: FR81922558002. Trade name: Heritage Hub.
For any questions regarding your data or to exercise your rights: contact@heritagehub.fr; phone: +33 (0)1 75 84 06 66; mail: SA & CONSULTANTS – Heritage Hub, 43 boulevard de Verdun, 92400 Courbevoie, France.
2 Data we may collect
Depending on your use of the site and services, we may process the following categories of data:
· identity and contact details: surname, first name, postal and email addresses, telephone number;
· information related to the client account: login, order history, preferences, and interactions with customer service;
· order and delivery information: products, amount, billing, delivery address, carrier, tracking, returns, and refunds;
· limited payment information: payment status, method used, transaction reference, and anti-fraud information. Full credit card data is processed by the payment service provider and is not accessible to Heritage Hub;
· data related to appraisal or research services: description of the item, photographs, documents provided, provenance information shared, request, report, and interactions;
· contact and marketing data: requests, preferences, newsletter subscription, consent, and unsubscription;
· technical and browsing data: IP address, session or device identifiers, browser, system, pages viewed, browsing events, date, time, referring site or campaign;
· content transmitted: reviews, messages, photographs, and attachments;
· information necessary for fraud prevention, security, and the defense of our rights.
We ask that you do not transmit sensitive data or data concerning third parties that is not necessary for your request. When you communicate information about a previous seller, owner, or any other person in a provenance file, you must be authorized to do so.
3 Source of data
Data is collected directly from you when you create an account, place an order, fill out a form, request an appraisal, subscribe to the newsletter, exercise a right, or contact Heritage Hub. It may also be generated during your navigation or received from service providers involved in the order, such as a payment provider, a carrier, or a platform used with your consent.
4 Purposes, legal bases, and retention periods
We only keep data for the duration necessary for the pursued purpose, extended when required by law or when necessary for the establishment, exercise, or defense of legal claims.
|
Purpose |
Main data |
Legal basis |
Retention duration or criteria |
|
Client account and authentication |
Identity, contact details, identifiers, history, and preferences |
Performance of the contract; legitimate interest for security |
Duration of account usage, then deletion or archiving after 3 years of inactivity, subject to legal obligations. |
|
Ordering, billing, and after-sales service |
Identity, contact details, order, invoice, interactions, returns, and refunds |
Performance of the contract; legal obligations |
Operational data during the relationship; invoices and accounting records for 10 years; evidence as per applicable legal timeframes. |
|
Payment and fraud prevention |
Transaction reference and status, method used, IP, anti-fraud signals |
Performance of the contract; legitimate interest to secure payments |
According to the duration necessary for the transaction, disputes, and the provider's obligations. Heritage Hub does not store the cryptogram. |
|
Delivery and tracking |
Name, address, telephone, order, tracking, and incident |
Performance of the contract |
Until delivery and incident processing, then archiving of elements necessary for claims. |
|
Appraisal or search for an artwork |
Identity, contact details, photographs, description, provenance, documents, report and correspondence |
Pre-contractual measures; performance of the contract; legitimate interest in retaining proof of the service |
Duration of the request or service, then up to 5 years for proof and handling of disputes, unless a longer obligation exists. |
|
Requests and complaints |
Identity, contact details, message, order and supporting documents |
Performance of the contract; legitimate interest; legal obligation |
Time necessary for processing, then archiving for the period useful for proof or defense of rights. |
|
Newsletter |
Email address, preferences, proof of consent and interactions |
Consent |
Until withdrawal of consent or 3 years after the last active contact; proof of withdrawal kept on an opt-out list. |
|
Offers for similar products sent to clients |
Email address, relevant history and objection |
Legitimate interest, within the limits of electronic solicitation rules |
During the business relationship then up to 3 years after the last purchase or active contact, unless objection. |
|
Audience measurement and site improvement |
Identifiers, IP, terminal, pages, events and traffic source |
Consent, unless the solution is configured to benefit from a legal exemption |
Trackers for a maximum of 13 months; measurement data for a maximum of 25 months when these durations are applicable to the configured tool. |
|
Advertising and personalization |
Advertising identifiers, interactions, campaigns, audience and consent choices |
Consent |
According to the duration indicated in the cookie manager, limited to 13 months for trackers; withdrawal possible at any time. |
|
Site security and technical logs |
IP, terminal, logs, alerts and security events |
Legitimate interest; security obligations |
In principle from 6 to 12 months, unless it is necessary to retain a documented security event longer. |
|
Exercise of rights |
Identity, request, correspondence and proof if necessary |
Legal obligation |
Duration of the processing of the request, then retention limited to proof of its handling and applicable appeal periods. |
5 Mandatory nature of information
Fields marked as mandatory are necessary to process an order, deliver a product, perform a service, or respond to a request. Otherwise, we may not be able to enter into or perform the contract. Data used for the newsletter, personalized advertising, and non-essential trackers are optional.
6 Recipients and service providers
Within the limits of their responsibilities, the data may be accessible to authorized personnel of SA & CONSULTANTS and to service providers necessary for the operation of the site and the performance of the services:
· Shopify, for hosting and e-commerce functions;
· payment service providers offered at the time of ordering, for collection, security, and fraud prevention;
· the carriers and logistics providers selected for delivery and returns;
· messaging, hosting, backup, customer support, and newsletter delivery service providers;
· audience measurement tools and, only after consent where required, advertising platforms such as Google, Meta, or Microsoft when they are actually activated;
· professional advisors, insurers, auditors, and technical service providers bound by confidentiality;
· administrative or judicial authorities when required by a rule of law, a decision, or the defense of our rights.
These recipients only receive the data necessary for their mission. When they act on our behalf, they are bound by confidentiality, security, and data protection commitments. Some service providers, particularly payment providers, may also act as independent data controllers for their own legal obligations; their policy then applies to these operations.
We do not sell your personal data.
7 Transfers outside the European Economic Area
Certain international service providers, notably Shopify or technical and advertising service providers, may process data in countries located outside the European Economic Area.
When the country in question benefits from an adequacy decision by the European Commission, the transfer is based on that decision. In other cases, we use a guarantee recognized by the GDPR, such as the European Commission’s standard contractual clauses, supplemented if necessary by additional measures. You may request information regarding the applicable guarantees by writing to contact@heritagehub.fr.
8 Cookies and other trackers
During your visit, cookies or comparable technologies may be placed or read on your device. They are classified according to the following purposes:
· strictly necessary cookies: security, login, shopping cart, language choice, ordering process, payment, and saving your privacy preferences;
· audience measurement cookies: understanding site usage and improving performance;
· personalization cookies: adapting the display or certain features;
· advertising cookies: measuring campaigns, frequency capping, audience creation, and personalizing ads.
Strictly necessary cookies are placed without consent when they are essential for the requested service. Other trackers are only used after your consent, unless they meet all the conditions for an exemption provided by regulation.
During your first visit, the banner allows you to accept, refuse, or configure trackers by purpose. Refusing must be as simple as accepting. You can modify your choice at any time using the "Manage my cookies" link available in the footer. Withdrawing consent does not affect the lawfulness of processing carried out previously.
Trackers subject to consent have a maximum lifespan of thirteen months. Your choice is retained for a limited period, in principle six months, after which your consent may be requested again. The detailed and updated list of trackers, their providers, purposes, and durations is accessible in the site’s cookie manager.
Browser "Do Not Track" settings do not correspond to a uniform legal standard. Your choices expressed in the cookie manager remain the reference method for the site.
9 Commercial prospecting
The newsletter is sent to individuals who have consented to it. Each message contains an unsubscribe link. Customers may also receive offers regarding products or services similar to those already purchased, within the limits authorized by law and with the option to object simply and free of charge.
You can withdraw your consent or object to prospecting at any time using the link provided in the messages or by writing to contact@heritagehub.fr.
10 Your rights
Under the conditions provided for by the GDPR and the Data Protection Act, you may exercise:
· the right to access your data and obtain a copy;
· the right to have inaccurate or incomplete data rectified;
· the right to request the deletion of data, when the legal conditions are met;
· the right to request the restriction of processing;
· the right to object to processing based on our legitimate interest, for reasons relating to your particular situation, and the absolute right to object to commercial prospecting;
· the right to the portability of data you have provided to us when processing is automated and based on consent or contract;
· the right to withdraw your consent at any time, without retroactive effect;
· the right to define directives regarding the fate of your data after your death, under the conditions provided for by French law.
Send your request to contact@heritagehub.fr or to SA & CONSULTANTS – Heritage Hub, 43 boulevard de Verdun, 92400 Courbevoie, France. Indicate the right exercised and the information allowing the data concerned to be identified. Proof of identity is only requested in case of reasonable doubt about your identity and only to the extent necessary.
We respond in principle within one month. This period may be extended by two months when the request is complex or numerous; you will be informed of this within the first month.
You may lodge a complaint with the Commission nationale de l’informatique et des libertés, CNIL, at www.cnil.fr or by mail to CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France.
11 Security and confidentiality
We implement technical and organizational measures proportionate to the risks in order to protect data against destruction, loss, alteration, disclosure, or unauthorized access. These measures include management of authorizations, securing access, backups, system updates, and contractual oversight of service providers.
No system, however, offers absolute security. In the event of a breach likely to create a risk to rights and freedoms, we apply the obligations of documentation, notification, and, when required, informing the individuals concerned.
12 Minors
The site is not specifically intended for minors and we do not seek to knowingly collect their data. If you believe that a minor has transmitted data to us without appropriate authorization, contact us so that we may examine the situation.
13 Automated decisions
SA & CONSULTANTS does not make, based on data processed for Heritage Hub, any decision based exclusively on automated processing producing legal effects or similarly significantly affecting an individual. Fraud prevention tools may generate indicators or lead a payment provider to refuse a transaction in accordance with its own obligations and policy.
14 Social networks and external links
The site may contain links or buttons leading to social networks or third-party sites. When you use them, these third parties process your data according to their own policies. The simple display of a link should not result in the placement of non-essential trackers before your consent.
15 Policy update
We may modify this policy to reflect changes in our processing, tools, or regulations. The update date appears at the top of the document. In the event of a substantial modification, appropriate information is presented on the site or sent to the concerned individuals when necessary.