Privacy policy

Last modified: 27 December 2022

Respecting your privacy is an essential part of our commitment.


This privacy policy is intended to provide you with a transparent explanation of how we handle the personal information you entrust to us with care.

Our privacy policy aims to comply with the following legislation:

  • The General Data Protection Regulation (the GDPR) of the European Parliament and of the Council of 27 April 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data.
  • Any relative legislation applicable to bogarel.com regarding the protection of personal data.
Note on minors under 15 years old:

LE CLOS D EUGENIE SARL-S does not voluntarily process data concerning minors under the age of 15. Any personal data of a minor under the age of 15 will be deleted immediately. Any user of the bogarel.com website is required to ensure that no minor under the age of 15 transmits any personal data.



Summary
  1. What is the scope of this privacy policy? 
  2. Who is the data controller?
  3. What personal data is processed? For what purposes? Who is concerned by the processing of personal data? What is the legal basis for the processing? How long is the data kept?
  4. What are the rights of a person concerned by the processing of personal data by ?
  5. Can the company LE CLOS D EUGENIE SARL-S refuse a data subject the exercise of his rights?
  6. How can a data subject exercise their rights?
  7. Are cookies used by the site of LE CLOS D EUGENIE SARL-S?
  8. Who are the recipients of the personal data?
  9. Where is the personal data hosted and is it kept secure?
  10. Is the data transferred outside the European Union?
  11. Update of this privacy policy


1. What is the scope of this privacy policy? 

This privacy policy applies to all personal data processed by the data controller, LE CLOS D EUGENIE SARL-S, in the context of the use of the services provided by it, in particular through the website operated at the address bogarel.com.



2. Who is the data controller? 

The data controller is the company LE CLOS D EUGENIE SARL-S with a capital of 10 000€, having its registered office at the following address: 31, Porte de France L-4360 Esch-sur-Alzette registered with the Luxembourg Register of Companies, under the number L33409477, telephone number: ++33 6 12 24 57 84, e-mail address: contact@bogarel.com.



3. What personal data is processed? For what purposes? Who is concerned by the processing of personal data? What is the legal basis for the processing? How long is the data kept?

The company LE CLOS D EUGENIE SARL-S, responsible for the processing, minimises the collection of all personal data and ensures that it only processes personal data that is strictly necessary for the purposes for which it is collected.

The main characteristics of the personal data processing activities are the following:

In order to respond to requests made via the contact form.

  • Legal basis: Legitimate interest of LE CLOS D EUGENIE SARL-S to respond to persons who make requests.
  • Categories of processed personal data affected by the processing: first name, last name, email address, phone number (not recquired), message subject, message
  • Person affected by the processing of personal data: users of the bogarel.com website who have made a request via our contact form
  • Storage time: 6 months from the last contact
In order to send our emailing campaigns to people who have subscribed to our newsletter.

  • Legal basis: User consent to receive our email campaigns
  • Categories of processed personal data affected by the processing: Email / Last name / First name / Date of subscription / Frequency of emailing desired
  • Person affected by the processing of personal data: Users of the website who have subscribed to our newsletter.
  • Storage time: 36 months from the subscription date
In order to send our commercial offers to people who have agreed to receive our commercial offers when registering for a customer account on our website, or when subscribing to our newsletter.

  • Legal basis: (1) Consent of the user to receive our commercial offers. (2) Legitimate interest of LE CLOS D'EUGENIE SARL-S to carry out prospecting (only to offer similar products or services to people who have already placed orders).
  • Categories of processed personal data affected by the processing: Last name / First name / Email / Consent date / Last order date
  • Person affected by the processing of personal data: Users of the website who have agreed to receive our commercial offers by subscribing to our newsletter, or by registering for a customer account on our website. Customers who have placed an order on bogarel.com.
  • Storage time: 36 months maximum from last contact or last order placed
Using cookies

Monitoring data security breaches.

  • Legal basis: Legal obligation to ensure compliance with applicable data protection provisions
  • Categories of processed personal data affected by the processing: Last name / First name / Email address / Address / Login date
  • Person affected by the processing of personal data: Data subjects whose personal data have been subject to a security breach
  • Storage time: 12 months maximum
Ensure the effectiveness of the rights of data subjects and ensure the identity of data subjects who exercise their rights under the applicable data protection regulations.

  • Legal basis: Legal obligation to ensure compliance with applicable data protection provisions.
  • Categories of processed personal data affected by the processing: Last name / First name / Address / Customer account details if any / Copy of an identity document if necessary
  • Person affected by the processing of personal data: Persons who asserts one of their rights under the GDPR 
  • Storage time : 13 months maximum (except for identity papers: maximum 1 month)
In order to publish the comment left by the user on the corporate blog of the bogarel.com website

  • Legal basis : Legitimate interest of the company LE CLOS D'EUGENIE SARL-S to operate the company blog (freedom of expression).
  • Categories of processed personal data affected by the processing: Last name / First name / Screen name / Date and hours of the message / Message
  • Person affected by the processing of personal data: Internet users who comment on the blog
  • Storage time: 5 years
In order to publish the testimonial left by an adopter on the bogarel.com website

  • Legal basis: Legitimate interest of the company LE CLOS D'EUGENIE SARL-S to operate the guestbook of the company.
  • Categories of processed personal data affected by the processing: Last name / First name / Screen name / Email / Phone number / Date and hours of the message / Message
  • Person affected by the processing of personal data: Adopters who leave a testimonial
  • Storage: 5 years from the last testimony left unless the person concerned gives their express consent.

In order to have a Facebook and Pinterest shop: 

In order to view user sessions and optimise the user experience: 


Where the processing is based solely on the consent of the data subject, the latter may at any time withdraw their consent by simple request sent to LE CLOS D EUGENIE SARL-S in the manner detailed in section Article 6.


The company LE CLOS D'EUGENIE SARL-S does not process sensitive data in the sense of the provisions of the applicable regulations on the protection of personal data without having a legal authorisation or the express consent of the person concerned.

When a person proceeds directly to the input of personal data (in particular by means of a digital form or on line) or by sending electronic emails, the information concerning them is provided with full knowledge of the facts and under their responsibility as to its content and accuracy.

The fields marked with an * in any digital or online form concern personal data that must be provided. Failure to respond to the data marked with an * in any form may result in LE CLOS D EUGENIE SARL-S being unable to respond to the request made. 



4.  What are the rights of a person concerned by a processing of their personal data by LE CLOS D'EUGENIE SARL-S?

4.1. A right of access to their data
The data subject has the right to obtain from LE CLOS D'EUGENIE SARL-S confirmation as to whether or not personal data relating to them are being processed and, where they are, access to such personal data as well as the following information:

  • The purposes of the processing;;
  • The categories of personal data concerned;
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients who are established in third countries or international organisations;
  • Where possible, the period for which the personal data is to be kept or, where this is not possible, the criteria used to determine this period;
  • The existence of the right to request from the controller the rectification or erasure of personal data, or a restriction on the processing of personal data relating to the data subject, or the right to object to such processing;
  • The right to register a complaint with a supervisory authority;
  • Where personal data are not collected from the data subject, any available information as to their source;
  • The existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4) of Regulation (EU) 2016/679 "General Data Protection Regulation", and, at least in such cases, relevant information about the underlying logic, as well as the significance and intended consequences of such processing for the data subject.
  • Where personal data is transferred to a third country or to an international organisation, the data subject has the right to be informed of the appropriate safeguards, pursuant to Article 46 of Regulation (EU) 2016/679 "General Data Protection Regulation", in relation to that transfer.

In the event of exercising the right of access, LE CLOS D'EUGENIE SARL-S will provide a copy of the personal data being processed, unless such copy infringes the copyright or rights of third parties.

LE CLOS D EUGENIE SARL-S may charge a reasonable fee based on administrative costs for any additional copies requested by the data subject.

4.2. A right of rectification

The data subject has the right to obtain from LE CLOS D'EUGENIE SARL-S, as soon as possible: 

  • The rectification of personal data concerning them which are inaccurate. 
  • Given the purposes of the processing, that incomplete personal data be completed, including by providing a supplementary declaration.

4.3. A right to be forgotten

The data subject shall have the right to obtain from the LE CLOS D EUGENIE SARL-S the erasure, as soon as possible and except for the cases referred to in Article 17.3 of the Regulation (EU) 2016/679 "General Data Protection Regulation", of personal data concerning them, where one of the following reasons applies:

  • The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
  • The data subject withdraws the consent on which the processing is based, in accordance with Article 6(1)(a) of Regulation (EU) 2016/679" General Data Protection Regulation", or Article 9(2)(a) of Regulation (EU) 2016/679 "General Data Protection Regulation", and there is no other legal basis for the processing;
  • The data subject objects to the processing pursuant to Article 21(1) of Regulation (EU) 2016/679 "General Data Protection Regulation", and there is no compelling legitimate reason for the processing, or the data subject objects to the processing pursuant to Article 21(2) of Regulation (EU) 2016/679 "General Data Protection Regulation";
  • The personal data have been processed unlawfully;
  • The personal data must be erased in order to comply with a legal obligation which is provided for by Union law or by the law of the Member State to which the controller is subject;
  • The personal data were collected in the context of offering information society services referred to in Article 8(1) of Regulation (EU) 2016/679 "General Data Protection Regulation".
The right to be forgotten does not apply where the processing is or continues to be necessary:

  • To exercise the right to freedom of expression and information;
  • To comply with a legal obligation which requires the processing laid down by Union law or by the law of the Member State to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • For reasons of public interest in the field of public health, in accordance with Article 9(2)(h) and (i) of Regulation (EU) 2016/679 "General Data Protection Regulation", as well as Article 9(3) of Regulation (EU) 2016/679 "General Data Protection Regulation";
  • For archival purposes in the public interest, for scientific or historical research purposes or for statistical purposes in accordance with Article 89, paragraph 1 of Regulation (EU) 2016/679 "General Data Protection Regulation", insofar as the right referred to in paragraph 1 is likely to make it impossible or seriously compromise the achievement of the purposes of the said processing;
  • For the establishment, exercise or defence of legal claims.

4.4. A right to the limitation of processing

The data subject shall have the right to obtain from the LE CLOS D'EUGENIE SARL-S the restriction of the processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period allowing the controller to verify the accuracy of the personal data;
  • The processing is unlawful and the data subject objects to the erasure of the personal data and demands instead the restriction of their use;
  • The controller no longer needs the personal data for the purposes of the processing, but they are still necessary for the data subject to establish, exercise or defend legal claims;
  • The data subject has objected to the processing by virtue of their right to, during the verification of whether the legitimate grounds pursued by the controller prevail over those of the data subject.
4.5. A right to object

THE DATA SUBJECT SHALL HAVE THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO THEIR PARTICULAR SITUATION, TO THE PROCESSING OF PERSONAL DATA CONCERNING THEM WHERE :

  • THE PROCESSING IS NECESSARY FOR THE PERFORMANCE OF A TASK CARRIED OUT IN THE PUBLIC INTEREST OR IN THE EXERCISE OF OFFICIAL AUTHORITY VESTED IN THE CONTROLLER
  • THE PROCESSING IS NECESSARY FOR THE PURPOSES OF THE LEGITIMATE INTERESTS PURSUED BY THE CONTROLLER OR BY A THIRD PARTY, UNLESS THE INTERESTS OR FUNDAMENTAL RIGHTS AND FREEDOMS OF THE DATA SUBJECT WHICH REQUIRE PROTECTION OF PERSONAL DATA PREVAIL, IN PARTICULAR WHERE THE DATA SUBJECT IS A CHILD;
  • THE PROCESSING IS CARRIED OUT FOR THE PURPOSE OF COMMERCIAL CANVASSING AT ANY TIME, INCLUDING PROFILING INSOFAR AS IT IS RELATED TO SUCH CANVASSING.
THE CONTROLLER SHALL NO LONGER PROCESS THE PERSONAL DATA UNLESS THEY CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE THE INTERESTS AND RIGHTS AND FREEDOMS OF THE DATA SUBJECT, OR FOR THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS, EXCEPT IN THE CASE OF COMMERCIAL CANVASSING.

WHERE PERSONAL DATA ARE PROCESSED BY CLOS D'EUGENIE LIMITED FOR SCIENTIFIC OR HISTORICAL RESEARCH OR STATISTICAL PURPOSES, THE DATA SUBJECT SHALL HAVE THE RIGHT TO OBJECT, ON GROUNDS RELATING TO THEIR PARTICULAR SITUATION, TO THE PROCESSING OF PERSONAL DATA CONCERNING THEM, UNLESS THE PROCESSING IS NECESSARY FOR THE PERFORMANCE OF A TASK CARRIED OUT IN THE PUBLIC INTEREST.

4.6. A right to data portability

The data subject shall have the right to receive the personal data concerning them that he or she has provided to LE CLOS D'EUGENIE SARL-S, in a structured, commonly used and machine-readable format, and shall have the right to transmit such data to another controller without LE CLOS D'EUGENIE SARL-S, to whom the personal data have been communicated, objecting thereto, where:

  • The processing is based on consent pursuant to Article 6(1)(a) of Regulation (EU) 2016/679 "General Data Protection Regulation" or Article 9(2)(a) of Regulation (EU) 2016/679 "General Data Protection Regulation", or on a contract pursuant to Article 6(1)(b) of Regulation (EU) 2016/679 "General Data Protection Regulation";

  • The processing is carried out using automated processes.

4.7. For data subjects residing in France, a right to define directives regarding the fate of the data after their death

The person concerned by the processing of their data has the right to define directives relating to the conservation, erasure and communication of their personal data after their death.

4.8. Absence of any automated individual decision, including profiling

The LE CLOS D'EUGENIE SARL-S does not carry out any decision-making based exclusively on automated processing, including profiling, which produces legal effects with regard to the data subject or which significantly affects them in a similar way.



5. May the LE CLOS D EUGENIE SARL-S refuse a data subject the exercise of their rights?

The LE CLOS D EUGENIE SARL-S may refuse the exercise of rights by a data subject where:

  • The data subject does not allow LE CLOS D EUGENIE SARL-S to be sure that the data subject is identified;
  • The requests made by a data subject are manifestly disproportionate or excessive because of their repetitive or systematic nature.


6. How can a data subject exercise their rights?

Rights can be exercised by writing to LE CLOS D EUGENIE SARL-S by post to 31, Porte de France L-4360 Esch-sur-Alzette or by email to contact@bogarel.com.

In the event of reasonable doubt(s) as to the identity of the person concerned, LE CLOS D EUGENIE SARL-S may request a copy of an identity document in order to ensure the exact identity of the person making any request and to avoid the communication of data to an illegitimate third party.

If the answer brought by LE CLOS D'EUGENIE SARL-S should not satisfy the person concerned, the latter is informed by the present policy that they can address a complaint to the authority of control of the place of their usual residence, their place of work or the place where the violation would have been committed by mail or directly on the site of the authority of control, namely

In Europe :

  • In France:  Commission Nationale de l'Informatique et des Libertés 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07 or https://www.cnil.fr/fr/plaintes
  • In Germany: die bundesbeauftragte für den datenschutz und die informationsfreiheit, Graurheindorfer Str. 153, 53117 Bonn, Germany or https://www.bfdi.bund.de/DE/Home/home_node.html
  • In United-Kingdom: Information Commissioner's Office, Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK ou https://ico.org.uk/
  • In Italy: Garante per la protezione dei dati personali, la Piazza Venezia 11, 00187 Roma, Italia or https://www.garanteprivacy.it/
  • In Spain: Agencia Española de Protección de Datos, Jorge Juan 6, 28001 Madrid, Spain or https://www.aepd.es/es
  • In Portugal: Comissão nacional de proteção de dados, Ave. D. Carlos I 134-1°, 1200-151 Lisboa, Portugal or https://www.cnpd.pt/
  • In Belgium: Autorité de protection des données Rue de la Presse 35 - 1000 BRUXELLES, or www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plaint
  • In Luxembourg: Commission nationale pour la protection des données, Service des réclamations- 15, Boulevard du Jazz, L-4370 Belvaux or https://cnpd.public.lu/fr/particuliers/faire-valoir/formulaire-plainte.html
  • In Switzerland: Préposé fédéral à la protection des données et à la transparence, Feideggwerg 1, 3003 Berne, Suisse or https://www.edoeb.admin.ch/edoeb/fr/home.html
  • In Netherlands: Dutch Data Protection Authority, Postbus 93374, 2509 AJ, DEN HAAG, Netherlands or https://www.autoriteitpersoonsgegevens.nl/ 

Abroad: 

  • In the United-States: Federal Trade Commission 600 Pennsylvania Ave, NW, Washington, DC 20580, États-Unis or https://www.ftc.gov/tips-advice/business-center/privacy-and-security/privacy-shield
  • In Mexico: Instituto Federal de Acceso a la Información y Protección de Datos, Av. Insurgentes Sur #3211 Col. Insurgentes Cuicuilco, Delegación Coyoacán, C.P. 04530, Distrito Federal, Mexico or https://home.inai.org.mx/
  • In Australia : Office of the Australian Information Commissioner, GPO Box, 5218 Sydney NSW 2001, Australia, or https://www.oaic.gov.au/
  • In Canada: Commissariat à la Protection de la vie privée au Canada, 30 rue de Victoria, Gatineau, Québec, K1A 1H3, Canada or https://www.priv.gc.ca/fr/
  • In Japan: Personal Information Protection Commission, 1-9-13, Akasaka Minato-Ku, Tokyo 107-0052, Japon, or https://www.ppc.go.jp/en/
  • In South Korea: Personal Information Protection Commission, 209 Sejong-ro, Jongno-gu, Seoul, 110-760, Corée, or http://www.pipc.go.kr/cmt/main/english.do 


7. Are cookies used by the LE CLOS D'EUGENIE SARL-S website?

We use cookies on our website bogarel.com.

To find out more about the cookies we use, and how we ensure the secure processing of the data we collect, please see our Cookies Policy.



8. Who are the recipients of the personal data?

LE CLOS D'EUGENIE SARL-S only communicates personal data to authorised and determined recipients. The recipients may be the following:

  • Enterprise LE CLOS D EUGENIE SARL-S*
  • Governmental or judicial authority upon request or legal obligation (notably in the fight against money laundering or fraud).
  • To the successor of LE CLOS D'EUGENIE SARL-S, in particular in the event of a takeover of LE CLOS D'EUGENIE SARL-S or the transfer of the company as a result of a merger, takeover, demerger, universal transfer of assets, transfer of shares or the takeover of all or a substantial part of the assets of LE CLOS D'EUGENIE SARL-S.


9. Where is personal data hosted and is it kept secure?

LE CLOS D EUGENIE SARL-S implements all appropriate measures to prevent as far as possible any alteration or loss of personal data or any unauthorised access to them.

The company LE CLOS D EUGENIE SARL-S pays particular attention to the storage of personal data and requests from its service providers a commitment of conformity to the applicable provisions in data protection. It thus endeavours, as far as possible, to store the data in France or in a member country of the European Union, except if the data given by the person concerned was entered by them in a third country. The data is currently hosted by:

  • LE CLOS D EUGENIE LIMITED / The categories of personal data concerned: All data referred to in Article 3
  • Prestashop / The categories of personal data concerned: Data collected via the newsletter registration form, via the contact form
  • Lodago / The categories of personal data concerned: Data collected via the newsletter registration form
  • Google Analytics / The categories of personal data concerned: Data collected through cookies. See Cookies policy
  • Proton Mail / The categories of personal data concerned:  E-mail exchanges between Internet users and the company LE CLOS D EUGENIE SARL-S
  • Gmail / The categories of personal data concerned: E-mail exchanges between Internet users and the company LE CLOS D EUGENIE SARL-S
  • Hotjar / Categories of personal data processed and concerned : Data collected through cookies. See Cookies policy
  • Google Tag Manager / Categories of personal data processed and concerned : Data collected through cookies. See Cookies policy
However, it is up to the person concerned to ensure the confidentiality of their login and password for access to the site operated by LE CLOS D EUGENIE SARL-S, which cannot be held responsible if a third party has illegitimate access to this data due to a fault or negligence on the part of the person concerned. 



10. Is the data the object of a transfer outside the European Union?

The personal data processed by the company LE CLOS D EUGENIE SARL-S is not subject to a transfer outside the EU.



11. Updating of this data privacy policy

LE CLOS D EUGENIE SARL-S regularly updates this privacy policy in line with legal developments. Any updates will be available on this page.

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