Privacy Policy and Personal Data Protection

Version updated: May 2026 – Compliant with the GDPR (EU Regulation 2016/679), the French Data Protection Act (Loi Informatique et Libertés, as amended) and CNIL recommendations.

Article 1

Identity of the Data Controller

AVENUE DES VINS SAS, a simplified joint-stock company (Société par Actions Simplifiée) with share capital of €57,520, registered with the Paris Trade and Companies Register under number 523 018 588, whose registered office is at 12 rue Le Chatelier, 75017 Paris, is the data controller for personal data processing carried out through the website www.avenuedesvins.fr.

EU VAT Number

FR72523018588

Telephone

+33 (0)1 55 38 50 74

GDPR Contact

[email protected] or by post to the registered office address, for the attention of the Data Protection Officer.

Web Host

PROFILEO SAS (trading name 772424), Chemin du Petit Cabri, 13100 Le Tholonet - RCS Aix-en-Provence 481 998 730

Article 2

Data Collected, Purposes and Legal Bases

In accordance with Article 13 of the GDPR, we hereby inform you of the processing activities carried out:

Identification Data

Data Processed

Purpose

Creation and management of the customer account; verification of legal majority (18 years of age) required for the online sale of alcohol

Legal Basis

Performance of contract (Art. 6(1)(b)) + Legal obligation (Art. 6(1)(c))

Retention Period

3 years after the last account activity

Order Data

Data Processed

Order data and purchase history

Purpose

Processing, tracking and delivery of orders; after-sales service; accounting and tax obligations

Legal Basis

Performance of contract (Art. 6(1)(b)) + Legal obligation (Art. 6(1)(c))

Retention Period

Accounting records: 10 years (French Commercial Code, Art. L. 123-22)

Payment Data

Data Processed

Payment data

Purpose

Secure processing of transactions via a dedicated payment provider (not retained directly by Avenue des Vins)

Legal Basis

Performance of contract (Art. 6(1)(b))

Retention Period

Not retained directly – delegated to the payment service provider

Commercial Marketing

Data Processed

Purpose

Sending newsletters and personalised offers, following the collection of freely given, specific, informed and unambiguous consent

Legal Basis

Consent (Art. 6(1)(a)) - withdrawable at any time via the unsubscribe link

Retention Period

Until consent is withdrawn or after 3 years of inactivity

Browsing Data

Data Processed

Server logs, IP addresses, browsing data

Purpose

Website security, fraud prevention, performance improvement and audience analytics

Legal Basis

Legitimate interests (Art. 6(1)(f))

Retention Period

Maximum 13 months (CNIL)

Article 3

Recipients and Sub-processors

Your data may be shared with the following categories of recipients, bound to us by data protection contractual clauses in accordance with Article 28 of the GDPR:

Payment provider: secure processing of transactions

Web host – PROFILEO SAS (772424): hosting of the website and data on servers located in France

Delivery carriers and logistics providers: order delivery (DHL-UPS)

Email marketing tool: sending newsletters and commercial communications following consent

Audience analytics tool: website audience measurement using anonymised or pseudonymised data

Judicial and administrative authorities: only upon legal requisition or court order

Avenue des Vins SAS does not sell, rent or transfer your personal data to third parties for commercial purposes.

3.1 - Transfers outside the European Union

Some providers may be established outside the European Union. Any such transfer is governed by appropriate safeguards in accordance with Chapter V of the GDPR, in particular:

The standard contractual clauses adopted by the European Commission (Implementing Decision 2021/914/EU)

Adequacy decisions of the European Commission for countries recognised as providing an adequate level of protection

You may obtain a copy of the safeguards in place by contacting us at the address indicated in Article 1.

Article 4

Cookies and Trackers

Our website uses cookies and trackers. In accordance with CNIL deliberation no. 2020-091 of 17 September 2020, only cookies strictly necessary for the operation of the website are placed without prior consent. All others require your explicit agreement.

Strictly Necessary Cookies

Purpose

Website operation, shopping basket management, login session

Consent

Not required (exempt)

Max. Duration

Session or 13 months

Analytics Cookies

Purpose

Audience measurement, website improvement (anonymised statistics)

Consent

Required

Max. Duration

Maximum 13 months

Personalisation Cookies

Purpose

Remembering your browsing preferences

Consent

Required

Max. Duration

Maximum 13 months

Advertising / Social Media Cookies

Purpose

Remarketing, advertising targeting, social media sharing

Consent

Required

Max. Duration

Maximum 13 months

You may modify or withdraw your consent at any time via the cookie management tool (Axeptio) accessible at the bottom of every page of the website, or by configuring your browser settings. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

Article 5

Your Rights Regarding Your Personal Data

In accordance with the GDPR and the French Data Protection Act (Loi n°78-17 of 6 January 1978, as amended), you have the following rights:

Right of access (Art. 15 GDPR): to obtain confirmation that your data is being processed and to receive a copy thereof.

Right to rectification (Art. 16 GDPR): to have inaccurate or incomplete data corrected.

Right to erasure (Art. 17 GDPR): to request the deletion of your data, subject to legal retention obligations.

Right to restriction of processing (Art. 18 GDPR): to temporarily restrict the processing of your data.

Right to object (Art. 21 GDPR): to object to processing based on legitimate interests, in particular for direct marketing purposes.

Right to data portability (Art. 20 GDPR): to receive the data you have provided to us in a structured, machine-readable format, for processing based on consent or the performance of a contract.

Right to withdraw consent: to withdraw consent given at any time, without affecting the lawfulness of processing carried out prior to such withdrawal.

Exercising your rights: please send your request, together with a copy of your proof of identity, to [email protected] or by post to: AVENUE DES VINS SAS - 12 rue Le Chatelier, 75017 Paris, for the attention of the Data Protection Officer.

We undertake to respond to your request within one (1) month of receipt of your complete request (Art. 12 GDPR), extendable by a further two months in cases of complexity.

Right to lodge a complaint: if you consider that your rights have not been respected, you may lodge a complaint with the CNIL – 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 - www.cnil.fr (Art. 13(2)(d) GDPR).

Article 6

Data Security

Avenue des Vins SAS implements appropriate technical and organisational measures in accordance with Article 32 of the GDPR, including:

Encryption of communications via TLS/SSL protocol

Hosting on servers located in France (PROFILEO SAS / 772424), equipped with physical and logical security measures

Rigorous management of internal access rights, applying the principle of least privilege

Pseudonymisation of data upon archiving

In the event of a personal data breach presenting a risk to your rights and freedoms, we will notify the CNIL within the 72-hour period set out under Article 33 of the GDPR. Where the breach is likely to result in a high risk to your rights and freedoms, you will be informed without undue delay in accordance with Article 34 of the GDPR.

Article 7

Specific Provisions Applicable to Online Alcohol Sales

LEGAL NOTICE – French Évin Act (no. 91-32 of 10 January 1991) and Public Health Code

Avenue des Vins is a platform dedicated to the sale of wines and spirits. In accordance with Articles L. 3342-1 and L. 3342-3 of the French Public Health Code:

The sale and delivery of alcohol is strictly prohibited to persons under the age of 18

Your date of birth is collected and processed solely for the purpose of verifying your legal majority, prior to any order being placed

By placing an order, you declare on your honour that you are at least 18 years of age and undertake not to have your order delivered to a person under the legal age

Your date of birth is retained for the duration of the contractual relationship, in accordance with the retention periods set out in Article 2

ALCOHOL ABUSE IS DANGEROUS FOR YOUR HEALTH. PLEASE DRINK RESPONSIBLY.

Article 8

Updates to this Policy

This privacy policy may be amended to remain compliant with legislative, regulatory and case law developments, or with changes to our services. Any material change will be notified by email or by a prominent notice on the website prior to taking effect. The update date shown at the top of this document shall prevail.

Avenue des Vins SAS - RCS Paris 523 018 588 - 12 rue Le Chatelier, 75017 Paris - +33 (0)1 55 38 50 74 — Last updated: May 2026