General policy on the protection of personal data

EVELIA, SASU, whose registered office is located at 6 Impasse de la Renardière, La Varenne, 49270 Orée-d'Anjou, registered under number RCS Angers B 380619759, a subsidiary of the TERRENA Group (hereinafter “EVELIA”), processes personal data (as defined below) in the course of its business.

  • This Personal Data Protection Policy (the “Policy”) describes how EVELIA collects, uses and processes your personal data, in compliance with the applicable regulations. EVELIA values your privacy and is committed to protecting and preserving your data confidentiality rights.
  • This Policy applies to the personal data we may collect from our customers, suppliers and service providers in the context of performing all types of commercial contracts. It also applies to the personal data of users of our various websites, people applying for our job offers, and any other individuals whom we may legitimately contact in the course of EVELIA’s activities.
  • Under the applicable personal data protection regulations, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and French Law No. 78-17 of 6 January 1978 on information technology, files and liberties, as amended (together, the “Personal Data Regulations”), the entity responsible for your personal data is EVELIA.
  • EVELIA may amend this Policy. Please visit this page regularly to review any changes we may publish.
  • If you disagree with certain aspects of our Policy, you have legal rights which are explained where necessary.

Table of contents:

  • 1. Introduction
  • 2. Definitions
  • 3. Collection of personal data
  • 4. Protection of personal data of minors
  • 5. Purposes of collecting personal data
  • 6. Recipients of personal data
  • 7. Transfer of personal data outside the European Union
  • 8. Security of personal data
  • 9. Rights regarding data
  • 10. Easy contact for exercising rights
  • 11. Updating the policy

1. Introduction

The personal data protection policy is based on the non-exhaustive principles listed below:

  • Comply with optional standards and the recommendations of the Commission Nationale de l’Informatique et des Libertés (CNIL) and the Agence Nationale de la Sécurité des Systèmes d’Information (ANSSI), while meeting EVELIA’s operational needs;
  • Apply data protection rules from the design and implementation stages (“Privacy by design”, “Privacy by default”) of new products intended to process personal data and reduce data collection to what is strictly necessary (“data minimization”);
  • Continuously monitor compliance with legal obligations and EVELIA’s commitments throughout the lifecycle of computerized data processing;
  • Ensure the greatest transparency regarding data processing, except for information whose disclosure could compromise security;
  • Strengthen data subjects’ rights and facilitate their exercise.

2. Definitions

Personal data”: Any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to that person’s physical, physiological, genetic, mental, economic, cultural or social identity.

Data subject”: A natural person whose personal data is processed as indicated in Article 4.

Data Controller”: A natural or legal person which, alone or jointly with others, determines the purposes and means of the processing it uses. The Data Controller is, as a rule, the Terrena entity that collected the personal data. If the Terrena cooperative, the parent company of the Terrena Group, provides technical, administrative, marketing or commercial support to this entity, the Terrena cooperative may also be considered a Data Controller.

Data processing”: Operations performed, whether or not by automated means, on personal data, including collection, recording, use, transmission or disclosure.

Processor”: A natural or legal person, public authority, service or other body which processes personal data on behalf of the Data Controller.

Recipient”: A natural or legal person, public authority, internal or external department or other body to which personal data is disclosed.

TERRENA”: The Terrena cooperative and its subsidiaries.

3. Collection of personal data

The personal data that EVELIA may collect varies depending on the purpose of the processing. It is primarily intended to enable the identification of individuals in the context of their relationship with EVELIA.

In any event, the personal data collected will be limited to what is necessary for the purposes set out in Article 5 below.

Data subjects

The data subjects of the processing carried out by EVELIA are:

  • Visitors, users and customers of its websites
  • Customers (members and non-members) of SCA Terrena and its subsidiaries
  • In-store customers who identify themselves with their loyalty card
  • Participants in contests, lotteries, special operations online or in-store
  • Participants in surveys, polls or panels
  • Recipients of promotional, online or commercial prospecting operations
  • Suppliers and service providers
  • Applicants and employees

Collection of personal data

Data may be collected directly from data subjects in various ways, including via:

  • Contracts concluded with EVELIA;
  • Quotes during pre-contractual relations;
  • Appointments;
  • Paper or web forms through the websites;
  • Cookies present on the data subjects’ web browsers.

In the event of indirect data collection from third parties (e.g., purchased lists, publicly accessible sources), EVELIA will inform data subjects at first contact and, at the latest, within one month, unless the data subjects already have this information.

Note to visitors and users of its websites: certain features and characteristics of its websites can only be used if certain personal data is provided. Users are free to provide all or part of the requested personal data. However, if users decide not to provide it, such a decision could prevent the satisfactory achievement of the objectives described in Article 5 below, certain services and features of our websites may not function properly and/or users may be denied access to certain pages of the sites.

Data relating to customers (members and non-members):

The data that EVELIA collects about its customers is limited. As a rule, EVELIA needs the contact details of contacts within the customer or prospect company (notably their name, phone number, and email and postal addresses) in order to perform the contracts concluded with its customers. As part of customer satisfaction surveys, EVELIA also holds information relating to customers’ needs or constraints, which EVELIA may then use to ensure that marketing communications to them are relevant and timely. EVELIA may also hold additional information that contacts within customer organizations have chosen to provide, notably through loyalty programs. In certain circumstances, when customers interact with certain EVELIA services or departments, calls may be recorded, in accordance with applicable local laws and requirements.

Data relating to suppliers and service providers:

EVELIA also collects data about its suppliers and service providers. To properly manage our commercial relationships, EVELIA collects the details of contacts within the supplier or service provider company, such as their name, phone number, and email and postal addresses. EVELIA may also hold additional information that contacts within the supplier or service provider company have chosen to provide.

Data relating to HR management:

For applicants applying for positions at EVELIA, various types of information that allow the analysis of applications with respect to the positions offered are collected, including identity, personal contact details, elements of professional background, degrees, and motivations.

EVELIA also collects all information useful for proper personnel management, including identity, civil status, personal contact details, elements of professional background, degrees, bank details, social security, administrative information in accordance with legal and regulatory provisions.

Data relating to users of its various websites:

EVELIA collects from users of its various websites personal data that is used to improve the use of its sites and manage the services that EVELIA provides. This information includes in particular how its sites are used, how frequently users access them, the type of browser, the location from which users visit EVELIA’s sites, the language used and the hours when the sites are most visited.

4. Protection of personal data of minors

EVELIA’s products and services are intended for adults and are not designed to be marketed to minors, and EVELIA does not knowingly collect or retain Personal Data of minors, except as part of information relating to its personnel management.

5. Purposes of collecting personal data

Personal data is collected for the needs of EVELIA’s business such as the performance of contracts concluded with its customers (members or non-members), its suppliers and other service providers or any third party, for its legitimate interests or to comply with legal reporting obligations, as well as for recruiting employees and managing EVELIA employees.

EVELIA collects and uses personal data for the needs of its activities and notably to enable the performance of the following activities:

Purposes Legal basis Retention period
Regarding use of the websites
Provide the Websites, and the products and services offered on the Websites Performance of pre-contractual measures taken at the request of Users and/or Customers and/or performance of the contract Time necessary to achieve the purpose of the processing and for an additional period of five (5) years
Respond to requests expressed via forms or using the contact methods available on the websites Performance of pre-contractual measures taken at the request of Users and/or Customers and/or performance of the contract Time necessary to achieve the purpose of the processing and for an additional period of five (5) years
Regarding all customers (members and non-members) for customer relationship management
Create and manage customer accounts to enable issuing quotes, managing orders, reservations, delivery and invoicing of products, services and solutions Performance of pre-contractual measures taken at the request of Users and/or Customers and/or performance of the contract Five (5) years from the customer’s last activity, then archived for an additional period of five (5) years
Handle requests, questions, complaints Performance of pre-contractual measures taken at the request of Users and/or Customers and/or performance of the contract Five (5) years from each request, question or complaint
Know and profile customers, track the relationship, improve and personalize communications, offers and advice, carry out statistical studies Legitimate interest Five (5) years from the customer’s last activity, then archived for an additional period of five (5) years
Use personal data in the capacity of customer in order to be recognized as such by other services offered by other companies of the Terrena group Legitimate interest Five (5) years from the customer’s last activity, then archived for an additional period of five (5) years
Provide digital tools, services for managing financial activity and regulatory data, and maintain the security of these tools Legitimate interest Five (5) years from the customer’s last activity, then archived for an additional period of five (5) years
Manage commercial prospecting by post and by telephone or electronic prospecting for similar products and services Legitimate interest Three (3) years from your last activity, then destruction
Regarding all suppliers
Manage purchasing and supplies:

* Order management

* Tracking and management of purchases and stocks

* Performance management and operating account management

* Management of store supplies

* Invoice generation

Legitimate interest Five (5) years from the supplier’s last activity, then archived for an additional period of five (5) years
Regarding marketing and prospecting
Send promotions and offers, personalized or not, by electronic means Consent Three (3) years from the last activity
Participation in contests, lotteries, pooled funds Performance of pre-contractual measures taken at your request and/or performance of the contract Three (3) years from the closing of the relevant contest
Implement profiling to improve customer knowledge (Establishment of your profile, combination of online and offline purchasing and informational data, segmentation, studies and analyses to better understand people’s expectations in terms of services, products or offers) Legitimate interest Personal purchase data used for this purpose is kept for 24 months from the date of your purchase.

Other personal data used for this purpose is kept as long as you have a customer account or a loyalty account, never exceeding 5 years from your last activity.

Regarding all applicants
Analysis of applications in relation to the positions offered Legitimate interest 1 month if the applicant is not selected, with the possibility of inclusion in the CV database for a maximum of 2 years
Regarding compliance with legal and regulatory obligations, defense of its rights, safeguarding its interests and combating fraud
Accounting and tax: Retention of invoices and other mandatory documents as part of general accounting management and tax obligations Compliance with legal and regulatory obligations Personal data processed for accounting and tax obligations is kept for a period corresponding to the current financial year plus one (1) year, then archived for a period of ten (10) years
Exercise of Users’ and/or Customers’ rights: Management of rights requests (communications, extracts of the required information) Compliance with legal and regulatory obligations Personal data relating to rights requests is kept for three (3) or six (6) years from the request, depending on the right exercised. Where collection of an identity document was necessary, it is deleted as soon as the verification has been completed.
Defense of EVELIA’s rights and combating fraud: Establishment and retention of evidence necessary for the defense of rights in the context of actions and claims brought against it by Users and/or Customers and combating fraud Legitimate interest Personal data necessary to establish and retain evidence necessary for the defense of rights is kept for the duration of the applicable limitation periods, or for the entire duration of any dispute or litigation, until a final decision with res judicata effect has been rendered.
Public and judicial authorities: Management of requests from public or judicial authorities and communications with the authorities Legitimate interest Personal data relating to the management of authority requests is kept for the entire duration of the procedure before the authority concerned, until a final decision with res judicata effect has been rendered.

If EVELIA is led to process Users’ and/or Customers’ personal data for purposes other than those listed in the table above, EVELIA will carry out any additional steps necessary to ensure the legal compliance of all processing thus carried out.

6. Recipients of personal data

To achieve the purposes described above and only to the extent necessary for these purposes, the personal data we collect may be transmitted to all or part of the following recipients:

Within the Terrena group:

  • To Terrena Group subsidiaries responsible for the awarding, management and performance of contracts and orders;
  • To Terrena Group subsidiaries responsible for marketing, customer relations, complaints, prospecting, administrative services, IT services, online advertising or commercial prospecting;
  • To Terrena Group subsidiaries responsible for centralized management of our customer databases;
  • To any other Terrena Group subsidiary whose involvement is necessary for the performance of processing implemented in accordance with this policy.

Outside the Terrena group:

  • To our service providers involved in all or part of the identified processing (notably IT providers responsible for maintaining the site, partners in the field of online advertising and personalized communications, those responsible for the shipment and delivery of products);
  • To our partners who operate services available on our site or services accessible as part of the use of loyalty programs;
  • To our partners who sell products or services directly from our site;
  • To our partners involved in carrying out and sending commercial prospecting campaigns;
  • To our partners involved in delivering personalized online advertising or commercial prospecting;
  • A list of product and service providers of Terrena Group partner brands that may receive your personal data is available here.

7. Transfer of personal data outside the European Union

EVELIA is committed to ensuring that data is stored and transferred securely. Consequently, data that may occasionally be transferred outside the European Economic Area or EEA (comprising the member states of the European Union plus Norway, Iceland and Liechtenstein) will only be transferred to countries that comply with data protection legislation and where transfer mechanisms ensure an adequate level of protection for your data.

To ensure that personal information receives an adequate level of protection, appropriate procedures are in place with third parties with whom personal data is shared to ensure that personal information is processed by these third parties in a manner consistent with and respectful of data protection laws.

8. Security of personal data

The “processing” of personal data includes, in particular, the use, storage, recording, transfer, adaptation, analysis, modification, reporting, sharing and destruction of personal data as necessary in view of the circumstances or legal requirements.

8.1 Securing data by TERRENA

TERRENA attaches particular importance to the security of personal data.

TERRENA implements technical and organizational measures, taking into account the degree of sensitivity of the personal data, to ensure the integrity and confidentiality of the data and to protect it against any malicious intrusion, loss, alteration or disclosure to unauthorized third parties.

Whenever possible and necessary, the following measures are taken:

  • Encryption;
  • Anonymization;
  • Pseudonymization;
  • Deployment of means to ensure the confidentiality, integrity and availability of systems;
  • Deployment of means to restore availability and access to your personal data in the event of a technical incident.

All personal data is confidential, and access is limited to employees, processors or business partners who need it in the course of their duties.

8.2 Securing data by the recipients of the data

When using applications, services or products provided by third parties, Terrena ensures with their publishers that they comply with legal requirements and ensure the protection of the data to be processed therein.

Thus, in accordance with its commitments, Terrena carefully selects its processors and service providers and requires them, in particular, to:

  • Provide a level of protection for personal data at least equivalent to its own;
  • Use personal data solely for managing the services they must provide;
  • Strictly comply with applicable confidentiality, banking secrecy and personal data legislation and regulations;
  • Implement all appropriate measures to ensure the protection of personal data they may process;
  • Define the technical and organizational measures necessary to ensure security.

If you suspect misuse, loss or unauthorized access to your personal information, please inform us immediately.

9. Rights regarding data

Article 15 of the General Data Protection Regulation recognizes the right of any natural person to obtain from the Data Controller confirmation as to whether or not personal data concerning them are being processed and, where that is the case, access to such data.

EVELIA has implemented appropriate personal data protection measures to ensure that personal data is used in accordance with the purposes indicated above and to ensure its accuracy and updating.

Right to object:

You may object at any time to our processing of your personal data.

Your objection will be handled promptly and we will cease the activity to which you object. However, we reserve the right not to cease the activity if:

  • We can demonstrate that we have compelling legitimate grounds for processing your data which override your interests; or
  • We process your data for the establishment, exercise or defense of legal claims.

If your objection concerns direct marketing, we must comply with your objection by ceasing this activity with respect to you.

Right to withdraw consent:

If we have obtained your consent to process your personal data for certain activities other than those for which no consent is required, you may withdraw this consent at any time and we will cease the specific activity to which you had consented, unless we consider that there is another reason justifying the continuation of our processing of your data for this purpose, in which case we will inform you.

Access requests:

You may at any time ask us to confirm the information we hold about you, and you may ask us to modify, update or delete it. We may ask you to verify your identity and request further information about your request. If we give you access to the information we hold about you, we will not charge for this access unless your request is “manifestly unfounded or excessive.” If you ask us for further copies of this information, we may charge reasonable administrative fees where permitted by law. Where permitted by law, we may refuse your request. If we do so, we will always justify this refusal.

Right to erasure:

You have the right to request that we erase your personal data in certain circumstances.

As a rule, the information in question must meet one of the following criteria:

  • The data is no longer necessary for the purposes for which we originally collected and/or processed it;
  • You have withdrawn your consent to the processing of your data and there is no other valid reason for us to continue processing it;
  • The data has been processed unlawfully;
  • The data must be erased in order for us to comply with our legal obligations as data controller; or
  • Where we process the data because we consider it necessary for our legitimate interests, you object and we are unable to demonstrate that there is a compelling legitimate ground to continue processing.

We would be entitled to refuse to comply with your request only for one of the following reasons:

  • To exercise the right to freedom of expression and information;
  • To comply with legal obligations;
  • For reasons of public health in the public interest;
  • For archiving, research or statistical purposes; or
  • To establish or defend legal claims.

When we respond to a valid request for erasure, we will take all appropriate practical steps to delete the data in question.

Right to restriction of processing:

You have the right to request that we restrict the processing of your personal data in certain circumstances. This means that we may only continue to retain your data and may not carry out further processing activities except in one of the following cases: (i) resolution of one of the circumstances listed below; (ii) your consent; or (iii) further processing is necessary for the establishment, exercise or defense of legal claims, to protect the rights of another person, or for important reasons of public interest of the European Union or a Member State.

The cases in which you are entitled to request that we restrict the processing of your personal data are as follows:

  • Where you contest the accuracy of the personal data we process about you. In this case, our processing of your personal data will be restricted while we verify the accuracy of the data;
  • Where you object to our processing of your personal data for our legitimate interests. You can request that the data be restricted while we verify our grounds for processing your personal data;
  • Where your data has been unlawfully processed by us, but you prefer that we restrict its processing rather than erase it; and
  • Where we no longer need to process your personal data but you request it in order to establish, exercise or defend legal claims.

If we have disclosed your personal data to third parties, we will inform them of the restriction unless this proves impossible or involves disproportionate effort. Of course, we will inform you before lifting any restriction on the processing of your personal data.

Right to rectification:

You also have the right to request that we rectify inaccurate or incomplete personal data that we hold about you. If we have disclosed this personal data to third parties, we will inform them of the rectification unless this proves impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed this inaccurate or incomplete personal data to. If we consider it reasonable not to comply with your request, we will give you the reasons for this decision.

Right to data portability:

If you wish, you have the right to transfer your personal data from one controller to another. In practical terms, this means that you are able to transfer the data to another online platform. To allow you to do so, we will provide your data in a readable format. This right to portability applies to the following data: (i) personal data that we process automatically (i.e., without human intervention); (ii) personal data that you provide; and (iii) personal data that we process on the basis of your consent or in the performance of a contract.

Right to define general or specific directives relating to the storage, erasure or communication of your personal data after the death of a User and/or a Customer:

You may define general or specific directives on how you wish the rights guaranteed to you by the applicable regulations to be exercised after your death.

General directives concern all personal data relating to you and you may revoke them at any time. They may be registered with a trusted digital third party certified by the Commission Nationale de l’Informatique et des Libertés.

Specific directives concern the processing mentioned by these directives and are registered with us: they are subject to your specific consent and you may revoke them at any time.

Right to lodge a complaint with a supervisory authority:

If, after contacting us, you believe that your rights regarding your personal data are not being respected, you can lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (3 place de Fontenoy - TSA 80715 – 75334 Paris cedex 07 - telephone: +33 1 53 73 22 22 or https://www.cnil.fr/fr/plaintes).

It is important that the personal information we hold about you is precise and accurate. Please inform us of any changes to your personal information during the period in which we hold your data.

10. Easy contact for exercising rights

Although EVELIA has taken reasonable measures to protect personal data, no transmission or storage technology is completely infallible.

However, EVELIA is committed to ensuring the protection of personal data. If you have reason to believe that the security of your personal data has been compromised or that it has been misused, please contact EVELIA at dataprotection[@]moulins-evelia.fr.

You can exercise your rights at any time and contact the Data Protection Officer at the following address:

  • By mail to: EVELIA (Terrena group), Protection des données/DPO, 7 avenue Jean Joxé, CS 20248, 49002 ANGERS CEDEX 01, or
  • By email to: dataprotection[@]moulins-evelia.fr

11. Updating the policy

This Policy may be updated to reflect EVELIA’s needs and circumstances or as required by law. We therefore invite you to regularly review updates.

EVELIA undertakes to comply with legal or regulatory developments regarding personal data.

As such, EVELIA reserves the right to modify its processing and security measures at any time and to adapt its data privacy policy accordingly.

Updated on 26/02/2025