PRIVACY POLICY AND COOKIE MANAGEMENT

LAST UPDATED March 27, 2025

The https://divine-couture.com/ website is published by AMELINE, a société par actions simplifiée (simplified joint stock company) under French law, , a service provider whose registered office is located at 13 RUE DES ECOLES, 78400 CHATOU France and registered in the Versailles Trade and Companies Register B 980835466(hereinafter referred to as “we” or “AMELINE” or the “Company”).

The Company is responsible for processing the data of its customers and more generally of Internet users (hereinafter referred to as ” you “) browsing this site from a computer, tablet or any other computer device that allows access to the public part of the site and any sub-sites dedicated to Beds24 customer member areas(hereinafter collectively referred to as the “Site”).

We are committed to ensuring that the collection and processing of personal data is carried out lawfully, fairly and transparently, in accordance with the General Data Protection Regulation (“RGPD”) and the French Data Protection Act of 1978 as amended.

If you have any queries or complaints, please do not hesitate to contact us by post at 13 RUE DES ECOLES, 78400 CHATOU France, or by e-mail at info [at] divine-couture.com.

1. DEFINITIONS

Personal data ” means any information relating to an identified or identifiable natural person (the “data subject”); an “identifiable natural person” is one who can be identified, 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 his or her identity.

Processing ” means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

A ” controller ” is the person who, alone or jointly with others, determines the purposes and means of processing, and a ” processor ” is the person who processes personal data on behalf of the controller.

A ” recipient ” is the natural or legal person, public authority, department or any other organization that receives personal data, whether or not it is a third party.

Compulsory collection and processing. On the Site, you are informed of the compulsory nature of the answers by the presence of an asterisk next to the field concerned or by a mention to this effect. In the event of failure to provide compulsory information, the Company reserves the right to request additional information or to prevent validation of the form concerned by any technical means in the event of a request relating to this data collection (e.g. on-line registration or order, request for information, etc.).

Warnings. We invite you to be cautious about what you decide to make public on the Internet. With regard to personal data , including data relating to your private life or sensitive data made public at your initiative or deduced from your contributions, comments and statements of any kind whatsoever on the Site or social networks.

Please note that the processing of personal data made public by the data subject is not subject to the prohibition in principle on the processing of sensitive data by law (Art. 6, II, 4° of the 1978 Data Protection Act).

2. CUSTOMER-PROSPECT DATABASE MANAGEMENT AND ONLINE SALES

Through the Site, you provide us with the following categories of information by completing the information form(s) and communicating with us:

Identity data (title/gender; surname; first name; optional date of birth);
Contact data (e-mail address; postal address (address, zip code, city); telephone number);
In the event of a customer service request, the nature and content of your request;
Your user account login and password. These may be stored automatically on the Site if you agree to this via your browser settings.

When you register on the Site, we may also collect information indirectly (see “social networks and third-party sites”). We reserve the right to make registration of your user account subject to validation of your e-mail address.

In the event of an order, we will also process information relating to the contractual and commercial relationship (in particular details of the product ordered) that you may enter into. As orders are subject to a charge, we will also process payment and transactional information (transaction date, amount, payment method, order number).

Lastly, we collect data relating to account connection and the use of tools made available to individuals on the virtual space dedicated to them (IP address, connection time, connection duration, account settings, tool management).

Purposes of processing	Data	Legal basis
Carry out operations relating to the management of files concerning: contracts (registrations); orders; deliveries; legal and commercial guarantees; invoices; accounting and follow-up of commercial relations (after-sales service).	All data may be processed for these purposes	Pre-contractual measures or contract performance; Compliance with legal obligations
Authentication procedure management Management of procedures for lost logins or passwords	Identity, contact, user account and account login data	Contract performance
Management, processing and follow-up of your requests and exchanges with the Company via the Site Management of relations with prospects and customers and of people’s opinions on products, services or content	Identity and contact data; Content, date, nature of request or advice	Legitimate interest Pre-contractual measures
Canvassing and/or sending information (newsletter), including the follow-up of prospects (including in the event of abandoned orders), the management of technical canvassing operations, the selection of persons to carry out loyalty-building, canvassing, survey, product testing and promotional actions, as well as the carrying out of solicitation operations. Organization of contests, lotteries or any promotional operation	Identity and contact data Information about the contractual relationship	Legitimate interest Consent in accordance with the regulations of article 34-5 of the CPCE
Commercial statistics and advertising, including on social networks Site and offer improvement	All the data needed for analysis	Legitimate interest
Handling queries and any complaints from individuals and managing requests for access, rectification and opposition rights Preventing and combating fraud and payment card fraud in particular Managing overdue payments and litigation	All information authorized by law	Compliance with legal obligations

Accuracy of information provided: You must not provide any false personal information and must not create an account for another person without that person’s authorization. The contact details you send us must always be accurate and up to date.

Personal identifiers All account holders who access a virtual space to make online purchases have access rights that are strictly personal, confidential and non-transferable. Any holder of an account with the Company must preserve the integrity of his/her access rights (login, password) to prevent a third party from connecting to his/her account, and modify his/her user account data in case of doubt.

The holder of access rights shall be liable for any fraudulent or abusive use of his/her access codes, where this results from his/her own negligence. In any event, the holder of access rights must inform us without delay of the loss or theft of his/her access codes.

3. PROVISION OF A DEDICATED MEMBER AREA

On the Site, we offer our customers the possibility of subscribing to various formulas, training and consulting programs, by providing them with a “member’s area” on a dematerialized platform enabling them to access the content and services they have subscribed to.

The legal basis for this processing is contractual.

Personal profile information required	First name, last name, email Password
Optional personal profile information	Username, Skype, Address (street, city, country), Age
Training follow-up data	Module consultation data, time spent, webinar participation data, etc. Note-taking data in the training area (content, date, related module) Progress indicators, statistics and tracking of progress (by course, student or group), information on the awarding of badges or other forms of reward
Document data	Information on audio files downloaded and/or listened to, grades, surveys and quizzes taken, past evaluations
Data on consulting sessions	Information about your corrections, appointments and available or used consulting credits
Information about your publications and contributions	Content of the publication of your contribution (comment, question, publications…) date, time, response rate, information on the publication space concerned.
Group membership data	Social network account name Join date Data related to contributions and interactions on the group

4. INFORMATION ABOUT COOKIES

On the Site, we use several types of cookie, including those necessary for the operation of our sites, for their proper performance, marketing cookies and for social networking and content exchange. You will be informed that we use cookies by the appearance of a dedicated banner on your first visit, and at least every 6 months thereafter.

The cookie records information about your browsing on our sites (the pages you have visited, the date and time of your visit, etc.) which we can read on your subsequent visits. Cookies are kept for a maximum of 13 months after they are first stored on your terminal. The lifetime of cookies is not extended with each visit.

Cookies may be used for statistical purposes, in particular to optimize services rendered, based on the processing of information concerning access frequency, page personalization, operations carried out and information consulted. They may also be used for advertising purposes, in particular to offer you targeted content in banners and inserts on the Internet. Some site functionalities, such as video players or interactive content, may use services provided by third parties and may deposit cookies enabling them to identify your consultation of the content.

Cookies enable us to analyze browsing patterns and improve the Site, and then to identify people likely to be interested in our advertising. Cookies can also facilitate and improve your experience by allowing us to record your actions on the Site and your preferences.

If you do not want cookies to be used on your terminal, most browsers allow you to disable cookies through the settings options (Firefox with enhanced anti-tracking protection ; Firefox with cookie deletion ; Chrome ; Explorer ; Safari).

Cookie information table
Name	Supplier	Applicable privacy policy	Type Purpose	Conservation Expiration
Facebook	Facebook		Remarketing	30j
Youtube	Youtube		Remarketing	30j

You can also deactivate cookies directly on the site at any time, with the exception of those strictly necessary for site operation, using the dedicated settings tool (click on the “Privacy & Cookies Policy” tab in the bottom right-hand corner of the site). However, you are informed that certain services may no longer function correctly.

5. SOCIAL NETWORKS AND THIRD-PARTY SITES

You have the right to access the data concerning you, to rectify or delete it, to query it, to limit the processing of your data, to portability(more info here), within the limits set by the regulations and in particular the RGPD.

You also have the right to object at any time, for reasons relating to your particular situation, to the processing of personal data whose legal basis is our legitimate interest, as well as the right to object to commercial prospecting by clicking on the unsubscribe link in the newsletter.

You can always contact us for further information and to exercise your rights. Requests should be sent by post to XXXXXXXX or by e-mail to https://divine-couture.com.

We reserve the right to ask you for proof of identity and to specify this request. If you are not satisfied with our response, you can lodge a complaint with the authority responsible for controlling and protecting your personal data (in France, the CNIL).

For all intents and purposes, it is specified that once the right to erasure, to object to processing, or to withdraw consent is exercised, the proper functioning of the Site may be disrupted or even interrupted. For example, if these rights are exercised at the time of ordering, the order cannot be validated.

6. EXERCISING YOUR RIGHTS

Data used to manage commercial prospecting is kept for a maximum of three years from the last contact with the prospect or customer. If you have not logged on to the Site, or if you have not engaged in active behavior (for example, by clicking on a link) for a period of three years, you may receive an e-mail inviting you to log on as soon as possible, failing which your data will be deleted from our databases.

Means of effective deletion of data are put in place as soon as the retention or archiving period necessary for the fulfillment of the purposes determined or imposed is reached, in particular after deletion of your account with our company.

In accordance with our legal obligations, certain documents relating to our internal operations and containing personal information (purchase orders, contracts, invoices, etc.) will be archived. Similarly, we may archive documents until the expiry of the statute of limitations/forclosure periods applicable to legal proceedings, in order to defend our interests before the courts in the event of subsequent litigation.

In any event, personal data that is processed will not be kept beyond the time required to fulfill the obligations defined when the contract was concluded, or as required by current legislation. Beyond this period, the data may be anonymized and stored exclusively for statistical purposes.

7. SHELF LIFE

8. MAIL TO

We do not sell any personal data files. The information you give us is for internal use by authorized persons. It is strictly confidential and may not be divulged to third parties, except with your express consent or if you have decided to make it public.

Our external service providers (e.g. IT service providers, suppliers, carriers, etc.) may, in the context of the processing described above, receive personal data when this is necessary for the performance of their tasks.

As such, we undertake to (i) ensure that any data recipient presents sufficient and appropriate contractual guarantees to respect your rights, so that processing meets the requirements of the RGPD (particularly with regard to subcontracting) and (ii) comply with the provisions of the RGPD applicable to data transfers.

On the basis of our legal obligations, your personal data may be disclosed in application of a law, regulation or by virtue of a decision by a competent regulatory or judicial authority.

Business partnership. In the case of commercial canvassing, we will ask for your consent before passing on information concerning you to commercial partners. In addition, we reserve the right to make offers in collaboration with third parties, of which you will be informed. If you order on the Site a product or service that is not delivered directly by the Company but by a commercial partner, we will transmit to this partner the information necessary for the execution of the order.

Transfers outside the EU. We undertake to comply with the applicable regulations relating to the transfer of data to countries outside the European Union, in particular as follows:

We will transfer the data of visitors, prospects and customers to countries recognized as offering an adequate level of protection. In the case of transfers to the United States, to organizations that have signed up to the Privacy Shield only;
When the country of destination does not offer an adequate level of protection, we use transfer tools that comply with regulations, such as the European Commission’s standard contractual clause.

9. COMPUTER SECURITY

We undertake to implement all appropriate technical and organizational measures using physical and logistical security measures in order to guarantee a level of security appropriate to the risks of accidental, unauthorized or illegal access, disclosure, alteration, loss or destruction of your personal data.

Access Passwords

Passwords are created manually on the Site. By default, when we ask a customer to create a secure password. For more information on password security, users can consult the CNIL website: https://www.cnil.fr/fr/les-conseils-de-la-cnil-pour-un-bon-mot-de-passe .

Secure payment

All transactions carried out on our Site are secure. Credit card payments are handled by our Payment Service Providers (“PSP”), as indicated in our general terms and conditions or on the order page for our products and services. We use SSL encryption to protect your personal data and the means of payment used. At no time do we have direct access to your bank details through this process.

The address of the payment page begins with “https” and is accompanied by a closed padlock or key in the bottom right-hand corner of your browser. This allows you to check that you are in a secure payment zone when you are asked for your credit card number. PSPs automatically check that this connection is secure before sending your banking and transaction data. As a result, the highest security standards are applied to data storage and comply with all applicable norms.

General Data breach

In the event that we become aware of an event leading to the realization of the risks identified above, we undertake to :

Examine the causes of the incident;
Take the necessary measures to limit the negative effects and damage that may result from the incident;
Notify the CNIL or the persons concerned as soon as possible when required by law.

Under no circumstances may the commitments defined in the above point be assimilated to any acknowledgement of fault or responsibility for the occurrence of this incident.

If you observe any security breach or any incident likely to affect the integrity of your personal data or those of others, we thank you in advance for informing us immediately by e-mail at info [at] divine-couture.com.

10. APPLICABLE LAW, LANGUAGE, MODIFICATION OF POLICY

This Privacy Policy is governed by French law. It is written in French. Should it be translated into one or more languages, only the French text will be deemed authentic in the event of a dispute. The temporary or permanent non-application of one or more clauses of the present policy shall not constitute a waiver of the other clauses of the present policy, which shall continue to have full effect.

We reserve the right to modify this Privacy Policy. Data subjects will be notified when this is provided for by the RGPD or any other regulation. The update date is indicated in the header and we invite you to consult it regularly.