Personal Data Protection – Privacy Policy

Last updated: July 7, 2026

1. INTRODUCTION AND DATA CONTROLLER FOR PERSONAL DATA

Welcome to the website of Le Comptoir Éolien (hereinafter referred to as "we," "our," or "us"). We are committed to protecting and respecting your privacy in accordance with applicable data protection laws, including the European Union's General Data Protection Regulation (GDPR) and the French Data Protection Act.

This privacy policy explains how we collect, use, share, and protect your personal information when you visit our website www.comptoireolien.fr or interact with us in the context of our e-commerce activities.

1.1 Data Controller

The data controller for personal data is Le Comptoir Éolien, a sole proprietorship registered under number 515 355 857 R.C.S. Montauban. Our headquarters is located at 928 chemin du vignoble, 82200, Moissac, FRANCE. You can contact us by email at [email protected] or by phone at +33 7 81 34 05 36.

1.2 Purpose of the Policy

The purpose of this privacy policy is to inform you about how we process your personal data, the types of data we collect, the purposes of their processing, as well as your rights as a data subject. We are committed to respecting the principles of transparency, legality, and data minimization in accordance with Article 13 of the GDPR.

1.3 Commitment to Data Protection

We take the protection of your personal data very seriously and have implemented appropriate technical and organizational measures to ensure their security. In the event of a data breach, we commit to notifying the CNIL and, if applicable, the affected individuals within 72 hours, in accordance with Articles 33 and 34 of the GDPR.

We encourage you to read this privacy policy carefully to understand our practices regarding your personal information and how we process it. If you have any questions or concerns, please do not hesitate to contact us using the contact details provided above.

PRIVACY POLICY

Last updated: July 7, 2026

2. DEFINITIONS

2.1 Data Controller for Personal Data

The data controller for personal data refers to the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data. For the website www.comptoireolien.fr, the data controller is Le Comptoir Éolien, represented by Madaule Jérôme.

2.2 Personal Data

Personal data refers to any information relating to an identified or identifiable natural person ('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 the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2.3 Data Processing

Data processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated 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.

2.4 Consent

The consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2.5 Processor

A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

2.6 Cookies

Cookies are small text files that are placed on your device to help the site provide a better user experience. Generally, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymized tracking data to third-party applications like Google Analytics.

2.7 General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) is 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 repealing Directive 95/46/EC (General Data Protection Regulation).

2.8 Data Subject

The data subject is any living identified or identifiable natural person to whom the personal data processed by the controller relates.

2.9 Personal Data Breach

A personal data breach is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

These definitions are essential for understanding the rights and obligations related to personal data protection in the context of using the site www.comptoireolien.fr.

PRIVACY POLICY

Last updated: July 7, 2026

3. DATA COLLECTED

3.1 Types of Data Collected

In the context of operating our e-commerce site Le Comptoir Éolien (www.comptoireolien.fr), we collect several types of personal data in order to provide our services efficiently and securely. The categories of data collected include:

• Personal identifiers: such as name, first name, and user ID.
• Contact details: including email address, phone number, and postal address.
• Payment information: such as credit card details or other payment information necessary to process transactions.
• Login data: such as IP address, login credentials, and activity logs.
• Browsing data: including cookies, browsing history, and interactions with our site.

3.2 Collection Methods

Data is collected directly from you when you:

• Create an account on our site.
• Make a purchase or transaction.
• Contact our customer service.
• Browse our site and accept the use of cookies.

3.3 Purposes of Collection

The collected data is used to:

• Provide and manage our services: order processing, customer account management, and providing customer support.
• Improve our site and services: analyzing browsing behaviors to optimize the user experience.
• Ensure security: fraud prevention and protection of our systems.
• Communicate with you: sending order confirmations, service notifications, and marketing communications (with your prior consent).

3.4 Legal Basis for Processing

In accordance with Article 6 of the GDPR, the processing of your data is based on several legal grounds, including:

• Performance of a contract: to process your orders and provide the requested services.
• Consent: for sending marketing communications.
• Legitimate interest: to improve our services and ensure the security of our site.
• Legal obligations: to comply with applicable laws.

3.5 Indirect Collection

In certain cases, we may receive data about you from third parties, such as business partners or payment services. In these situations, we ensure that these third parties have obtained your consent or have another legal basis to share your data with us, in accordance with Article 14 of the GDPR.

3.6 Transparency and Information

We are committed to respecting the information and transparency obligations provided by Article 13 of the GDPR. You will be informed clearly and concisely about the collection and use of your personal data during your interaction with our site.

For any questions regarding the collection of your personal data, you can contact us at the following address: [email protected].

PRIVACY POLICY

Last updated: July 7, 2026

4. PURPOSES OF COLLECTION

Le Comptoir Éolien, as the data controller, collects and processes your personal data for various legitimate and specific purposes. In accordance with Article 13 of the GDPR, we inform you of the purposes for which your data is used:

4.1 Order and Transaction Management

We use your personal data to process your orders, manage payments, and ensure the delivery of products purchased on our e-commerce site. This includes verifying your identity, managing payments through payment service providers, and communicating regarding the status of your order.

4.2 Customer Service and Support

Your contact information is used to provide you with effective customer service, respond to your inquiries, and handle your complaints. We may also contact you for satisfaction surveys to improve our services.

4.3 Marketing and Communication

With your explicit consent, we use your data to send you marketing communications, promotional offers, and newsletters. You can withdraw your consent at any time by following the unsubscribe instructions provided in each communication.

4.4 User Experience Improvement

We analyze your browsing and site usage data to improve our platform, personalize your user experience, and optimize our services. This includes using analytical cookies to understand how you interact with our site.

4.5 Legal Compliance and Regulatory Obligations

We process your data to comply with our legal obligations, such as maintaining accounting and tax records, and to respond to requests from competent authorities, in accordance with Article 6 of the GDPR.

4.6 Security and Fraud Prevention

Your data is used to ensure the security of our site, prevent fraud, and protect our rights and those of our users. This includes monitoring suspicious activities and implementing appropriate security measures.

Each data processing is carried out on the basis of an appropriate legal basis, such as consent, the execution of a contract, compliance with a legal obligation, or the legitimate interest of our company. For more details on specific legal bases, please refer to the corresponding section of our privacy policy.

PRIVACY POLICY

Last updated: July 7, 2026

5. LEGAL BASIS FOR PROCESSING

In accordance with Article 6 of the General Data Protection Regulation (GDPR), the processing of your personal data by Le Comptoir Éolien is based on several legal grounds, depending on the nature of the processing operations carried out:

5.1 Consent

For certain processing operations, we request your explicit consent. This includes, for example, the use of non-essential cookies for analysis and marketing purposes. You have the right to withdraw your consent at any time, without affecting the legality of the processing based on consent before its withdrawal.

5.2 Execution of a contract

The processing of your personal data is necessary for the execution of the contract to which you are a party, particularly for managing your orders on our e-commerce site. This includes collecting your contact and payment information to process your purchases.

5.3 Legal obligation

We may be required to process your personal data to comply with legal obligations, such as retaining documents for tax or accounting purposes.

5.4 Legitimate interests

In certain cases, the processing of your personal data is based on our legitimate interests, such as improving our services, preventing fraud, or securing our website. We ensure that these interests do not infringe on your fundamental rights and freedoms.

5.5 Protection of vital interests

Although rare, the processing of your data may be necessary to protect your vital interests or those of another natural person, for example in the event of a medical emergency.

Each processing of personal data is carefully evaluated to ensure it complies with legal requirements and the rights of the individuals concerned, in accordance with Articles 13 and 14 of the GDPR.

PRIVACY POLICY

Last updated: July 7, 2026

6. DATA RECIPIENTS

In the course of our business, we may be required to share your personal data with certain third parties, in compliance with applicable legal and regulatory provisions, including the General Data Protection Regulation (GDPR).

6.1 Sharing with service providers

Your personal data may be shared with third-party service providers who assist us in operating our website and providing our services. These providers act as processors and are required to comply with data confidentiality and security obligations. Categories of providers include, but are not limited to:

• Hosting service providers: Our site is hosted by Cloudflare Inc., located in the United States. Cloudflare ensures the security and availability of our website.
• Analytics Services: We use Google Analytics to analyze visitor behavior on our site. Google LLC, as the provider of this service, may have access to certain browsing data, in accordance with its privacy policy available here.

6.2 Sharing for Legal Reasons

We may also be required to disclose your personal data if required by law, legal proceedings, a court decision, or a request from a public authority, in accordance with Articles 13 and 14 of the GDPR.

6.3 International Data Transfers

As part of the use of certain third-party services, your personal data may be transferred outside the European Economic Area (EEA). In this case, we ensure that these transfers are carried out in accordance with Articles 44 to 49 of the GDPR, using appropriate safeguards such as the Standard Contractual Clauses approved by the European Commission.

6.4 Third-Party Commitments

All third parties with whom we share your personal data are required to comply with applicable data protection laws and to process your information only for the purposes specified in our privacy policy. They are not authorized to use your data for other purposes without your explicit consent.

If you have any questions regarding the recipients of your personal data, you can contact us at the following address: [email protected].

PRIVACY POLICY

Last updated: July 7, 2026

7. DATA RETENTION PERIOD

In accordance with Article 5(1)(e) of the General Data Protection Regulation (GDPR), the personal data collected by Le Comptoir Éolien is retained in a form that allows the identification of the data subjects for no longer than is necessary for the purposes for which they are processed.

7.1 Specific Retention Period

The personal data collected is retained for a maximum period of three years from the end of the business relationship or the last contact with the data subject, unless a legal provision requires a longer retention period.

7.2 Criteria for Determining Retention Period

The retention period of the data is determined based on the following criteria:

• Nature of the Data Collected: Contact and identification data are retained for the management of business relationships and order tracking.
• Legal Obligations: Certain data may be retained longer to comply with legal or regulatory obligations, particularly in tax and accounting matters.
• Consent of the Data Subject: When processing is based on consent, the data is retained until the consent is withdrawn.

7.3 Deletion and Anonymization

At the end of the retention period, personal data is either deleted or irreversibly anonymized to ensure the privacy protection of the data subjects.

7.4 Exceptions

In certain cases, specific retention periods may be applied, particularly to comply with legal obligations or for the defense of rights in court. These exceptions will be clearly communicated to the individuals concerned at the time of data collection.

By adhering to these principles, Le Comptoir Éolien is committed to ensuring the protection of personal data in accordance with the requirements of the GDPR and the French Data Protection Act.

PRIVACY POLICY

Last updated: July 7, 2026

8. RIGHTS OF THE DATA SUBJECTS

In accordance with Articles 15 to 22 of the General Data Protection Regulation (GDPR), you have several rights concerning your personal data. These rights can be exercised at any time by contacting our data protection officer at the following address: [email protected].

8.1 Right of access

You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the said data as well as information on the purposes of the processing, the categories of data concerned, and the recipients or categories of recipients to whom the data has been or will be disclosed.

8.2 Right to rectification

You can request the rectification of inaccurate personal data concerning you. You also have the right to request that incomplete data be completed, including by providing a supplementary statement.

8.3 Right to erasure

Under certain conditions, you can request the erasure of your personal data, particularly if the data is no longer necessary for the purposes for which it was collected or processed, or if you withdraw your consent on which the processing is based.

8.4 Right to restriction of processing

You have the right to request the restriction of the processing of your personal data in certain cases, for example, when you contest the accuracy of the data, for a period enabling the data controller to verify the accuracy of the data.

8.5 Right to data portability

You have the right to receive the personal data concerning you, which you have provided to a data controller, in a structured, commonly used and machine-readable format, and you have the right to transmit this data to another data controller without hindrance from the data controller to which the personal data was provided.

8.6 Right to object

You can object at any time, on grounds relating to your particular situation, to processing of personal data concerning you based on Article 6, paragraph 1, points e) or f) of the GDPR, including profiling based on those provisions.

8.7 Right not to be subject to automated individual decision-making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

8.8 Right to withdraw consent

Where the processing of your personal data is based on your consent, you have the right to withdraw this consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise these rights, please contact us at the following address: [email protected]. You also have the right to lodge a complaint with a supervisory authority, such as the Commission Nationale de l'Informatique et des Libertés (CNIL) in France.

PRIVACY POLICY

Last updated: July 7, 2026

9. DATA SECURITY

9.1 Security Measures

Le Comptoir Éolien is committed to protecting the security of its users' personal data. We have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risks, in accordance with Article 32 of the GDPR. These measures include, but are not limited to:

• Data encryption: Sensitive data is encrypted using advanced security protocols to prevent unauthorized access.
• Access control: Access to personal data is strictly limited to employees and service providers who need this information to process orders or provide services.
• Firewalls and intrusion detection systems: We use firewalls and intrusion detection systems to protect our network against external attacks.
• Regular backups: Regular data backups are performed to prevent any data loss in the event of a technical incident.

9.2 Data Breach Notification

In accordance with Articles 33 and 34 of the GDPR, in the event of a personal data breach likely to result in a high risk to the rights and freedoms of natural persons, Le Comptoir Éolien is committed to notifying the breach to the CNIL within 72 hours of becoming aware of it. If the breach is likely to result in a high risk to the rights and freedoms of the affected individuals, we will also inform the affected individuals as soon as possible.

9.3 Awareness and Training

We ensure that our staff is trained and aware of good data security practices. Regular training sessions are organized to ensure that all employees understand the importance of personal data protection and the measures to take to prevent breaches.

9.4 Continuous Evaluation and Improvement

Le Comptoir Éolien regularly evaluates its security measures to ensure their effectiveness and improve them if necessary. We remain vigilant to new threats and adapt our security practices accordingly to ensure the continuous protection of our users' personal data.

PRIVACY POLICY

Last updated: July 7, 2026

10. INTERNATIONAL TRANSFERS

As part of our activities, Le Comptoir Éolien may transfer your personal data outside the European Economic Area (EEA). These transfers are carried out in accordance with the requirements of the General Data Protection Regulation (GDPR), notably Articles 44 to 50.

10.1 Legal Frameworks for Transfers

Data transfers to third countries are carried out based on one of the following legal frameworks:

• Adequacy decisions: When the European Commission has recognized that a third country offers an adequate level of protection, your data may be transferred on this basis.
• Standard Contractual Clauses (SCCs): In the absence of an adequacy decision, we use the Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection.
• Binding Corporate Rules (BCR): For intra-group transfers, we can rely on Binding Corporate Rules approved by a competent data protection authority.

10.2 Additional Safeguards

When necessary, we implement additional safeguards to ensure the protection of your data, such as enhanced technical and organizational measures.

10.3 Rights of Data Subjects

In accordance with Articles 15 to 22 of the GDPR, you have the right to request information about international transfers of your data, including the safeguards in place. You can exercise these rights by contacting us at the following address: [email protected].

10.4 Remedies and Complaints

If you believe that your rights are not being respected, you have the right to file a complaint with the National Commission for Informatics and Liberties (CNIL) or to take the matter to the competent courts.

We are committed to protecting your personal data and adhering to the highest standards of data protection during any international transfer.

PRIVACY POLICY

Last updated: July 7, 2026

11. COOKIES AND SIMILAR TECHNOLOGIES

11.1 Introduction

The Le Comptoir Éolien website uses cookies and similar technologies to enhance user experience, analyze traffic, and personalize content. This section explains how we use these technologies, the types of cookies we employ, and how you can manage your preferences.

11.2 What is a cookie?

A cookie is a small text file stored on your device when you visit a website. Cookies allow the site to recognize your device and remember certain information about your preferences or past actions.

11.3 Types of cookies used

We use the following types of cookies on our site:

• Cookie Name / Provider / Category / Duration / Purpose
• _ga / Google LLC / Analytics / 13 months / Audience measurement and visitor behavior analysis.
• ga* / Google LLC / Analytics / 13 months / Audience measurement and visitor behavior analysis.
• _gid / Google LLC / Analytics / 24 hours / Audience measurement and visitor behavior analysis.
• YSC / Google LLC / Marketing / Session / Embedded video playback and profiling by YouTube.
• VISITOR_INFO1_LIVE / Google LLC / Marketing / 6 months / Viewing embedded YouTube videos.

11.4 Purposes of cookies

The cookies we use serve to:

• Essential cookies: Ensure the proper functioning of the website.
• Analytical cookies: Help us understand how visitors interact with our site, allowing us to improve our services.
• Marketing cookies: Personalize the advertising content you see on our site and other sites.

11.5 Consent and management of cookies

In accordance with the ePrivacy Directive 2002/58/EC and its national transposition, your consent is required for the use of certain cookies, including analytical and marketing cookies. You can manage your cookie preferences at any time via your browser settings or by using our cookie management tool available on the site.

11.6 User rights

You have the right to withdraw your consent at any time. For more information on your rights, please refer to the section on the rights of data subjects in our privacy policy.

11.7 Changes to the cookie policy

We reserve the right to modify this cookie policy at any time. Any changes will be posted on this page with an update date. We encourage you to regularly check this page to stay informed of updates.

For any questions regarding our use of cookies, please contact us at the following address: [email protected].

PRIVACY POLICY

Last updated: July 7, 2026

12. UPDATES TO THE POLICY

Le Comptoir Éolien reserves the right to modify this Privacy Policy at any time to reflect changes in our personal data processing practices or to comply with legislative and regulatory developments. We encourage you to regularly check this page to stay informed of any changes.

12.1 Notification of Changes

In the event of a substantial change to this policy, we will inform you through a prominent notice on our website, or by any other appropriate means, before the changes take effect. This notification will allow you to become aware of the changes and understand them before they are applied.

12.2 Acceptance of Changes

By continuing to use our website after the changes are posted, you accept the terms of the updated policy. If you do not accept the changes, you must stop using our site and may exercise your rights as described in the section on the rights of data subjects.

12.3 History of Changes

To ensure transparency, we will keep a record of changes made to this policy, accessible upon request. This will allow you to track the evolution of our practices regarding personal data protection.

12.4 Contact for Questions

For any questions regarding changes to this policy, or for any other inquiries related to the protection of your personal data, please contact us at the following address: [email protected].

We are committed to processing your requests as quickly as possible and providing you with all necessary information regarding your rights and our obligations in terms of data protection.

PRIVACY POLICY

Last updated: July 7, 2026

13. CONTACT AND COMPLAINTS

For any questions related to this privacy policy, or if you wish to exercise your rights as a data subject as defined by the articles 15 to 22 of the GDPR, you can contact us using the following information:

• Company Name: Le Comptoir Éolien
• Postal address: 928 chemin du vignoble, 82200, Moissac, FRANCE
• Email address: [email protected]
• Phone number: +33 7 81 34 05 36

Although Le Comptoir Éolien has not appointed a Data Protection Officer (DPO), we are committed to responding to all your inquiries regarding your personal data as quickly as possible.

Complaints

If you believe that the processing of your personal data constitutes a violation of applicable laws, particularly the General Data Protection Regulation (GDPR), you have the right to file a complaint with the competent supervisory authority. In France, the supervisory authority is the National Commission on Informatics and Liberty (CNIL). You can contact the CNIL via their website www.cnil.fr or by mail at the following address:

• CNIL
  3 Place de Fontenoy
  TSA 80715
  75334 PARIS CEDEX 07
  FRANCE

We encourage you to contact us directly before filing a complaint with the CNIL, so that we can attempt to resolve your issue amicably.