Privacy Policy
APM MONACO SAM takes the protection of personal data very seriously. Pursuant to Act no. 1.165 of December 23rd, 1993, on the protection of personal data, please find below a description of how your data is processed, a statement of your rights with respect to your personal data, as well as our cookie policy.
A. Processing of personal data
1. Data Controller
The Data Controller is the Monegasque company APM MONACO SAM (hereinafter referred to as: “APM”), registered in the Registre du Commerce et de l’Industrie of Monaco under number 97S03369 located 3, rue de l’Industrie – 98 000 MONACO.
2. Purposes of the processing (purpose and legal basis)
As part of its online store, APM processes personal data for the following purposes:
- To carry out customer management operations in relation to the creation of a customer account; contracts; orders; deliveries; invoices; accounting and in particular the management of customer accounts; the loyalty program within one or more legal entities, excluding programmes that are common to several companies; customer relationship monitoring such as conducting satisfaction surveys and managing after-sales service complaints;
- To carry out prospecting operations;
- To develop audience measurement statistics;
- To manage requests for the right of access, rectification and objection;
- To manage customer reviews of products, services or contents.
The legal justifications for the processing are as follows:
3. Data categories and retention periods
APM processes the following personal data:
- Identity, address and contact details: title, surname, name, address, delivery and billing address, e-mail address, telephone number.
The above data is kept until the account is deactivated or after three years of inactivity;
- Order-related data: transaction number, purchase details, purchase amount, purchase history, invoice payment data, product return.
The above data is kept until the account is deactivated or after three years of inactivity. However, the invoice is kept for 10 years in accordance with the applicable legal requirements;
- Data on means of payment: credit card number, date of expiry of the credit card, visual cryptogram (which is immediately deleted).
The above data is not retained by APM;
- Cookies: 13 months.
4. Data recipients
The following are the exclusive recipients of the data within the limits of their respective responsibilities:
- public bodies, exclusively to meet legal obligations;
- court officers and public officers within the frameworl of their debt collection duties;
- financial institutions and professional account-keepers;
- the payment service provider, the delivery service provider
5. Transfer to a country laking an adequate level of protection
We inform you that your personal data is transferred to countries that do not have an adequate level of protection considered as such because their level of protection is not equivalent to the one provided for by Monegasque legislation. The list of countries whose level of protection is considered adequate is published on Monaco's national commission for personal data protection’s website, Commission de Contrôle des Informations Nominatives (https://www.ccin.mc/images/documents/1d5232eab615f91192612a62d7bcdc42-liste-des-pays-disposant-d-un-niveau-de-protection-adequat.pdf)
Please note that for transfers to countries whose level of protection is not considered adequate, we rely either on a legal exemption listed in Article 20-1 of Act 1.165, applicable to the situation, and/or on the establishment of one of the appropriate safeguards, recognised by the Commission de Contrôle des Informations Nominatives and after authorisation issued by the latter, to ensure the protection of your personal data.
To obtain a copy of these security measures or to know how to access them, please send a written request in accordance with Section B hereof.
The concerned transfers are described below:
a) Transfer of personal data from customer files to the parent company in Hong Kong, whose servers are located in Singapore, for customer relationship management purposes
This includes the following information:
- Identity, address and contact details: title, surname, name, address, delivery and billing address, e-mail address, telephone number;
- Order-related data: transaction number, purchase details, purchase amount, purchase history, invoice payment data, product return.
b) Transfer of personal data to Shopify Inc. servers in the United States from the APM website for hosting purposes
The website apm.mc is hosted by Shopify Inc., whose servers are located in the United States, thus implying the transfer of your personal data to the United States.
This includes the following information:
- Identity, address and contact details: title, surname, name, address, delivery and billing address, e-mail address, telephone number;
- Order-related data: transaction number, purchase details, purchase amount, purchase history, invoice payment data, product return.
c) Transfer of data for statistical purposes from Google Analytics to Google Inc. in the United States
The transfer concerns “Google Analytics” cookies to the company operating this module, namely Google Inc., located in Mountain View (USA). For a more detailed description of this transfer, please refer to Part C “Cookie Policy” below.
B. Existence of the right to object, to access and to rectify with respect to your personal data
Pursuant to Act no. 1.165 of 23 December 1993 on personal data protection, you have the right to object, access and rectify data concerning you.
To exercise these rights, please send a letter to:
The Chief Financial Officer
APM SAM
3 rue de l'Industrie, l'Hercule
98 000 MONACO
You can also send an email to the following address: customercare@apm.mc
Your letter or email must specify your request and be accompanied by a copy of one of your valid identification documents to enable us to verify that you are the sender of the request. The said copy must be in black and white and crossed out, in accordance with Deliberation No. 2015-113 of 18 November 2015 of the Commission de contrôle des informations nominatives.
To check the proper processing of your personal data, you can contact the Commission de contrôle des informations nominatives at the following address:
“Le Suffren” Bloc B 4ème étage 7, rue Suffren Reymond 98000 - Monaco
Tel: (+377).97.70.22.44
C. Cookie policy
A cookie is a very small text file that websites, visited by the user, send to the user’s computer or mobile device.
APM MONACO processes different types of cookies:
- Necessary cookies: these are cookies necessary for the operation of our website and for the core services that form an integral part of it. They allow you to use the main features of our website.
- Advertising cookies: these are cookies used to present advertisements or to send you information tailored to your interests on our website or outside.
- Functional cookies: these are cookies that provide you with certain features that are not essential for accessing the service but that significantly improve your visitor experience.
- Analytical cookies: these are cookies that allow us to understand the use, traffic and usage volumes as well as the performance of our website.
Regarding necessary cookies, in accordance with the applicable regulations, your consent is not required.
Regarding advertising, functional and analytical cookies your consent is necessary and can be withdrawn at any time.
Regarding analytical cookies, please note that:
- We use the “Google Analytics” module that implies the transfer of data to the company operating this module, namely Google Inc., located in Mountain View (USA);
- The data processed are the IP address, the user’s Internet domain name, the pages visited and their number, the number of displays per page, the length of time spent on each page, the number of clicks, the name and version of the Internet user’s web browser, the user’s operating system, the timestamp of access to the website and the pages visited on the website.
Analytical cookies will only be activated and used on the website if you give your consent to their use via the banner that is displayed when you visit the website’s home page.
You can choose to accept only technical cookies, to accept all cookies, or to change your choices and consents, at any time, in the cookie preference settings, by clicking on the corresponding buttons in the banner that is displayed at the bottom of the home page when you first visit the website.
In any case, you can also change your cookie preferences on your Internet browser, according to the instructions for each of them, whose links are available below:
Internet explorer: http://windows.microsoft.com/en-us/windows7/block-enable-or-allow-cookies
Safari: http://support.apple.com/kb/PH19255?viewlocale=en_UK
Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=fr&hlrm=en
Opera https://help.opera.com/en/latest/web-preferences/#cookies
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
In this regard, you may refuse the use of Cookies by changing the settings of your web browser as follows:
– On Internet Explorer:
- Go to Tools & Internet Options
- Click on the “Privacy” tab.
- Click on the Advanced button, tick the “Ignore automatic cookie handling” box
– On Firefox:
- At the top of the Firefox window, click on the Firefox button (Tools menu in Windows XP), then select Options
- Select the Privacy panel
- Set the Retention Rules to: use custom settings for history
- Untick Accept cookies
– On Google Chrome:
- Click on the Chrome menu icon
- Select Settings
- Click on Show Advanced Settings
- In the “Privacy” section, click on Content Settings
- Select "Block sites from setting any data"
Lastly, we remind you that you can exercise your rights under the terms and conditions provided for in Article B “Existence of the right to object, to access and to rectify with respect to your personal data” hereof.