PRIVACY POLICY

The website accessible at the URL https://sinnerparis.com/ (hereinafter referred to as the “Site”) is published by the company Experimental Group, a simplified joint-stock company with a share capital of €20,085,900, registered with the Paris Trade and Companies Register under number 524 095 064, whose registered office is located at 104, rue d’Aboukir, 75002, Paris, France (hereinafter “Experimental Group”).
Individuals who can access the website are referred to as “users.”

Collection of Personal Data
Experimental Group may collect and process, for its own purposes, the personal data of the User that (i) has been provided by the User through the submission of a form available on the Site, (ii) subsequently in the context of various exchanges with Experimental Group, and (iii) through the use of the Site, provided valid consent has been obtained from the User.
Experimental Group will not process any personal data other than those described in this privacy policy (hereinafter the “Privacy Policy”) without the User’s express consent.

Legal Basis for Processing
In accordance with applicable data protection laws, the processing of personal data carried out by Experimental Group is based on one of the following legal bases:

• The execution of Experimental Group’s contractual relationships with Users
  To use the website and benefit from the services it offers, users must accept the general terms and conditions available on the website https://sinnerparis.com/.
  These documents formalize a contractual relationship between each User and Experimental Group.
  The personal data collected and processed by Experimental Group in this context is necessary for the execution of these contracts, the purposes of which are specified in Article 4 – “Purposes of Processing” below.
• User’s Consent
  When Users browse the Site, Experimental Group may read and/or write trackers on their devices (e.g., computer, mobile device).
  Before installing cookies on the User’s device, Experimental Group collects the User’s consent through a “cookie banner.”
• Compliance with a Legal Obligation to Which Experimental Group is Subject
  The processing of User’s personal data carried out by Experimental Group may be required by a legal obligation (e.g., Decree No. 2011-219 of February 2011 relating to the retention of data identifying any person who has contributed to the creation of online content).
• Legitimate Interest of Experimental Group
  Experimental Group may have a legitimate interest allowing it to collect and process the personal data of Users who visit the Site (e.g., conducting commercial prospecting operations for its prospects).
  In this context, Experimental Group ensures that the processing carried out is necessary for the achievement of its legitimate interest and does not infringe on the interests and fundamental rights of Users.

Categories of Personal Data Collected and Processed
Experimental Group may collect, store, and process the following categories of personal data:

• Identification data (e.g., name, surname, date of birth);
• Contact details (e.g., phone number, email address, postal address);
• Economic and financial information (e.g., card number, transaction details);
• Data relating to personal life and lifestyle;
• Experimental Group may collect information regarding the User’s meal preferences, which could indirectly indicate religious beliefs, ethnic origin, or health status and thus be considered sensitive data under Article 9 of the GDPR. Such data would only be collected when the User voluntarily makes a specific request in this regard;
• Professional life data (e.g., resume);
• Location data (e.g., GPS);
• Connection data (e.g., IP address, logs).

Experimental Group does not collect any information relating to political opinions, morals, sexual orientation, or genetic characteristics.

Purpose of Processing
The processing of the User’s personal data by Experimental Group is necessary to achieve the following purpose:

• Processing for Online Reservations
  Optimizing the website for user navigation;
  Creating a customer account on the Site;
  Confirming and processing the User’s reservation at one of Experimental Group’s establishments;
  Processing the payment for the reservation at one of Experimental Group’s establishments;
  Sending a confirmation or pre-arrival message to the User;
  Conducting a customer satisfaction survey.
• Processing for Handling Requests
  The processing of the User’s personal data by Experimental Group is necessary if the User accesses the job application service:
  Receiving job applications;
  Recruiting a candidate.
• Processing for Sending Newsletters and Marketing Communications
  Sending the Experimental Group newsletter, with the User being able to unsubscribe from marketing messages at any time by clicking the unsubscribe link at the end of said message;
  Measuring statistics and marketing analysis;
  Communicating with a User who fills out a contact form on the website;
  Creating a file of customers and prospects;
  Informing Users of changes affecting the services offered by the website.
• Processing for Rights Management
  Preventing and combating fraud during payment of the order;
  Managing disputes;
  Complying with a legal obligation or in the context of a legal procedure or dispute;
  Informing Users of changes affecting the services offered by the website;
  Managing requests for the exercise of rights.

Rights of Data Subjects
Users have the right to access, modify, object to, restrict, port, rectify, define directives regarding the fate of their data after death, and erase their personal data, subject to the following conditions:

• The request is made by the person concerned and is accompanied by a copy or valid identity document;
• The request must be made in writing to the following address: gdpr@expegroup.com.

For data portability purposes, the information requested by the User will be provided in electronic form, unless otherwise requested.
Regarding the right to erase the User’s personal data, it will not be applicable where processing is necessary to comply with a legal obligation.

Data Retention
The User’s personal data for an information request about Experimental Group’s services (e.g., name, first name, email address) is kept for three (3) years from the time of collection.
Audience measurement data is not retained for more than thirteen (13) months.
In the event of a dispute, all information, documents, and evidence containing the User’s personal data used to establish disputed facts may be retained for the duration of the procedure, including for periods longer than those indicated above.
Certain data may be archived beyond the retention periods for criminal investigation purposes, solely to provide this data to the judicial authority if needed.
Archiving implies that this data is anonymized and can no longer be accessed online but is extracted and stored on an independent and secure medium.

Data Recipients
The User’s personal data collected and processed by Experimental Group is communicated to the following recipients solely for the purposes described above.

• Internal Services of Experimental Group
  Experimental Group shares the Users’ personal data with its internal services solely for the purpose defined in Article 4 above.
  Members of the internal service processing the Users’ personal data are subject to a confidentiality obligation regarding this data.
• Affiliates of Experimental Group
  Experimental Group shares the Users’ personal data with its affiliates strictly to:
  Manage reservations, requests for privatization, and group bookings in each establishment managed by an affiliate;
  Manage job applications for vacancies in each establishment managed by an affiliate.
  In accordance with European and French data protection laws (European Regulation No. 2016/679 of April 27, 2016, relating to personal data protection, and French Data Protection Act No. 78-17 of January 6, 1978), Experimental Group affiliates process the User’s personal data.
• Third-Party Suppliers and Service Providers
  Experimental Group may transfer certain User’s personal data to third parties temporarily and securely when necessary:
  The operation and maintenance of the website (e.g., Milk Digital);
  Partners with whom Experimental Group has contracted to enable the execution of its contracts with Users (e.g., Synxis, Zenchef, OTAs);
  Partners contracted by Experimental Group to manage its customers and prospects (e.g., advertising platforms, Sendethic, Milk Digital);
  Certain regulated professionals such as accountants, auditors, or lawyers.

When the concerned third party is located outside the European Union or in a country that does not have adequate regulations within the meaning of GDPR, Experimental Group arranges its contractual relationship with the third party by implementing appropriate contractual measures.

• Administrative and Judicial Authorities
  Only when such disclosure is required by a legal obligation, Experimental Group will disclose the User’s personal data to the administrative or judicial authorities requesting it.

Cookies
Experimental Group also uses web analytics cookies to better understand Users’ behavior. These tools collect information and generate reports on the site’s usage statistics without the Users necessarily being personally identified by the cookie provider (e.g., Google).
In addition to generating reports on website usage statistics, these audience measurement cookies also allow, in combination with certain other advertising cookies (placed by third-party websites and/or content viewed by the User), more relevant ads to be displayed on the website.

Click here to change your cookie preferences.
Reject cookies

Each User can refuse cookies by configuring their web browser:

• Internet Explorer™: http://windows.microsoft.com/fr-fr/internet-explorer/use-tracking-protection#ie=ie-11
• Safari™: http://support.apple.com/kb/PH11952
• Chrome™: https://support.google.com/chrome/answer/114836
• Firefox™: https://support.mozilla.org/fr/kb/comment-activer-option-ne-pas-pister
• Opera™: http://help.opera.com/Windows/12.10/fr/notrack.html
• Edge™: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

Partners
The following partners may use cookies:

• Google: https://policies.google.com/technologies/cookies?hl=fr
• Sendethic: https://www.sendethic.com/legal/cgu/

Policy Updates
The Privacy Policy may be updated periodically. The latest version will be published on the website with an update date.