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DAROME GROUP PERSONAL DATA PROTECTION POLICY

Last updated: November 6, 2025

This document constitutes the Personal Data Protection Policy (“Policy“) implemented by DAROME company, its current and future subsidiaries and affiliates, including but not limited to: DAREGAL, DARBONNE AROMATIQUE, DAREGAL IBERICA, DAREGAL GOURMET LIMITED, DAREGAL Inc., DAREGAL GOURMET DEUTSCHLAND (collectively referred to as “DAROME Group” or “we”), in accordance with the European General Data Protection Regulation and French Law No. 78-17 of January 6, 1978, as amended, relating to data processing, files, and freedoms.

We attach great importance to respecting your privacy and are committed to building strong and lasting relationships with you. The protection of your personal data is paramount to us. Therefore, we provide you with this Policy to inform you as clearly as possible about the processing carried out when using the site’s services.

1. SCOPE OF APPLICATION

This Policy applies to all websites, applications, online games/sweepstakes, as well as any other online initiative belonging to a DAROME Group company and collecting personal data (the “Media“).

The concept of personal data (“Personal Data“) refers to any information relating to an identified or identifiable natural person. A person is “identifiable” if they can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to them.

Please note that if required by the legislation of your country, this Policy may be supplemented by local provisions, which we strongly encourage you to consult on our Media.

2. DATA COLLECTED

When you use our Media, we may collect and process all or part of the data you provide (i) by filling out forms, (ii) by uploading content online, (iii) by subscribing to online services (e.g., applications and social media pages), or (iv) by sending us correspondence:
– first name and last name;
– email address;
– gender;
– phone number;
– postal address;
– age/date of birth;
– your opinion on our products;
– payment information (on e-commerce Media);
– your purchase history (on e-commerce Media);
– any specific request you may send us (primarily for archiving purposes);
– photos or videos of yourself that you wish to share.

We may ask you to respond to surveys that we use for scientific and statistical purposes.

We may collect your IP address and browser type for the purposes of administering our systems and/or compiling statistics, without identifying or retaining any other individual information.

3. COOKIES

In some cases, we may also use cookies, which are small files of letters and numbers downloaded to your device when you access our Media. We primarily use cookies to recognize you when you log back into our Media and to display content that may match your interests.

To learn more about the cookies we use, their purpose, and how to manage them, please consult our Cookie Policy.

4. PURPOSES OF PERSONAL DATA COLLECTION

Personal Data is generally collected for the needs of the DAROME Group’s activity, such as improving the DAROME Group’s marketing and advertising efforts, better adapting the DAROME Group’s products and services to customer needs, or complying with legal reporting obligations, and other similar activities.

We also use your Personal Data to enhance your digital experience on our Media: to understand your interest in our Media and their content, manage your online account, validate your participation in our operations, process your payments, ensure that our Media are presented in the most suitable way for you and on your device, and protect you against potential fraudulent actions.

When the processing of your Personal Data is based on your consent, you have the option to withdraw this consent at any time. In this case, we will cease using your Personal Data for the purposes concerned.

We will ask for your explicit consent before collecting and using your Personal Data for commercial prospecting purposes, particularly by electronic means.

5. NON-DISCLOSURE OF PERSONAL DATA

Your Personal Data will never be sold, shared, or communicated to third parties, except as provided for in this Policy. However, we may be required to communicate your Personal Data to other affiliated companies of the DAROME Group, which agree to process them in accordance with this Policy. Your Personal Data may also be communicated to third parties acting for us or on our behalf as part of specific processing in accordance with the purposes for which they were initially collected, or may be processed legally, according to the local regulations in force, as part of activities such as service provision, evaluation of the usefulness of this site, product commercialization and marketing, data management, or technical support. These third parties have contractually committed to using your Personal Data only for the agreed purposes, and not to sell or disclose them to other third parties unless required by law, if we explicitly authorize them to do so, or if a provision to that effect is included in this Policy.

The Personal Data we collect may also be communicated to a third party if all or part of this site’s activity and associated customer data are sold, assigned, or transferred, in which case we will require the buyer or assignee to process said Personal Data in accordance with this Policy. Furthermore, Personal Data may be disclosed to a third party if we are compelled to do so under an applicable law or regulatory provision, a court order, or governmental regulation, or if such disclosure is necessary as part of an investigation or criminal proceedings, whether domestically or abroad.

6. SECURITY AND CONFIDENTIALITY

To ensure the security and confidentiality of the Personal Data we collect online, we use networks protected by standard devices such as firewalls and passwords. When processing your Personal Data, we take all reasonable measures to protect them against any loss, misuse, unauthorized access, disclosure, alteration, or destruction.

7. STORAGE OF PERSONAL DATA

Your Personal Data is stored either in our databases or in those of our service providers.

In some cases, and primarily for technical reasons, these databases may be stored on servers located outside the country from which you initially entered the data.

8. RETENTION PERIOD OF YOUR PERSONAL DATA

We retain your Personal Data for a limited period, in accordance with applicable laws and regulations, and only for the duration necessary to achieve the purposes for which they were collected. More specifically:
• Data collected for commercial prospecting purposes is retained for a period of three years from the last contact with you.
• Data related to your customer account is retained for the entire duration of your contractual relationship with us and for a period of five years from the end of this relationship.
• Browsing data collected via cookies is retained for a maximum period of 13 months.
Beyond these periods, your data will be deleted or archived in accordance with applicable legal provisions.

9. TRANSFER OF PERSONAL DATA ABROAD

Due in particular to the international dimension of the DAROME Group and in order to optimize service quality, the information communications referred to above may involve transfers of Personal Data outside your country and/or to countries not members of the European Economic Area, whose personal data protection laws differ from those of the European Union.

When we transfer your Personal Data outside the European Economic Area to countries whose personal data protection legislation differs from that of the European Union, we implement appropriate safeguards to ensure an adequate level of protection for your data.

10. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

We attach great importance to respecting your rights regarding your Personal Data.
In accordance with current regulations, you have the following rights:
• Right of access: you have the right to know whether we process your Personal Data and, if so, to obtain a copy of this data as well as information on the purposes of processing, the categories of data concerned, the recipients or categories of recipients, the planned retention period, and the rights you have.
• Right to rectification: if you believe that the Personal Data we hold about you is inaccurate or incomplete, you have the right to ask us to rectify or complete it.
• Right to erasure (right to be forgotten): in certain cases, you can ask us to delete your personal data, particularly when:
– They are no longer necessary for the purposes for which they were collected.
– You have withdrawn your consent (when processing is based on consent).
– You object to the processing (under the conditions provided below).
• Right to restriction of processing: you can ask us to restrict the processing of your personal data in the following cases:
– You dispute the accuracy of the data (for the period necessary to verify accuracy).
– The processing is unlawful, but you object to the erasure of the data and request restriction of processing instead.
– We no longer need the data, but they are still necessary for you to establish, exercise, or defend legal claims.
• Right to data portability: you have the right to receive the Personal Data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit them to another data controller, when the processing is based on your consent or on a contract and is carried out by automated means.
• Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of your Personal Data based on our legitimate interest. In the event of an objection, we will cease processing, unless there are compelling legitimate grounds for the processing that override your interests and your rights and freedoms, or for the establishment, exercise, or defense of legal claims. You also have the right to object at any time to the processing of your Personal Data for prospecting purposes, including profiling to the extent that it is related to such prospecting.
• Right to withdraw your consent: if 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 carried out before its withdrawal.
• Right to define directives regarding the fate of your data after your death: you have the right to define directives regarding the retention, erasure, and communication of your Personal Data after your death.

To exercise any of these rights, please contact us by email at the following address: dpo@daregal.fr.

Please specify the right you wish to exercise and attach a copy of your identity document so that we can verify your identity.

We commit to responding to your request as soon as possible and, in any event, within the deadlines provided by applicable regulations.

If, after contacting us, you believe that your rights are not being respected, you have the option to lodge a complaint with the French National Commission for Data Protection and Liberties (CNIL).

11. LINKS TO OTHER SITES

This Policy applies only to DAROME Group websites, and not to websites owned by third parties. We sometimes provide links to other websites that we believe may be of interest to our visitors. In such cases, we ensure that these sites meet the highest standards. However, due to the nature of the Internet, we cannot guarantee the privacy and Personal Data protection rules of websites for which we provide an access link and cannot be held responsible for the content of sites other than those of the DAROME Group.

12. CONTACT

For any questions regarding the protection of your Personal Data, you can contact our data protection department at the following address:

DAREGAL SAS,
6 boulevard Joffre,
91490 Milly-la-Forêt
dpo@daregal.fr.

We inform you that this Policy may be modified, supplemented, deleted, or updated. In such a case, these modifications will be available on this page. However, we will always process your Personal Data in accordance with the Policy in effect at the time of their collection.