Privacy Policy

Le Marché Duty Free is committed to providing the highest level of data protection for the personal data it collects and processes in accordance with 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 (the “GDPR”) and the loi Informatique et Libertés n°78-17 of 6 January 1978 as amended (together, the “Personal Data Protection Regulations”).

This privacy policy applies to all collection and processing of personal data concerning you (the “Personal Data”), whether you are a customer, supplier, or prospect of Le Marché Duty Free, and informs you of your rights regarding your Personal Data.

Identity of the data controller

Le Marché Duty Free, a simplified joint stock company with a share capital of €6,005,000, whose registered office is located at Bâtiment CH, Terminal Eurotunnel, 62231 Coquelles, registered with the Boulogne-sur-Mer Trade and Companies Register under number 984 177 592 (“LMDF” or “we”) processes your Personal Data as the data controller.

How to contact us?

If you have any questions about the processing of your Personal Data or if you wish to exercise any of your rights regarding the protection of personal data, you can contact LMDF at the following address:

  • by email: gdpr@lemarchedutyfree.eu ;
  • by mail: Le Marché Duty Free, Bâtiment CH, Terminal Eurotunnel, 62231 Coquelles.

What Personal Data do we collect?

Personal data is any information relating to an identified or identifiable natural person. 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.

LMDF only collects personal data that is appropriate, relevant, accurate (or updated), and limited to the minimum necessary for its processing activities.

In most cases, regardless of your status or capacity, LMDF requires your Personal Data in the context of your contractual and/or commercial relationship with LMDF.

Your Personal Data is collected directly from you when a sale is made, contracts are negotiated/concluded, or when you contact us.

No sensitive personal data or information is required by LMDF in the context of your contractual and/or commercial relationship.

Any additional personal data that is not directly necessary your contractual and/or commercial relationship is only collected if you have given your explicit consent to such collection or if LMDF has a legitimate interest in collecting such data. You will be notified in advance of the reasons for any additional collection of Personal Data.

Customers Data collected when making a sale: Name, Surname, ID document, QR code containing travel information (destination, travel time)

Personal contact details: email address, phone number

3 years from the end of the contractual relationship
Customers Sales data: purchase history, transaction data, invoices, refunds Deletion once the transaction has been completed

Except where there is a legal obligation to retain accounting
documents and supporting documents for 10 years

Suppliers and Service providers Identification data: Name, Surname, company, role, department, professional contact details (phone number, email address), any information contained in a business card, contact preferences, business interests and preferences, professional opinions, judgment 3 years from the end of the contractual relationship
Financial and economic data: bank details, invoices, all information contained in transaction logs
and accounting records
10 years for accounting documents and supporting documents
Prospects Identification data: Name, Surname, company, role, department, professional contact details (phone number, email address), any information contained in a business card, contact preferences, business interests and preferences, professional opinions, judgment 3 years from the last contact made by the prospect
All users of the website Information stored on terminal equipment (cookies and other trackers) 13 months

 

Why do we process your Personal Data?

The following table identifies the reasons (the purpose) and the main legal justification (the legal basis) for processing your Personal Data. 
If LMDF processes your Personal Data on the basis of a legitimate interest, this interest is described in the purpose mentioned. LMDF will systematically inform you in advance of any other purpose for processing your Personal Data.

Management of business transactions Enable the completion of sales Performance of the contract
Maintain a record of sales and transaction information (cash register log) Legitimate interest
Market products Legitimate interest Performance of the contract
Improvement of customer 
experience Carry out market analysis/statistics for the Ospree Group Legitimate interest
Providing  a click-and-collect system Legitimate interest
Purchase management Management of negotiations, call for tenders, and contracts Legitimate interest Preparation / Performance of the contract
Purchase management Management of the the purchase and payment process with suppliers and service providers by issuing purchase orders, receiving goods and services, and collecting and paying invoices Performance of the contract
Suppliers and service providers relationship management Keeping suppliers and service providers master data up to date in order to establish a business relationship if/when necessary Legitimate interest
Manage suppliers and service providers performance Legitimate interest
Manage suppliers and service providers requests and claims Performance of the contract
Prospects relationship management Tender management Legitimate interest Preparation of the contract
Keeping prospect master data up to date in order to establish a business relationship if/when necessary Legitimate interest
Commercial prospecting Implement a loyalty program Legitimate interest
Sending newsletter Legitimate interest
Establishing business relations through contacts and communications Legitimate interest
Accounting management Maintenance and management of suppliers and service providers invoice payments Legitimate interest
Compliance with legal or regulatory obligations Management of mandatory formalities (duty-free sales, regulated markets) Legitimate interest
Compliance with customs regulations Legitimate interest
Compliance with fiscal obligations Legitimate interest
Management of GDPR requests Management of requests related to the exercise of rights that everyone has over their personal data Legitimate interest
Management of potential disputes Management of disputes (pre-litigation/litigation) Legitimate interest

 

Who has access to your Personal Data?

Persons performing tasks or functions within LMDF are expressly authorized to access your Personal Data, strictly within the limits of their responsibilities and the performance of their duties within LMDF.

  • In addition, your Personal Data may be shared with categories of recipients outside LMDF for the purposes mentioned above. These recipients are as follows:
  • any company in the Ospree Group to which LMDF belongs;
  • our authorized service providers acting as subcontractors (in particular, video surveillance providers, CRM software publishers, IT service providers), and more specifically:
  • Microsoft 365, our office IT tools provider; 
TrustIT, our IT system maintenance provider;
  • competent authorities who request it (for example, to protect our rights or those of third parties);
  • our advisors (lawyers, accountants, etc.) when necessary for our legitimate interests.

Your Personal Data may be shared with the aforementioned recipients, particularly in the following situations and conditions:

  • when LMDF uses service providers to provide assistance to website users, payment services, or advertising. These service providers have limited access to your data in order to perform their services and are contractually obligated to use it in accordance with the provisions of applicable personal data protection regulations;
  • to enable LMDF to comply with its legal and regulatory obligations;
  • if required by law, LMDF may disclose your data in order to respond to claims made against it and to comply with administrative and judicial procedures;
  • connection with a potential or actual sale or restructuring of our company or certain of our assets, in which case your Personal Data may be included in the assets transferred. You will then be informed by the new data controller of the processing of your Personal Data.

LMDF contractually ensures that each entity receiving your Personal Data guarantees the confidentiality of the data communicated to it and undertakes to process it solely for the purposes of its intervention, and in compliance with the Personal Data Protection Regulations.

Security Measures

LMDF implements organizational, technical, software, and physical measures in terms of digital security and confidentiality to ensure the protection of your personal data that it collects against any alteration, destruction, or unauthorized access to your data.
LMDF takes all necessary precautions with regard to the nature of your personal data and the risks presented by the processing it carries out in the course of its business in order to preserve the security of your data and prevent its distortion, damage, or access by unauthorized third parties.
In any event, any breach of your personal data that is likely to result in a high risk to your rights and freedoms will be notified to you as soon as possible, in accordance with the applicable legal and regulatory requirements.

Policy Updates

  • LMDF may occasionally modify this policy, in particular to comply with any regulatory, jurisprudential, editorial, or technical developments applicable to data protection.
  • LMDF undertakes, in any event, to provide you with the new version of this privacy policy as soon as possible so that you can review any changes, corrections, and/or adaptations made.