Privacy Policy

Last update: July 29, 2025

Preamble

The present charter (“Privacy Policy”) describes the policy for processing personal data collected by Jinghi, a limited liability company with capital of 18.580 euros, registered under number 381 279 165 at the Paris Trade and Companies Register, whose registered office is located at 11 place des Vosges 75004 Paris, and operating under the trade name and brand LEMAIRE (“LEMAIRE” or “we”). In this Privacy Policy we also detail our rules for managing cookies when browsing the website https://www.lemaire.fr, which we own.

The purpose of this Privacy Policy is to inform you, regardless of your status (customer, candidate, subcontractor, partner, supplier or internet user) (“you”), about how we process your personal data in the context of our relationship.

LEMAIRE respects your concerns about the privacy of the personal information we collect. LEMAIRE is thus committed to protect and guarantee the security and confidentiality of your personal data, in particular by taking all necessary precautions to prevent this data from being distorted, damaged or accessed by unauthorized third parties.

LEMAIRE implements state-of-the-art technical security and management measures, in particular with regard to information systems. However, LEMAIRE does not control all the risks associated with the operation of the Internet and draws your attention to the existence of potential risks associated with its use and operation.

The Privacy Policy complies with the legal provisions applicable to the protection of Personal Data and in particular those defined by the General Data Protection Regulation No. 2016/679 (“GDPR”) and by the French Data Protection Act no. 78-17 (“Loi Informatique et Libertés”).

1. What is personal data?

Personal data are information that allows you to be personally identified as a natural person, directly or indirectly, in particular by reference to an identifier, such as a surname, a first name, an address, an identification number or to one or more factors specific to your identity (physical, cultural, social, etc.).

2. Who collects your personal data?

LEMAIRE is responsible for the processing of your personal data for the purposes described in Article 3 of the Privacy Policy.

3. What processing is carried out and how?

Purposes	Legal basis	Data collected	Retention periods
Management of the contractual relationship with our customers (Account creation, invoicing, claims management, shipping and returns)	Performance of the contract.	- Identification Data - Economic and financial data - Login data	5 years from account deletion or order processing
Management of the contractual relationship with subcontractors, partners, suppliers	Performance of the contract and LEMAIRE’s legitimate interest	- Identification Data - Economic and financial data	For the duration of the contract + 5 years
Purchase and sending of a digital gift card	Performance of the contract; LEMAIRE’s legitimate interest for third-party beneficiaries	- Identification Data - Economic and financial data of the purchaser	12 months validity + 5 years
Sending of newsletters	Consent	Identification Data	3 years from collection or last interaction
Commercial canvassing	LEMAIRE’s legitimate interest (customers); consent (non-customers or non-similar products)	Identification Data	3 years from collection or last interaction
Responding to contact and information requests	LEMAIRE’s legitimate interest	- Identification Data - Login data - Message content	Until request processed
Recruiting an applicant (Applications, CV database)	LEMAIRE’s legitimate interest	- Identification Data - CV data and cover letter	Until application processed then deleted
Website improvement, statistics	LEMAIRE’s legitimate interest; consent when required	Login data	Cookies: 13 months; Analytics data: 25 months
Management of data subject rights requests	Legal obligation	Identification Data	Duration necessary to process + archiving per statute

In any case, we undertake to ensure that your personal data is only collected and processed for the purposes mentioned above, according to a principle of proportionality and minimization.

In addition, we store your personal data for no longer than is necessary to achieve the purposes of the respective processing operations. In other words, this means that the data retention periods we apply may vary depending on the purpose for which we process the personal data in question.

In any event, at the end of the applicable retention period, we will irrevocably erase or anonymize your personal data so that you can no longer be identified.

The information that we do not need to process your orders or requests is identified with the mention “OPTIONAL” on the data collection forms on our website. If you do not fill in the mandatory fields, we will not be able to process your orders or requests.

4. How are your personal data collected?

LEMAIRE collects and processes your personal data directly from you. In the event that LEMAIRE indirectly collects your personal data, you will be informed at the time of collection.

5. Who has access to your personal data?

Within the limits of their respective responsibilities and for the purposes set out in Article 3 of the Privacy Policy, the categories of recipients who may have access to your personal data are:

• authorized personnel of the various departments of LEMAIRE (such as the authorized personnel of human resources, sales, accounting, IT, marketing, and legal departments);
• authorized personnel of our data processors (e.g., logistics providers, payment providers, technical service providers of the website);
• authorized personnel of our commercial partners;
• where applicable, the courts concerned, mediators, certified public accountants, auditors, lawyers, bailiffs, debt collection companies, supervisory authorities;
• third parties who may deposit cookies on your devices with your consent (for more details, see Article 7 of this Privacy Policy).

In order to combat fraudulent payments during online purchases, the payment service provider implements a procedure for risk assessment and fraud prevention using algorithms.

6. Do we transfer your personal data outside the EU?

Wherever possible, LEMAIRE turns to data processors located within the European Union.

However, we may transfer your data outside the territory of the European Union, for example, in the context of order management and payment.

These transfers are carried out in accordance with the provisions of the GDPR and LEMAIRE puts in place all the guarantees required to secure your personal data, in particular through the choice of processors located in countries guaranteeing an adequate level of protection or the application of the European Commission's standard contractual clauses supplemented by the implementation of additional guarantees where necessary.

For more information on data transfers, you can contact us:

• By post to the following address: LEMAIRE, 11 place des Vosges 75004 Paris
• By e-mail to the following address: customerservice@lemaire.fr

7. Rules for the management of cookies

What is a cookie?

A cookie is a small text file that is placed on the hard drive of your device when you visit a website. It records certain information about your browsing or online behavior that allows us to improve and facilitate your experience.

Only the issuer of a cookie or other tracer is likely to read or modify the information contained therein.

Why do we use cookies?

When you navigate on our website, cookies and other tracers may be deposited on your terminal. The website effectively uses cookies and other tracers to offer you an optimal navigation experience and to improve the services we provide to you.

The cookies are as follows:

• Strictly necessary cookies: essential tracers are necessary for the proper functioning of our website. They allow you to browse our website and use its services and features.
• Functionality cookies: functional tracers allow you to personalize your use of our website by remembering your choices and preferences.
• Performance cookies: analytical tracers collect or use information about your use of our website, which helps us to improve our website.
• Advertising cookies: advertising tracers are used to create user profiles in order to send advertisements or track users on this website or other websites with similar marketing purposes.
• Tracking cookies: tracking tracers allow you to interact with them (e.g. Facebook, LinkedIn, X, YouTube) and in return allow them to track your browsing on our website, simply because your account on these social networks was activated on your device while you were browsing our website.

How to remove cookies?

On your computers, smartphones and other Internet access terminals, the browser software accepts cookies on websites by default.

However, you remain in control of the installation of these cookies because you have the possibility to configure your browser software to:

• Accept or reject cookies from the website;
• Systematically refuse all cookies;
• Ask for your consent for each of the cookies you encounter while browsing the internet.

To do this, all you have to do is refer to your browser software and follow its instructions. For example:

• With Internet Explorer™: Tools (in the browser toolbar) > Internet Options > Privacy tab >Choose the level you want.
• With Firefox™: Tools menu (in the top toolbar) > Options > Privacy tab >Choose the desired options.
• With Chrome™: Configuration menu (settings logo) > Settings > Privacy and security > Site settings > Cookies and site data >Choose the desired options.
• With Safari™: Safari menu (settings logo) > Preferences > Security > Show cookies >Choose the desired options.
• With Opera™: Tools menu > Preferences > Advanced tab > Cookies section > Manage cookies > Choose the desired options.

During your first visit to our website, you will be asked to accept or reject the use of these cookies and other tracers. You can accept or refuse them all, or choose to configure the cookies by selecting certain ones via our cookie management console.

By choosing to block our cookies, we would like to inform you that browsing the website and/or the use of certain features may be altered. In any event, if you choose to delete all cookies, your user experience will be heavily affected, and your browsing preferences will be erased.

This will for example be the case if you attempt to access certain content or services or when LEMAIRE, or its technical partners, cannot identify, for technical compatibility purposes, the type of browser used by your device, its display language, its settings or the country from which the device appears to be connected to the Internet. In this case, LEMAIRE declines all responsibility for the consequences related to the altered operation of the site and/or services resulting from the failure to record or view the cookies necessary for their operation and which you may have refused or deleted.

8. What are your rights?

In accordance with the applicable regulation, you have rights when your personal data is processed.

Subject to the conditions applicable to the exercise of these rights, you may exercise the following rights:

• Right of access: you have the right to obtain confirmation about whether your personal data is being processed by LEMAIRE and where it is being processed. When we process your personal data, you have the right to receive a copy of all the personal data that we hold concerning you.
• Right to rectification: you have the right to supplement, correct, or have deleted, without undue delay, your personal data, where such data is inaccurate or incomplete.
• Right to object: you may object to the processing of your personal data for legitimate grounds. However, this right is not absolute, and LEMAIRE may reject your request if we demonstrate legitimate compelling grounds for the processing.
• Right to withdraw your consent at any time where the legal basis for processing is consent.
• Right to data portability: only where the legal basis for processing is the performance of a contract or consent, you may request the portability of your data and may receive the personal data concerning you in a structured, commonly used, and machine-readable format, in particular for the purposes of transmission to a third party. Where technically feasible, you have the right to have your personal data transmitted directly to this third party.
• Right to restriction of processing: you may request the restriction (e.g., suspension) of the processing of your personal data if (i) the personal data is incorrect, (ii) you have exercised your right to object, (iii) the personal data in question is no longer necessary for the purposes of the processing but is still necessary for the establishment, exercise or defense of your legal claims, or (iv) the processing is unlawful but you object to the erasure of your personal data.
• Right to erasure: you may request the deletion of your personal data in certain cases provided for by the applicable data protection regulation, and in particular Article 17 of the GDPR. Among other reasons, you may ask us to delete your personal data when the processing is based on your consent and you wish to withdraw it, or if it appears that your personal data is no longer necessary for the purposes for which it was collected or processed. However, this right is not absolute, and LEMAIRE may invoke a legal basis or a legitimate reason to retain your personal data.
• Right to not be subject to a decision based solely on automated processing, including profiling.
• Right to determine the fate of your personal data after your death and to choose whether or not LEMAIRE communicates your personal data to a third party that you have previously designated. In the event of your death and in the absence of instructions from you, LEMAIRE undertakes to destroy your data, unless its retention is necessary for evidentiary purposes or to meet a legal obligation.

You can exercise your rights in the manner indicated in Article 9 of the Privacy Policy.

9. How can you exercise your rights?

To exercise these rights, you must contact LEMAIRE’s dedicated service using the contact details provided in Article 10 of the Privacy Policy, and in particular by e-mail at: customerservice@lemaire.fr

You must always state clearly who you are, so that we can be certain that we do not modify or delete any personal data concerning the wrong person.

In order to process your request in the best possible way, we may ask you for certain additional information to confirm your identity and/or facilitate the location of the personal data concerned by your request (e.g., identity document or any other document allowing your identity to be verified).

The response to the request formulated on the basis of one or more of your rights will be sent within one month from the receipt of the request.

Some of your rights are subject to specific conditions set out in the applicable data protection regulations, including the GDPR. If your particular situation does not meet these requirements, we will unfortunately not be able to respond to your request. If so, we will inform you of the reasons of the refusal.

In any event, if you believe that your rights have not been respected or that your personal data has been processed in violation of the applicable data protection regulations and the principles set out in this Privacy Policy, you have the right to lodge a complaint with the French data protection authority (Commission Nationale de l'Informatique et des Libertés or “CNIL”) or the data protection authority competent in your country.

You can lodge your complaint on the CNIL's website or by post to the following address: CNIL – Service des Plaintes – 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07.

10. How can you contact us?

If you have any questions or requests regarding the processing we carry out with your personal data under this Privacy Policy, including the exercise of your rights as detailed above, you can contact us:

• By post to the following address: LEMAIRE, 11 place des Vosges 75004 Paris
• By e-mail to the following address: customerservice@lemaire.fr

11. How do we amend and update this Privacy Policy?

In order to ensure compliance with the applicable regulations, LEMAIRE reserves the right to make amendments to this Privacy Policy at any time. It is recommended that you consult this Privacy Policy regularly in order to be aware of any changes. In addition, we will actively inform you wherever possible.