Privacy Policy

1. Scope and purpose

The Focal and Naim brands (collectively referred to as the " Brands ", " we ", " us" and "our ") have joined forces to create the "Focal Powered By Naim", "Focal" and "Naim" websites (hereinafter referred to as the " Sites ") designed to present the world of their products in the best possible way.

This personal data protection policy (hereinafter referred to as the " Policy ") describes the framework within which the Brands collect, use, store and share information collected from users of the Site (hereinafter referred to as the " Users ", the " User ", " you ", " your ").

You will also find our contact details in order to send us your questions and/or exercise your rights under the applicable European data protection regulations.

The Brands pay particular attention to the protection of Users' personal data.

By using the Sites, or by providing information, the User acknowledges having been informed of the Policy and having accepted it.

2. Information and Data collected

Personal data refers to information relating to an identified or identifiable natural person (hereinafter the " Data "). Examples of Data include your name, address or telephone number.

In the course of our activities, we may collect, directly or indirectly, certain Data from Users. This Data depends on the use made of the Site and the information provided.

We collect three types of information: (1) Data that the User communicates directly; (2) information collected automatically; and (3) information collected from other sources.

(1) Data provided directly by the User

The Data we may collect and process when you use the Sites are as follows:

- To subscribe to our newsletter: e-mail address, surname, first name, country;

- To create an account: e-mail address, surname, first name, country;

- In the account area, you can enter personal information: surname, first name, date of birth, e-mail address, telephone number, city, zip code, country;

- In the account area, you can also register your purchase in order to obtain a warranty extension certificate for eligible products. To do this, you can fill in the purchase invoice, which includes at least your full name, address and place of purchase;

- On the various contact forms, depending on your request, you may be asked to provide your surname, first name, e-mail address, postal address and telephone number;

- To use the Store locator, you may be asked to provide your geolocation.

(2) Information collected automatically when using the Site

When a User visits the Sites for information purposes, the Brands collect certain information automatically. Various third-party technologies are used, including cookies and similar tools. For further information, please consult the Cookies policy.

The information collected in an automated manner includes: date and time of visit to the Site, country of consultation of the Site, content of the request (specific page), access status/HTTP status code, volume of data transmitted, website from which the request originated, browser, operating system and desktop, language and version of browser software, state or country of connection, characteristics of hardware or software used, referring and exit URLs, pages consulted and the order in which they are consulted, time spent on certain pages.

This data is nevertheless anonymized.

(3) Information collected from other sources

The Brands may receive information from other sources, such as business partners, marketing services, social networking services or other third parties.

For example, if the Site is accessed via another third-party website, application or social networking platform, the Brands may receive information via that third-party website, application or platform.

This data is nevertheless anonymized.

Anonymization of certain information: Certain information collected is anonymized so that it cannot reasonably be used to identify the User or his or her device. Brands may also collect information that has already been anonymized. The Policy in no way restricts the use or disclosure of anonymized information, which may be used and/or disclosed to third parties for any purpose, without limitation.

3. Legal basis and purposes of data collection

The Brands collect and use Data on one or more of the following legal bases:

- prior consent: in this case, the User has the right to revoke his or her consent at any time under the following link "Management by the User of his or her Data" (link to the corresponding page)) ;

- a contractual basis: processing is necessary as part of a contract between the Brands and the User.

The collection and processing of Data has various purposes, which mainly include:

- managing the User's customer account ;

- issuing extended warranty certificates, where applicable;

- responding to a User's questions, requests and suggestions.

4. Data protection

The Brands implement appropriate technical and organizational controls to safeguard Data against unauthorized or unlawful processing and against accidental loss, destruction or damage, in compliance with applicable laws.

5. Data storage

User Data is stored on :

This site is hosted on Amazon Web Services (AWS) infrastructure, in a data center located in France. AWS is an Amazon Web Services Inc. company, headquartered at 410 Terry Avenue North P.O. Box 81226 Seattle, WA 98108-1226 - USA - (206) 266-1000.

The platform on which the data is stored guarantees optimum protection of the Data, in compliance with current legislation.

6. Data transfer

It is possible that certain Data may be transmitted to third parties, within the limits provided for by law or by a decision issued by a judicial/administrative authority.

It is also possible that certain Data may be transmitted subject to the User's consent, in particular to resellers or distributors worldwide.

Data is generally stored and processed within the European Economic Area (EEA). All transfers are carried out in compliance with the rules laid down by the General Data Protection Regulation (GDPR).

In certain situations, Brands are required to transfer Data outside the EEA. The laws of the countries to which your Data is transferred may not present the same level of protection for personal data, but such transfers are carried out with adequate guarantees, in particular contractual guarantees, in accordance with the regulations applicable to the protection of personal data.

If Data is shared with a third party, the Brands will take all necessary measures to ensure that the third party complies with the obligations of confidentiality and respect for Users' privacy.

7. Data retention period

The Brands retain Data for no longer than is necessary for the purposes for which it is processed.

8. User rights

The User has a right of access to the Data. Processed Data may be transmitted to the User in a structured, commonly used and machine-readable format.

The User has the right to rectify Data. The User is invited to update their data regularly.

The User also has the right to delete Data. The Brands may nevertheless decide to retain the Data, in compliance with applicable laws and regulations.

If the User does not wish to delete the Data, they may request that its processing be limited.

The User may, at any time, for any reason relating to his or her particular situation, object to the processing of Data where such processing is based on legitimate interests.

The User also has the right to object to the processing of Data for direct marketing purposes.

Some Data processing operations are based on the User's consent. The User has the right to withdraw consent at any time.

Users wishing to exercise one or more of these rights may do so:

- By sending an e-mail to the following address [email protected] ;

- By sending a letter to the following address:

Vervent Audio Group

For the attention of the webmaster

108, rue de l'Avenir

42350 La Talaudière

And :

- By providing information enabling the Brands to identify him/her (surname, first name, telephone number, invoice/order number);

- Enclosing proof of identity (copy of ID); and

- By specifying which right they wish to exercise.

It is also possible for Users to contact the French Data Protection Authority (CNIL) to make a complaint if they consider that they are unable to exercise their rights, by following this link.

9. Identity and contact details of the data controller

Vervent Audio Group, a one-person simplified joint stock company with capital of 32,422,660 euros, registered under number 801 358 235 in the Saint-Etienne Trade and Companies Register, with its registered office at 108 rue de l'Avenir, 43250 La Talaudière.

10. Third-party services

The Sites enable Users to access applications and links to services operated by third parties. These services fall outside the scope of this Policy. Users agree that the Brands are not responsible for these third-party services.

11. Modifications to the Policy

The content of this Policy may change over time, at the discretion of the Brands. The date of the last update will appear at the top of the Policy. The User is therefore encouraged to visit this page regularly.

12. Applicable law and jurisdiction

The Policy is governed by French law to the exclusion of its conflict of laws rules.

In the event of any dispute, controversy or claim arising out of or in connection with the Policy, including the validity, invalidity, breach or termination thereof, you have the right to have recourse to a conventional mediation procedure or any other alternative dispute resolution procedure.

Any dispute concerning the validity, interpretation or execution of the Policy shall be submitted to the exclusive jurisdiction of the competent courts.