Privacy Policy

Effective Date: 19/09/2026

Henry de Freycinet (“we”, “our”, “us”) attaches particular importance to protecting the privacy and personal data of its clients and visitors.

This Privacy Policy explains how personal data is collected, used, stored and protected when you visit www.henrydefreycinet.com (the “Website”), contact us or place an order.

1. Data Controller

The controller responsible for the processing of personal data collected through the Website is:

Henry de Freycinet

Montcaret, France

Website: www.henrydefreycinet.com

Email: contact@henrydefreycinet.com

2. Personal Data We Collect

Depending on your interactions with the Website, we may collect the following categories of personal data.

Identity and Contact Information

• first name;
• last name;
• postal address;
• billing address;
• delivery address;
• email address;
• telephone number.

Order Information

• products ordered;
• personalisation choices;
• order number;
• order date;
• order value;
• delivery information;
• communications relating to your commission.

Payment Information

Payments may be processed through specialised payment service providers.

Henry de Freycinet does not normally have access to or store complete payment card details.

Payment providers may process information necessary to complete and secure the transaction in accordance with their own privacy policies.

Communications

When you contact us, we may process information contained in:

• emails;
• contact forms;
• customer service requests;
• order-related correspondence;
• after-sales or restoration requests.

Technical and Navigation Data

When you use the Website, certain technical information may be collected, including:

• IP address;
• browser type;
• device type;
• operating system;
• pages visited;
• date and time of access;
• technical logs;
• cookie identifiers where applicable.

Optional analytics or marketing data is collected only where permitted by applicable law and, where required, after obtaining your consent.

3. Purposes of Processing

We may process your personal data for the following purposes:

• processing and managing orders;
• managing bespoke commissions;
• processing payments;
• preparing invoices;
• organising delivery and international shipping;
• communicating regarding production and delivery;
• providing customer service;
• managing warranties, repairs and restoration requests;
• preventing fraud and securing transactions;
• complying with accounting, tax and legal obligations;
• maintaining and securing the Website;
• measuring Website performance where permitted;
• sending communications or marketing information where legally permitted and, where required, with your consent.

4. Legal Bases for Processing

Depending on the processing activity, we rely on one or more of the following legal bases.

Performance of a Contract

Processing is necessary when it enables us to:

• process your order;
• manufacture your trunk;
• process payment;
• arrange delivery;
• provide customer service relating to your purchase.

Legal Obligations

Certain information must be processed and retained in order to comply with legal, accounting, tax, consumer protection and regulatory obligations.

Legitimate Interests

We may process certain data where necessary for our legitimate interests, including:

• preventing fraud;
• protecting the Website and our information systems;
• managing disputes;
• improving the reliability and security of our services.

Such processing is carried out only where our interests do not override your fundamental rights and freedoms.

Consent

Where required, we rely on your consent for purposes including:

• optional cookies and tracking technologies;
• certain analytics services;
• electronic marketing communications where consent is required.

You may withdraw your consent at any time.

5. Recipients of Personal Data

Your personal data is accessible only to persons and service providers who need it for the purposes described in this Policy.

This may include:

• Henry de Freycinet and authorised representatives of Henry de Freycinet;
• website hosting and technical service providers;
• payment providers;
• accounting and administrative service providers;
• logistics companies and carriers;
• security and fraud-prevention providers;
• analytics or marketing providers where applicable and authorised.

Only the information necessary for each service is transmitted.

We do not sell personal data.

6. Hosting

The Website is hosted by:

HOSTINGER INTERNATIONAL LIMITED

61 Lordou Vironos str.
6023 Larnaca
Cyprus

Website: www.hostinger.com

Hostinger may process certain technical data necessary to provide hosting, infrastructure, security and related technical services.

7. International Transfers

Certain service providers involved in payment, hosting, analytics, technical infrastructure or international delivery may process personal data outside France or the European Economic Area.

Where personal data is transferred outside the European Economic Area, appropriate safeguards are implemented where required by applicable data protection law.

These safeguards may include:

• an adequacy decision adopted by the European Commission;
• Standard Contractual Clauses approved by the European Commission;
• other legally recognised transfer mechanisms.

8. Data Retention

Personal data is retained only for as long as necessary for the purposes for which it was collected and to comply with applicable legal requirements.

In particular:

• order and customer data is retained for the duration necessary to manage the commercial relationship;
• invoices and accounting documents may be retained for ten years in accordance with French accounting obligations;
• information relating to commercial prospecting may generally be retained during the commercial relationship and for up to three years following the end of that relationship or the last relevant contact;
• technical security logs are retained only for an appropriate period necessary for security and fraud prevention;
• cookie-related data is retained in accordance with the durations described in our Cookie Policy.

Certain information may be archived for longer where required to establish, exercise or defend legal claims or comply with a legal obligation.

9. Security

We implement appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;
• alteration;
• loss;
• disclosure;
• destruction;
• misuse.

Access to personal data is limited to authorised persons and service providers who require access for legitimate purposes.

However, no online system can guarantee absolute security.

10. Your Rights

Subject to the conditions provided by applicable data protection legislation, you may have the right to:

• access your personal data;
• request correction of inaccurate or incomplete data;
• request deletion of your personal data;
• restrict certain processing;
• object to certain processing;
• request portability of eligible personal data;
• withdraw your consent at any time where processing is based on consent.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

11. Exercising Your Rights

To exercise your rights or ask a question regarding the processing of your personal data, you may contact:

Email: contact@henrydefreycinet.com

We may request reasonable information necessary to verify your identity before responding to certain requests.

Requests will be processed in accordance with the time limits provided by applicable law.

12. Complaints

If you believe that your personal data has been processed in violation of applicable data protection law, you have the right to lodge a complaint with the competent supervisory authority.

In France, the competent authority is:

Commission Nationale de l’Informatique et des Libertés (CNIL)

www.cnil.fr

You are encouraged to contact us first so that we may attempt to address your concerns directly.

13. Cookies

The Website uses cookies and similar technologies.

Strictly necessary cookies may be used without consent where permitted by applicable law.

Optional cookies, including certain analytics, advertising or third-party tracking technologies, are used only where permitted and, where required, after obtaining your consent.

More information is available in our Cookie Policy.

14. Marketing Communications

Where you have subscribed to receive communications from Henry de Freycinet, we may use your email address to send you information regarding Henry de Freycinet, collections, products or events.

Where required by law, such communications will only be sent with your prior consent.

You may unsubscribe at any time using the unsubscribe mechanism provided in the communication or by contacting us.

15. Automated Decision-Making

Henry de Freycinet does not intend to make decisions producing legal or similarly significant effects on customers solely through automated processing.

Automated systems may nevertheless be used by payment or security providers for fraud detection and transaction security.