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Privacy Policy

Protection of your personal data

Last updated: April 2025

MUSIC VINS is committed to protecting the privacy of its users. This policy explains how we collect, use and protect your data as part of our Online Cellar service.

1. Data Controller

MUSIC VINS Simplified Joint Stock Company (SAS) Share capital: €2,423,760.00 Registered office: 4 Rue du Chapelier, 93290 Tremblay-en-France, France RCS Bobigny: 432 280 592 Email: contact@music-vins.com We are responsible for processing your personal data in accordance with the General Data Protection Regulation (GDPR) and French data protection law.

2. Data Collected

Identification Data: • Title, surname, first name • Date and place of birth • Nationality • Postal and email address • Phone number Identity Verification Data (KYC): • Copy of ID document (ID card, passport) • Proof of address • For companies: registration certificate, articles, directors' identity Financial Data: • Bank details (IBAN, BIC) • Transaction and operation history Connection Data: • IP address • Browsing data • Language preferences

3. Processing Purposes

Your data is used for: Online Cellar Management: • Creation and management of your personal account • Execution of entrusted sales mandates • Tracking of your lots and resale operations • Communication of real-time buyback offers Regulatory Compliance: • Identity verification (KYC) • Anti-money laundering (AML) • Tax and accounting obligations Personalized Support: • Contact by your dedicated advisor • Lot recommendations tailored to your profile • Information about new opportunities Service Improvement: • Anonymized statistical analysis • User experience improvement

4. Legal Bases for Processing

Contract Performance: Processing necessary for the execution of the Sales Mandate Contract and management of your online cellar. Legal Obligation: KYC/AML verifications required by current regulations. Legitimate Interest: Transaction security, fraud prevention, service improvement. Consent: Commercial and marketing communications (revocable at any time).

5. Retention Period

Active customer data: Throughout the duration of the business relationship. Inactive customer data: 3 years after the end of the business relationship. KYC documents: 5 years after the end of the business relationship (AML legal obligation). Billing and transaction data: 10 years (accounting and tax obligation). Connection data: Maximum 1 year. At the end of these periods, your data is deleted or irreversibly anonymized.

6. Data Recipients

Your data may be shared with: MUSIC VINS Staff: Sales teams, advisors, customer service, accounting. Technical Providers: • Hosting: Vercel Inc. • Secure payment solutions • Identity verification services Operational Partners: • Approved bonded warehouses (storage) • Insurance companies (product coverage) • International network of buyers (resale) Authorities: In case of legal obligation or judicial requisition. Important: We never sell your data to third parties. Our partners are contractually bound to confidentiality.

7. International Transfers

Your data is primarily processed within the European Union. In case of transfer to a third country (particularly for hosting), we ensure appropriate safeguards are in place: • European Commission standard contractual clauses • European Commission adequacy decision • Approved certification or code of conduct

8. Your Rights

Under the GDPR, you have the following rights: Right of access: Obtain a copy of all your personal data. Right to rectification: Correct inaccurate or incomplete data. Right to erasure: Request deletion of your data (within legal limits). Right to restriction: Request temporary suspension of processing. Right to portability: Receive your data in a structured, reusable format. Right to object: Object to processing for legitimate reasons. Withdrawal of consent: At any time for consent-based processing. To exercise your rights: Email: dpo@music-vins.com Mail: MUSIC VINS - Data Protection 4 Rue du Chapelier, 93290 Tremblay-en-France, France You can also file a complaint with the CNIL: www.cnil.fr

9. Data Security

We implement robust technical and organizational measures: Technical Measures: • Encryption of sensitive data (AES-256) • HTTPS protocol for all communications • Two-factor authentication available • Firewall and intrusion detection • Daily encrypted backups Organizational Measures: • Access limited to authorized personnel • Regular security training • Incident management procedures • Periodic security audits

10. Cookies

Our site uses cookies to improve your experience: Essential Cookies (required): Necessary for site operation (authentication, security, language preferences). Analytics Cookies: Anonymized analysis of site usage to improve our services. Preference Cookies: Remembering your choices (currency, display). You can manage your preferences via the cookie banner or in your browser settings. Refusing non-essential cookies does not affect access to the service.

11. Contact and Updates

Data Protection Officer: Email: dpo@music-vins.com Phone: +33 1 62 14 22 27 Updates: This policy may be updated to reflect regulatory changes or changes in our practices. Significant changes will be notified to you by email. Effective date: Changes take effect upon publication on the site.
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