Groupe Beneteau's business is to support all its customers in their boating projects and help make them come true. In this context, Groupe Beneteau is a leader in manufacture and distribution of recreational boats ("Boats”), parts and services associated with Boats (maintenance, commercial warranty, connected services, etc.), in particular those of the FOUR WINNS brand.

This policy covers the processing of personal information of individuals (customers and prospective customers) who have, in the past, purchased, ordered or shown an interest in our products or services, as well as visitors of the website www.fourwinns.com (the "Customer(s)", "You", "Your"). Its purpose is to explain how we process your personal information and how you can control and manage it. Where appropriate, additional information may be provided when we collect your personal information. This policy also applies to you as a professional if you are the legal representative or authorized representative of a corporate customer.

Groupe Beneteau is an international group composed of several companies active in France and abroad, whose parent company is BENETEAU SA, having headquarters based in France.

Within the Groupe Beneteau, SPBI SA acts as data controller and centralizes the collection and processing of customers' personal information, all customer relationship management activities, the management of the websites & services offered through them (e.g. boat configurator, customer service, events ...), as well as all personal information of Customers who have signed up to our commercial initiatives and events. For the purposes of this policy, "FOUR WINNS", "We", "Us" or "Our" refers to the data controller which centralizes the collection and processing of customers' personal information, all customer relationship management activities, the management of the websites & services offered through them (e.g. boat configurator, customer service, events ...), as well as all personal information of Customers who have signed up to FOUR WINNS commercial initiatives and events, and more specifically:

• For all geographies except Americas : SPBI SA, registered with the commercial register of La Roche-sur-Yon under number 491 372 702 and whose registered office is located Parc d'activités de l'Eraudière, 34 rue Eric Tabarly, 85170 Dompierre-sur-Yon (France), or
• For Americas: . Beneteau Group America Inc, a company organized under the laws of the state of Delaware, whose head office is located at 1535 SE 17th Street, Suite 205, Fort Lauderdale, FL 33316 (U.S.A.)

(Hereinafter individually the “Data Controller”)

Please note that we rely on independent networks to sell and maintain FOUR WINNS’ Boats, as well as, as the case may be, some products or services associated thereto ("the Network(s)"). The Website together with events or boat shows we attend offer you the opportunity to be put through them.

This privacy policy is not intended to specifically cover the relationships you have with independent members of our Networks (including when you have entered into a relationship with them through services offered on our Website or when attending our events or a boat show). It is not intended either to cover services offered through other group companies or directly by them. These companies and the members of our Networks act as independent data processors in that respect within the meaning of applicable laws and regulations on data protection and privacy.

You have the right to exercise control over your personal information. If you wish to exercise any of the rights described below or if you have any questions concerning the use of your personal information under this privacy policy, please send us a request by e-mail at contact.rgpd@beneteau-group.com or by post to Groupe Beneteau, Group Data Protection Officer, Les Cyclades, ZA du Soleil Levant, 85804 Saint-Gilles-Croix-de-Vie Cedex (France).

2.1. You may request access to your personal information

If you wish to have access to your personal information, we will provide you with a copy of personal information to which your request relates as well as information relating to its processing.

2.2. You may request the rectification of your personal information

If you consider that your personal information is inaccurate or incomplete, you may request that we amend or complete it.

2.3. You may request the deletion of your personal information

If you wish, you may request the deletion of your personal information to the extent permitted by applicable laws and regulations.

2.4. You may object to the processing of your personal information based on legitimate interests

If you disagree with processing based on legitimate interest, you may object to it by indicating precisely what processing is involved and on which grounds (relating to your particular situation) your objection is based. We will no longer process your personal information unless we have legitimate and compelling grounds for doing so or it is necessary for the establishment, exercise or defense of legal claims or disputes.

2.5. You may object to the processing of your personal information for commercial prospection or solicitation purposes

You have the right to object to the processing of your personal information for commercial prospection or solicitation purposes at any time; including profiling insofar it is linked to such prospection or solicitation.

2.6. You may suspend the use of your personal information

If you question the accuracy of the information we use or object to your personal information being processed, we will verify or investigate your request. While your request is being processed, you may ask us to suspend the use of your personal information.

2.7. You may withdraw your consent

If you have given your consent to the processing of your personal information, you may withdraw this consent at any time.

2.8. You may request the portability of part of your personal information

You may request a copy of personal information you have provided to us in a structured, commonly used and machine-readable format. Where technically possible, you may request that we transfer this copy to a third party.

2.9. How to make a complaint to the Data Protection Authority

In addition to the above-mentioned rights, and if you are not satisfied with our answer, you may lodge a complaint with the competent Data Protection Authority, which is usually that of your place of residence, such as the “Commission Nationale de l'Informatique et de Libertés” (CNIL) in France.

We provide you with explanations regarding the purposes for which we process your personal information and legal grounds on which we rely in in that respect.

3.1. Your personal information is processed to comply with our legal obligations

Your personal information is processed where necessary to comply with laws and regulations applicable to Us. We use your personal information for the following purposes:

• To send you, as part of service communications, and if necessary, an urgent product security or recall notice. These communications are necessary to comply with our legal obligations.
• To prevent, detect and manage legal, compliance, reputational and corporate social responsibility (CSR) risks that we may face in the operation of our business.
• To fulfil, where applicable, our obligations in connection with customs, prevention of fraud and corruption, compliance with international sanctions (e.g any economic or commercial sanctions, including any laws, regulations, restrictive measures, embargoes or asset freezes imposed or implemented by any state, the European Union, the US Department of the Treasury's Office of Foreign Asset Control, and any competent authority in the territories where we are established).
• To record, as necessary, any operations and transactions for accounting purposes
• To comply, where applicable, with the provisions of the European eIDAS regulations on electronic signatures
• To provide any relevant answer to official requests from duly authorized local or foreign judicial, criminal, administrative, financial or tax authorities, arbitrators or mediators, law enforcement authorities, government bodies or public organizations
• To comply with our obligations regarding the accessibility of our online services as may be necessary.
• To answer to any request you may send us regarding your privacy (see "What are your rights"), it being understood that we may request to verify your identity.

3.2. Your personal information is processed to perform a contract you have with Us or pre-contractual measures taken at your request.

Your personal information is processed when required for the conclusion or performance of a contract or for pre-contractual measures:

• To provide you with products and services according to the terms of any applicable contract or order form for your Boat, especially to ensure its manufacture, delivery and associated logistics.
• To efficiently manage after-sales service and any commercial warranty claims you may have, particularly with regard to your requests and questions about your Boat
• To carry out any internal or administrative operations, in particular in connection with the management of your commercial warranties, and where applicable, collection management and response to any request for information that you may send us in connection with your Boat.
• Organize contests and lotteries, notably online, for which applicable rules provide with additional indication regarding the processing of your personal information)

The processing of personal information necessary for the conclusion and execution of services associated with your Boat, such as for instance your Connected Services or ancillary services, are specified in separate privacy policies specific to these services which we invite you to consult.

3.3. Your personal information is processed to meet our legitimate interest or that of a third party, including You or other Group companies.

Where the processing of personal information relies on legitimate interest, we ensure that this interest is properly balanced against your interests or your fundamental rights and freedoms.

In the course of our activities, we use your personal inormation to :

• To manage our consolidated prospect and customer database
• To manage risks to which we are exposed, for example, keeping proof of operations or transactions (including in electronic form), managing your claims and defending ourselves in the event of a dispute or litigation.
• To manage the organization and holding of events (such as our open-doors days, sea trials, boat shows…)
• To answer your queries and resolve any complaints, issues or problems relating to our products and services.
• To answer your requests for information about our products and services and, if necessary, to assist you with your queries. This is notably the case :
  • Via e-mail: when you contact us (through the contact details available on our website) or when you send us messages through the “contact” section on our website;
  • Directly via the website: our website is a general audience site designed to inform and help you better understand our products and services. We also offer online functionalities, in particular our online forms. Such forms use the information you provide when you ask to be kept informed, to be added to our mailing lists, to attend events or experiences, to book or request for services (such as sea trials, boat configuration) or to be put through members of our Networks.
• To carry out and manage satisfaction surveys and to proceed with any other actions, including without limitation internal research and development in order to improve customer satisfaction, our products and services or to measure our brand image; it being specified that the choice to contribute to such surveys is entirely yours. We may share this information with our Network, with your consent where relevant.
• To improve your online experience in relation to the Website as well as your overall customer experience, in particular, your online browsing experience (screen size, pre-filling of certain fields, personalized online experience etc.
• To ensure security and improve the management and maintenance of our Website and services offered on it, as well as to assist you in their use
• To improve (cyber)security of our information and networks, with the aim of taking adequate measures to protect your personal information against loss or damage, theft or unauthorized access.

As a company member of the Groupe Beneteau, and unless you object :

• We would like to offer you full access to the Groupe Beneteau’s products and services if they are similar to those you have purchased or subscribed to. In this context, we may send you marketing and promotional offers by electronic means (e-mail, SMS, social and digital media, third-party platforms, etc.). To ensure a fair balance between our respective interests, we always ensure that these offers relate to products or services that are relevant to your needs and complementary to those you already have.
• We may also send you, by telephone or post, offers concerning our products, services and events as well as those of the Groupe Beneteau, our Networks and trusted partners.
• We analyze your personal information in order to personalize our offers but also in order not to send you communications if we understand that they do not fit your special interests.
• In order to improve your experience and satisfaction but also to personalize our services and offers, we need to know which customer panel you belong to. To do this, we create a standard profile (without automated decisions) based on relevant information selected from the following information:
  • those you have directly communicated to us during your interactions with us or that you have provided when acquiring or subscribing to a product or service;
  • your use of our various communication channels such as our Website, events or boat shows you attend.

If you are a business customer, we may send you marketing and promotional offers related to your business activity unless you object.

3.4. Your personal information is processed subject to your prior consent

Some processing activities require your prior consent and specific information. We remind you that you may withdraw your consent at any time. In particular, we ask for your consent for :

• Sending you any marketing and promotional offers by electronic means (e-mail and/or SMS) or any advertising campaign (digital or otherwise, including the sending of our newsletter) relating to products and services that are not similar to those you own or have subscribed to, or products and services from our Networks and trusted partners.
• Sharing your personal information with a professional of our Networks where necessary (consent is requested directly on our online forms)
• Use your browsing data (cookies or other technologies) for commercial purposes or to improve our knowledge of your profile (targeted advertising, content personalization…). In this respect, please refer to section 9 "Cookies" of this policy.

Further consent may be requested where necessary.

“Personal information" means any information that directly identifies you (such as your name) or allows us to identify you indirectly (for instance, a unique identification number).

In all instances, we collect only personal information that is relevant and appropriate to each of purpose for which we process it. We invite you to keep us regularly informed in writing of any changes concerning your personal information.

In all our forms, information required to answer your query or for the purposes of a contract or legal obligations is indicated by asterisks. If you do not wish to provide such mandatory information, it is likely that we will not be in position to process your query or to provide you with the relevant services. Other information is used to get to know you better, in particular to send you personalized communications. This information is therefore optional.

Personal information we collect depends on our interaction with you and may include the following:

• Contact information (private or professional) and identification data: e.g. full name, gender, place and date of birth, postal address, e-mail address, telephone number, photo, signature, customer number;
• Information related to your personal and/or professional situation (family situation, socio-professional category, etc.),
• Information relating to your lifestyle: hobbies and interests, sailing area or preferences;
• Economic, financial and tax information: e.g. tax status, tax residence;
• Information relating to our commercial relationship, in particular our interactions and contracts (order history, after-sales interventions, service contracts, contests, interactions with our customer service or, where applicable, our after-sales services, etc.),
• Information relating to products and services you own, for example information identifying your boat (model, WIN number, options, etc.).
• Information collected in the context of your interactions with us: your comments, suggestions, needs collected during our exchanges at boat shows or events (comments), from your answers to our satisfaction surveys (your experience of our products and services), through online exchanges or your any complaint you may have lodged (including your requests for protection of your privacy);
• Information required to build and improve loyalty programs, prospection, studies and surveys (e.g. your boat preferences),
• Information in connection with the use of our website, online services and pages on social networks, as well as our communications (actions on our website such as behaviour in terms of clicks, number of visits, pages visited, opening of our messages, connection data and data such as cookies used for analytical or non-commercial purposes).
• Information related to your devices (cell phone, computer, tablet, etc.): IP address, technical characteristics and unique identification data, hardware type, domain, browser type and language, operating system and settings, , time and time zone.

The products and services we offer are intended for adults. We therefore do not carry out any specific data processing on minors or children.

We may collect your personal information directly from you as indicated above in article 4 or indirectly through:

• Our Networks: they control all information you provide them. If you have any questions about their use of your personal information, we recommend that you contact them directly.
• Other trusted partners (including other companies within the Groupe Beneteau) and our technical service providers: to ensure the performance of our services, particularly our online services, and to enable us to retain relevant information only, to process ongoing queries, provide and/or improve our products and services, we may receive information about you or your activities from third-party suppliers or service providers.

Within the Groupe Beneteau, only persons duly authorized are allowed to process your personal information considering their functions.

We may share your personal information with :

6.1. Other Group BENETEAU companies

As a member of the Groupe Beneteau, we work closely with other Group companies in France and abroad. Your personal information may therefore be shared between Groupe Beneteau entities, when necessary, in order to :

• Comply with the legal and regulatory obligations above-described
• Fulfil your orders for products and services services and satisfy your commercial guarantee
• Satisfy our legitimate interests:
• Improve the accuracy and reliability of information about you that may be held by other companies within the Groupe Beneteau Group.
• Carry out studies, notably statistical, for commercial, security, compliance and risk management purposes
• Provide you with access to all Groupe Beneteau’s products and services best suited to your needs and desires.
• Personalize products and services we offer you
• Conduct activities, without limitation internal research and development activities, aimed at improving our Boats and our services as well as at ensuring customer knowledge and satisfaction (provided that your consent is not specifically required, in which case it is specifically asked prior to any processing of your personal information)
• Pool resources within the Groupe Beneteau, in particular for the purposes of maintenance and support of services and systems, global analytics but also commercial, IT and administrative continuity.

Your personal information may also be shared, where necessary, to dedicated teams with the Groupe Beneteau in charge of fraud prevention, collection risk, accounting or those responsible for carrying out compliance checks, processing alerts or dealing with your requests in connection with your privacy.

6.2. Companies outside the Groupe Beneteau: recipients or subcontractors

6.2.1. Recipients

We may share some of your personal information with independent partners who will use it for their own purposes. In such cases, these partners act as independent data controllers and their privacy policies apply to personal information shared in this context.

We inform you in all circumstances and make sure to ask for your prior consent to this sharing when required by applicable laws and regulations or at least to allow you to object to it.

More specifically, we may share personal information with:

• Our Networks: if you have requested for a service they provide (for instance, a request for a sea trial close to your home, a request to attend to an event they organize), assistance they provide or we provide through them and more generally to satisfy your requests for products and services, for the purposes of evaluating and training our Networks and to be able to improve your experience as a customer and the quality of services you receive when you interact with our Networks. We ask for your consent where necessary.
• Public authorities: the police or other public authorities and bodies (local or foreign tax, administrative, stock exchange, criminal or judicial authorities, arbitrators or mediators) may at any time request personal information about you, for example for the purposes of crime prevention or detection, or the arrest or prosecution of criminals. We may also need to share personal information with them in connection with the defense of our rights, any legal action, lawsuits or proceeding, or to comply with our legal and regulatory obligations.
• Investors, professional advisors and regulated professions: for example, our insurers, lawyers, statutory auditors, bailiffs in specific circumstances (audits, litigation, internal restructuring, contests, etc.) or third-party investors or potential purchasers and their professional advisors (lawyers, chartered accountants) in the event of future disposals or investments involving us or the Groupe Beneteau.

6.2.2. Subcontractors

We may share your personal information with third-party suppliers and service providers acting as subcontractors on our instructions and on our behalf only, in particular to:

• Host, operate or maintain our databases and website.
• Carry out certain services related to our commercial relations or your customer experience (studies, surveys, etc.).
• Provide marketing and advertising support (including digital), in particular the sending of marketing and promotional offers and the management of advertising campaigns.
• Provide services related to the organization and logistics of contests, events or boat shows.

For all these data-sharing operations, we are seeking to work only with trusted companies, and to secure these relationships by means of contracts, audits, guarantees and by the implementation of security measures.

Your personal information is stored on secured servers. We implement, and require our subcontractors and partners to implement, appropriate and reasonably necessary security and confidentiality measures in line with the latest technologies.

As far as possible, your information is processed in the European Economic Area (“EEA”). However, as some Group companies, service providers or their subcontractors or mother companies are located in countries outside the EEA, your personal information may be processed in these countries.

In the case of international transfers from the EEA to a non-EEA country, the transfer of your personal information may rely on a decision issued by the European Commission, where it has recognized that the country to which your information is transferred ensures an adequate level of protection.

In the event your information is transferred to a country whose level of data protection has not been recognized as adequate by the European Commission, we will either rely on a derogation applicable to the specific situation or take measures to ensure the protection, security and confidentiality of your personal information, in particular through the implementation of standard contractual clauses approved by the European Commission.

Upon request at the contact details available at section "What are your rights" above, we can provide you with more information about security measures and international transfers.

We will keep your personal information for as long as is strictly necessary to achieve our purpose, meet your needs or satisfy our legal and regulatory obligations, resolve disputes and enforce our rights, taking into account our legitimate interests.

To determine this retention period, we specifically take into account the following:

• Duration and provisions of your contracts, in particular the contractual warranty for your boat
• Time required to process your query or resolve your complaint
• Your interest in our brands,
• Need to keep a certain track record of our interactions for proper management of our commercial relationship and your customer experience, this period varying in particular according to whether you have purchased a boat, a service or simply interacted with us without entering into a contract.
• Our legal and regulatory obligations.

We also take into account the categories of personal information processed, the recommendations of any competent data protection authority, statutory limitation periods, applicable legal or regulatory requirements and industry standards.

When we no longer need to use your personal information, it is deleted from our systems and records or anonymized so that it can no longer identify you. However, we may keep certain of your personal information for the duration of the statute of limitations provided for by the applicable legislation in order to be able to face any dispute, lawsuit or legal proceedings,

This section explains how we place, use and store cookies and web beacons on your devices when you visit our website. By device, we mean any computer, smartphone, tablet or other device you use to access the internet.

9.1. What is a cookie?

A cookie is a small text, image or software file that can be palcedread and/or read on your device when you access our website. They may be session cookies, in which case they are deleted from your device once you have closed your session and browser, or persistent cookies, in which case they are stored on your device until they are deleted. In addition to cookies, other technologies may be used, such as web beacons, image tags, pixels or invisible GIFs. For the sake of clarity, we will refer to all these technologies as "cookies" in the remainder of this section.

We use cookies to:

• Improve security of our website, including the protection of your information from unauthorized access
• Track the way you are using our website in order to improve your browsing experience.
• Improve your online experience by tailoring the content of our website to your interests, providing you with relevant advertising and content on our websites or third-party websites.
• Send you personalized advertising based on your online preferences or browsing history.
• Remind information you have given us (e.g. to store your boat configurations)
• Save your preferences and settings when using our website (language, time zone...)

9.2. What type of information can be stored in a cookie?

The information stored by cookies (during their retention period) may relate to the following: the web pages you have visited, the advertisements and communications you have clicked on, your IP address, the type of browser you are using and any other information you have provided on our website. It may contain personal information covered by other sections of this privacy policy.

9.3. What types of cookies do we use and why?

We use different categories of cookies, as detailed below.

a) Cookies strictly necessary (mandatory) and audience measurement cookies exempt from consent

Mandatory cookies are required for the operation of our website. They include, for example, cookies that enable us to personalize our website's interface (e.g. language selection) or to comply with our obligations to provide you with a safe online environment.

Our website also uses audience measurement cookies, which do not require your consent. 

I oppose the use of cookies

b) Functional cookies (subject to your consent)

These cookies enable us and our partners to personalize and offer the content and functionalities of our website, notably the display of our pages. They are used to improve our website and your user experience. If you do not accept these cookies, some or all of the associated services may not be delivered properly.

c) Audience measurement cookies (subject to your consent)

These cookies allow us and our partners to understand how you arrive on our website, to measure the number of visitors but also to analyze your use of our website or to reconstruct your “click path” (number of pages viewed, frequency of return...).

These studies help us to improve the way our website works by ensuring, for example, that you can easily find what you are looking for.

d) Advertising cookies (subject to your consent)

There are different categories of cookies used to propose advertising. Information obtained via advertising cookies is frequently shared with our partners using third-party cookies.

• Personalized advertising cookies :

These cookies are used to disclose personalized advertising when you are using our website or third-party websites. They record your visits on our website, pages you have visited and links you have followed.

They may also be used to display personalized advertisements for our products or services on other websites, for affiliate advertising purposes, for click fraud detection, market research, product & service improvement or debugging but also to measure the efficiency of an advertising campaign, limit the number of times you see an advertisement.

• Non-personalized advertising cookies :

These cookies enable us and our partners to display advertisements that are not personalized according to your interests. These cookies can also be used to measure the performance of a marketing campaign.

• Location-based advertising cookies :

These cookies enable us and our partners to display personalized advertising based on your location (geolocalized advertising).

e) Social network cookies (subject to your consent)

These cookies are activated by the social networking services we have added to our website in order to enable you to share our content with your network. They also enable us to track your browsing on other websites and to profile your interests. This may have an impact on the content and messages displayed on other websites you visit. If you do not allow these cookies, you may not be able to use or view these sharing tools/buttons.

Further information on our partners and regarding how to configure your preferences can be found in section 10.4 below.

Who places cookies on your devices and how long do they last?

Cookies and tracers may be placed by us or by third-party partners. The use of such partners enables us to benefit from the technical services they offer.

The list of partners is available in the "Manage my cookies" section (at the bottom of every page of our website) by clicking on "Associated partners" under each cookie category.

We may share information such as your hashed email address or any other technical identifier with our advertising partners in order to establish a link between your different connection terminals or web browsers and offer you a seamless experience on them.

In some cases, our third-party partners may use such information for their own purposes, and are therefore responsible for the processing they carry out. Please note that such data processing can sometimes be carried out outside the EEA, in a "third-party country" where data processing rules are different from those in force within the European Union. For more information on these transfers and, more generally, on the processing carried out by the partner, you can consult the link to the partner's privacy policy via the "Manage my cookies" link (available at the bottom of every page on the website) by clicking on "Associated partners" and then selecting the relevant partner. The lifetime of cookies is also indicated for each partner at the same place of our website.

How do I manage cookies (activation, deactivation and deletion)?

Some cookies used by our website require your prior consent, which is collected via a banner when you first connect to our website. By default, we save your choices regarding cookies on a given device for a maximum period of six (6) months. We will therefore ask you again to make a choice every 6 months.

• Setting cookies using the tool we provide

To consult the list of the different categories of cookies we use on our website and to configure your choices, you can consult the cookie management module accessible at the bottom of the page.

Please note that the use of “strictly necessary cookies” (mandatory) does not require your consent. This is why the corresponding option is pre-checked in our cookie management tool and is not optional.

In all cases, you can modify your preferences at any time, and withdraw your consent, by clicking on the link at the bottom of each of our pages "Manage my cookies".

• Setting cookies via your browser

You can set your browser to accept or reject all cookies, to delete cookies periodically, or to see when a cookie is issued how long it remains valid and its content, to refuse cookies’ storage on your hard drive.

You can choose to block or deactivate these cookies at any time by configuring the Internet browser on your device in accordance with the instructions provided by your browser provider, usually available on the support pages of their websites.

You can also type "cookies" in the "help" section of your browser to access the instructions for setting the parameters.

We regularly review and update this privacy policy as necessary.

We therefore invite you to consult the latest version of this document each time you visit our website.