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Personal data

 

1. 1. Identity and details of the data controller

This policy outlines the way in which the company FRED PARIS, a limited liability company with a capital of €15,513,375 whose registered office is at 131 avenue Charles de Gaulle, 92200 Neuilly-sur-Seine (France), recorded in the Register of Commerce and Companies of Nanterre under No. 582 088 159 (referred to hereinafter as “FRED”), processes the personal data which concerns you (referred to hereinafter as your “Data”) in its capacity as data controller according to the regulations applying to the protection of personal data.

In accordance with French Act n° 78-18 of 6 January 1978 on Information Technology, Data Files and Civil Liberties in its consolidated version of 25 May 2018 referred to hereinafter as the “French Data Protection Act”) and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the General Data Protection Regulation, “GDPR”), personal data is defined as any information which relates to an identified or identifiable natural person, i.e. who can be identified, directly or indirectly.

 

2. Data collection conditions

The website www.fred.com (referred to hereinafter as the “Website”) and the “Atelier FRED” mobile application available on App Store and Google Play application platforms (referred to hereinafter as the “Atelier FRED App”) are operated by FRED and allow FRED to collect your Data.

The staff of the FRED boutiques are required to collect Data and carry out Data processing within the framework of their activities. The Data collected by the FRED boutiques is notably obtained from:

- Data collection forms provided by the staff of the FRED boutiques which are to be completed and signed by yourself and are then retained by FRED;
- FRED digital catalogue available on a dedicated table (referred to hereinafter as the “Digital Catalogue”); and
- “Force 10” collection personalization customer service available in some FRED boutiques, named “Atelier FRED” (referred to hereinafter as the “Atelier FRED”)

The FRED customer services department is also required to collect and process your Data when you contact it with your requests.

 

3. 3. Processed Data, basis and purposes of processing

The Data which relates to you and which is collected via the Website, the Atelier FRED App, when you visit a FRED boutique and when you contact our customer services department mainly consists of the following, depending on the services provided by FRED (and according to your choices and the configuration of your terminal in relation to cookies and other plotters):

- Civil status;
- First name and last name;
- Company name;
- Email address;
- Mailing address;
- Mobile and landline numbers;
- Contact preferences;
- Date of birth;
- Date of marriage;
- Bank details in the context of sales of FRED products;
- Purchase history;
- Preferences and interests;
- IP address; and
- Login data.

This Data is either collected on the basis of your consent or is required for the completion of your orders according to a contract.

Your Data is therefore collected notably for the following purposes:

- in order to answer your questions sent via the “Contact us” form available on our Website;
- to enable you to create a personal “My account” space on our Website and and thus to buy our products online;
-to send you information on our offers, products, latest news and events (newsletters, invitations and other publications) subject to your consent;
-to manage your orders, if any (online on our Website or in the FRED boutiques), including delivery, and the guarantees applying to FRED products;
- - to ensure the security of online transactions, prevent fraud and payment incidents (see our General Terms and Conditions for more details);
- to manage and optimise customer relations (notably within the framework of the management of complaints and the FRED after-sales service);
- to save your details and usage preferences for our Website;
- to access your FRED history on our Website;
- to organise involvement in FRED events;
- to compile statistics and marketing analysis;
- to manage your user account and in particular to register your photographs and colors within the back office of the Atelier FRED App so that you can order personalized products in FRED boutiques;
- to manage the invoicing and payment of your transactions in FRED boutiques;
- to allow you to create and feed a wishlist via the Wesite and the Digital Catalogue; and
- to allow you to create and feed a favorites list on the Atelier FRED App.

The Data required by FRED in order to fulfil the purposes outlined above is marked with an asterisk on the different pages of our Website and of the Atelier FRED App, as well as on the Data collection forms available on FRED boutiques. If you do not complete these compulsory fields, FRED will not be able to answer your requests and/or provide you with the requested services. The other information is optional and helps us to understand you better and to improve our communications and services for you.

 

4. Cookies

Cookies are stored on your terminal when you have browsed the FRED Website and used the Atelier FRED App. Cookies are small text files which are likely to be saved to a dedicated hard disk space on your terminal (computer, tablet, smart phone, etc.) when you consult an on-line service using your browsing software.

Cookies contain a certain amount of Data concerning your browsing activities (for example the date, time and number of visits, supply source and preferences). FRED may be required to install cookies on your terminal when you connect to our Website or to the Atelier FRED App, depending on your choices.

FRED uses cookies in order to:

- analyse activity on our Website: the use of cookies allows us to obtain information on the usage and traffic recorded by our Website and thereby measure its performance;
- provide you with sharing buttons via social networks: if you click on one of these buttons, more cookies may be stored in your terminal from these websites. These cookies are governed by the personal data protection policy associated with each social network. FRED therefore has no control over their storage; and
- to allow your navigation within the Atelier FRED App: these cookies are essential to allow you to navigate on the Atelier FRED App and to use its functionalities. Without these cookies, the services you have requested, such as storing your login Data, cannot be provided.

Cookies are kept for a maximum of twelve (12) months . This deadline will not be extended by additional visits.

Your consent is required for cookies to be stored on your terminal.

- Upon your arrival on our Website, an information banner is displayed to indicate that we use this technology and that, by continuing to browse, you agree to cookies being stored on your terminal.
- When using the Atelier FRED App, you can configure your mobile phone to disable some or all cookies. However, such an approach could disrupt your use of the Atelier FRED App.

 

5. Configuring cookies

 

You have the option of managing the storage of cookies by configuring your browser. This configuration may alter your browsing activity on the Internet and your access conditions for certain services requiring the use of cookies.

The removal of functional cookies, which are necessary for the provision of content or services by FRED, will no longer allow you to access certain content or services which require you to log in and notably to detect the type of browser used by your terminal, its language and display settings.

FRED declines all responsibility relating to consequences stemming from the reduced operation of its services due to the impossibility of storing or consulting the cookies required for the operation of said services whose storage you have refused or whose deletion you have requested.

However, you may decide at any time to express and amend your requirements and browser settings relating to the use of cookies using the methods outlined below.

-Choices offered by your browser: You may configure your browser so that cookies are saved on your terminal or instead are rejected either systematically or depending on their issuer. You may also configure your browser so that you have the option of accepting or refusing cookies before they are likely to be stored on your terminal.

-How to implement your choices depending on the browser that you use? The management of cookies varies according to the configuration of each browser. Click on the following links for further details.

 

- For Internet Explorer™ :

https://support.microsoft.com/fil-ph/help/17442/windows-internet-explorer-delete-manage-cookies

- For Safari™ :

https://support.apple.com/kb/PH21411?locale=fr_CA&viewlocale=en_US

- For Google Chrome™ :

https://support.google.com/chrome/answer/95647?co=GENIE.Platform=Desktop&hl=en

- For Firefox™ :

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

- For Opera™ :

https://www.opera.com/help/tutorials/security/privacy/

- Expressing on-line choices via inter-professional platforms: With regard to advertising cookies, you can also consult the YourOnlineChoices website provided by on-line advertising professionals belonging to the European association EDAA (European Digital Advertising Alliance) managed in France by IAB France. You will find a list of firms which allow you to configure the cookies that they use in order to adapt the adverts likely to be displayed on your terminal depending on the information relating to your browsing activities: http://www.youronlinechoices.com/fr/controler-sescookies/.

These settings will not prevent adverts from being displayed on the websites that you use but they will block the technologies used to adapt adverts to your particular interests.

Further information on cookies and their use can be obtained from the website of the French Data Protection Authority (CNIL) at the following address: https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs

 

6. Data recipients

Your Data will be processed by FRED, its subsidiaries and branches, branches and/or affiliates, and their local business partners.

Within the framework of the provision of its services, FRED may transmit or grant access to your Data exclusively for technical and logistical reasons to the following categories of Data processors:

- the providers of development, hosting and maintenance of the Webite, of the Atelier FRED App, the Atelier FRED and the Digital Catlogue;
- the service provider conducting the intrusion tests on our Website;
- the service provider in charge of circulating news (newsletter, invitations and other publications);
- the marketing and segmentation analysis service providers;
- the provider of the statistical analysis solution for cookies and plotters;
- the media agencies in charge of monitoring the performance of FRED;
- the service providers managing all the processes within the FRED boutiques (transactions, inventory management, labelling and customer database management , logistics and order management);
- the department stores in which FRED shop-in-shops may be located, that may require FRED upon request to share your Data because of the consignment structure of our activity; and
-the service provider managers in charge of the development and maintenance of the FRED customer relations management platform.

FRED may also be required to pass on your Data to third parties if this is required by law, a statutory provision of legal decision or if such communication is required in order to protect and defend its rights.

With the exception of these cases, your Data will not be passed on or made accessible to any third parties, subject to the restructuring of FRED, including a total or partial asset transfer, merger, absorption, acquisition, demerger and in general any reorganisation operation.

 

7. Transferring Data to third countries

Since FRED has subsidiaries and branches located abroad and works with Data processors located abroad, the recipients of your Data may also be located abroad, including outside the European Economic Area (referred to hereinafter as the “EEA”).

If your Data is transferred outside the EEA, notably to a state for which no adequacy decision has been reached by the European Commission, it will be governed by appropriate contractual guarantees in accordance with the regulations applying to the protection of personal data.

A copy of the relevant guarantees can be obtained by writing to: FRED PARIS  SA, for the attention of the data protection officer, 131 avenue Charles de Gaulle, 92200 Neuilly-sur-Seine, France, or by contacting our data protection officer at the following address: privacy@fred.fr.

 

8. Data security and confidentiality

FRED applies technical and organisational security measures in line with accepted practice particularly with regard to the security of its information system.

FRED strives to take all the necessary steps in order to protect the confidentiality and security of your Data and prevent it from being amended, damaged, destroyed or accessed by unauthorised third parties. FRED will ensure in this respect that its Data processors present the same security, technical and organisational guarantees.

 

9. Your rights

According to the regulations in force, you have the right to access and correct your Data, to withdraw your consent at any time, to request the deletion of your Data, to oppose its processing and to obtain its limitation or portability if applicable subject to legitimate imperious grounds which may be justified by FRED to retain your Data.

Furthermore, you may at any time request that you no longer receive communications relating to our offers, products, news and events using the hypertext link provided in every email which we send to you.

These rights may be exercised at any time by sending an email to our data protection officer at the following address: privacy@fred.fr.

 

10. Right to object

You have the right to object to your Data continuing to be processed for commercial prospecting purposes.

The right to object may be exercised at any time by sending an email to our data protection officer at the following address: privacy@fred.fr.

 

11. Data retention period

Your Data which is collected and processed via the “Contact us” section of our Website will only be retained for the duration of period during which your request is processed. After this period it will be destroyed.

If you decide to create a customer account, your identification Data will be retained for as long as your account remains active provided that you do not close it. You may close your account at any time. Your request will be acknowledged as soon as possible or, in the case of a current order, as soon as it has been fully executed. If your account remains inactive for a period of ten (10) years, FRED will contact you to determine whether or not you wish to maintain your account. Otherwise your account will be closed and your Data destroyed.

The Data used for the purposes of managing transactions of the e-commerce FRED Website will be kept until the transaction is completed

The Data relating to your product orders will in principle be retained by FRED for a period not exceeding the applicable statutory limitation periods. However, this Data will also be available on your customer account as long as it is active.

Your banking Data will be kept secure for the time necessary for validation of your order and payment, and will then be immediately destroyed. In the event of a payment incident, your Data will be kept for the duration of the incident management, then for a period of three (3) to five (5) years depending on the seriousness of the incident.

The Data used for the purpose of sending communications relating to offers, products, news and events concerning FRED will be retained for a period of ten (10) years from their collection or your last contact with FRED. Prior to the expiry of this period, FRED may contact you to determine whether you wish to continue to receive communications relating to our offers, products, news and events.

FRED will delete your Data at the end of this period. Your Data will also be destroyed within a maximum period of one (1) month from your deregistration request.

Moreover, the connection logs collected with your agreement within the framework of the use of cookies and other plotters used on our Website and on the Atelier FRED App will be retained in accordance with the applicable regulations for a period of no more than thirteen (13) months.

 

12. Combating fraud and counterfeiting

FRED is a jewellery House within the LVMH group. The LVMH group places a great deal of importance on the protection of its trademarks, products, know-how and image. In this context the LVMH group, alongside and in cooperation with the public authorities, has introduced a number of tools to detect fraud and counterfeiting and centralises all information relating notably to counterfeiting offences and parallel imports which it may detect or which are reported concerning the brands and products of the LVMH group or any other infringement of the rights of the companies within the LVMH group, a list of which can be obtained from the website www.lvmh.fr, including in relation to the FRED House.

In this context, the LVMH group may be required to collect and process certain personal data concerning individuals who are suspected to have committed or been involved in such infringements as well as any witnesses.

This information will only be retained for the requirements and duration required for the verification of the detected or reported facts and, if applicable, for the implementation of proceedings or means intended to settle the matter until the case is finally closed or, if the LVMH group decides not to initiate proceedings, for a period of five (5) years from the last incident recorded.

 

13. Identity and details of the Data Protection Officer (DPO)

The company TNP Consultants SAS is the data protection officer for FRED.

If you have any questions relating to the collection and processing of your Data by FRED, please contact the data protection officer by email at the following address: privacy@fred.fr.

 

14. Right to file a claim

You may also contact the French Data Protection Authority (CNIL), 3 place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07 with any claims concerning the manner in which FRED collects and processes your Data.

 

Dernière mise à jour : 22 june 2018