Personnal Data Policy

last update 25/03/2019

Personnal Data Policy

last update 25/03/2019
PRIVACY POLICY

FRED protects your personal data and attaches particular importance to its confidentiality and integrity. We invite you to read:

The information provided by FRED in these documents allows you to understand:
  • the personal data we collect and process. In practice, this refers to the data that FRED collects from you; and
  • why we collect your personal data. That is,the objectives pursued by FRED when we collect this data.

Privacy policy
General information
1.      Identity and details of the data controller
2.      Identity and details of the Data Protection Officer (DPO)
Personal data protection policy
1.      Data collection conditions
2.      Children Data
3.      Processed Data, legal basis and purposes of processings
4.      Data recipients
5.      Data transfers to third countries
6.      Data security and confidentiality
7.      Your rights
8.      Data retention period
9.      Combating fraud and counterfeiting
10.   Right to file a claim
11.   Changes to the privacy policy
Cookie policy
1.      General information
2.      Configuring cookies
2.1.  Cookie list
2.2.  Cookies consent settings
General information

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 29 rue des Pyramides, 75001 Paris (France), recorded in the Register of Commerce and Companies of Paris 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.
The provisions of Regulation (EU) 2016/679 of 27 April 2016 (the General Data Protection Regulation or “GDPR”), as well as the provisions of the French Act n° 78-18 of 6 January 1978 on Information Technology, Data Files and Civil Liberties, as amended (hereinafter referred to as the “French Data Protection Act”) apply to the processing of your Data by FRED. Terms used for the purposes of this policy have the meanings given to them by the GDPR.

2. Identity and details of the Data Protection Officer (DPO)
If you have any questions relating to the collection and processing of your Data by FRED, please contact the Data Protection Officer at the following addresses:

  • By postal mail:
FRED Paris
To the attention of the Data protection officer
29 rue des Pyramides
75001 Paris – France
  • By email: privacy[at]fred.fr
 
Personal data protection policy
1. 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 that you can complete and sign and that are then retained by FRED;
  • FRED digital catalogue available on a dedicated table (referred to hereinafter as the “Digital Catalogue”);
  • “Force 10” collection personalization customer service available in some FRED boutiques, named “Atelier FRED” (referred to hereinafter as the “Atelier FRED”); and
  • FRED interactive mirror available in some FRED boutiques (referred to hereinafter as the “FRED Mirror”).

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

2. Children Data
Protecting the safety and privacy of children is very important to FRED. We do not knowingly collect or use the Data of minors under the age of majority in accordance with local legislations in force.
If you are under the minimum age requirement, please do not submit any Data without the express consent and participation of your parent or guardian.
If you believe that we have collected Data about a minor without such consent, please contact us at privacy[at]fred.fr and we will delete this information.

3. Processed Data, legal basis and purposes of processings
The Data which relates to you and which is collected via the Website, the Atelier FRED App, when you visit a FRED boutique or 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 device in relation to cookies and other trackers):
  • 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;
  • Photographs;
  • IP address;
  • Cookies and trackers; and
  • Login data.

In the particular case where you wish to communicate with FRED staff through third-party instant messaging services, FRED cannot guarantee the confidentiality and security of your Data or any other information exchanged through such messaging services. Companies offering this type of messaging services are themselves responsible for processing of your Data and comply with their own data protection and confidentiality policies. In this specific context, the processing of your Data by third-party messaging services remains outside FRED’s control: FRED therefore declines any responsibility in the context of this use.
Your Data is either:
  • collected based on your consent; or
  • required for the completion of your orders according to a contract; or
  • collected for the purpose of pursuing a legitimate interest of FRED (e.g. to combat fraud and counterfeiting).

Your Data is therefore collected or processed notably for the following purposes:

Purposes

Legal bases

… to answer your questions sent via the “Contact us” form available on our Website

It is in our legitimate interest to respond to your queries to ensure your satisfaction and maintain our relationship.

… to enable you to create a personal “My account” space on our Website and thus to buy our products online

Performance of a contract

… to send you information on our offers, products, latest news and events (newsletters, invitations to events organised by FRED, including private sales and other news publications)

Your consent, where required.

… to manage your orders, if any (online on our Website or in the FRED boutiques), including delivery, and the guarantees applying to FRED products

Performance of a contract

… to ensure the security of online transactions, prevent fraud and payment incidents (see our e-commerce General Terms and Conditions  for more details)

Legal obligations
It is also in our legitimate interest to make sure our transactions are secure.

… to manage, optimise and customize customer relations (notably within the framework of the management of complaints and the FRED after-sales service)

Performance of a contract

… to save your details and usage preferences for our Website in order to optimize your navigation

Your consent, where required
It is also in our legitimate interest to offer great user experience online.

… to manage retargeting devices and suggest targeted advertising

Your consent, where required
It is also in our legitimate interest to serve relevant ads to our customers.

… to access your FRED orders history on our Website

Performance of a contract

… to organize FRED's private sales and other events: your Data may then be processed in order to meet FRED's legitimate interest in promoting its products and activities. Thus, FRED uses your contact Data to inform you about FRED news, select guests at FRED events according to the nature of the relationship you have with FRED (customer, LVMH group employee, VIP guest, etc.), the history of relationships (e.g. participation in other sales or events, purchasing history, etc.), the history of the relationship (e.g. participation in other sales or events, purchasing history, etc.), etc.

Your consent, where required

… to compile statistics, segmentations and marketing analysis following your visits to the FRED boutiques, your visits to the FRED Website, or your use of the Atelier FRED App, in order to send you personalized messages and to implement an adapted relational program

Your consent, where required
It is also in our legitimate interest to understand and address our customers better and more effectively.

… to be shared with its business partners, including companies operating department stores in which certain FRED outlets are located, for example to support their own customer relationship management programs, subject to your consent

Your consent

… to manage your user account and in particular to register your photographs and colours within the back office of the Atelier FRED App so that you can order personalized products in FRED boutiques

Performance of a contract

… to manage the invoicing and payment of your transactions in FRED boutiques

Performance of a contract

… to allow you to create and feed a wish list via the Website and the Digital Catalogue

Performance of a contract

… to allow you to create and feed a favourite shackles list on the Atelier FRED App

Performance of a contract

… to allow you to participate in the contest organised by FRED, in FRED boutiques or via social networks

Performance of a contract

… to allow you to create, edit and send you a personalized picture according to your favorite FRED universe

Your consent


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. FRED collects your image when you use the FRED Mirror in order to provide your with the FRED Mirror features. If you do not want FRED to collect your image, please do not use the FRED Mirror. In such case, FRED will be unable to provide you with the FRED Mirror features.
The other information is optional and helps us to understand you better and to improve our communications and services for you.
4. Data recipients
Your Data will be processed by FRED, its subsidiaries, branches and/or affiliates, and their business partners.
Within the framework of the provision of its services, FRED may transmit or grant access to your Data for technical, logistical or commercial reasons to the following categories of recipients:
  • the providers of development, hosting and maintenance of the Website, of the Atelier FRED App, the Atelier FRED, the Digital Catalogue and the FRED Mirror;
  • 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 trackers;
  • 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, when you agree; these companies then process your Data in accordance with their own data protection policies. They define the purposes and means of the processing operations they carry out and therefore have the status of data controller. FRED cannot therefore be held responsible for the conditions of the processing of your Data by these companies and declines any responsibility in this respect.
  • the business partners to whom the FRED private sales organization is entrusted: the private sales organization may also be entrusted to partners. In order to ensure the management of our invitations to these partner events, we may use the services offered by them to manage the sending of our invitations to the sales they organize and to reconcile our customer database with theirs in order to determine the most appropriate channel to inform you of the sale and avoid in particular the multiplication of invitations for the same sale or to select the guests to FRED events according to the nature of the relationships you have with FRED (customer, LVMH group employee, guest of honour,...), relationship history (for example, participation in other sales or events, purchasing history,...). These partners are bound by strict confidentiality obligations when processing your Data on behalf of FRED as a data processor and may not use your Data for purposes unrelated to the services we entrust to them. However, if you use their services directly, for example by registering on a private sales platform, your Data will be collected and used by the partner under the conditions provided for in their privacy policy, to which you should refer.
  • the service provider in charge of the development and maintenance of the FRED customer relations management platform;
  • the service providers in charge of transaction management and the fight against payment fraud, whose data protection policy you can consult by contacting them directly.

As part of the management of your orders, some FRED service providers who receive your Data may act as data controllers: this is the case in particular for delivery logistics service providers (Fedex) and service providers in charge of payment and fraud management (Cybersource). In this case, the processing of your Data is subject to the personal data protection policies of these providers, which FRED will be able to provide you with on request or which you can obtain by contacting them directly. Similarly, the rights you have under the applicable regulations on the protection of personal data must be directly exercised with these service providers. FRED may also pass on your Data to third parties if this is required by law, a statutory provision or legal decision or if such communication is required in order to protect and defend its rights. Except for these cases, your Data will not be passed on or made accessible to any third parties, excepted the event of the restructuring of FRED, including a total or partial asset transfer, merger, absorption, acquisition, demerger and in general any reorganisation operation, subject to appropriate security and confidentiality measures. As part of the management of your orders, some FRED service providers who receive your Data may act as data controllers: this is the case in particular for delivery logistics service providers (Fedex) and service providers in charge of payment and fraud management (Cybersource).
In this case, the processing of your Data is subject to the personal data protection policies of these providers, which FRED will be able to provide you with on request or which you can obtain by contacting them directly. Similarly, the rights you have under the applicable regulations on the protection of personal data must be directly exercised with these service providers.
FRED may also pass on your Data to third parties if this is required by law, a statutory provision or legal decision or if such communication is required in order to protect and defend its rights.
Except for these cases, your Data will not be passed on or made accessible to any third parties, excepted the event of the restructuring of FRED, including a total or partial asset transfer, merger, absorption, acquisition, demerger and in general any reorganisation operation, subject to appropriate security and confidentiality measures.

5. Data transfers to third countries
Since FRED has subsidiaries, branches and affiliates 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”) in countries/regions where FRED runs its activities such as Monaco, Switzerland, People’s Republic of China (PRC), Hong-Kong, Japan and Singapour (this list being not exhaustive).
Any transfer of Data outside the EEA, notably to a state for which no adequacy decision has been reached by the European Commission under Article 45 of the GDPR, it will be governed by appropriate guarantees, notably contractual, in accordance with the regulations applying to the protection of personal data, such as standard data protection clauses under Article 46 §2 of the GDPR.
A copy of the relevant guarantees can be obtained by writing to our Data protection officer to the addresses given in Article 2 of the General information.

6. 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 similar, appropriate security, technical and organisational guarantees.

7. Your rights
In accordance with the regulations in force, you have the following rights:
  • Withdrawal of consent: you can withdraw at any time your consent in respect of any processing of personal data based on your consent, without affecting the lawfulness of processing based on your consent before its withdrawal.
  • Access: you can ask us to confirm whether we process your personal data and, as the case may be, inform you of the characterisics of such processing, allow you to access such data and give you a copy of it.

  • Rectification: you can ask us to rectify or complete inaccurate or incomplete personal data.
  • Erasure: you can ask us to erase your personal data in the following cases: where it is no longer necessary for the purposes for which it was collected; you withdrew your consent; you objected to the processing of your personal data; your personal data has been processed unlawfully; or to comply with a legal obligation. We are not required to comply with your request notably if the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

  • Restriction: you can ask us to restrict the processing of your personal data (i.e., keep but not use your personal data) where: the accuracy of your personal data is contested; the processing is unlawful, but you do not want it erased; it is still necessary to establish, exercise or defend legal claims; to verify the existence overriding grounds following the exercise of your right of objection. We can continue to use your personal data following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
  • Portability: you can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another data controller, but only where the processing is based on your consent or on the performance of a contract with you, and the processing is carried out by automated means.
  • Digital legacy: you have the right to define (general or specific) directives regarding the fate of your personal data afte your death.

You also have the right to object:
  • for reasons relating to your particular situation, to processing operations based on FRED's legitimate interest. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defense of legal claims;
  • to processing for the purpose of commercial prospecting. As such, you may at any time request to no longer receive communications regarding our offers, products, news and events by using the unsubscribe link provided for this purpose in each email we send you.

These rights may be exercised at any time by contacting FRED’s Data Protection Officer at the addresses given in Article 2 of the General information.

8. Data retention period
FRED processes your Data for a specified period of time depending on the purposes for which it is processed.
Your Data which is collected and processed for customer service purposes will only be retained for the duration of period during which your request is processed.
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 two (2) years, FRED will contact you to determine whether you wish to maintain your account or not. Otherwise your account will be closed and your Data destroyed.
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.
The Data used for the purposes of managing transactions of the e-commerce FRED Website will be kept until the transaction is completed. 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 commercial communications relating to offers, products, news and events concerning FRED will be retained for a period of three (3) years from their collection or your last contact with FRED. This Data is your contact information as well as information about your participation in previous FRED events and your purchase history. 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.
The Data collected via the Atelier FRED App will be kept for a period of twelve (12) months from the last time your customizations were registered in the Atelier FRED App, subject to the purchase of a FRED product.
Moreover, the connexion 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 twelve (12) months.
In any event, FRED processes your Data for a period not exceeding that necessary for the purposes for which they are processed.

9. 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.

10. Right to file a claim
You may contact any competent supervisory authority, such as the one in the Member State of your habitual residence, place of work or of an alleged infringement of the GDPR with any claims concerning the way in which FRED collects and processes your Data.
In France, the local supervisory authority is the French Data Protection Authority (CNIL), 3 place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07.

11. Changes to the privacy policy
In the event of a change to this policy, FRED will inform you of the update of its Privacy policy, by mentioning it on the Privacy policy page of its Website and/or by email.


Cookie policy
1. General information
Browsing on the FRED Website and using the Atelier FRED App results in the deposit of cookies, with your consent where required.
Cookies are stored on your device 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 device (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 install cookies on your device when you connect to our Website or to the Atelier FRED App, depending on your choices.
The placement of certain cookies on your device requires that you give your prior consent. Thus, as soon as you arrive on our Website, an information banner indicates that we are using this technology and that by clicking on "Accept cookies", you agree to the placement of these cookies on your device. When using the Atelier FRED App, you can configure your mobile phone to disable all or part of the cookies. However, such an approach could disrupt your use of the Atelier FRED App.

FRED uses cookies in order to:
  • Personalize your navigation on our Website in order to offer you a better service: the deposit of cookies allows FRED to memorize your navigation choices, to recognize you in case of a new visit and thus to activate the application of your preference and/or personalized settings (for example the language chosen, the type of browser used), to memorize the information of a form that you filled in during your registration or previous visit, or to access your user account.
  • Analyse activity on our Website, in particular by establishing statistics of visits: the use of cookies allows FRED to obtain information on the usage and traffic recorded by its 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 device from these websites. These cookies are governed by the personal data protection policy associated with each social network;
  • Carry out advertising targeting operations: the deposit of cookies allows FRED to offer you targeted ads adapted to your interests ; 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.

    2.Configuring cookies
     
    2.1 Cookie list
    FRED gives you access to a detailed cookie list including description and table of cookies.

    Click here to get access to FRED’s Website cookie list.
    2.2 Cookies consent settings
    You can manage your consent to the use of cookies and trackers via the cookie consent management tool chosen by FRED. This tool allows you to manage your consent for each categorie of cookie or tracker.

    Click here to express your consent to cookies and tracking devices.
    Cookie Settings

  • 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 device depending on the information relating to your browsing activities: http://www.youronlinechoices.com/uk/your-ad-choices.

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 UK’s Data Protection Authority (ICO) at the following address: https://ico.org.uk .