Our Privacy and Personal Data Protection Policy

Your privacy is important to us and we strive to protect it. Below you will find our privacy policy and our data protection policy.

OUR COMMITMENT TO DATA PROTECTION

1. When we need to use external service providers for any of our assignments, we select them carefully and ensure that they are also committed to data protection.
2. We are committed to respecting your rights as a customer and we will do everything in our power to ensure that we accommodate your requests and that you can exercise your rights.
3. We value your privacy and your preferences, which is why you can opt out of receiving communications from us or request a change in the delivery frequency at any time.

1. Identity of the data controller

All personal data are collected by Paris Fashion Shops registered in the Paris Trade and Companies Register under number 819 963 919 with a registered capital of 1,738,000 Euros, headquartered at: 91 rue du Faubourg Saint Honoré, 75008 Paris, France.

The protection of personal data entrusted to us is of utmost importance to us. We are committed to ensuring the highest level of protection of your personal data in compliance with the GDPR 'General Data Protection Regulation' Regulation (EU) 2016/679 of the European Parliament and Council dated April 27, 2016, and the Data Protection Act No. 2018-493 of June 20, 2018, promulgated on June 21, 2018, which amended the Data Protection Act of January 6, 1978.

For any information on the protection of personal data, you can also visit the website of the Commission National de l'Informatique et des Libertés www.cnil.fr.

2. Your rights

Pursuant to the Data Protection Act 78-17 of January 6, 1978, as amended and the General Data Protection Regulation, Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, any individual using the service has the right to exercise the following rights:

• A right of access: as a data subject, you may inquire about the nature of the personal data stored or processed about you by any entity of the Group. You shall be provided with access to your personal data.
• A right to rectification: if personal information is inaccurate or incomplete, you may request that it be amended.
• A right to object: you have the right to object at any time to the processing of your personal data where Paris Fashion Shops processes your data for legitimate interests or for direct marketing purposes.
• A right to the erasure of your data: you can request the deletion of your personal data in accordance with the law.
• A right to restriction of the processing of your data: you have the right to request the restriction of the processing of your personal data where permitted by applicable laws and regulations.
• A right to data portability of your personal data: if you meet the conditions defined by the laws and regulations on the protection of personal data, you have the right to receive a subset of your personal data and to transfer it to another data controller.
• Disposal of your data: the user may give instructions concerning the retention, deletion and communication of their personal data after their death in accordance with Article 40-1 of Law 78-17 dated 6 January 1978.

2.1 Exercising your rights

If you wish to exercise your rights, please send a letter to Paris Fashion Shops, 91 rue du Faubourg Saint Honoré, 75008 Paris or by e-mail to dpo@parisfashionshops.com.

Proof of identity is required with your request. Upon receipt of your query, we will provide you with a response within 30 working days. Please note that some complex inquiries may take longer, in which case the deadline will be extended, and you will be notified.

If you believe that the Company has failed to abide by any of your rights, you may file a complaint with the CNIL via its website: www.cnil.fr or by mail to the address: 3, place de Fontenoy - 75007 Paris.

3. What information do we collect?

The provision of your personal data is in most cases on a voluntary basis. We are required by law to verify the accuracy of some of your personal data, in which case we may ask you to do so.

3.1 How do we collect your personal data?

We collect personal data about the user in order to provide our Service. The collection of your personal data can be done:

• Via the website https://parisfashionshops.com/fr
• Through your customer center;
• By mail, whether in electronic or paper format;
• At the time of your online payment;
• During a request for information, a phone call, or when contacting our services;
• When you attend events organized by the company (trade shows, webinars, training, customer satisfaction surveys, etc.)

On our Website forms, the user is informed whether or not the collection of personal data is mandatory. Unfortunately, if a compulsory data field is not provided, we will not be able to perform the Service and respect our commitments.

3.2 Personal data collected from legal entities

Last name, first name, title, e-mail address, invoicing address, delivery address, cell phone number, landline phone number, title of the legal representative of the legal entity.

Company name, corporate number, IBAN, European VAT number, industry category, customer satisfaction data, customer service data, and any other data that may be necessary for the management and follow-up of your customer account.

3.3 Why we collect personal data

We process your personal data to provide you with the most suitable service to meet your needs. When you use our services, we may process your personal data for the following purposes:

• Managing the customer relationship and your contract;
• Customer account management;
• Order and delivery management;
• Online payment management;
• Litigation management;
• Customer satisfaction management and surveys;
• Answering any questions and complaints;
• Monitoring the service quality;
• Collecting comments and opinions from users on the website;
• Tracking and analyzing statistics about the use of our website;
• Marketing purposes;
• Drawing up statistics, including commercial statistics;
• Sending invitations to attend certain events held by the company (trade shows, workshops, training, etc.)
• Sending newsletters by email;
• Sending promotional offers and promotional codes by text messages and by email based on your preferences;
• Fraud prevention.

In accordance with the applicable regulations governing the protection of personal data, the company has defined a legal basis for each of the personal data processing operations that it carries out as follows:

• Carrying out pre-contractual or contractual actions;
• Carrying out a legal obligation;
• When it is in the legitimate interest of the Data Controller;
• When the user has given their consent.

4. Retention period of your data

PFS has defined separate retention periods for prospective customers and customers. We ensure that the retention periods are relevant and comply with the legal deadlines.

To determine the retention period of personal data, Paris Fashion Shops shall apply the following criteria:

• Personal data of prospective customers: are kept for thirty-six (36) months. The start of the retention period shall be based on the date of your last communication with one of our teams.
• Customer personal data: are kept for the duration of the contractual relationship and then sixty (60) months after termination of said relationship.
• Candidates' personal data: are kept for twenty-four (24) months if the candidate has agreed to the conservation of his/her application. You may, at any time, request the deletion of your information.

The company may retain certain data beyond the above-mentioned periods in order to fulfill its legal or regulatory obligations.

The user is hereby advised that the company may retain personal data in order to compile statistics on its users. Should this be the case, the data will be anonymized and cannot be restored.

5. Fraud Prevention

To ensure the security of any order payment, the personal data collected on the site is processed to assess any associated risk of fraud. Any order that is deemed to be suspicious will be subject to verification. Should a fraudulent order be detected, the data may be transmitted to law enforcement agencies for investigation.

The data that may be analyzed in the event that fraud is suspected:

• Name, address, date of birth
• Previous address history
• Contact information, e.g. e-mail, phone
• Financial information
• Your account information
• Data identifying the computers/devices you use to connect to the internet, e.g., IP (Internet Protocol) address
• Order history, order amount
• Website browsing data

The data processed to prevent illegal activity is kept for a maximum of five (5) years after the fraud investigation has been completed. Should legal proceedings be initiated, the data will be kept until the end of the proceedings and the expiration of the applicable prescriptions.

Individuals registered on a list of suspected fraud perpetrators will be removed from the list after a period of five (5) years from the date of their inclusion on the list.

In accordance with the French Monetary and Financial Code, rights of access to this data may be exercised with the Commission Nationale de l'Informatique et des Libertés (see cnil.fr).

6. Business prospecting

Paris Fashion Shops uses your contact information to send you targeted advertisements, including by email, text message and via social media. In such instances, we are committed to respecting the rules dictated by Directive 2002/58/EC dated July 12, 2002. The receipt of our email and text message communications will be based upon your consent. At the time of your registration, you may choose whether or not to agree to receive:

• Our promotional offers by email;
• Our promotional offers by text message;
• Our newsletters;
• Promotional offers from our partners.

However, one exception to this rule applies. If you are already a Paris Fashion Shops customer, we may send you promotional offers about products that you usually order from us without any prior consent from you.

In any event, you may opt out of receiving such communications by taking the following actions:

• By clicking on the unsubscribe link at the bottom of each newsletter;
• By sending a 'stop SMS' message to the number indicated in the text message;
• By contacting customer service;
• By sending an email to the following address: dpo@parifashionshops.com

6.1 Business prospecting over the phone

We may occasionally contact you by telephone with offers on PFS products or services. If you do not wish to be contacted, please note that you can register on the phone marketing opt-out list available at www.bloctel.gouv.fr or exercise your right to opt out by contacting us online or by sending an e-mail to dpo@parifashionshops.com.

7. Rules governing credit card payments and banking data protection

We use a payment service provider, MANGOPAY, to ensure the security of your payments. This provider guarantees secure processing of all sensitive data such as bank details and user identity, in compliance with the directives and standards: DSP2, GDPR and PCI-DSS.

When paying for your order by credit card, our order-taking system connects in real time with the MANGOPAY system, which collects your data and carries out various checks to prevent abuse and fraud. The data is stored on MANGOPAY servers and is not transmitted to our servers at any time. MANGOPAY requests authorization from the bank and only sends us the transaction number.

You can choose to have your credit cards associated with your online account by checking the appropriate acceptance box so that you do not have to re-enter your credit card information for subsequent orders. Your credit card information is stored securely by MANGOPAY. For the purpose of charging the account upon invoicing or crediting the account in the case of a return, MANGOPAY stores the bank data associated with the authorization number until the transaction is completed (payment after shipment of the goods) and until any complaints (returns, disputes) are processed.

• MANGOPAY Terms & Conditions: https://www.mangopay.com/terms/end-user-terms-and-conditions/Mangopay_Terms-EN.pdf
• MANGOPAY data protection policy: https://www.mangopay.com/privacy_doc/Privacy_EN.pdf

8. Who do we share your personal data with?

To provide you with the full benefit of our expertise, your personal data may be communicated to:

Our internal departments: marketing, accounting, human resources, communication, sales departments, customer service, quality assurance, etc.

Our Subcontractors: when we use subcontractors, we ensure that the contractual relations are subject to strict supervision within the scope of Article 28 of the GDPR. We may use Subcontractors for the following operations in the provision of our Services:

• Online payment management;
• Outstanding payment collection;
• Handling telephone calls and customer follow-up;
• Postal mailings;
• Site content customization, maintenance and technical development of the site;
• Customer reviews and feedback collection;
• Newsletter dispatch;
• Marketing emails dispatch;

Additional parties to whom your data may be sent include:

• Marketplace sellers;
• Financing and credit institutions;
• The police authorities as part of legal requests relating to fraud prevention;
• Customs authorities for international deliveries;
• Commercial partners, in particular marketing and advertising agencies.

Should we have to legally defend our rights, your personal data could be communicated to the relevant authorities and to our legal counsel.

9. Data transfer outside the EU

Paris Fashion Shops hereby informs you that some personal data may be transferred to companies located in countries outside the European Union that do not provide an adequate level of protection for such data. Such transfer may particularly occur when you use the social media channels we provide on our site or certain search engines.

Prior to the transfer outside the European Union, and in accordance with the regulations currently in effect, we shall endeavor to obtain the necessary guarantees for the security of such transfers.

10. The security measures that we implement to protect your data

In its capacity as Data Controller, Paris Fashion Shops shall take all reasonable precautions to preserve the security and confidentiality of your data. These measures include the physical security of the buildings housing our systems and the security of the computer system to prevent external access to your data. We restrict access to your data to strictly need-to-know individuals.

11. Third-party websites and social media

You may wish to use social media channels provided by PFS on its website to communicate with our teams (e.g., via Facebook messenger) and thereby enjoy a close business relationship. You may also be interested in sharing the content provided by PFS (e.g., via the "share" button). Through social media, PFS could offer personalized advertising based on your interests. Social media interactions with PFS may involve the exchange of data between PFS and these channels. As such, we recommend that you review the privacy policies and settings of the social media sites with which you interact to see what information may be collected, used or shared by those sites.

12.Cookie policy

12.1 What are cookies?

Cookies are small data files that are stored on your computer or mobile device by your browser when you visit a website. A cookie usually contains the name of the website that uses it and a text string or "unique identifier" that allows websites to recognize that cookie on each subsequent visit throughout its lifetime.

Cookies can collect and store a wide range of information, such as the type of browser or operating system used, the language or other browser settings, or your interactions with the website. Cookies are not usually used to collect personally identifiable information. However, when combined with personally identifiable information such as an individual's email address, information collected with cookies can be traced back to an individual.

When you log on to our site, you will see a warning at the bottom of the site that cookies are being stored. We require your consent to store certain cookies. You may accept or decline the storage of cookies on your computer or mobile device.

If you decide not to accept cookies, you may not be able to use certain features on the site.

We generally use two different types of cookies on this site:

Single-session cookies are used to store information about your activities on this site for the duration of your visit. They are deleted when you close your browser.

Persistent cookies are stored in one of your browser's subfolders for one or more sessions. They expire after a certain period of time (defined in the file) or can be deleted manually.

Web tags, embedded scripts and similar technologies:

PFS and its third-party partners may also use similar technologies on this site, such as web tags (also called Pixel-Tags or GIFs) or scripts.
Web tags are small graphic images that may be embedded in websites or HTML emails that are not generally visible to the user. They allow us to track user interaction with the site or our newsletters. For instance, they help us understand whether you have read our newsletter or clicked on links in it, so that we can deliver offers tailored to your interests.
An embedded script or pixel is a code designed to collect information about your interactions with this site, such as what links you click on. The code is temporarily downloaded to your device from our web server or that of a third-party service provider. It is active only when you are logged on to the website, and is disabled or deleted afterward. While you may not be able to specifically block or disable these technologies, they work in conjunction with some cookies. Disabling cookies will therefore prevent the aforementioned technologies from working.

In accordance with Directive 2002/58/EC of July 12, 2002, we require your prior consent for the storage of advertising, audience analysis and social media sharing cookies.

12.2 What type of cookies do we use and why?

Strictly Necessary Cookies

These cookies are required for operations specific to the services that are provided on our websites. They are used to provide basic functionality on our websites, such as to recall information that has been entered into a form. If you disable these cookies, you will not be able to use these features and the website may not function properly.

Statistics and Performance Cookies

These cookies are used to collect anonymous data for statistical purposes. These cookies allow us to monitor the website's audience and to track how visitors use the website (number of website visits, number of visits per page, time spent on each page, location of clicks, measures of advertisement performance, etc.). They are also used to detect browsing issues and any other difficulties. These cookies help us improve our website and your browsing experience.

Functionality or Preference Cookies

These cookies are used to remember your choices, settings and content preferences on the website (such as your language, preferences regarding the use of the website, etc.) and to provide you with a personalized browsing experience by tailoring the content of the website to you. If you choose not to accept these cookies, we will not be able to provide certain features and some pages of the website may not function properly.

Sharing Cookies Specific Features

These cookies are specific to the use of sharing buttons on a page of the website on social media (Facebook, Twitter, LinkedIn, etc.). The sharing buttons will let you share a page of the site directly on the social media platform of interest. When you click on the share button on the respective social media channel, one or more cookies are placed on your computer, smartphone or tablet by this channel. We have neither access nor control over these third-party cookies, which may be analytical, performance or targeting cookies.

You may wish to refer to the websites of these third parties for more information about their cookies and how they are managed:

• Facebook:  https://fr-fr.facebook.com/policies/cookies/
• Twitter:  https://help.twitter.com/fr/rules-and-policies/twitter-cookies
• LinkedIn:  https://www.linkedin.com/legal/cookie-policy?_l=fr_FR
• YouTube: https://www.youtube.com/static?template=terms&gl=EN

12.3 Setting and blocking cookies using our cookie manager

The list of cookies that we use can be reviewed through the management tool that we provide. You can disable them at any time. We would like to point out, however, that some cookies are required for our website to function properly and that it is therefore not recommended to disable them.

12.4 Setting and blocking cookies using your browser settings

You can also manage cookies through your browser settings. While most browsers are set by default to accept cookies, you can choose to accept all cookies, systematically decline them, or choose which ones you accept depending on who is setting them. You can also set your browser to accept or deny, on a case-by-case basis, cookies prior to their implementation. You can also regularly delete cookies from your device through your browser.

The use of cookies or similar technologies by any third party website or advertising content provider is subject to their own cookie privacy policy.

The CNIL (Commission Nationale de l'Informatique et des Libertés) offers a cookie management software that can be downloaded free of charge from its website: go to https://www.cnil.fr/vos-droits/vos-traces/les-cookies/ to find out more

To manage cookies and your preferences, each browser's layout and settings will differ. A description of how to modify your cookie preferences can be found in the help menu of your browser.

For example :

• For Internet Explorer™:  https://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
• For Safari™:  https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
• For Chrome™:  https://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
• For Firefox™   https://support.mozilla.org/fr/kb/Activer et désactiver les cookies

12.5 Smartphone operating system settings

You have the option to manage the storage of Cookies on your smartphone in the operating system parameters.
On iOS: https://support.apple.com/fr-fr/HT201265
On Android:  https://support.google.com/chrome/topic/3434352

13. Amendment of the Policy

Paris Fashion Shops may revise the policy at any time. Any changes shall not impact any service purchases previously made on the site. The user is kindly advised to take note of the policy each time he/she uses the services of the website, and no formal notification is required.

14. Governing Law and Jurisdiction

The policy is governed by French law. In the event of a dispute and should an amicable agreement not be reached, the applicable courts will be defined as those within the jurisdiction of the Paris Court of Appeal, notwithstanding multiple defendants or third party claims.

This policy was posted online on May 10, 2022