Personal data – any information directly or indirectly related to a data subject
Data subject – identified individual, the www.chloe.com user, who is the sole owner of the personal data belonging to him/her
Personal data processing – any action (operation) or set of actions (operations) performed with or without automated means on personal data, including the collection, recording, systematisation, accumulation, storage, alteration (update, modification), retrieval, use, transfer (dissemination, provision, access), depersonalisation, blocking, deletion or destruction of personal data
Personal data operator – legal person YOOX NET-A-PORTER GROUP S.p.A., registered at via Morimondo, 17 – Milano 20143, Italy, business registration number, tax code and VAT number 02050461207, share capital €1,338,942.89 (hereinafter "YOOX NET-A-PORTER GROUP"): organises and performs personal data processing and also defines the purposes of personal data processing, the composition of personal data subject to processing and the actions (operations) performed on the personal data
Richemont brand – legal person Chloé SAS, registered at 5/7 avenue Percier 75008 Paris – FRANCE Paris, France, business registration number, tax code and VAT number RCS 562 076 299 – SIRET 562 076 299 00048, manufacturer and sole owner of the goods sold and also sole owner of exclusive intellectual property rights (hereinafter Richemont)
YOOX NET-A-PORTER GROUP S.p.A. and Richemont act jointly as co-proprietors of the website www.chloe.com
Personal data processing policy and principles
- When navigating on www.chloe.com without making a purchase and also when using services offered on www.chloe.com without completing registration
- When completing registration for My Account and also when entering www.chloe.com through social networks
- When making purchases on www.chloe.com.
YOOX NET-A-PORTER GROUP and Richemont ask users to read the www.chloe.com General Terms and Conditions of Use carefully. They include essential information about privacy assurance and the security systems used on this website.
YOOX NET-A-PORTER GROUP, in its capacity as personal data operator, acts in accordance with the principles set out in legislation guaranteeing protection of human rights and freedoms in the processing of www.chloe.com users’ personal data.
YOOX NET-A-PORTER GROUP performs personal data processing on a fair and legal basis.
YOOX NET-A-PORTER GROUP defines the purposes and means of processing www.chloe.com users’ personal data and also the security measures required in accordance with the level of protection with which YOOX NET-A-PORTER GROUP S.p.A. handles www.chloe.com users’ personal data.
YOOX NET-A-PORTER GROUP does not allow personal data processing incompatible with the purposes of personal data collection.
YOOX NET-A-PORTER GROUP does not collect personal data that is superfluous to the declared purposes of information processing.
YOOX NET-A-PORTER GROUP does not require the input of personal data when it is possible to provide services without the use of such data (for example, for marketing surveys conducted to improve the quality of service or to sign up to a newsletter mailing list), either using other methods allowing YOOX NET-A-PORTER GROUP to identify users only when necessary or at the request of the competent authorities (e.g. for personal data related to traffic and site visits or with user IP addresses).
YOOX NET-A-PORTER GROUP respects www.chloe.com users’ rights to access to their personal data and also their right to access to information about operations for the use of such data.
When processing personal data, YOOX NET-A-PORTER GROUP S.p.A. ensures the accuracy of personal data, its adequacy and, when necessary, also its relevance in relation to personal data processing purposes.
YOOX NET-A-PORTER GROUP guarantees that users will have the possibility to exercise their rights concerning the deletion and correction of incomplete or inaccurate personal data.
YOOX NET-A-PORTER GROUP stores personal data in a format allowing identification of the data subject for a period necessary for the purposes for which this data was collected and subsequently processed and, in all circumstances, in accordance with the applicable legislation.
YOOX NET-A-PORTER GROUP is not responsible for personal and other data transferred by www.chloe.com users to third parties.
Purposes of personal data processing
Consistent with personal data protection legislation, YOOX NET-A-PORTER GROUP processes www.chloe.com users’ data strictly in accordance with the following processing purposes:
- Use of www.chloe.com and its services
- Fulfillment of a contract for the sale of goods offered on www.chloe.com, to which the data subject is a party. For more detailed information, users can refer to the General Terms and Conditions of Sale.
YOOX NET-A-PORTER GROUP S.p.A. notably processes personal data in the following circumstances:
- Registration and use of services proposed on www.chloe.com, such as the advantages provided by the My Account service (wishlist and others)
- Fulfillment of orders and other related activity
- Any transfer of user data required to provide services and complete marketing initiatives, when the user has given prior consent to this
- Processing of payments, including those made with a payment card: in this case, the personal data provided at the time of purchase (first name, surname, card number, billing and delivery address) are transferred to the company providing security control for payment operations
- When technical and commercial user requests are received: when contacting the technical support service, YOOX NET-A-PORTER GROUP S.p.A. processes personal data to provide the necessary information about work with the website; when using the services of the Client Relations department, personal data processing is carried out strictly for the purposes necessary to fulfil the user’s request.
- Transfer of information received from persons who have expressed their wish to apply for a vacancy at Richemont by sending a CV.
Personal data can be used for other personal data processing operations not mentioned above but strictly within the limits of the indicated purposes of personal data collection.
Personal data processing methods
The personal data of www.chloe.com users is processed by YOOX NET-A-PORTER GROUP S.p.A. and other third parties primarily by electronic and telematic methods.
Personal data processing is carried out with the consent of the data subject to the processing of his/her personal data.
The personal data of www.chloe.com users may not be transferred abroad to a country that is not a signatory to the Strasbourg Convention of the Council of Europe for the Protection of Individuals with regard to Automatic Processing of Personal Data (1981) or to a country that is not on the list of countries that provide adequate personal data protection (this list is approved by the competent personal data protection authority of the user’s country) without the prior consent of the data subject. For example, an exception might be if the aforementioned action is necessary to provide services and/or to fulfill a contract with YOOX NET-A-PORTER GROUP for the sale of goods ordered on www.chloe.com (and also in other circumstances provided for in the applicable legislation). In this case, the transfer of personal data to these countries will be carried out only to fulfill specific contracts between YOOX NET-A-PORTER GROUP and companies processing personal data in accordance with the applicable legislation, only for purposes related to the provision of services on www.chloe.com.
YOOX NET-A-PORTER GROUP may transfer users’ personal data to Richemont for the purposes of direct marketing, to send communications about new commercial initiatives exclusively related to the activity and services of this website via email and other communication channels, only after receiving consent from the data subject.
YOOX NET-A-PORTER GROUP reserves the right to delete all My Account accounts and related information if:
- Their content is illegal or damaging to the image of YOOX NET-A-PORTER GROUP and/or Richemont and/or their goods or of third parties
- The data promotes illegal or libellous actions
- The content is of a pornographic nature
- The content promotes violence or racial, sexual or religious discrimination.
The personal data of www.chloe.com users is stored by YOOX NET-A-PORTER GROUP until consent to the processing of personal data is withdrawn directly by the data subject.
If the data subject wishes YOOX NET-A-PORTER GROUP to stop processing his/her personal data or update this data, he/she can contact YOOX NET-A-PORTER GROUP by phone or email in the Client Relations section, selecting the “Privacy” topic.
YOOX NET-A-PORTER GROUP may transfer personal data to Richemont of all persons who have expressed their wish to apply for a vacancy at Richemont by sending a CV.
Any www.chloe.com user may send his/her data for purposes related to professional opportunities at Richemont. In this case, YOOX NET-A-PORTER GROUP and Richemont will process this data only for the aforementioned purposes and in accordance with applicable legislation. YOOX NET-A-PORTER GROUP and Richemont never disclose personal data to third parties.
Besides this, personal data is collected at the Press department in order to process requests for information sent by journalists, the media and news agencies and also for the dissemination of press releases.
YOOX NET-A-PORTER GROUP S.p.A. may transfer personal data to Richemont of third parties who are interested in establishing business relations with Richemont, only for these purposes.
Transfer of personal data to third parties
The personal data of www.chloe.com users is not transferred to third parties for purposes not provided for in legislation and not indicated in the declared information processing purposes without the prior consent of the data subject.
Personal data may be transferred to third parties only if this is necessary to process an order with the purpose of subsequently selling the goods ordered and, consequently, fulfilling the contract of sale and also for initiatives related to direct marketing.
For these purposes, personal data is transferred to specific companies who, in accordance with instructions from YOOX NET-A-PORTER GROUP and with reciprocal legal obligations, process users’ personal data, only for the declared processing and information purposes, including for the purposes of fulfilling a contract of sale for goods or provision of services proposed on www.chloe.com.
Personal data is processed by:
- The data centre – for purposes related to the hosting of YOOX NET-A-PORTER GROUP servers on the territory of the Russian Federation
- The bank – for purposes related to payment processing
- The delivery service – for purposes related to the shipping and delivery of goods purchased on www.chloe.com
- The call centre – for purposes related to the operation of the call centre and Client Relations departments accessible to www.chloe.com users.
YOOX NET-A-PORTER GROUP regularly checks that the companies performing personal data processing on behalf of YOOX NET-A-PORTER GROUP S.p.A. are following YOOX NET-A-PORTER GROUP S.p.A. instructions and have provided sufficient guarantees of compliance with personal data processing requirements.
Furthermore, on official request personal data may be transferred to the police or judicial authorities in accordance with applicable legislation (e.g. if YOOX NET-A-PORTER GROUP is required to assist with the prevention of fraud in the purchase of goods on www.chloe.com).
In all the aforementioned circumstances, separate consent from the data subject to personal data processing is not required. Personal data is not disclosed, disseminated or transferred to third parties without prior notification of the data subject of this disclosure, dissemination or transfer without their consent (if the applicable legislation states that it is necessary to obtain consent).
For a full list of the authorised persons with access to personal data, the data subject may contact YOOX NET-A-PORTER GROUP by phone or email in the Client Relations section, selecting the “Privacy” topic.
Mandatory or optional nature of personal data provision to YOOX NET-A-PORTER GROUP S.p.A.
The personal data provided to YOOX NET-A-PORTER GROUP (including first name and surname, email address, billing and delivery address, payment card number and security code, telephone number) is essential to process an order for the purchase of goods on www.chloe.com, to provide other services proposed on this website at the request of the data subject and also if personal data is necessary to fulfil obligations imposed in applicable legislation.
A refusal to provide YOOX NET-A-PORTER GROUP with the personal data indicated as mandatory may lead to it being impossible for YOOX NET-A-PORTER GROUP S.p.A. to process the order for the purchase of goods on www.chloe.com, or a refusal to provide other services proposed on www.chloe.com.
It is possible to determine whether or not personal data is mandatory for provision of the requested services or purchase of goods on www.chloe.com because mandatory fields are marked with an asterisk (*).
However, disclosure to YOOX NET-A-PORTER GROUP of personal data other than that required to fulfill contractual obligations or to provide necessary services is optional and has no effect on the use of this website and the services proposed on it or on the purchase of goods on www.chloe.com.
Failure to provide optional personal data does not result in any consequences or disadvantages for the user.
Data subject rights
Data subjects have the right to obtain information related to the processing of their personal data from YOOX NET-A-PORTER GROUP S.p.A. at any time, including information comprising:
- Confirmation of the fact of personal data processing by YOOX NET-A-PORTER GROUP
- The legal basis for personal data processing
- The purposes of and methods used by YOOX NET-A-PORTER GROUP for personal data processing
- The name and location of YOOX NET-A-PORTER GROUP, information about persons (excluding YOOX NET-A-PORTER GROUP employees) who have access to personal data or who may have personal data disclosed to them on the basis of a contract with the operator or of applicable legislation
- The personal data processed relating to the corresponding data subject and the source it was obtained from
- The duration of personal data processing, including the duration of its storage
- Procedure for the exercise of rights by the data subject
- Information about any past or future cross-border data transfer
- The name and address of the party processing personal data on behalf of the operator if the processing is assigned or will be assigned to such a party
- Other information provided for in applicable legislation.
To obtain the aforementioned information, the data subject may contact YOOX NET-A-PORTER GROUP by phone or email in the Client Relations section, selecting the “Privacy” topic.
Data subjects also have the right at all times either to request that YOOX NET-A-PORTER GROUP perform or personally perform the following actions:
- Correct their personal data, block it or destroy it if the personal data is incomplete, out of date, inaccurate, illegally obtained or is not essential for the declared processing purpose and also take the measures provided for in the law to protect their rights
- Fully or partially oppose the processing of their personal data for legitimate reasons, even it is pertinent to the purposes of collection
- Fully or partially oppose the processing of their personal data for promotional or direct marketing purposes, to perform market research or for use in commercial informational materials.
The data subject may exercise his or her rights freely and at any time, provided that he/she complies with the requirements of applicable legislation, and may contact YOOX NET-A-PORTER GROUP S.p.A. by phone or email in the Client Relations section, selecting the “Privacy” topic.
Data subject consent and refusal
YOOX NET-A-PORTER GROUP S.p.A. processes personal data only after obtaining free consent from the specific data subject.
Separate prior consent is required to send him/her promotional materials, direct marketing materials or other commercial information messages related to the services provided by YOOX NET-A-PORTER GROUP S.p.A., including by post, email or other means of communication, on user request (for example, this includes the newsletter mailing list).
Each time the data subject’s consent to the processing of his/her personal data is required in accordance with applicable legislation, YOOX NET-A-PORTER GROUP S.p.A. will inform him/her of this in advance and provide the opportunity to give or withhold this consent in the specified manner. YOOX NET-A-PORTER GROUP S.p.A. informs users that, in accordance with applicable legislation, the data subject’s consent is not required and that YOOX NET-A-PORTER GROUP S.p.A. may process the personal data of www.chloe.com users without such consent if this processing is necessary to fulfil legal obligations imposed on YOOX NET-A-PORTER GROUP S.p.A. or when this processing is necessary to process orders made by the user (e.g. for the purchase of goods on www.chloe.com or to request the use of specific services through www.chloe.com).
In all cases, users have the right to opt out of receiving marketing communications related to the specific services used (e.g. from receiving newsletters).
However, YOOX NET-A-PORTER GROUP cannot guarantee that the security measures undertaken for protection of the website and transfer of data and information on www.chloe.com prevent or exclude all risk of unauthorised access or loss of data.
In order to minimise possible risks, we recommend that www.chloe.com users also equip their computers with web data transmission and reception protection software (e.g. up-to-date antivirus system), and also make sure that their internet provider has undertaken sufficient measures to ensure secure web data transmission (e.g. use of firewalls and spam filters). On www.chloe.com, every purchase is completed with maximum security measures due to the use of advanced technology systems and encryption (SSL).
www.chloe.com uses automatic data collection systems such as cookie files.
Cookies are a set of information sent by the web server to the user’s browser and navigation device.
In the process of navigation, the user’s IP address and other information related to user data traffic or user preferences in the selection of services proposed by the website or goods proposed through the services provided is automatically collected.
The data is processed in an aggregated and anonymised form for commercial purposes. Thus, cookies do not contain information about personal data although they do allow the user to be linked with his/her personal information, communicated by the user on www.chloe.com.
This data is collected by the website in the process of navigation via cookies directly and automatically as part of the execution of operational functions and is not used to identify data subjects.
Cookies, used for marketing purposes, are designed to improve user navigation on www.chloe.com, reduce the time taken to place an order and also to improve the Richemont service level: in the process of information www.chloe.com cookie data is used to display goods corresponding to user interests and preferences.
Third party cookies are used to provide users with Richemont commercial offers hosted on partner websites. The information received from third party cookies is not controlled by YOOX NET-A-PORTER GROUP and is under the control of the third parties. Social network cookies enable interaction between social networks and www.chloe.com users.
Cookies are stored on YOOX NET-A-PORTER GROUP servers and there is no access to the information contained in them. Information collected using cookie files is processed by YOOX NET-A-PORTER GROUP and Richemont in aggregated and anonymised form for the optimisation of their services and the website according to user needs and preferences.
All web browsers have the option to delete cookies after every session. The instructions on how to perform this deletion operation can be found in the web browser’s help section. If data subjects wish to delete cookies, they can refer to the deletion instructions in the help section of the web browser they use.
If the cookie deletion procedure has been fully or partially activated, YOOX NET-A-PORTER GROUP and Richemont cannot guarantee that www.chloe.com web pages and/or specific site services will function correctly (e.g. retention or display on the web pages of the selected goods at the final stage of the internet purchasing process).
Links to other websites
www.chloe.com contains links to other websites, which may have no connection to www.chloe.com, YOOX NET-A-PORTER GROUP or Richemont.
YOOX NET-A-PORTER GROUP and Richemont do not control or monitor these websites and their content.
YOOX NET-A-PORTER GROUP and Richemont bear no responsibility for the content of these websites and/or the rules they implement concerning personal data confidentiality or processing when they are visited.
Links to other websites are provided on www.chloe.com exclusively for the purposes of helping users search and browse websites on the internet and for the use of other links to websites on the internet. By providing links to other websites, YOOX NET-A-PORTER GROUP S.p.A. and/or Richemont are not recommending that users visit these websites and are not providing any guarantees to the internet user concerning their content or the services or products provided or sold on these websites.
If they require further information about personal data processing on www.chloe.com, users can contact YOOX NET-A-PORTER GROUP by phone or email in theClient Relations section, selecting the “Privacy” topic.
YOOX NET-A-PORTER GROUP, as an Italian company, exercises its activity in accordance with Italian legislation. In addition to this, the website //www.www.chloe.com/ru operates in accordance with the requirements of Russian Federation legislation on personal data protection.
Any disagreements, disputes or claims arising in connection with use of YOOX NET-A-PORTER GROUP websites are heard in the court of Milan (Italy), which has sole jurisdiction.
If users require more detailed information about their rights or about legislation in the area of personal data protection, they can visit the website of the competent authority for the protection of data subjects’ rights – Federal Service for Supervision of Communications, Information Technology and Mass Media http://rkn.gov.ru/personal-data/.
Latest revision - August 2015.