YOOX NET-A-PORTER GROUP S.p.A., company subject to the management and coordination of Compagnie Financière Richemont S.A., located at via Morimondo, 17 – Milano 20143 Italy with Tax ID and VAT Registration No. 02050461207, has been appointed a data processor in connection with some of the services offered on the Platforms, including the processing of orders you place on the Platforms.
Where we offer our products for sale online or by phone through the Chloé Client Relations Center, you must read the applicable Conditions of Sale, which will govern the terms and conditions of any such purchases made in this way.
Information you provide to us and how we use it
We collect the information from you as detailed below:
- To access certain areas of our Platform, you will need to register with us. During the registration process you will be asked to submit personal information about yourself (including your name and address, date of birth, email address and telephone number). By entering your details in the fields requested, you enable Chloé to provide you with the services you select;
- When you purchase products online or by phone, we collect information such as your purchase details and relevant payment information. In addition, we will also collect personal information from you when you correspond with us (for example, if you contact us with a query about one of our products or services), when you provide your details when you visit a Chloé boutique or contact the Chloé concierge by telephone. Please note that phone calls will on occasion be recorded for security, training and development purposes;
- If you choose to interact with Chloé via a social media platform or other third party service, we will collect the information you have provided to us through that platform;
- We also collect certain information automatically about visitors to our Platform, described in the section headed “Cookies and other information that we automatically collect", below; and
- We will collect information about your location to the extent that we provide any location services, described in the section headed “Location services” below.
We will use the information we collect from you to:
- Manage and fulfil purchase and repair orders, facilitate delivery, and to provide after-sales services;
- Manage our accounts and records;
- Deal with your enquiries and requests;
- Send service related communications, including announcements and administrative messages such as order confirmation;
- Identify products and services we think you might be interested in based on your information, such as your purchase history and your previous interactions with us;
- Send you marketing communications (including emails and social media audience matching) relating to us and other third party partners and that we think may be of interest to you where we have a legitimate basis to do so (please see the “Your choices” section below for further information about how you can control these updates);
- Conduct market research so that we can continuously improve the services we provide to our customers;
- Undertake credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our Platform and services secure; and
- Understand how our Platform is used so that we can continuously improve our Platform and services and other offerings.
Where you have agreed to a particular use of your information, we process it on the basis of your consent. You may withdraw that consent at any time (for example, for us to send you marketing communications) by contacting us (see the section headed “Contact us” below). We also process your information where this is necessary for the performance of a contract with you or where it is necessary for our legitimate interests of operating, protecting and improving our business.
Cookies and other information that we automatically collect
We will collect information about your computer or mobile device, including where available your IP address, operating system, log-in times and browser type. We use this information to better understand how visitors use our Platform and for internal reporting purposes. We will anonymise and share this information with advertisers, sponsors or other businesses.
The Platforms use third parties such as network advertisers and ad exchanges to serve you ads on third party platforms after you leave our Platforms, and we use third party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Platforms and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which are based on your visits to the Platforms and other apps and sites you have visited. Third party ad serving enables us to target advertisements to you for products and services that you might be interested in.
You have choices in respect of the delivery of ads. You can opt-out of receiving certain types of behavioural ads by visiting the third party websites described in the section headed “How to control or delete cookies” above. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.
Some of the services that we provide are able to use information about your location. For these services, which are typically available on mobile devices or applications, you are provided with the opportunity to provide your consent to the use of location services, which, for example, process information deriving from GPS, sensors, beacons or Wi-Fi access points in order to allow you to benefit from a more personalised service. Your device will have settings that allow you to turn off these services should you no longer wish to benefit from them.
Sharing your information
We do not share personal information about you with other people or non-affiliated companies except under the following circumstances:
- we will disclose your personal information to third party providers, for the purposes of providing online and other payment services, handling credit checks and fraud prevention, and any other services required in order for us to use your information for the purposes specified in the section entitled “Information you provide us and how we use it”;
- we will disclose your personal information to any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party; and
We have implemented standard contractual clauses to ensure adequate safeguards are in place to protect your information where it is transferred to our affiliated companies and boutiques in territories outside the European Economic Area and Switzerland. Where we share your information with a third party service provider outside of the European Economic Area and Switzerland (as detailed in the section entitled “Sharing your information”), we contractually oblige the third party service provider to implement adequate safeguards to protect your information.
Protecting your information
We want you to feel confident about using our Platform, and we are committed to protecting the personal information we collect. We limit access to personal information about you to employees who reasonably need access to it, to provide products or services to you or in order to do their jobs. We have appropriate technical and organisational physical, electronic, and procedural safeguards to protect the personal information that you provide to us against unauthorised or unlawful processing and against accidental loss, damage or destruction. However, where we ask you to choose a password in order to access certain parts of our Platform, you are responsible for selecting a secure password and keeping that password confidential. You should choose a password which you do not use on any other site, and you should not share it with anyone else.
Retaining your information
We keep your information for only as long as is necessary for our purposes, and in particular to protect ourselves in the event of a legal claim (for example, information relating to a contract with you will be kept for the lifetime of the contract and up to ten years after). After this period it will be deleted or in some cases anonymised. Where we sought your consent to process your personal information and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent we will delete your personal information.
If you request that we no longer send you direct marketing communications, we will keep a record of your request and contact details to ensure that your request is respected.
You have the right to ask for access to any personal information that we hold about you in our records, to correct any inaccuracies and to update any out-of-date information. In some circumstances, you have the right to request the erasure of your personal information or a restriction of its use.
You have the right to object to us processing your personal information in some cases. In particular, you can ask us to stop sending you direct marketing communications at any time (however please note that we may continue to send you service-related (i.e. non-marketing) communications, such as email updates on your order status). If you wish to exercise any of these rights, please write to us at the address listed below.
You may unsubscribe from email marketing communications at any time by emailing the address below in the section headed “Contact us” or clicking on the ‘unsubscribe’ link in any Chloé marketing emails.
If you have a concern about how we use your information, as a first step please contact us using the details set out below and we will do our best to resolve your concern. After investigating your concern, we will respond to you in writing within a reasonable time setting out our proposed remedial action. If you think we have processed your personal information in a manner which is unlawful or breaches your rights you also have the right to complain to a European Data Protection Authority in your place of residence or work, or the jurisdiction in which the processing took place.
Chloé SAS, 5/7 avenue Percier 75008 Paris – FRANCE
Last updated: May 2018