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Paule Ka policy on the protection of personal data on its website, its social media outlets, its stores and its points of sale

PAULE KA attaches considerable importance to the protection of the privacy and personal data of its potential or existing Clients. For PAULE KA, the extent of this protection contributes to the quality of its services and products.

The purpose of this Policy is to define and explain how PAULE KA collects, processes and protects your personal data, in compliance with the European General Data Protection Regulation (Regulation (EU) 2016/679, or “GDPR”), when you browse the PAULE KA website, use its applications or when you purchase PAULE KA products via the PAULE KA website or at PAULE KA stores.

This Policy applies to both the PAULE KA website and to the applications that include a link to said website.

 

 

1 – THE DATA CONTROLLER

 

 

The publisher of the PAULE KA website is PAULE KA, a French simplified joint-stock company (société par actions simplifiée), with capital of €2,500,000, having its registered office at 223 rue Saint Honoré, 75001 Paris, registered with the Paris Trade and Companies Register under the number 302 077 927, represented by its President, Mr Xavier Marie.

The PAULE KA websites, applications and other digital platforms are hosted by AGENCE SMILE, 2 boulevard Jean Jacques Bosc, 33130 Bègles. PAULE KA may also disclose information to its affiliates, in accordance with the guarantees provided for by this Policy.

All the sales generated via this website’s online store are made by PAULE KA, and all the marketing communications are sent to you by PAULE KA.

If you wish to contact PAULE KA or its Data Protection Officer (DPO), you can send an email to the following address: dpo@pauleka.com or call the following number: 01 40 29 80 31.

 

 

2 – THE PERSONAL DATA COLLECTED AND THE COLLECTION METHOD

 
Personal data is defined as any information concerning an individual who is or who can be identified, directly or indirectly, via reference to an identification number or to one or more pieces of data that are specific to him/her such as his/her surname, his/her first name, his/her date of birth, his/her client number or order number, his/her photo, etc.


PAULE KA collects the following personal data:

 

2-1 Minimum age for use of the PAULE KA website and collection of personal data

The purpose of the PAULE KA website is the sale of women’s prêt-à-porter items and accessories. The website is not intended for minors under the age of 16: clients or potential clients must be at least 16 years old in order to disclose their personal data. PAULE KA does not collect data on children under the age of 16 and, if it is found that, in error, such data has been collected, PAULE KA should be informed of this immediately (dpo@pauleka.com) so that the data can be deleted.

 

2-2 Direct collection:

This is information that is collected online on our website or on other digital platforms and applications, or in-store (e.g. when creating an account, registering for the PAULE KA Newsletter, placing an order, making in-store purchases or submitting job applications);

When said data is collected, the obligatory fields are those that are not marked as being optional. If these fields are not filled in, this can prevent you from accessing our products or services. The other information is optional and is requested in order to get to know you better, so as to provide you with enhanced service.

 

2-3 Indirect collection:

PAULE KA also collects, this time indirectly, information that concerns you when you browse the PAULE KA website, its applications or other digital platforms.

Collecting this information is necessary for the smooth technical operation of the PAULE KA website, for the quality of your browsing experience and to enable PAULE KA to carry out analyses in order to be in a position to provide you with the best possible service and to personalise the services that are offered.

The information that is collected indirectly includes:

  • Technical information that is associated with your browsing of the PAULE KA websites, for login purposes and the identification of your country/city via geolocation (e.g. IP address and cookies);
  • Information concerning your online profile and data concerning the use of the website (e.g. tracking of your browsing of the website, saving of products that are placed in the shopping basket);
  • Personal data that is collected via media and social media platforms (e.g. when you follow PAULE KA pages on social media, personal information that is designated as being public and that can be seen by everyone on your profile on said social media).

 

3 – THE PURPOSES OF THIS PROCESSING OF YOUR PERSONAL DATA

 

This processing of your personal data is necessary for us to comply with the laws and regulations that are applicable to our sector of activity and to sales.

This processing is also a vital tool for the performance of the sale contract that is entered into with our clients, as well as for making available to our potential or current clients, a website, applications or any other online service that makes it possible to support and enter a sale contract.

This processing of your personal data is necessary for the proper functioning of PAULE KA, the activity of which involves making sales and offering you quality, personalised products, service and after-sales service. PAULE KA therefore has a legitimate interest in being able to carry on its business activity and provide a quality of services that is high and personalised.

PAULE KA may use your personal data in order to:

  • Enable you to browse the PAULE KA website and access your client account;
  • Enable you to obtain information on our products and services;
  • Enable you to purchase PAULE KA products in our PAULE KA stores and other points of sale;
  • Enable you to access our after-sales services;
  • Subject to your consent, offer you personalised services that take into account your needs and preferences;
  • Obtain your opinion on our PAULE KA products and services;
  • Make it possible to generate statistics and carry out financial and commercial studies;
  • Keep you apprised of our latest collections, campaigns and events by sending you PAULE KA communications (by email, by letter or by SMS and via third party social media);
  • Fulfil legal and administrative requirements;
  • Concerning job applications: recruit and select applicants.

 

4 - THE PROTECTION OF THIS PERSONAL DATA

 

4-1 At PAULE KA

Your personal data will only be accessible to the employees who need to be aware of it in order to carry out their assignments. These employees will have to obtain authorisation and use a secure connection to the processing.

Thus, if you are a current or potential client of PAULE KA, only the PAULE KA employees who work in the teams that need to hold your information and that process this information (the employees of the E-commerce and Retail teams that are in charge of Client Relations,) will have access to your personal data.

If you have submitted a job application, only the human resources department staff who are responsible for recruitment will have access to your data.

 

4-2 Outside of PAULE KA

Your personal data will not be disclosed to third parties, except to other PAULE KA entities, for the aforementioned purposes, and to our trusted service providers (e.g. maintenance, security and IT assistance service providers, hosts, payment service providers, etc.) that are acting on behalf of PAULE KA, on the basis of secure contractual agreements that include strict data protection obligations.

PAULE KA may also be compelled to transfer personal data to third parties if the empowered authorities ask it to do so, in accordance with the laws and regulations in force.

In the event of a merger or sale, your personal data will be transferred definitively to our successor.

 

5 - DATA TRANSFERS ABROAD

 

PAULE KA does not transfer any of your Personal Data abroad.

In the event that such a transfer is implemented, in particular outside the European Union, it would be effected with appropriate guarantees and in compliance with the regulations that are applicable to personal data protection.

 

6 - STORAGE OF PERSONAL DATA

 

In order to ensure that you are provided with quality, personalised services, PAULE KA needs to store your personal data for the time needed to provide said services and in order to fulfil its legal obligations. PAULE KA stores your data as follows:

 

6-1 If you are a PAULE KA Client:

Due to the quality and the nature of PAULE KA products and services, the durations of the shelf-life, purchasing cycle and after-sales service are longer than for ordinary consumer products and require appropriate Client follow-up, as well as appropriate data storage durations.

 

The data associated with your Client account will thus be stored and used for a maximum duration of five years as from your last purchase or interaction with the PAULE KA brand (contact with the client service department or attendance at an event). At the end of this five-year period, PAULE KA may contact you again in order to know whether or not your wish to continue to receive information on its offers, news and events.

 

Data on your past transactions with PAULE KA is stored and archived for periods of time that vary according to the type of data and do not exceed 10 years, so that PAULE KA can fulfil its administrative and legal obligations. Upon expiration of these periods, the data will be destroyed.

 

6-2 If you are a prospective PAULE KA client

In other words, if you have requested information about PAULE KA but have never purchased PAULE KA products or created a PAULE KA client account.

 

Your data, which you agreed to provide to us when you signed up for our Newsletter, is retained for a period of three years as from the date on which it is collected. This period will be renewed each time that you interact with PAULE KA (for example, attend an event). At the end of this three-year period, PAULE KA may contact you again in order to know whether or not your wish to continue to receive information on its offers, news and events.


6-3 If you are a candidate for professional opportunities at PAULE KA:

Your data will be stored for two years as from your application.

 

6-4 Credit Card Data

 

Bank card data storage following a payment: said data will be stored for 15 months by a secure payment service provider.

 

Storage of bank card details in an electronic wallet for future purchases: this data will only be stored by a secure payment service provider if you have consented thereto and until you withdraw your consent or your bank card expires.

 

7 - SECURITY

 

PAULE KA has implemented appropriate technical and physical means to ensure the confidentiality and the security of your personal data.

PAULE KA’s IT systems benefit from state-of-the-art hardware and software protection. Procedures to control access to premises, computers, servers and software have been implemented. The data stored is backed up physically and electronically, in accordance with the French legislation in force on the protection of personal data and in accordance with market standards.

PAULE KA employees who, because of their duties, may have access to your Personal Data, are subject to strict confidentiality obligations.

Please be aware, however, that no data transmission over the Internet is 100% secure and that information that is exchanged online can potentially be intercepted and used by persons other than the intended recipient.

 

8 - THE RIGHTS OF CLIENTS AND POTENTIAL CLIENTS:

 

You have various rights in order to ensure better protection and control of the use of your personal data:

  • A right to information: you have the right to be informed of the way in which your personal data is processed.
  • A right of access and of rectification: you have the right to obtain confirmation of whether the personal data that concerns you is processed or not and, as applicable, to access said personal data and to obtain a copy thereof. You have a right to rectify your personal data in order to correct, update or complete it.
  • A right of erasure: in certain cases, you have the right to obtain the erasure of your personal data. However, this is not an absolute right, and PAULE KA may have legal or legitimate reasons to store said data.
  • A right to restrict data processing: in certain cases, you have the right to obtain a restriction on the processing of your personal data.
  • A right to data portability: you have the right to receive the personal data that you provided to PAULE KA in a structured, commonly used, machine-readable format, and you can transmit said data to another data controller without PAULE KA being to prevent this. This right only applies if the processing of your personal data is based on your consent or on the performance of a contract and if this processing is carried out using automated methods.
  • A right to object to the processing: you have the right to object to the processing of your personal data for marketing purposes at any time.
  • A right to file a complaint with the relevant supervisory authorities in the event of a breach of the laws and regulations in force concerning data protection, in particular the GDPR, but also any other national or regional law on data protection that concerns you.

For the exercise of these rights, you must notify PAULE KA by contacting the PAULE KA Data Protection Officer (tel.: +33 1 40 29 80 31 – email: dpo@pauleka.com) and by providing the following information: first name, surname, e-mail address or any other information that is necessary to confirm your identity and to enable us to process your request, such as your postal address, for example. To ensure the best possible security of your data, proof of ID may be requested before your request is processed.

You can also decide to stop receiving our Newsletter at any time by following the procedure below:

Contact the client service department by calling +33 1 73 01 45 71 or sending an email to serviceclient.eshop@pauleka.com and asking to stop receiving the newsletter.

You can also file a complaint with the relevant regulatory authorities in the event of a breach of the laws and regulations on data protection that are in force, in particular the GDPR, but also any other national or regional law on data protection that concerns you.

 

9 - COOKIES

 

Cookies are files that store small quantities of data linked to your use of the website (including your IP address) on your computer’s hard drive. The data collected by the cookies used on the website is anonymous and does not include personal data.

 

9-1 Cookies generated by PAULE KA

Some of the cookies generated by our server enable us to run our website and, in particular, process orders, while others enable us to monitor traffic on the website, identify the main interests of visitors, perform analyses and adapt the personalisation of the website and of the advertisements displayed accordingly. By storing information on your previous visits, they also help you to access the website more quickly and more efficiently.

 

9-2 Cookies generated by third-party companies

We may have to include third-party software applications on our website so that you can share content from our website or your opinion on our products with other persons, via social media (e.g. Facebook, Twitter, Instagram or Pinterest) or via websites (e.g. YouTube) in particular by clicking on the “share” or “like” buttons or by writing comments.

These social media outlets and websites may identify you when you interact with their applications that are included on our website. PAULE KA has no information on or control over the use and processing of your personal data by these sites. You should consult their specific personal data protection policies.

 

9-3 Management and control of cookies

Most browsers accept the use of cookies by default and by accessing the website, you consent to this use.

You may nevertheless change your browsing parameters in order to control the use of cookies or prohibit them. If you choose this option, you should note that the website may not function correctly, and may not even function at all. The ways to change these parameters vary with each browser (such as Internet Explorer, Firefox, Safari, Chrome etc.) and we suggest that you consult the “Help” menu of your browser for all additional information.

 

9-4 Cookies:

The cookies managed by PAULE KA are stored for a maximum period of 13 months.

 

10 - PERSONAL DATA PROTECTION POLICY AMENDMENTS AND UPDATES

 

By using the PAULE KA website OR by purchasing our products in PAULE KA Stores and Points of Sale, you agree to the collection and use of your data in the manner described in this Personal Data Protection Policy. This Policy reflects the professional practices that are in force at PAULE KA.

In the event of amendments or updates, the revised Policy will be made available online on pauleka.com, including the date of the most recent update.

 

11 - DATE OF THE MOST RECENT UPDATE OF THE PERSONAL DATA PROTECTION POLICY

 

June 2019