Last updated on 11/16/2020
Introduction
This personal data protection policy ("the Policy") aims to explain to you how, within SASSY France, we collect your personal data through our various channels (such as our websites, our stores, our customer relations centers). It also contains information on the type of data collected, how we process it and for what purposes, so as to make its use most suited to your needs.
This policy therefore applies to the owner of this website.
For the purposes of the Privacy and Cookie Policy, the following terms are defined as follows:
“We”: refers to any SASSY France company that may collect or process your personal data and cookies, as well as its service providers located in France or abroad.
“You”: refers to any user of SASSY France Services, whether paid or not.
1. Our commitment to the protection of personal data
We strive to collect only the personal data necessary for the intended processing and uses and for the purposes described in this Policy;
If the retention of your data is not mandatory and they are no longer useful for the processing of personal data, we will ensure that they are destroyed;
We respect your privacy rights and prohibit the sale of your data;
We are committed to being transparent about our use of your personal data;
Please note that some of your data may be mandatory to access certain Services. However, you are not required to provide us with the personal data we request.
2. How do we collect your personal data?
We collect your data through all types of digital means; our websites, pages dedicated to SASSY France products or brands on the Internet or on social networks, electronic communications or your interactions with advertising banners of SASSY France brands. All your communications with our Consumer Services also allow us to collect information about you. We collect certain data using cookies in order to understand your habits and actions on our websites. In other cases, you provide us with your information directly when you contact us, when you make a purchase on our sites, during in-store events, at trade fairs, by completing offline registration forms or by participating in market research.
3. What personal data do we collect?
Depending on how you interact and communicate with SASSY France (online, offline, by telephone, etc.), we may collect different types of information from you, which differ according to the purposes, as described below:
Personal and demographic contact information including: name, first name, gender, email address, date of birth, postal address, telephone number, places of residence;
Technical information about the devices you use to access our websites or applications such as operating system and Internet Protocol (IP) address;
Data relating to your use of our websites/applications: last site visited, pages viewed, advertisements you clicked on;
Information you share directly with us about your experience as a consumer (market research, content shared on social media or on one of our websites)
Financial and payment data, which we need to fulfil an order
Telephone interactions between You and our Consumer Services
Interactions between You and Us at Trade Shows
What uses? Principles on which this use is based Our legitimate interests
Consumer services and/or customer relations center: we use your personal data to respond to your requests, resolve any problems, improve and personalize our services. – Compliance with our contractual obligations
– Legal obligations
– Our legitimate interests – Improving and developing new products and services
– Gain in efficiency
Marketing communications, games, competitions and other promotions: with your consent (where necessary), we use your personal data to provide you with information about our products or services (for example, in the context of marketing or promotional communications/campaigns). – Your consent (where necessary)
– Compliance with our contractual obligations
· Our legitimate interests – To determine which of our products and services may be of interest to you and to tell you about them
– Define consumer or customer profiles for new products or services
Interaction with our consumers: We use your personal data when you use third-party social media features, such as the “Like” feature, in order to serve you ads and interact with you on those third-party social media. – Your consent (where required)
– Our legitimate interests – To determine which of our products and services may be of interest to you and to tell you about them
– Define consumer or customer profiles for new products or services
Creation and management of an account: we use this data to manage your orders, answer your questions, allow you to manage your preferences or send you commercial communications adapted to your profile. – Your consent
– Our legitimate interests
– Compliance with our contractual obligations – Help us better understand your needs and expectations and, thus, improve our services, products and brands
Personalization of our Services and Offers: with your consent, we use your personal data (i) to analyze your preferences and habits; (ii) to anticipate your needs based on our analysis of your profile; (iii) to improve and personalize your experience on our websites and applications; (iv) to ensure that the content coming from our websites or applications is the most adapted to you and your computer or device; (v) to provide you with targeted advertising and content; and (vi) to allow you to participate in interactive activities, when you choose to do so. – Your consent (when necessary)
– Our legitimate interests – To determine which of our products and services may be of interest to you and to tell you about them
– Define consumer or customer profiles for new products or services
Order processing: We use your personal data to process and ship your orders, inform you of the status of your orders, verify that we have the correct addresses and verify your identity. – Compliance with our contractual obligations
– Your consent (where necessary)
– Legal obligations
– Our legitimate interests – Improving and developing new products and services
– Gain in efficiency
– Protect our operating systems, networks and personnel
Operation of our websites: We use your personal data to ensure appropriate delivery of content on our websites and appropriate settings for your device, including screen resolution, etc. – Our legitimate interests
– Your consent – Improve our quality of service
Other general uses (internal or market research, analysis, security, etc.): In accordance with applicable laws, we use your personal data for other general business purposes, including to conduct internal or market research and measure the effectiveness of our advertising campaigns. If you have multiple accounts for SASSY France brands, we reserve the right to merge these accounts into a single account. – Compliance with our contractual obligations
– Your consent (where necessary)
– Legal obligations
– Our legitimate interests – Improving and developing new products and services
– Gain in efficiency
– Protect our operating systems, networks and personnel
Testimonials: SASSY France may publish on its websites and other information media a list of Client Cases containing information on the name of our clients and their titles. SASSY France undertakes to obtain the authorization of each client before publishing any testimonial on its websites. – Your consent (when necessary)
– Our legitimate interests – To determine which of our products and services are of interest to you and to learn about your opinion on our Services
Applications/CV/information about your career: we use your data to process and respond to your spontaneous application in SASSY France or to process and respond to your application for a position offered within SASSY France – Compliance with our contractual obligations
– Your consent (where necessary)
– Legal obligations
– Our legitimate interests – To analyse or have analysed your CV and other information relating to your career;
– Determine if your profile may interest SASSY France
– Determine whether your application meets the characteristics of a position offered within SASSY France, all on the basis of SASSY France’s legitimate interest in hiring qualified human resources.
Applications: your personal and demographic details described above, your CV and any annexes, all information relating to your motivation and your background and, in general, all information necessary for the study of your profile with regard to our human resources needs.
We have no reason to collect or process sensitive personal data (e.g. health data) in the course of our normal business activities.
4. What is SASSY France’s policy regarding children’s personal data?
We believe that protecting the privacy of children accessing the Internet is extremely important and encourage parents or guardians to spend time with them to participate in and manage their online activities.
On some of our websites, access to said site and/or the creation of an account is reserved for adults.
You must therefore ensure that your children do not give their personal data or your personal data on the Internet without first asking for your permission. Indeed, any minor can only directly transmit their personal data through a parent or guardian, with their explicit consent. You can check, modify, delete your child's personal data at any time. You can also request the deletion of your child's data by sending the request by mail to the address given in the contacts indicated in Question No. 9 - "What are your rights and how to exercise them?".
5. What uses do we make of your personal data?
You will find in the table below the list of purposes pursued by SASSY France when collecting and processing your personal data and the different types of personal data that are collected for each purpose. Please note that some people may not be concerned by some of the uses listed below.
6. Does SASSY France disclose your personal data and why?
When we are required to share your data with our various websites within SASSY France or with other structures (such as service providers for example), we ensure that these organizations also have a security policy to protect your data.
As expressed in "1. Our commitment to the protection of personal data", your personal data will not be shared, sold, rented or disclosed for purposes other than those described in the Policy. Therefore, except in cases where you have given your consent, we will not sell your personal data to third-party companies for their own marketing purposes. However, it is possible that your data may be transmitted if required by law and government authorities for example. In the event of a transfer of an activity of SASSY France to another company, the legal successor will have access to the data held by the transferring entity and therefore probably to some of your personal data.
7. How long will your personal data be kept?
Your personal data will be retained by SASSY France only for the time that is reasonably necessary for the purposes described in this Policy. The criteria we use to determine the retention periods of your personal data are as follows:
SASSY France will keep your personal data in a form that allows your identification for the entire duration of your participation in a loyalty program, a promotional offer, or for the entire duration of our contractual relationship;
If you contact us with a request, we will retain your personal data for the duration necessary to process your request;
If you create an account, we will retain your personal data until you ask us to delete it or after a period of inactivity (no active interaction with the brands) defined in accordance with local regulations and instructions.
Applications: If you contact us to send us your CV and any other information about your motivation and background (hereinafter "Application Data"), we will keep your Application Data for the entire period necessary to assess your application. In the event of a negative outcome to your application, the retention period of your Application Data will be that indicated in the forms relating to the position concerned or that which will be indicated to you in the response letter or email that will be sent to you. In the event of a positive recruitment outcome, your Application Data will be kept for the duration of your presence with your employer within SASSY France.
Your personal data may, however, be kept for longer under specific legal obligations or in light of applicable legal limitation periods.
Beyond the retention periods mentioned above, your personal data will either be deleted from all SASSY France databases in a secure manner or anonymized.
8. How does SASSY France protect, store and transfer your personal data?
Your rights What does this mean?
The right to information You have the right to access, review and request a physical or electronic copy of the information we hold about you and how we use it. This information must be transparent, clear and easily understandable. You also have the right to request information about the origin of your personal data.
The right to access
The right to modification You can request the deletion, portability, rectification or modification of your personal data; if they are inaccurate or outdated and/or to be completed if they are incomplete.
Where possible, our websites include a dedicated feature allowing you to review and modify the personal data you have provided to us.
Please note that, in some cases, the deletion of your personal data will necessarily involve the deletion of your user account. We may also be required to retain some of your personal data, after your deletion request, in order to meet our legal or contractual obligations.
The right to erasure/to be forgotten These rights mean that the processing of data about you that we carry out is limited, so that we can keep this data, but not use or process it.
The right to manage your data provided These rights mean that the processing of data concerning you that we carry out is limited, so that we can keep this data, but not use or process it.
The right to restriction of processing These rights mean that the processing of data about you that we carry out is restricted, so that we can keep this data, but not use or process it.
The right to object to data processing based on our legitimate interest You may withdraw your consent to any of our processing of your personal data if it is based on consent. The withdrawal of such consent shall not affect the lawfulness of processing based on consent carried out before its withdrawal.
The right to withdraw your consent You may withdraw your consent to any of our processing of your personal data if it is based on consent. The withdrawal of such consent shall not affect the lawfulness of processing based on consent carried out before its withdrawal.
The right to lodge a complaint with a supervisory authority You have the right to lodge a complaint with the data protection authority, the CNIL (https://www.cnil.fr/fr/plaintes), to contest SASSY France's practices regarding the protection of personal data and respect for privacy.
The right to non-prospecting At any time, by contacting us or by clicking on the “unsubscribe” link in any email or communication that we send you, you can object to receiving our commercial prospecting messages.
The right to disable or manage Cookies You can adjust your browser settings to disable Cookies or to be alerted when cookies/similar technologies are used. However, this may prevent you from using certain parts of our websites.
The right to block targeted advertising We may be partners with advertisers displaying advertising banners on the Internet, targeted to your interests, for one of our brands or brands of companies outside the SASSY France group.
You can visit www.aboutads.info/choices to learn more about how you can block the appearance of these targeted advertisements.
We use all necessary technical and organizational measures to ensure the confidentiality and security of your personal data. Please note, however, that these measures do not apply to information you choose to share in public spaces, including on third-party social networks.
When it comes to your financial data, we apply industry standards for protection and comply with legal obligations. Your information is encrypted when you make online purchases on our websites.
You can also help us ensure that your data is protected by using the privacy settings on our websites, choosing a complex login password, and being careful when logging into your account on a public device.
The storage and processing of your personal data requires that your personal data be, at one time or another, transferred to, and stored in, a country other than the one in which you reside. Personal data may be processed outside the European Economic Area (EEA). If this is the case, SASSY France will make every effort to ensure that this international transfer of data has an adequate level and guarantees of security. The guarantees that we use to protect international data transfers include (i) standard contractual clauses validated by the European Commission, (ii) certification mechanisms that certify that third parties located outside the EEA process personal data in a manner that complies with the Regulations.
9. What are your rights and choices, how to exercise them?
We are committed to enabling you to assert your rights and make the most informed choices possible regarding the personal data you provide to us.
In the following table, we mean by you: “yourself, your descendants, representatives and/or agents”
You may exercise these rights as indicated in the relevant pages of this website.
We will ask you to attach a copy of your ID or other proof of identity to your request. If the request is submitted by someone other than you, without proof that the request is legally made on your behalf, the request will be rejected.
Please be aware that any information provided to us will be processed only in accordance with, and to the extent permitted by, applicable laws.
We will handle and investigate any complaints about how we handle your personal data (including complaints that we have infringed your rights under applicable privacy laws).
10. Changes to our Policy
If there are any changes to the way we manage and process your personal data, we will update this Policy. We reserve the right to change our practices and this Policy at any time. Please check our Policy regularly for updates or changes.
