Privacy policy

Introduction

This Privacy Policy is addressed to you as the user of the website www.groupe-claire.fr (hereinafter “the WEBSITE”) and its objective is to inform you of how your personal data may be collected and processed by CLAIRE HOLDING SAS, a simplified joint-stock company listed on the Paris Register of Trade and Commerce at No. 538 319 260, headquartered at 28 boulevard Poissonnière – 75009 Paris, and its subsidiaries (hereinafter collectively “CLAIRE Group”).

Respect for the private lives and personal data of data subjects is a priority for CLAIRE Group, which undertakes to comply with the provisions of Regulation (EU) no. 2016/679 of 27 April 2016 on the protection of personal data.

CLAIRE Group undertakes in any case to respect the two (2) basic principles outlined below:

• You remain in control of your personal data;
• Your data will be processed in a transparent, confidential and secure manner.

Article 1.   Definitions

• WEBSITE: means the website accessible at www.groupe-claire.com; the WEBSITE includes all the web pages, services and functionalities offered to you as a USER or CUSTOMER via the CLAIRE Group;
• USER: means anyone accessing or browsing the WEBSITE as an internet user.

Article 2.   Identity of the Data Controller

The person responsible for the processing of personal data in connection with the operation of the WEBSITE is the company CLAIRE HOLDING SAS.

Article 3.   Data Protection Authority (CNIL) requirements

The processing of your personal data is the subject of a declaration submitted to the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés (CNIL)), no. 2089850.

Article 4.   Collection and processing of personal data 

In connection with the USER's use of the WEBSITE, CLAIRE Group may collect personal data. These data will be processed in accordance with the purposes indicated at the time of collection.

In particular, CLAIRE Group may collect personal data:

• When you visit the WEBSITE;
• When you use the functions and/or services available on the WEBSITE;
• When correspondence is exchanged with CLAIRE Group via the WEBSITE;
• When you submit a contact request to CLAIRE Group.

Whatever the means of collection, CLAIRE Group undertakes to inform you of the purpose of the data processing, whether it is obligatory or optional to provide a response, the consequences of failing to provide a response, the recipients of the data, the existence and arrangements for exercising the rights of access, rectification and opposition to processing of the data.

Where necessary for the purposes of Regulation (EU) No. 2016-679 of 27 April 2016, CLAIRE Group will obtain your consent and/or allow you to object to the use of your data for certain purposes.

The data that may be collected and processed by CLAIRE Group in connection with the purposes described in Article 5 of this Privacy Policy concern:

• identification data (title, name, surname, postal address, telephone and email address, date of birth, nationality, language, copy of an ID card where applicable, copy of other ID required to prove the right of access, rectification or opposition or to respond to a legal obligation);
• connection data (IP addresses, connection logs);
• data relating to the selection of persons for loyalty campaigns, prospecting, market surveys, product testing and promotional activities;
• data relative to the organisation and processing of competitions, lotteries and promotional campaigns, including date of entry, replies to competition questions and the nature of the prizes offered;
• data relative to the contributions of persons leaving product reviews, particularly their pseudonyms;

Article 5.   Purpose of the data processing

The data collected in the context of use of the WEBSITE will be processed in order to fulfil the purposes described in the table below.

Current regulations protect the private lives of the data subjects and require all data controllers to provide proof of a legitimate interest. The regulation provides that the legal basis for the data processing includes:

• the execution of a contract between the CUSTOMER and CLAIRE Group. Certain personal data of the CUSTOMER are necessary in particular in order to fulfil an order and manage the ACCOUNT;
• the prior consent of the data subject;
• the legitimate interest of the data controller, in compliance with the rights and freedoms of the USERS. Therefore the enhancement of the customer experience or the prevention of fraud may justify the collection of personal data.

Article 6.   Consent

When browsing the WEBSITE, you may complete various forms and provide various types of personal data in order to benefit from the services provided by CLAIRE Group.

By voluntarily providing your personal data, you expressly consent to the collection and processing of such data by CLAIRE Group, for the stated purposes.

Article 7.   Recipients of the data

Only the persons mentioned below can have access to the USERS’ personal data:

• Members of the company’s management and personnel in the sales, marketing, administration, logistics and IT departments of CLAIRE Group companies who are responsible for customer relations, for the processing of orders or for customer service.

Your personal data will not be disclosed, exchanged, sold or leased to any other person other than those mentioned above.

Article 8.   Data conservation period 

CLAIRE Group will ensure that the collected data are kept in a form allowing identification of the data subject for a period not exceeding that which is necessary for the purposes for which the data was collected and processed.

With regard to cookies, mentioned in Article 10 of this privacy policy, please note that the information stored on your terminal (e.g. cookies) or any other element used to identify you for statistical purposes will not be kept for more than thirteen (13) months. After that period, the raw browsing data associated with an identifier will be eliminated or anonymised.

Article 9.   Your rights as the data subject

In accordance with Articles 14-22 of Regulation 2016/679 of 27 April 2016, any natural person using the WEBSITE may exercise the following rights:

• a right of access, rectification or erasure of the data collected;
• a right of opposition to the processing of their personal data;
• a right to the portability of the collected data;
• the right to give instructions on the conservation, erasure or communication of personal data after death, in accordance with Article 40-1 of Law No. 78-17 of 6 January 1978.

If CLAIRE Group becomes aware of any breach of personal data that could lead to a high risk to the rights and freedoms of USERS, it will inform the USERS concerned as soon as possible thereof.

These rights may be exercised on simple request, by sending an email to rgpd@groupe-claire.com, or by post to Claire Holding in Paris: 28, boulevard Poissonnière 75009 PARIS with proof of your identity and a legitimate reason, where this is a legal requirement.

The USER must include a copy of their ID with the request.

For more information about your rights, you can also consult the website of the French Data Protection Authority (Commission Nationale de l’Informatique et des Libertés) at: http://cnil.fr.

Article 10. Browsing data and cookies 

On the WEBSITE, CLAIRE Group uses browsing data (date, time, web address, visitor’s computer internet protocol, pages visited) and cookies (small files stored on your computer) which may identify you, record your visits and provide measurements and statistics regarding the visitors to the WEBSITE and the pages viewed.

When navigating the WEBSITE, you agree that CLAIRE Group will install this type of “technical” cookie, the sole purpose of which is to permit or facilitate the electronic communication between your terminal and our website and to facilitate browsing and management of this site.

We will only access the information stored on your terminal or record information on it, in the following cases:

• to permit or facilitate electronic communication;
• where necessary for the supply of our online service at your express request.

As with all other data, you can exercise your right to access these browsing data by sending a request by email to rgpd@groupe-claire.com or by post to Claire Holding in Paris: 28, boulevard Poissonnière 75009 PARIS. It is necessary to include a copy of your ID.

If your browser permits, you can deactivate these cookies at any time by following the procedure below, as indicated for your browser. However, CLAIRE Group informs you that deactivating cookies may slow down and/or disrupt the access to the WEBSITE.

Furthermore, CLAIRE Group informs you that it uses Google Analytics and Matomo to measure the visitors to this WEBSITE. You can reject the tracking of your visit to the WEBSITE by Google Analytics by downloading and installing the Google Analytics Opt-out Browser add-on for your browser, from the website at the following address: http://tools.google.com/dlpage/gaoptout?hl=fr. You can reject the tracking of your visit to the WEBSITE by Matomo, by clicking on https://groupeclaire.matomo.cloud/index.php?module=CoreAdminHome&action=optOut&language=fr

In any case, the information stored on your terminal (e.g. cookies) or any other element used to identify you for statistical purposes will not be kept for more than six (6) months. After that period, the raw browsing data associated with an identifier will be eliminated or anonymised.

Article 11. Social media

You can click on the social media icons for TWITTER, LINKEDIN and YOUTUBE on the website.

Please note that the personal data you have made public and accessible on your TWITTER, LINKEDIN and YOUTUBE profiles will be accessible to CLAIRE Group and you therefore give express consent in this regard.

However, CLAIRE Group does not create or use any database independently of TWITTER, LINKEDIN or YOUTUBE that contains the personal data you may have published on those platforms and CLAIRE Group will not use any data relative to your private life in this way.

If you wish to object to CLAIRE Group having access to personal data published in the public area of your profile or social media accounts, you must use the policies made available by TWITTER, LINKEDIN and YOUTUBE in order to limit access to your data.

Article 12. Security

As the data controller, CLAIRE HOLDING SAS will take all the necessary precautions relative to the nature of your personal data and the risks of the data processing, in order to preserve the security of your data and in particular, to prevent them from being corrupted or damaged and from third-party access (physical protection of premises, customer authentication procedure including secure personal access using identifiers and confidential passwords, logging of connections and encryption of certain data).