Effective Date: October 2021
ICICLE PARIS RETAIL (“ICICLE” or “we”) is very mindful about privacy issues and is committed to protecting your privacy. We want you to be familiar with the personal data we collect and use, as well as to inform you of your rights in accordance with the applicable data protection laws, and in particular, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("GDPR").
- COLLECTING PERSONAL DATA
- Information you provide directly to us
- Depending on what you provide us with, examples of Personal Data collected may include:
- Your identity (including your full name, gender, image, nationality);
- Your contact details (including your postal address, email address, phone number);
- Your personal status (including your title);
- Your preference (including your size);
- Certain payment information (including billing information, payment type or method);
- Other information you may provide by contacting us.
- Source of collection: Personal Data may be collected from you:
- When you create an account on the Site;
- When you purchase products or services on our Site;
- When you subscribe to our newsletter;
- When you visit our Site;
- When you contact our Customer Service.
- Device Information
- Examples of Personal Data collected:
- We collect your device information when you use our Site, such as version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
- Source of collection: collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
- Sensitive Data
We will NOT ask you or collect from you any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Site or otherwise to us. We hence ask you not to send us or disclose any such sensitive personal data on or through the Site or otherwise to us.
The Site is not intended for individuals under the age of sixteen (16). We do not intentionally collect Personal Data from children. If you are the parent or guardian and believe your child has provided us with Personal Data, please contact our Customer Service (email@example.com) to request deletion or confirm the processing of such Personal Data.
- SHARING PERSONAL DATA
We share your Personal Data with:
- Magento. We use Magento to power our online store. You can read more about how Magento uses your Personal Data here: https://magento.com/trust/privacy.
- ICICLE’s affiliates. ICICLE’s affiliates are authorised to have access to your Personal Data in order to provide you with a consistent level of service across all ICCF group companies. This may include providing you with the products and services that you have requested, improving the services provided and – with your prior consent – sending you Promotional Communications concerning offers, services, products or events (for such purpose, you may withdraw your consent at any time – see section 9 below).
- Our third party service providers (including without limitation SPLIO, CEGID) who provide services, such as data analysis, IT development and support, information technology and related infrastructure provision, customer service, delivery services, email delivery, auditing and other services.
- Any potentially relevant third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
If necessary, we may also share your Personal Data with the competent authorities in order to comply with applicable laws and regulations, to respond to a search warrant or other lawful request for information we receive, or to otherwise protect our rights.
- USING PERSONAL DATA
- Depending on the context, we may use your Personal Data in order to :
- provide products or services to you, which includes: offering products for sale, processing payments, shipping, fulfillment of your order, provide you after-sale services and manage refunds;
- provide you with invoices and/or order confirmations;
- keep you up to date on new products, services, and offers;
- screen our orders for potential risk or fraud;
- send you Promotional Communications (with your prior consent);
- use the device information in order to load the Site accurately for you;
- perform analytics on Site usage to optimise our Site;
- respect our legal obligations, including providing information to regulatory bodies when legally required.
- Pursuant to the GDPR, we collect and use your Personal Data based on one or many of the following legal basis:
- Your consent (e.g. for receiving newsletters and commercial communications, unless you already have purchased similar products or services on the Site);
- The performance of the contract between you and ICICLE;
- Compliance with our legal obligations;
- Our legitimate interests (e.g. performance of analytics).
- DATA TRANSFER
In the course of services, and subject to the appropriate GDPR safeguards, ICICLE's service providers may transfer Personal Data to third countries outside the EEA. For example, Personal Data processed by Magento may be transferred to its entities in Canada and the United States. For more information, see GDPR Whitepaper of Magento: https://magento.com/gdpr and of Splio: https://eu.icicle.com/en/privacy-policy.
- PROMOTIONAL COMMUNICATIONS
With your express prior consent (usually obtained by ticking a specific box in a form), you may receive information concerning offers, services, products or events sent by ICICLE (“Promotional Communications”). We rely on your consent to process the Personal Data you provide to us for this purpose. Therefore, if you no longer wish to receive such information, you can withdraw your consent at any time (see “Your Rights” section below).
- RETENTION PERIOD
- The length of time we have an ongoing relationship with you and provide the services to you (for example, for as long as you have an account with us or keep using the services) or the time period necessary to execute the contract with you for the purchase of products;
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them) or;
- The applicable statutes of limitations, or potential litigations or regulatory investigations.
- AUTOMATED DECISION-MAKING
- If you are a resident of the European Economic Area (EEA), you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.
- Our processor Magento uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.
Services that include elements of automated decision-making include:
- Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
- Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.
- HOW WE PROTECT YOUR PERSONAL DATA
We recognise and take seriously our responsibility to protect personal data you entrust to ICICLE from loss, misuse or unauthorised access. ICICLE uses a variety of security technologies and organisational procedures to protect your personal data. For example, we implement access controls, use firewalls and secure servers. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please notify us immediately in accordance with the “How to Contact Us” section below.
- YOUR RIGHTS
- In accordance with applicable law and the GDPR, you have the following rights with respect to your Personal Data:
- Right of access: you can obtain information about the nature and use of the Personal Data that relates to you;
- Right to rectification: you can request that inaccurate or incomplete Personal Data be rectified or completed;
- Right to erasure: you can request erasure of your Personal Data, particularly if the Personal Data is no longer necessary for the processing carried out;
- Right to restriction of processing: you can request that the processing of your Personal Data be temporarily restricted in certain circumstances, for example if you contest the accuracy of the Personal Data;
- Right of objection: you can object to the processing of your Personal Data based on our legitimate interests, including for commercial and marketing purposes;
- Right to portability: in the applicable cases, you can ask to have the Personal Data you supplied to ICICLE communicated to you in a structured and commonly used IT format;
- Right to give us instructions on the processing of your Personal Data after your death;
- Right to lodge a complaint by the CNIL: if you have any objections on the manner we process your personal data, you have the right to lodge a complaint with the CNIL (French Data Protection Authority), 3 place de Fontenoy TSA 80715, 75334 Paris, CEDEX 07.
- When the processing of your Personal Data is based on your consent, you may at any time withdraw it. If your consent is withdrawn, it will not affect the processing of your personal data based on other legal bases, such as fulfilling your orders and storing your order data as required by applicable law.
- If you no longer wish to receive our Promotional Communications, we remind you that you may withdraw your consent at any time from the unsubscribe link included in each electronic promotional message we send to you. If you do so, we will promptly update our databases, and will take all reasonable steps to meet your request at the earliest possible opportunity, but we may continue to contact you to the extent necessary for the purpose of any products or services you have requested.
- To exercise any of the aforementioned rights, please contact us using the contact information below (see “How to Contact Us” section below). In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data erased from our database or otherwise let us know what limitations you would like to put on our use of your personal data. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any case within the time limits set by applicable law.
- What is a Cookie?
A cookie is a file that is downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the Site to remember your actions and preferences (such as login and region selection). This means you do not have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the Site, for instance whether it is their first time visiting or if they are a frequent visitor.
- What Cookies We Use
We use the following cookies to optimise your experience on our Site and to provide our services.
Cookies Necessary for the Functioning of the Site:
Reporting and Analytics:
. _ Secure-3PSID
. _ Secure-3PSIDCC
3rd Party Services:
- How long does a cookie remain on your Computer or Mobile Device?
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between thirty (30) minutes and thirteen (13) months from the date they are downloaded to your device.
- How do I manage Cookies?
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of the Site may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file, in particular:
- If you use the Internet Explorer browser, we invite you to consult the following page: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d.
- If you use Firefox browser, we invite you to consult the following page: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox.
- If you use the Safari browser, we invite you to consult the following page: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac.
- If you use the Google Chrome browser, we invite you to consult the following page: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en.
- HOW TO CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact our DPO:
- By e-mail at firstname.lastname@example.org;
- By mail: 35 avenue George V, 75008 Paris.
©2023 ICICLE PARIS RETAIL. All rights reserved.