WHO IS RESPONSIBLE FOR YOUR DATA

Polène UK Limited, with its registered office address at 8th Floor South, 11 Old Jewry, London, ENG, EC2R 8DU, GB and with the Information Commissioner’s Office (the “ICO”) registration number [XXX] (referred to as “”, “we”, “us” or “our”), is the data controller and decides how your personal information is processed. 

If you have any questions about this privacy policy or would like to make a request to exercise your legal rights, please contact us using the contact details set out below.

Email address: antoinergpd@polene-paris.com

Postal address: 11 Old Jewry, 8th Floor South, London, ENG, EC2R 8DU, GB

This Privacy Policy provides you with information about how we process your personal information. It applies when you visit our retail stores or our website https://uk.polene-paris.com (the "Site"), make a purchase from us or otherwise communicate with us regarding our retail stores or the Site (together the “Services”). For the purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them unless this is clear from the context.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law.

HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

To provide the Services, we collect personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.

In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide or improve the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

WHAT PERSONAL INFORMATION WE COLLECT

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies you. The following sections describe the categories and specific types of personal information we collect.

INFORMATION WE COLLECT DIRECTLY FROM YOU

Information that you directly submit to us through our Services may include:

• Identity details: including your first and last name
• Contact details: including your, address, phone number, and email address.
•  Order information: including your billing address, shipping address, and payment confirmation.
•  Account information: including your username, password, security questions and other information used for account security purposes.
•  Shopping information: including the items you view, put in your cart, or save into your account (e.g. loyalty points, reviews, referrals or gift cards, or purchases).
• Customer support information: including the information you choose to include in communications with us, for example, when sending a message through the Services.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

We will not collect special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, information about your health, genetic or biometric data).

INFORMATION WE COLLECT ABOUT YOUR USAGE

We may automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

For more details on our use of Cookies, see the section below.

INFORMATION WE OBTAIN FROM THIRD PARTIES

We may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

• Companies who support our Site and Services, such as Shopify.
• Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfil your orders and provide you with products or services you have requested, in order to perform our contract with you.
• When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.

HOW WE USE YOUR PERSONAL INFORMATION

We collect and use your personal information for different purposes depending on how you interact with us and the services that we supply to you or your business. Data protection law requires us to have a legal basis to process your personal information for each particular purpose. We will only use your personal information when we have a legal basis for doing so. Most commonly, we will rely on one of the following legal bases: 

• Where it is necessary to perform the contract we are about to enter into or have entered into with you (“Performance of a contract with you”).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Necessary for our legitimate interests”).
• Where we need to comply with a legal obligation (“Necessary to comply with a legal obligation”).
• We may also rely on your consent as a legal basis for processing your personal information (“Consent”).

Below, we have provided you with further information about how we process your personal information.

•  Providing Products and Services. We may use your personal information to provide you with the Services where this is necessary to perform a contract with you, including to process your payments, fulfil your orders, to send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and other features and functionalities related to your account. We may also enhance your shopping experience by enabling Shopify to match your account with other Shopify services that you may choose to use. In this case, Shopify will process your information as set forth in its Privacy Policy and Consumer Privacy Policy.
  
  
•  Marketing and Advertising. We may use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites. If you are a UK or  EEA resident, the legal basis for these data processing activities is that the processing is necessary for our legitimate interest in selling our products, or we may in some cases rely upon consent. 

•  Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately. If you are an EEA or UK resident, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers.
  
  
•  Communicating with You and Service Improvement. We use your personal information to provide you with customer support and improve our Services where such processing is necessary for our legitimate interests as it enables us to be responsive to you, provide effective services, and support our business relationship with you.
  
  

HOW WE DISCLOSE PERSONAL INFORMATION

In certain circumstances, we may disclose your personal information to third parties for contract fulfilment purposes, and other legitimate purposes that we may lawfully and transparently pursue whilst adhering to this Privacy Policy. Such circumstances may include:

• With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfilment and shipping).
  
  
• With business and marketing partners to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
  
  
• When you direct, request or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or facilitate your use of social media widgets or login integrations.
  
  
• With our affiliates group companies and other stakeholders, in order to pursue our legitimate interests in running a successful business .
  
  
• In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including compliance with subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We disclose the following categories of personal information about our users for the purposes set out above in "How we Collect and Use your Personal Information" and "How we Disclose Personal Information":

Opting out of marketing

You can opt out of receiving marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us on the contact details below.

If you opt out of receiving marketing communications, you may still receive non-marketing service-related communications that are essential for administrative or customer service purposes (e.g. order confirmations).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is lawful and compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we intend to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Please note that, in limited circumstances, we may process your personal information without your knowledge or consent where this is required or permitted by law.

COOKIES

Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies or to alert you when websites set or access Cookies through your browser controls . Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

USER GENERATED CONTENT

The Services may enable you to post product reviews and other user-generated content. If you choose to submit user generated content to any public area of the Services, this content will be public and accessible by anyone.

We do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.

CHILDREN'S DATA

Our Site and the Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms may be defined in any applicable law) the personal information of individuals under 18 years of age.

SECURITY AND RETENTION OF YOUR INFORMATION

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These include limiting access to your personal information to our employees, contractors, agents and other third parties who have a business need to access it. We have also put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee perfect security. In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes for which we collected the information. How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as any other relevant legal, regulatory, tax, accounting or other requirements.

If you want to know more about how long we keep your data please contact us using the contact details below.  In some circumstances you can ask us to delete your data: see your legal rights section below for more details.

YOUR RIGHTS

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

•  Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
  
  

•  Right to Erasure: You may have a right to request that we delete personal information we maintain about you. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

•  Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

•  Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances where this is technically feasible, and the data has been provided in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  
  

•  Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• if you want us to establish the data’s accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or 
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

• Right to Object: You have a right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

•  Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

• Appeal/ Complaints: You may have a right to appeal a decision in relation to your rights. You can do so by replying directly to us. If you are based in the UK or our processing of your personal information otherwise falls within the scope of UK data protection laws you also have a right to complain to the ICO if you are concerned about  this, or any other aspect of our processing of your personal information. You can contact the ICO to make a complaint by accessing their website https://ico.org.uk/make-a-complaint/.
  
  
•  Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may, in certain limited circumstances, still send you non-promotional emails, such as those about your account or orders that you have made.
  
  

You may exercise any of these rights by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. However, we may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

COMPLAINTS

If you have complaints about how we process your personal information, please contact us using the contact details provided above. If you are based in the UK or our processing of your personal information otherwise falls within the scope of UK data protection laws you have the right to complain to the ICO about our processing of your personal information (see above). If you are based outside of the UK and not subject to UK data protection laws then you may still have the right to complain to your local data protection authority. For the EEA, you can find a list of the responsible data protection supervisory authorities here.

INTERNATIONAL USERS

Please note that we may transfer, store and process your personal information outside the country you live in, including for processing by staff and third-party service providers and partners in these countries. 

We will not transfer your personal information outside of the EEA.