PRIVACY CHARTER FOR PERSONAL DATA
This charter (the “Charter”) details the policy of the Etam Group and its affiliates (the “Etam Group”) on personal data and cookies for the site www.1-2-3.com or any other website operated by the Etam Group (the “Site”). The purpose of this Charter is to inform you of the conditions under which the Etam Group collects personal data, the reasons why this data is collected, how it is used and your rights, and applies to all information provided by you or collected by the Etam Group when you browse the Site.
- When browsing the Site, the Etam Group may collect personal data about you. Personal data shall include in particular:
- personal data, such as your marital status, phone numbers, address of your home to deliver your order, email address to send you the newsletter, pictures you communicate,
- electronic identification data available on or from your computer (such as cookies or IP addresses). Your electronic identification data can identify or geolocate (without being more specific than the city) your connection terminal or pages viewed on the Site during your browsing session and are generally insufficient to identify you personally.
1. GENERAL INFORMATION
Through the Site, you may be invited to notify the Etam Group of personal data, such as when creating a customer account, ordering products or subscribing to the newsletter.
The Etam Group may be required to collect certain information about your browsing on the Site, under the conditions described in the “Cookies” section below.
In accordance with applicable rules, the POGGI Law Firm, Anne-Sophie Poggi, Attorney, 50 rue Etienne Marcel 75002 Paris, was designated as Data Protection Officer.
2. RIGHT OF ACCESS, CORRECTION, DELETION AND OPPOSITION TO PROCESS
You have a right of access, correction and deletion of personal information about you, as well as the possibility to oppose the processing of this data, which you can exercise at any time by sending an email to the following address: email@example.com.
You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you reside, your place of work or the place where the infringement is alleged to have occurred, if you consider that the processing of your personal data constitutes a violation of applicable regulations.
3. MANAGEMENT OF PERSONAL DATA BY THE ETAM GROUP
3.1 Data collection purposes
- Through the Site, the Etam Group processes your data that are necessary for the following purposes:
- Management of your subscription to the newsletter (registration and unsubscribing),
- Execution and follow-up of your product orders made on the Site,
- Production of anonymous statistics on site attendance,
- Allow access to certain Site features.
- Provide information about products and/or services and commercial prospecting messages,
- Conducting surveys.
3.2 Data retention
- The data shall be retained for a period which does not exceed the period necessary for the purposes for which they were collected:
- For managing your newsletter subscription: The Etam Group retains data for 3 years from the last contact. If you unsubscribe, the Etam Group will stop sending newsletters.
- For product orders: the data collected shall be kept for the purposes of the execution of your order and then for the period necessary to establish proof of a right or contract; such data may be archived in accordance with the provisions of the Code of Commerce relating to the shelf life of books and documents created during commercial activities and the Consumer Code relating to the conservation of contracts concluded electronically.
3.3 Recipients of data
- Your personal data are intended for the departments of the Etam Group affected by your requests. However:
- When ordering a product on the Site, the personal data you provide under the Order are intended for the company of the Etam Group or its subcontractors in charge of executing the order.
- In any event, there is no transfer outside Europe and the Etam Group does not transmit your personal data except:
- If the Etam Group has to share this information with third parties to provide you with the service you are requesting; or
- If the Etam Group is summed up by a judicial authority or any other administrative authority to disclose the information, or
- If you have agreed to the sharing of this information.
3.4 Data security and confidentiality
The Etam Group has endeavored to put in place reasonable precautions to preserve the confidentiality and security of personal data processed and prevent them from being distorted, damaged, destroyed or otherwise accessed by unauthorized third parties. Technical and organizational security measures have been introduced to this end.
The Etam Group does not, however, control all risks associated with the operation of the Internet and draws the attention of users to possible risks inherent in its use and operation.
- For the technical storage of your personal data, your data will be centralized with the following providers:
- oXya - in Ile-de-France and Hauts de France,
- Salesforce Commerce Cloud - in Ireland,
- Amazon Web Service - in Germany and Ireland,
- Jaguar Networks - in Provence-Alpes-Côte-d’Azur,
- OVH - in Hauts-de-France,
- Actito - in Belgium.
The Etam Group attaches the utmost importance to the protection and security of its information systems.
Tools have been put in place to enable the Etam Group to detect possible vulnerabilities. These tools may inadvertently lead to access to personal data by security teams. Such data will be collected and processed for the exclusive purpose of managing these faults and in compliance with the applicable rules for the protection of personal data.
4.1 What is a cookie?
A cookie is a text file that can be stored in a dedicated space of your electronic equipment on the occasion of consulting an online service with your browsing software. A cookie file allows its issuer to identify the terminal in which it is registered during the cookie’s period of validity or registration.
4.2 Cookies issued on the Site
When you log on to the Site, the Etam Group may be prompted, subject to your choices, to install a variety of cookies to recognize the browser you are using during the cookie’s period of validity.
- The purpose of the cookies issued is to:
- establish statistics and volumes of use and use of the various elements of the Site (headings and content visited, courses), enabling the Etam Group to improve the interest and ergonomics of services and the visibility of published content;
- allow or facilitate your browsing on the Site, or to provide you with the online communication services you seek during your browsing session, and thus:
- adapt the presentation of the Site to the display preferences of your terminal (language used, display resolution, operating system used, etc.) during your visits to the Site, depending on the hardware and viewing or reading software that your terminal contains;
- remember information about a template you have completed on the Site (registration or access to your account) or to products, services or information you selected on the Site (subscribed service, content of a shopping cart, wish list, etc.);
- allow you to access reserved and personal spaces on the Site, such as your account, with identifiers or data you may have previously configured;
- implement security measures, for example when you are asked to re-connect to content or service after a certain period of time.
4.3 Cookies issued on the Site by third parties
The Etam Group may include third-party computer applications on the Site, which allow you to share Site content with other people or to let other people know about your consultation or your opinion regarding Site content.
The Etam Group does not control the process used by social networks to collect information about your browsing on the Site. The Etam Group invites you to consult the privacy policies of these social networks in order to understand the purposes of use, including advertising, of the browsing information they can collect through these application buttons. These protection policies must, in particular, allow you to exercise your choices with these social networks, including setting your accounts for each of these networks.
The Site may contain cookies issued by third parties (communications agency, audience measurement companies, etc.) and allow them, during the period of validity of these cookies, to collect browsing information relating to the Terminals, and in particular to measure the effectiveness of paying referencing campaigns with search engines.
4.4 Your choices regarding cookies
You can make the choice at any time to express and modify your cookie choices using the means described below.
You can configure your browsing software so that cookies are stored in your Terminal or rejected either systematically or according to their issuer.
You can also configure your browsing software so that the acceptance or refusal of cookies is offered before a cookie is likely to be registered in your terminal. For more information, see “How to exercise your choices depending on the browser you use?”
(a) The Agreement on Cookies
The registration of a cookie in a terminal is essentially subject to the choices of the Terminal user, which he/she can express and modify at any time and free of charge through the choices offered to him/her by his/her browsing software.
If you have accepted the registration of cookies on your Terminal in your browsing software, cookies included in the pages and content you have consulted may be stored temporarily in a dedicated space of your Terminal. They will be readable only by their issuer.
(b) Refusal of cookies
If you refuse to register cookies in your Terminal, or if you delete them, you will no longer be able to benefit from a number of features that are still necessary to navigate some of the Site’s areas.
This would be the case if you have access to content or services that require you to identify you. This would also be the case when the Etam Group or its providers could not recognize, for technical compatibility purposes, the type of browser used by your terminal, its language and display parameters or the country from which your Terminal appears to be connected to the Internet.
If so, the Etam Group assumes no responsibility for the consequences associated with the degraded operation of its services resulting from our inability to register or consult the cookies required to operate and which you would have refused or deleted.
(c) How to exercise your choices depending on the browser you use?
For the management of cookies and your choices, each browser configuration is different. It is described in your browser’s help menu, which will help you know how to change your cookies.
4.5 If you share the use of your terminal with other people
If your terminal is used by a number of people and the same terminal has several browsing software, the Etam Group cannot ensure that the services and advertisements intended for your Terminal are consistent with your own use of this terminal and not that of another user of that Terminal.
If so, sharing the use of your Terminal with other people and configuring your browser settings for cookies is your choice and responsibility.
PFor more information on cookies and their use, you can find the CNIL (National Commission of Computing and Freedoms) file at the following address: https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs.
5. CHARTER AMENDMENT
The Etam Group may be required to amend the Charter and ensure that you are informed of it either by a special mention on the Site or by a personalized warning including via newsletters.
6. PERSONAL DATA POLICY RELATING TO MINORS
The Site does not target minors as a public. Access to the Site is not prohibited, however, because it does not contain content prohibited for minors under the age of 18.
If information was collected on a minor by the Site, the legal representative of the minor will have the opportunity to firstname.lastname@example.org modify or delete this information.