PRIVACY POLICY

Updated on 24.05.2018

Personal Data Protection Policy

Vilebrequin collects and processes personal data. Vilebrequin respects the privacy of users and customers.

The data protection policy implemented by Vilebrequin complies with 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 (hereinafter GDPR).

This Personal Data Protection Policy (hereinafter referred to as the Policy) details and explains:
- What personal information and data we collect, process and use for the purpose of procedural efficiency and in order to offer you the optimum experience when you use our services in store or online and more generally in the context of our relations with you;
- The level of security that Vilebrequin provides to protect these data;
- Our commitments to you;
- Your rights and how to exercise them.

1.1 What is personal data?
Data considered as personal is any information relating to a directly or indirectly identified or identifiable natural person, in particular by reference to a user ID, such as a name, an identification number, location data, an online user ID, or regarding one or more elements specific to his or her physical, physiological, genetic, psychological, economic, cultural or social identity.

1.2 Your consent to this Policy
When making a purchase in our shops or on our Website or when creating a customer account, we have offered you the opportunity to accede to this Policy. In expressing your agreement, we consider that you have read and understood this Policy.
Please note that at any time you may ask a question, withdraw your consent(s) or exercise your rights by contacting the department responsible for personal data directly by email at privacy@vilebrequin.com or by writing to the following address:

VILEBREQUIN
Personal Data Protection Department
(Data Privacy)
Chemin du Pré-Fleuri 5, 1228 Plan-les-Ouates, Switzerland


By withdrawing your consent to this Policy, you waive all or part of the services described below (Section 1.4).

When you interact with us on behalf of a third party (e.g. a purchase made on behalf of a third party or delivered to a third party) we assume that you have obtained the party’s prior consent to the fact that you are communicating their personal information to us.

1.3 Scope of the Policy
This Policy applies to all data processing operations performed within the Vilebrequin network. The Vilebrequin network includes all the Vilebrequin stores around the world belonging to T.R.B. International SA (hereinafter referred to as the Vilebrequin Network or Vilebrequin). Your relations with the other stores bearing the tradename “Vilebrequin” or distributing the “Vilebrequin” trademark but not belonging to T.R.B. International SA are subjected by their own privacy policies (see also section 2.2.2). You can find the list of Vilebrequin stores belonging to T.R.B. International SA via the following link:https://www.vilebrequin.com/eu/en/store-locator.

1.4 Activities and services
This Policy applies to all the services set up and offered by Vilebrequin in its capacity as a luxury brand owner, designer and manufacturer of luxury goods, in particular in the domain swimsuits, ready-to-wear and accessories, whether online, in our store network or with our partners. These services also include activities related to the development of our brands’ reputation and related marketing activities (hereinafter referred to as the Service or Services).

What types of data do we collect and in what circumstances?

The specific nature of the data that we collect depends on the form of your interaction with us. You will find below details of the information collected according to the time and form of this collection.

2.1 Spontaneous communication of your information to Vilebrequin
2.1.1 When you, as a guest, order a product on our Website, we collect the following information:
- Your details (Surname, first name, address, telephone number, e-mail);
- Your payment information (name of the debit or credit card holder, debit or credit card number, expiry date and CVV code).

2.1.2 When you create a customer account or when you make a purchase with this account or in one of our stores, we may collect the following information:
- Your details (Surname, first name, address, telephone number, e-mail);
- A user ID and a password
- Your preferred language;
- Your date of birth;
- Your title;
- Your payment information (name of the debit or credit card holder, debit or credit card number, expiry date and CVV code);

2.1.3 When you make purchases on our Website or in stores, we may collect any information relating to your shopping history and preferences.

2.1.4 When you subscribe to our Newsletter or agree to receive commercial communications, we collect the means of communication that you have stated to us.

2.1.5 When you spontaneously communicate information about yourself (including via social networks) or through correspondence with us, we process and store this information.

2.2 Transmission of your information by third parties or via the Internet
2.2.1 During your visit to our site
We collect standard information from all Users who browse our Website, even those who do not have a customer account. Vilebrequin monitors the interaction of Users with the Website, monitors performance and collects other information that may be considered Personal Data such as the date and time of access, the IP addresses of Users and information regarding equipment, operating systems and browsers used to access the Website and the URL of the sites that refer Users to the Website.
To do this we use cookies and other tracers. In this regard we invite you to consult our Cookie Policy.

Where allowed by applicable laws, Vilebrequin also uses the services of Google Analytics, a Google Inc. internet service, or similar services to this, in order to track the Users’ interaction with the Website and its performances. For this purpose, Google Analytics collects data and automatically generates reports that are supplied to Vilebrequin. Users may refuse this data processing by disabling the Cookies To view the full list of cookies that we use and to find out how we use them, please read our Cookie Policy.

2.2.2 Orders or payment to third-party providers
When you order VILEBREQUIN products from third parties who are not part of the Vilebrequin Network, they may be required to provide us with some of your personal information in connection with the order you have made.
Similarly, when you make payments online, the payment services with whom you contracted may be required to supply us with some of your personal information relating to the purchase you have made (this is particularly the case when using a PayPal account). In this case, your payment details are not communicated to us.

2.3 Age restrictions
During visits to our shops, we do not collect, use or deliberately disclose personal data provided by a minor under the age of 16, without the prior consent of their parent or legal guardian.
We inform this legal guardian of the specific categories of personal data collected in regard to the minor, and of the possibility of opposing the collection, use or retention of these. We comply scrupulously with child protection laws.
Regarding online purchases, Vilebrequin considers that the use of a credit or debit card implies either (i) that the User is over 16 years of age, or (ii) that he or she has the consent of his or her parent or legal guardian to use said credit or debit card.

2.4 Banking Data
Payment processing services allow Vilebrequin to process payments via credit or debit card, bank transfer or any other means of payment. To ensure greater security, Vilebrequin only shares data necessary to complete the transaction with the financial intermediaries that are conducting this transaction.
Vilebrequin works with trusted service providers whose reputation is proven and recognised.
When Vilebrequin collects your payment information, this is not retained once the transaction is completed.

Depending on the financial intermediary selected, you may be required to transfer your personal information directly to this service provider, in which case the applicable confidentiality policy is that of the service provider in question (e.g. PayPal).

What are the purposes of collecting and processing your data?

3.1 When processing is necessary for pre-contractual purposes or for the performance of a contract that you have concluded with us, we collect your personal data on the basis of Article 6.1 (b) GDPR with the intention being:
1. To fulfil our contractual obligations with you and particularly, to carry out operations with regard to the processing:
- of your orders;
- of your deliveries;
- of your invoices;
- of monitoring our commercial relationship (such as satisfaction surveys, management of claims, and after-sales service).
2. To communicate with you.

3.2 When processing is necessary for our legitimate interests, we collect your personal data on the basis of article 6.1 f) GDPR with the intention being:
1. To send our commercial or promotional catalogues to you via mail;
2. To ensure the constant improvement of our services and in particular, of our commercial communication with you;

3.3 When you have expressly given your consent, we collect your Personal Data on the basis of Article 6.1 (a) GDPR, for one of the following purposes:
1. Vilebrequin collects and processes your personal information during your purchases in order to:
a. Create a file containing the history of your purchases and orders, which will then be shared within the Vilebrequin Network in order to serve you better;
b. Analyse and track your orders so as to understand your preferences and offer you a unique and personalised customer and user experience;
c. Operate a sub-division process based on the history of your purchases in order to send targeted communications corresponding to your wishes;

2. Vilebrequin also collects and processes your personal data in order to improve your user experience on the Website and to enable the Vilebrequin Network to improve the quality of its services. The collected data are processed in order to:
a. Secure and improve your use of the Website, including:
i. Improved navigation;
ii. Improved security and fraud prevention in order to prevent misuse of the Website.
b. To perform cross-checks, analyses and combinations via trusted providers, to determine your interests, your customer profile according to your wishes, your habits or the place where you are located (according to your IP address) and allow us to send you personalised offers;
c. To manage technical canvassing operations (which includes technical operations such as standardisation, enrichment and deduplication of your Personal Data);
d. To establish profiles, in order to carry out targeted loyalty, canvassing, survey and promotion actions. In this respect, it is stated that our profiling operations are in no way likely to reveal sensitive data (racial or ethnic origins, philosophical, political, trade union, religious opinions, sexual life or health);

3. Vilebrequin collects and processes your personal data (including telephone, e-mail, address, surname and first name) in order to send you commercial communications by the means of communication that you have transmitted and indicated to us.

With whom we share your personal data

We do not sell any data that can identify you.

We share your personal data solely in one of the following situations:
- When your data are necessary for the accomplishment of the Services and the purposes described in this Policy;
- When your data has been anonymised;
- When you ask us expressly to share your personal data.

Your data may be shared with recipients within the Vilebrequin Network or with external recipients.
The list of internal recipients includes all entities of the Vilebrequin Network (as mentioned in paragraph 1.3 of this Policy).
The list of external recipients includes:
- The companies with which you ask us to share your data
- Companies offering services of Cookies and other tracers (please read our Cookie Policy)
- The service providers that we use in the course of our activities including the processing of your personal data.

4.1 Sharing of data that allows you to be identified
Vilebrequin relies in particular on a network of external service providers in order to provide the following services:
o Order and logistics processing;
o E-mail and marketing management;
o The processing of bankcards.

Vilebrequin only shares the data necessary to carry out the intended purpose with its network of service providers.
We make sure that the external service providers with which we liaise protect all the personally identifiable data that we transmit to them in compliance with this Policy.

In the case of the processing of certain orders (depending on the place of dispatch), you may be required to contract directly with specialist service providers in the worldwide shipment of products, such as for example the Pitney Bowes Inc. company. In this case, some of your personal data will be sent to these service providers who are responsible for invoicing, debiting your bankcard, collecting taxes and other fees and delivering the ordered products. We may be contractually bound to provide you with links to the confidentiality policies of third party service providers, which we do directly on our Website.

In the context of the payment execution of your orders, we may be required to transmit your payment information to service providers who carry out payment transactions for us on our behalf. In this case, the collected data is encrypted and processed according to the highest security standards (including, but not limited to, PCI-DSS compliance).
We may also be required to disclose your information when it is necessary to comply with the law, regulations or with a legal procedure, or to respond to a government or regulatory request, to enforce or apply the User Conditions or the Terms of Sale, in order to protect the security or integrity of our services and/or to protect the rights, property, including intellectual property, or the security of our entities, our personnel, our customers or users or others. In such a case we will do our best to notify you by e-mail, unless the law prevents us from so doing.

Finally, we may be required to disclose or transmit your personally identifiable data in the event of a sale, merger, bankruptcy, sale of assets or restructuring of our company. If another company acquires your personally identifiable data, we will let you know, and the commitments contained in this Policy will apply to the data transferred to the new entity.

4.2 Sharing data that does not allow you to be identified
Vilebrequin is likely to share data that does not identify you as an individual or that has been anonymised, with partners and the public in different ways, for example by providing research or reports on Users’ purchasing habits.
When we transmit these data, we implement all the appropriate procedures so that the transmitted data cannot be re-identified. Similarly, we contractually prohibit the recipients of the data to re-identify them.

4.3 Third party websites
The Website may contain links to other websites such as Facebook, Instagram, Twitter, YouTube, Pinterest, LinkedIn and others. Please note that the conditions of this Policy do not apply to the practices of companies outside the Vilebrequin Network or to any website that is not controlled by an entity of the Vilebrequin Network.

Users are invited to carefully review the confidentiality policies of all websites they visit when directed from the Website, so as to learn about the information and confidentiality practices that prevail when these confidentiality policies govern the collection and use of Users’ Personal Data.

Protecting your data during international transfers

As an owner of internationally sold brands and in operating a worldwide distribution network, we may share your personal data with recipients who may be located in countries other than the one in which the data was collected.

In this context, your data may be transmitted to recipients outside the European Union, the EEA or Switzerland and in particular, in the following countries: United States, United Kingdom, Hong Kong, Singapore, Macao, China and Mexico.

When personal data are transmitted to countries that do not have an adequate level of protection, we have put in place, in addition to this Policy, appropriate measures, and we control the international transfer of data by means of contractual clauses that meets European standards as defined by the European Commission or we require compliance with the EU-UE Privacy Shield.

The security of your data

In general, we implement all the appropriate technical and organisational measures, in accordance with the applicable legal provisions as well as with the usual standards in this regard, in order to protect your personal data against any destruction, loss or alteration, or any disclosure or unauthorised access request.

When you provide us with data on our Website, including your credit or debit card information, SSL (Secure Socket Layer) encryption technology allows these to be secured, as well as your transactions.

Retaining your data

We retain your personal data only during the period necessary for the purposes set forth in this Policy or as provided by the applicable law.

For each data category, we have defined a retention period based on the categories of data collected.

Regarding the data relating to your details (such as name, address, e-mail, etc.) the data retention period is 12 months from the last use of your data and in all cases 10 years since your last transaction.

Regarding the data relating to your purchase history, the retention period of this data is 10 years, this is due in particular to our wish to offer you an after-sales service throughout this period.

Regarding data that concerns the invoicing processes, the retention period of such data is 10 years, this is chiefly due to the legal duration of invoice dispute as generally accepted in the countries in which the Vilebrequin Network is located.

The identity of the entity responsible for processing your data

The entity responsible for collecting and processing your personal data is:

VILEBREQUIN
Personal Data Protection Department
(Data Privacy)
Chemin du Pré-Fleuri 5,
1228 Plan-les-Ouates
Switzerland


What are your rights and how can you exercise them?

In order to ensure that your personal data are processed in a fair and transparent manner, we strive to provide you with information about the use of your data in the most concise and understandable form, as well as in clear and simple terms.

In accordance with the applicable law, you have the rights of access, rectification, deletion, limitation, portability and opposition to the use of your personal data.
- Right of access: You can ask us directly for the data we hold about you, and request that we communicate all of these data to you. The exercise of the right of access makes it possible to check the accuracy of the data and, if necessary, to have them rectified or deleted.
- Right of rectification: You can ask us to correct inaccurate data that concerns you. The right of rectification completes the right of access. It prevents us from processing or spreading false information about you.
- Right of opposition: You may object, for legitimate reasons, to your inclusion within a file. In the field of canvassing, especially commercial canvassing, this right can be exercised without having to justify a legitimate reason. You may object to your data being disseminated, transmitted or stored.
- Right of deletion: You can ask us to delete the data we hold about you.
- Right to limit processing: You can ask us to limit the processing of your data in the following situations:
o You dispute the accuracy of the personal data;
o You consider that we treat your data unlawfully and oppose their deletion while requiring the limitation of their use;
o You request that your data be kept for the purpose of ascertaining, exercising or defending your rights in court;
o You have exercised your right of opposition.
When you request limitation of the processing of your personal data, Vilebrequin cannot, with the exception of the retention, process your personal data without your consent.
- Right of portability: The right to portability gives you the ability to recover some of your data (actively and consciously reported data and data generated by your activity) in PDF or Excel format. This data can be easily stored and transmitted from our information system to another, in order to be reused for personal purposes.

To exercise your rights, do not hesitate to contact the department in charge of the personal data for the Vilebrequin Network directly by email at the address: privacy@vilebrequin.com or by writing to the following address:

VILEBREQUIN
Personal Data Protection Department
(Data Privacy)
Chemin du Pré-Fleuri 5, 1228 Plan-les-Ouates, Switzerland


In order to secure access to your data, any request that did not originate from your Customer account or from the e-mail address that you have communicated to us must be signed and accompanied by a photocopy of an identity document bearing your signature and specifying the address to which the reply must be sent to you.

A reply will be sent to you within 7 days of receiving the request.

Similarly, via your customer account we also provide you with the opportunity to directly correct or update your personal data.

Finally, in the event of any disagreement with this Policy, you have the right to lodge a complaint with the supervisory authority of your country.

By clicking on the following link you will find the list and contact addresses of the supervisory authorities.

Update

We will notify you of any material changes to this Privacy Policy, as required by law, and give you the opportunity to review the revised version before continuing to use our Services.

Questions and contacts

For any questions concerning the personal data policy within Vilebrequin, please contact the Data Privacy Department

VILEBREQUIN
Personal Data Protection Department
(Data Privacy)
Chemin du Pré-Fleuri 5, 1228 Plan-les-Ouates, Switzerland




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