PRIVACY AND CONFIDENTIALITY POLICY
The below privacy and confidentiality policy (the “Policy”) sets out the policy of BERLUTI SA and its affiliated companies (“BERLUTI”) concerning personal data and cookies on the www.berluti.com website (the “Website”), or any other website operated by BERLUTI (together “the Websites”). You can obtain the name and address of the data controller entity in your jurisdiction, by consulting our website berluti.com or by sending and email to the address in reference in below section 2. This Policy applies to all information which you (the user) supply to us or which is collected when you are browsing our Website.
BERLUTI respects your concerns regarding the confidentiality of the data you supply to us. By communicating your personal information and data to us, you are informed of the conditions according to which your data is being used, studied and if appropriate, disclosed by us; for the purposes provided in below section 3.1. We therefore strongly advise you to read this Policy very carefully.
1. GENERAL INFORMATION
Via the Website, you may be asked to communicate personal data to BERLUTI, including when creating a “My Berluti Space” customer account, when placing orders for BERLUTI products or when subscribing to our newsletter.
Any personal information which you transmit to BERLUTI for use for certain services is submitted to the provisions of the Data Protection Act of n° 78-17 of 6 January 1978 as amended by the Act of 6 August 2004, and as from 25 May 2018, to the European Regulation 2016/679 of 27 April 2016 on the Protection of Personal Data.
Furthermore, BERLUTI may also, with your consent, gather certain information related to your browsing on our Website under the conditions described in the “Cookies” section below.
2. YOUR RIGHTS
You have a right to access, rectify, limit, delete and to enjoy the portability of your personal information as well as the possibility of opposing the processing of such data for legitimate reasons or at any time when opposing the use of your personal data for marketing purposes, as well as to provide us instructions about the processing of data after your death, which you can exercise at any time:
- For the newsletter: either inside of your personal “My Berluti Space” area or by using the unsubscribe link on each electronic newsletter you receive.
- When ordering BERLUTI products: in the dedicated section of your “My Berluti Space” area.
- In all cases: by email to the data privacy department of BERLUTI at firstname.lastname@example.org or by letter to:
Protection of personal data
120 rue du Faubourg Saint Honoré
75008 Paris France
3. OUR COMPANY’S MANAGEMENT OF PERSONAL DATA
3.1 Collection Purposes of Personal Data
BERLUTI processes your personal data through its Website. This data is required for the following purposes:
- Management of client/prospect relationship
- The management of your newsletter subscriptions (registrations and cancellation of subscriptions),
- The performance and follow-up of your orders for BERLUTI products placed on our Website,
- The compilation of anonymous statistics on visits to our Website,
- To enable access to certain functionalities on our Website.
- Subject to your prior agreement, to inform you of information about our company and its activity it’s products and/or services and sales prospection messages,
- Management of client satisfaction regarding products, services or contents
- Procurement management and litigation
- Conduct of surveys and polls, with your approval.
The information we collect and which is essential for processing your requests (mainly your surnames, first names, postal addresses, email addresses and if appropriate, bank account details and telephone number for delivery purposes) is marked with an asterisk on the collection forms and are processed to allow BERLUTI to perform their agreement with you or because you have agreed to their use for certain purposes above or to provide you better service. We cannot satisfy your requests if you do not complete these compulsory fields.
We also collect, subject to your consent, your geolocation data in order to localise the nearest shop to you when you connect to the BERLUTI mobile application.
3.2 Storage of Data
The maximum period that data is stored is the duration required for the purposes which it is collected for:
- Management of your newsletter subscription: we keep your data for as long as your subscription is effective. As soon as we receive your subscription cancellation request, we delete the data we kept for the sending of newsletter.
- Orders of BERLUTI products: we conserve the data necessary for processing your order, and for the period required to prove a right or a contract. These data can be archived in accordance with the provisions of the Commercial Code for the conservation period for ledgers and documents created for business activities and in the Consumer Code, for conserving contracts concluded electronically.
- Management of prospects: three (3) years as of the latest contact with the prospect
- Geolocalisation data: two (2) months
3.3 Data Recipients and Data Transfers outside the European Economic Area
Your personal data is transmitted to BERLUTI’s departments which process your requests.
Please note that your identification data may be transferred to countries that are located outside the European Economic Area, in the context of foreign BERLUTI stores accessing your customer profile during product purchase, especially in the BERLUTI stores located in China, South Korea, United Arab Emirates, United States, Japan, Singapore, Taiwan, Hong Kong and Macao. These transfers are protected by data transfer contracts with the recipients based on the standard clauses adopted by the European Commission in order to ensure that all personal data benefit from an adequate level of protection as provided under the Data Protection Regulation, and that appropriate technical and organizational security measures have been implemented to protect personal data against accidental or unlawful destruction, accidental loss, alteration, disclosure or unauthorized access and against all other forms illicit processing. BERLUTI only disclosed your personal data to a third party if:
- You have agreed to share this information, or
- BERLUTI has to share this information with third parties in order to provide you with the service you have requested, or
- BERLUTI is ordered to disclose this information by a judicial authority or any other administrative body.
3.4 Data Security and Confidentiality
BERLUTI has striven to set up all necessary safeguards to protect the confidentiality and security of the personal data which is processed and to prevent it from being deformed, damaged, destroyed or unauthorised third parties having access to it. Technical security and organisational measures which satisfy industry standards, notably regarding information systems, have been installed.
You must therefore enter a personal password when creating your “My Berluti Space” account, and this contributes to our Policy. This password shall be composed of at least 12 characters of 4 different types:
However, BERLUTI does not control all the risks associated with the functioning of the Internet and draws the user’s attention to the risks inherent in the use and functioning of the Internet.
The storage of your personal data will be centralised on our host’s servers located in Sweden.
We take the protection and security of our information systems very seriously. Tools have been created to enable us to detect any security vulnerabilities. These tools may require our security teams to have occasional access to personal data. These data will be collected and processed exclusively for managing these vulnerabilities in compliance with the legislation which applies to the protection of personal data.
4. “SEND TO A FRIEND” FUNCTIONALITY AND COLLECTION OF DATA CONCERNING THIRD PARTIES
- You can use our Website to send information you think is interesting on our products or services or even the products or services themselves, to your friends.
- To send a product sheet: we ask you to enter your friend’s email address so the information can be transmitted. We only collect this data in order to send the email. We do not store or record the sender’s and/or the recipient’s data.
- To send a BERLUTI product to a friend or relative: we ask you to enter the email address and the surname, first name, and delivery address for this person to send them the product. These data is used exclusively for this.
- You must always inform us that the said person has been informed of your disclosure of their personal data.
5.1 What Is A Cookie?
A cookie is a text file which is stored in a dedicated space on the hard disk of your Terminal* when you consult an online service with your browser. A cookie allows the sender to identify the terminal on which the cookie is stored during the period the cookie is valid or stored.
* Terminal means the hardware (computer, tablet, smartphone, etc.) which you use to consult or display a Website, an application, advertising content etc.
5.2 Cookies We Place From Our Website
When you connect to our Website we may, depending on the choice you make, install different cookies in your terminal which enable us to recognise your terminal’s browser during the period the cookie is valid.
The purpose of the cookies we send is to:
- Compile statistics, and volumes of traffic and to use different components of our Website (the sections and contents visited, click trails etc.) to improve the attractiveness and ergonomics of our services and the visibility of the content we publish;
- Make it easier for you to browse on our Website or to supply you with the online communication services you request whilst browsing and to:
- Adapt the presentation of our Website to your terminal’s display preferences (language used, display resolution, operating system used etc.) during your visits to our Website in accordance with the materials and visualisation or reading software which your Terminal supports, and therefore:
- Remember the information on a form you completed on our Website (registration or access to your account) or on the products, services or information you selected on our Website (the service subscribed, content of a basket, a wish list etc.);
- Enable you to access the private and personal areas on our Website such as your account, using the identifiers or data you may have entrusted to us;
- Implement security measures, for example when you are asked to reconnect to content or service after the page has time out.
5.3 Cookies Which Are Placed From Our Website by Third Parties
5.3.1 Cookies placed by the third party applications integrated on our Website: we include third-party applications in our Website which enable you to share its content with other people or to inform them of your consultation or opinions on its content. This concerns the “share” or “like” buttons on social networks (such as “Facebook” or “Twitter” etc.).
The social network which supplies this application button can identify you via this button when you consult our Website, even if you do not activate this button. In point of fact, this type of application button enables the social network to monitor your browsing on the Website, if your social network account is activated on your terminal (open session) whilst you are browsing on our Website.
We have no control over the process which social networks use to gather information on your browsing on our Website, and which is associated with the personal data they possess. Please consult the privacy protection policies of the social networks concerned to establish the purposes, in particular advertising, which the browsing information they gather via these application buttons is used for. These protection policies must permit you to exercise your options with the social networks, especially by parameterizing your user accounts for each of them.
5.3.2 Cookies which are sent to our Website by third parties: our Website may also contain cookies sent by third parties (communication agencies, audience measurement companies etc.) which enable them, whilst the cookies are valid, to collect browsing information on the terminals visiting our Website and in particular to measure the effectiveness of our paying referencing campaigns with search engines.
5.4 Your Options Concerning Cookies
Options offered by your Internet browser:
You can configure your browsing software to install cookies on your terminal or alternatively to reject them either systematically or according to their sender. You can also configure your browsing software to accept or refuse occasional cookies, before they are stored on your Terminal.
(a) Cookies acceptance
Cookies stored on a terminal are stored subject to the choices of the Terminal’s user, which choices the user can express at his first Website connexion via the cookie banner, and modify his or her wishes at any time, free of charge, using the options give by the user’s internet browser regarding the following cookies [to be completed], or via the cookie consent tool [insert link].
If you have agreed in your browsing application to cookies being stored on your Terminal, the cookies incorporated in the pages and contents you consult can be temporarily stored in a dedicated area on your Terminal, where they will only be readable by the sender.
(b) Refusing to accept Cookies
If you refuse to allow cookies to be stored on your Terminal or if you delete cookies which have been stored, you will cease to benefit from a certain number functionalities which are necessary for browsing certain areas on our Website. For instance, this would be the case if you tried to access our content or services which require you to identify yourself, or if we, or our service providers, could not recognize, for reasons of technical compatibility, the type of browser used by your terminal, its language and display parameters or the country from which your terminal appears to be connecting from.
We therefore disclaim all liability for the consequences connected to the downgrading of the functioning of our services resulting from our impossibility to store or consult the cookies required for them to function and which you may have refused or deleted.
(c) How to Choose According to The Browser You Use?
Each browser is configured differently to manage cookies and your choices. Your browser’s Help Menu describes this configuration and will indicate to you how to modify your choices in terms of cookie use.
For more information, please go check the following websites (depending on the navigator that you use): Firefox, Internet Explorer, Google Chrome and Safari.
5.5 If You Share Your Terminal with Other People
If your Terminal is used by several people or if it has several browsers, we cannot be certain that the services and advertisements intended for your Terminal corresponds to your own use of this Terminal and not to another user.
Thus sharing your terminal with other people and the configuration of your browser’s configurations for cookies is something you do freely and is your responsibility entirely.
6. MODIFICATION OF OUR CONFIDENTIALITY POLICY
BERLUTI may have to make modifications to its Policy. We will ensure that you are informed of the modifications either by a special message on our Website or a personalised notification when sending newsletters.