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Le Pull Français Personal Data Protection Principles

Your Requests to Modify Your Personal Data

  • As a user of Le Pull Français services, you can modify your personal data directly from your customer account.

     

  • If you wish to delete your customer account, you can also do so from your customer account (please note: this action is irreversible, and you will lose access to your order history, loyalty points, promo codes, etc., though it remains possible to create a new customer account).

     

  • You can export your personal data from your customer account.

     

  • For any other request for access, obtaining, rectifying, or erasing your personal data, we invite you to contact our data protection service:

 

By email: serviceclient@le-pull-francais.com

 

By phone: Monday, Tuesday, Thursday, and Friday from 10:00 AM to 4:00 PM, at 06 46 04 07 48

 

By mail: LE PULL FRANÇAIS – 236 Chemin Martin 42153 RIORGES.

Introduction

LE PULL FRANÇAIS attaches particular importance to the protection of personal data, collected and processed in compliance with applicable laws and regulations. This specifically includes the French Data Protection Act of January 6, 1978, as amended, and the European Regulation (EU) 2016/679 of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) (together referred to as the “GDPR Legal Framework”).

 

This privacy policy (the “Privacy Policy”) presents and summarizes the commitments of LE PULL FRANÇAIS regarding the protection of personal data. It is specified that the GDPR Legal Framework applies to any processing of personal data, defined as any operation on one or more pieces of information (first and last name, phone number, email, date of birth, etc.) that allows for the direct or indirect identification of a natural person (“personal data”, “data subject”).

 

This page describes the principles by which LE PULL FRANÇAIS collects different types of data from its customers and details the commitments concerning the security and personal data protection policy of LE PULL FRANÇAIS in order to respect your privacy to the fullest extent.

 

LE PULL FRANÇAIS regularly updates this Privacy Policy as operations or services change or develop. For this reason, we encourage you to regularly consult the latest statement. Where applicable, customers are invited to accept any new version of the Privacy Policy when logging into their customer account.

 

It is specified that “Processing” corresponds to any operation or set of operations, whether or not performed using automated processes, applied to personal data or sets of personal data (collection, recording, transmission, storage, retention, extraction, consultation, use, interconnection, segmentation, etc.).

Data Controller

Any processing of personal information provided to LE PULL FRANÇAIS is carried out under the responsibility of LE PULL FRANÇAIS, a simplified joint-stock company (société par actions simplifiée) with a capital of €75,000, whose registered office is located at 236 Chemin Martin 42153 RIORGES, and registered with the Roanne Trade and Companies Register (RCS) under number 821 443 470, in its capacity as data controller.

How do we collect data about you?

Personal data is collected through the following means:

 

  • Cookies: while browsing the website www.le-pull-francais.com (the “Site”), cookies may be installed on the data subject’s device (see Cookies Appendix for more information).

  • Use of LE PULL FRANÇAIS network and communication services: for example, by placing a call, creating your customer account (account creation/login form on the Site), or sending an email; please note that we record customer service calls to verify the actual conversation if necessary.

  • Participation in contests, sweepstakes, or customer events.

  • Use of the Site’s online payment solutions (third-party providers).

  • Relations with customers, suppliers, and partners: particularly commercial relations (trade fairs, contact requests/networking).

 

Where applicable, whether data provision is mandatory or optional is indicated during collection by an asterisk (*). The requirement to provide mandatory data (i) is of a regulatory or contractual nature or (ii) is a condition for processing the request, including the conclusion and execution of the contract where applicable. Failure to provide this data will result in the inability to process the request and/or conclude/execute the contract. By voluntarily providing data, including optional data, data subjects expressly agree that it will be processed in accordance with the purpose stated at the time of collection and under the terms of the Privacy Policy. When you visit LE PULL FRANÇAIS websites or load pages, you leave various types of anonymous browsing data, such as your IP address and browsing history. The operation of the services is based on the use of cookies.

What data do we collect?

The personal data processed are as follows:

 

  • Identification: last name, first name, date of birth.

  • Contact Information: postal address, email address, phone number.

  • Payment Data: credit card details.

  • Communication / Connection Data: communicating parties, time of connection, routing information, data transfer protocol, connection format and location information, customer service calls where applicable.

What are the purposes of processing personal data?

The customer information we collect helps us to personalize and continually improve your shopping experience with LE PULL FRANÇAIS services. We use this information to process orders, deliver products and services, process payments, and communicate with you about your orders, products, services, and promotional offers. It is also used to maintain and update our records and your accounts with us, provide content such as wish lists and customer reviews, and recommend products and services that may interest you. Additionally, we use this information to improve our stores and websites, prevent or detect fraud or abuse on our website, and enable third parties to carry out technical, logistical, or other functions on our behalf.

Purposes of Processing

As such, the processing of personal data by LE PULL FRANÇAIS serves the following purposes:

 

  • Communication with data subjects: particularly for responding to inquiries and requests for information regarding our activities and offers.

  • Customer record creation and CRM: managing customer relations, communicating with customers, verifying commercial transactions, responding to requests, and monitoring/developing service quality.

  • Contract conclusion (orders): execution, processing, management, invoicing, and payment of orders, as well as the provision of any associated services.

  • Warranty and after-sales service: processing warranty claims and providing technical, logistical, or other functions via third parties on our behalf (notably online payment solutions, carriers, accounting, etc.).

  • Improvement of offers: inviting customers to participate in polls, studies, and satisfaction surveys.

  • Commercial statistics: developing business statistics and sending personalized offers via electronic communication (direct marketing: email, SMS, etc.).

  • Event management: creating and managing events related to LE PULL FRANÇAIS’s activity (trade fairs, annual events, contests).

  • Exercise of rights: managing requests from data subjects to exercise their rights.

  • Protection of legitimate interests: notably debt collection and the exercise of any legal rights.

  • Compliance with legal and regulatory obligations: such as document retention, accounting, and/or tax obligations.

 

We also use data for customer profiling based on invoicing, usage amounts, duration of the customer relationship, and external classifications. We use both summarized usage data and person-specific data to create target groups for marketing. No fully automated individual decision-making activities are performed. Cookies: The purposes of each cookie implemented on the Site can be consulted in the table in the Cookies Appendix and/or via the tag management solution. Should the personal data of the data subject be processed for different purposes, LE PULL FRANÇAIS undertakes to inform them and, where required by law, to obtain their prior consent.

Legal Basis

Personal data processing is carried out by LE PULL FRANÇAIS in accordance with current regulations, and in particular the GDPR Legal Framework. As such, processing is based on one or more of the following legal grounds:

 

  • Free, specific, informed, and unambiguous consent from the data subjects regarding the processing of their data.

  • Necessity for the performance of contractual obligations of LE PULL FRANÇAIS towards the data subjects or for pre-contractual measures taken at their request.

  • Necessity for compliance with legal and regulatory obligations of LE PULL FRANÇAIS (such as the fight against fraud).

  • Necessity for the purposes of the legitimate interests of LE PULL FRANÇAIS (such as conducting satisfaction surveys to improve its offers).

  • Necessity for the exercise or defense of legal claims by LE PULL FRANÇAIS (such as debt collection, civil or criminal liability actions, etc.).

 

Cookies: to learn more about the legal basis for processing implemented via cookies and your ability to object to the placement of certain cookies, please consult the Cookies Appendix.

List of the types of information we collect

Information you provide to us

We collect and store information you provide to us via our website or by other means, in accordance with the principles detailed in this Privacy Policy. You may choose not to provide us with certain information; however, this decision may limit your use of our services.

Information collected automatically

Every time you contact us, we receive and store certain types of information. Like many other websites, we specifically use ‘cookies’ and obtain certain types of information when your browser accesses the LE PULL FRANÇAIS website or advertisements and other content displayed on other websites by LE PULL FRANÇAIS or on its behalf.

Information regarding emails

To optimize the usefulness and relevance of our emails, if your computer allows it, we frequently receive confirmation of the emails sent by LE PULL FRANÇAIS that you have opened. If, after having consented—either by accepting the Privacy Policy during your orders, or expressly by subscribing to the LE PULL FRANÇAIS newsletter or through a contact request—you no longer wish to receive emails from us, you may simply notify us via your account or through the dedicated link provided in the emails sent.

How do we manage your information?

Please note that the staff of LE PULL FRANÇAIS, its subsidiaries, and their subcontractors act under an obligation of confidentiality when processing your data. We maintain the confidentiality of your data and ensure it is only used for predefined purposes, as detailed in the Privacy Policy. We strive to ensure that customer data is up to date and accurate, retaining it for the periods specified in the Privacy Policy, and deleting obsolete and unnecessary data in accordance with the Privacy Policy and in compliance with our legal and regulatory obligations.

Where do we send your data?

We only submit your data to authorities and other telecommunications companies to the extent permitted by applicable legislation and as stated in the file description. When we use subcontractors, we sign a security agreement with them that also covers the use of your data. We also remain responsible for this type of data handling on your behalf.

Le Pull Français Data Protection Principles

Core values important to LE PULL FRANÇAIS include the confidentiality of customer data and communications, as well as the protection of customer privacy in all company operations. When handling our customers’ personal data, we follow French legislation, the orders and instructions of authorities, and best data processing practices. LE PULL FRANÇAIS implements a high level of data protection.

We protect all data concerning you through task-based personal access rights and prevent third-party access to the data to ensure its security. We protect the security of your personal information during transmission by using SSL (Secure Sockets Layer) software, which encrypts the information you enter before it is sent to us. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personal customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

 

We constantly train our staff on data processing principles and monitor data usage through appropriate means. LE PULL FRANÇAIS takes care to perform actions aimed at preventing data security breaches or eliminating disruptions affecting data security. Furthermore, we use every means to ensure that message confidentiality or privacy protection is not unduly compromised when performing the above actions. We provide information on actions related to the data security of our services and other matters concerning data security through appropriate channels, such as our website or customer bulletins.

 

In order to prevent data security breaches and eliminate disruptions affecting data security, we may, among other things, block the receipt of electronic messages, remove viruses and other malware from messages, and take other comparable technical measures. We use physical, administrative, and technical protection measures to keep messages and identification data transmitted over the communication network secret. These actions reduce the risk of your data being disclosed to third parties and prevent misuse or other unauthorized access.

 

Please note that as a user of LE PULL FRANÇAIS services, you must also use the most appropriate methods to ensure your own data security. We encourage you to store and use our services and your devices with care and to control their use—for example, by using secure codes and unique passwords, and by using sufficient antivirus and firewall services while keeping them and your operating system updated.

General Principles of Customer Data Management

The processing of personal data must always be justified for LE PULL FRANÇAIS’ operations. LE PULL FRANÇAIS only processes customer data necessary for its operations, as defined in the purpose of use stated in the file description for the customer register. We strive not to process incorrect, incomplete, or obsolete data. We encourage our customers to regularly update their contact details. Please note that as a customer of LE PULL FRANÇAIS, you have the right to verify what data concerning you has been stored in our information systems, or that there is no data concerning you in our records. You may also refuse the use of your data in accordance with relevant legislation.

 

Measures Applicable to Personal Data Processing – Transfers Outside the EU All necessary measures are implemented to guarantee the confidentiality, integrity, and security of personal data, including with respect to subcontractors, given the risks involved, in order to prevent personal data from being distorted, damaged, or accessed by unauthorized third parties. Personal data is stored within the European Union. However, as part of the transmission of personal data to certain recipients, its transfer outside the European Union is possible. In such cases, adequate measures resulting from the GDPR Legal Framework are taken to ensure that the recipients involved provide a level of security comparable to that resulting from compliance with the GDPR Legal Framework and present the guarantees required in this regard.

Collection, storage, extraction, and processing of personal data – Register of data collected directly via Le Pull Français services:

Contact form

  • Data collected: email address and message, order reference, any attached files.

  • Objective pursued: Management and follow-up of the customer relationship.

  • Data storage: Recorded in the database.

  • Retention period: 1 year.

  • Data access: LE PULL FRANÇAIS customer relations department.

  • Is data stored or processed outside the EU: No.

Customer Account Creation and Login / Customer Relationship

  • Data collected: first name, last name, address, phone number, email address, date of birth, direct marketing information and consent, contact person information and company name where applicable, information provided by yourself, customer classification information, order, delivery, agreement and invoicing, customer service calls where applicable, location data (opt-in).

  • Objective pursued: Order / Order tracking / Address / Returns / Credit notes / Loyalty management / After-sales service / Warranties.

  • Data storage: Recorded in the database.

  • Retention period: Duration of the commercial relationship, then until a deletion request is sent or after a period of inactivity, fixed at a maximum of 2 years.

  • Data access: Logistics (partially, only data related to the processing and shipping of your order) / Marketing department / Customer service.

  • Is data stored or processed outside the EU: No.

Newsletter opt-in form

  • Data collected: email address.

  • Objective pursued: Marketing emails.

  • Data storage: Opt-in recorded in the database.

  • Retention period: Duration of the customer’s opt-in, unless a deletion request is made by the customer, for a maximum period of 2 years.

  • Data access: Marketing department.

  • Is data stored or processed outside the EU: No.

Payment data

Only for the duration necessary to complete the transaction, by the payment provider only.

Supplier / Partner Data

Retention period: For the duration of the commercial relationship, then for the applicable statute of limitations period.

Cookies

  • Retention period: For a maximum period of 25 months, in accordance with the CNIL guidelines of July 4, 2019.
  • For more information, please consult the Cookies Appendix.

 

Finally, it is specified that certain personal data is kept longer for the purposes of (i) compliance with applicable legal and regulatory obligations (such as document retention, invoicing, or the fight against fraud), and/or (ii) ensuring the establishment, exercise, or defense of LE PULL FRANÇAIS’s legal rights during the applicable statute of limitations period. In accordance with the ‘Data Protection’ act, you may exercise your right of access to your data and have it rectified via the contact button available at the top of this page. We store required invoicing data for at least one year from the invoice due date and for a period not exceeding three years from the invoice due date, unless it is necessary to retain the data for a longer period.

Register of data transmitted to subcontractors via Le Pull Français services:

Shopimind

Provider information: https://www.shopimind.com/

Provider location: France

Objective pursued: Marketing emails

Is data stored or processed outside the EU: No

Provider GDPR policy: https://www.shopimind.com/rgpd/

Mailjet

Provider information: https://fr.mailjet.com 

Provider location: France

Objective pursued: Marketing emails

Is data stored or processed outside the EU: No

Provider GDPR policy: https://fr.mailjet.com/rgpd/

Nosto

Provider information: http://www.nosto.com/fr/

Provider location: Finland

Objective pursued: Marketing emails + remarketing

Is data stored or processed outside the EU: No

Provider GDPR policy: http://www.nosto.com/data-privacy/

Facebook

Provider information: https://www.facebook.com/

Provider location: United States

Objective pursued: Login to your customer account on the site via your Facebook account

Is data stored or processed outside the EU: Yes

Provider GDPR policy: https://www.facebook.com/

Google Analytics

Provider information: https://analytics.google.com/analytics

Provider location: United States”

Objective pursued: Site traffic analysis + Remarketing

Is data stored or processed outside the EU: Yes

Provider GDPR policy: https://privacy.google.com/intl/fr_fr/businesses/compliance/

Google Adwords

Provider information: https://adwords.google.com

Provider location: United States

Objective pursued: Advertising + Remarketing

Is data stored or processed outside the EU: Yes

Provider GDPR policy: https://privacy.google.com/intl/fr_fr/businesses/compliance

Mailchimp

Provider information: https://mailchimp.com/

Provider location: United States

Objective pursued: Marketing emails

Is data stored or processed outside the EU: Yes

Provider GDPR policy: https://kb.mailchimp.com/fr/accounts/management/about-the-general-data-protection-regulation

Sending and Sharing of Data

LE PULL FRANÇAIS may only submit your data to third parties in accordance with current legislation. We submit information upon request to authorities, such as the police and security authorities, as well as other authorities for reasons specified by law. Information about our customers is an important part of our business, and our business is not to trade it. We share this information only in the cases previously stated and for the purposes described in this privacy policy with entities controlled by LE PULL FRANÇAIS that are either subject to this privacy policy or apply rules at least as protective as those described in this privacy policy.

 

Furthermore, we may submit your data to subcontractors, in which case we will ensure that data confidentiality is maintained, and we will remain responsible for data management. If we process your data outside the EU region, we will protect your data by ensuring that the subcontractor guarantees appropriate data processing. This includes: Subcontractors, specifically in the following categories: accounting firms and information systems technical providers, cookie providers (please consult the Cookies Appendix on this point), banking institutions and online payment service providers, social and tax organizations. Where applicable, personal data may be communicated to authorized third parties under legislative and regulatory provisions, as part of an express and reasoned request from judicial authorities.

Processing of Identification and Location Data Related to Electronic Communication

LE PULL FRANÇAIS treats all data and messages created during communication as confidential. Our staff is bound by an obligation of secrecy and a prohibition against using messages or other confidential information. When communication occurs over a network, it always leaves a trace. Network traces are created, for example, during telephone calls, sending electronic messages and SMS, and internet browsing; these may contain information about the correspondents, the connection route or routing, the data transfer protocol used, the event, and the devices used or their location.

Use of Location Data

A real-time tracking method where another person can track where another individual is located requires the consent of the person to be located. The customer may choose not to be located at all by refusing geolocation services. If we submit location information to location service providers, we ensure through appropriate means that consent from the person to be located has been obtained.

Persons Authorized to Manage Identification and Location Data

Only specific individuals at LE PULL FRANÇAIS whose work requires access to identification and location data may process such data. In practice, authorization is granted only to persons performing tasks related to billing, maintenance or development of communication networks or services, prevention and investigation of abuse, customer service, and marketing. Persons with the right to handle the data may only manage it to the extent required to perform individual tasks.

Websites, visit tracking

We also collect data regarding website visits. This data includes the IP address and the corresponding DNS name, the organization that registered the IP address, the name and address of the page visited, the page loading time, and the browser type. Please note that the IP address is an identification required for the functioning of the Internet, used to direct messages transmitted over the Internet to the appropriate locations. Generally, the IP address is not connected to the person using the computer, but it can be connected to the organization that registered the IP address. The IP address connection may be established at the request of the authorities.

Customer Communication and Direct Marketing

LE PULL FRANÇAIS sends customer messages regarding its products and services to its customers via the consent available in the customer account. LE PULL FRANÇAIS also sends direct marketing messages in electronic format. You have the right to prohibit LE PULL FRANÇAIS from sending direct marketing messages. You can opt-out of marketing by following the instructions included in the direct marketing message or via your customer account available on our website.

 

Rights of Data Subjects

 

Under the GDPR legal framework, data subjects have the following rights: rights of access, inquiry, rectification, erasure, restriction, and withdrawal of consent to processing, as well as the right to object to processing for legitimate reasons and at any time in the context of commercial prospecting. You also have the right to personal data portability and the right to define post-mortem instructions regarding the fate of your personal data.

 

These rights may be exercised by sending a complete request accompanied by proof of identity to the following addresses:

 

  • Email address: serviceclient@le-pull-francais.com

  • Postal address: LE PULL FRANÇAIS – 236 Chemin Martin 42153 RIORGES

 

The request must include the last name, first name, and the email or postal address where the data subject wishes to receive the response from LE PULL FRANÇAIS. For security reasons and to avoid fraudulent requests, this application must be accompanied by proof of identity. After processing the request, this proof will be destroyed. In accordance with the law, unless justified by special circumstances, a response will be provided within one month of receiving the request.

 

Finally, data subjects have the right to lodge a complaint with the CNIL or any other competent supervisory authority in their state of residence. This complaint can be filed with the French CNIL at the following addresses:

 

Cookies Appendix

As a customer of LE PULL FRANÇAIS, you can browse our websites anonymously. However, like most websites, we use cookie technology. You can prevent cookie storage by changing your browser settings. In some cases, preventing this may slow down or make it impossible to navigate the pages or the website.

What are cookies?

When visiting the Site, tracking technologies are used and data is collected. The term ‘cookies’ refers to all tracking technologies that may be used. These are notably text files saved on the user’s device during their visit to the Site, containing information about their navigation and enabling certain features. When you view our website, the cookie sets a random number for the browser that does not reveal your identity. Cookies help LE PULL FRANÇAIS determine which sections of its websites are most popular, where visitors go, and how long they stay there.

 

The data is used to implement and develop services and to target advertisements on the websites. There are several categories of cookies, which pursue different purposes:

 

  • Technical cookies: these cookies help make the Site usable by enabling basic functions like page navigation. The Site cannot function properly without these cookies.

  • Audience measurement cookies: these cookies help, by collecting and communicating information anonymously, to measure the number of visitors and understand how they interact with the site.

  • Social media cookies: these so-called ‘social’ cookies are linked to services provided by third-party sites, such as ‘Like’ or ‘Share’ buttons or multimedia content players. They are used to provide services to users or to remember their sharing preferences with social networks. The social network providing such a button may identify the user through this button, even if the user does not use it while consulting the Site. Indeed, this type of button can allow the social network concerned to understand the user’s navigation on the Site simply because the user’s session is open on their device.

  • Advertising cookies: these cookies are used to present advertisements that may match the user’s interests by personalizing the advertising and content of the Site. Cookies may be placed by LE PULL FRANÇAIS or by third parties. In the latter case, the user is informed and their consent is collected prior to their placement, but LE PULL FRANÇAIS has no direct control over these cookies. The user is invited to refer to the privacy policies of the third-party cookie publishers.

Rights regarding cookies

Consent to the placement of cookies

 

In accordance with applicable provisions and CNIL recommendations, no cookie is placed if the user has not previously consented to it. Express consent is collected through a device informing the user of the cookies used, their publishers, and their purposes; this device allows them to accept or refuse the placement of cookies. The validity period of the user’s consent regarding cookies is 13 months; at the end of this period, consent is required again.

 

Certain cookies, considered strictly necessary for the provision of the service, are exempt from consent. This is notably the case for the following tracers: “Shopping cart” cookies, “Session ID” cookies for the duration of a session (or persistent cookies limited to a few hours in some cases), Authentication cookies, Certain audience measurement analysis solutions (analytics), Persistent user interface personalization cookies (choice of language or presentation). In any case, the user may withdraw their consent at any time by objecting to the placement of cookies.

 

Objecting to the placement of cookies

 

When the user objects to the installation or use of a cookie, a refusal cookie is installed on their device.

 

Browser settings

 

The user can configure their browser regarding cookies to refuse or accept certain categories of cookies:

 

 

Settings for cookies placed by third parties

 

The user can object to the placement of third-party cookies. For example, to disable the Google Analytics cookie, it is possible to download an add-on at: https://tools.google.com/dlpage/gaoptout

 

Personalized advertising cookie settings via the “Youronlinechoices” interprofessional platform

 

The user can connect to the Youronlinechoices website, offered by digital advertising professionals grouped within the European Digital Advertising Alliance (EDAA) and managed in France by the Interactive Advertising Bureau France. This allows users to identify the companies registered with this platform that offer the possibility of refusing or accepting cookies used to adapt advertisements likely to be displayed on the user’s device based on their browsing information: http://www.youronlinechoices.com/uk/your-ad-choices

 

This European platform is shared by hundreds of internet advertising professionals and provides a centralized interface allowing the user to express their refusal or acceptance of cookies. This procedure will not prevent the display of advertisements on the websites visited but will only block technologies that allow advertisements to be adapted.