Personal data use

THE SOCIALITE FAMILY (“TSF”) operates a platform accessible via the website www.thesocialitefamily.com (“the Site”), which allows the online ordering of furniture and decoration items. 

As part of its activities, TSF processes personal data ("the Data") and undertakes to process your data in a safe and responsible manner in accordance with applicable regulations, in particular the "Data Protection Act" of 6 January 1978 as amended by the European Regulation of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the GDPR). 

This privacy policy establishes the principles according to which TSF processes your Data and the measures put in place to ensure their security and confidentiality. This privacy policy allows you to communicate mandatory information regarding the processing of personal data that TSF carries out. 

As a reminder, any data relating to an identified or identifiable natural person is personal data. A person is identifiable if it can be identified directly or indirectly in particular by reference to an identifier, for example location data, an online identifier, etc. 

Data processing consists of any operation or set of operations performed or not performed using automated processes and applied to personal data or sets of data (collection, recording, transmission, storage, retention, retrieval, consultation, use, interconnection, segmentation, etc.). 

As a data controller, TSF decides the purposes and means of processing your personal data. This data is collected directly from you, in particular via the Site, by telephone, in TSF shops or via exchanges with TSF customer service or indirectly through public sources. In the latter case, these are the professional email addresses that TSF obtains via their website. This privacy policy will subsequently be communicated in the first email sent to them by TSF.

This privacy policy is brought to your attention when you create your account and can be consulted at any time on the Site. 

TSF may change this Privacy Policy at any time and will inform its customers by such means as it deems appropriate. 

1/ TSF's commitments regarding personal data

In general, TSF undertakes to comply with the regulations in force, and incorporates internal procedures so as to adopt the basic principles of data protection and in particular: 

  • Only collect data for specific, explicit and legitimate purposes, 
  • Collect only the data necessary for the purposes pursued, 
  • Process this data lawfully, fairly and transparently, 
  • Take all reasonable steps to ensure that the data is accurate and up-to-date,
  • Keep the data for a limited time and proportionate to the purpose of the processing,
  • Take all technical and organisational measures to ensure the security of data, protect it against unauthorised or unlawful processing, loss and destruction.

2/ What personal data is processed by TSF

2.1 In connection with the provision of the products or services offered by TSF

To benefit from the products or services offered by TSF, you must first create an account and provide TSF with personal data concerning you. 

The categories of data that may be processed in this context are: 

  • Registration information: username and email address (the password, if collected, is then encrypted in a non-reversible manner and not collected as such) 
  • Identification data, for example: surname, first name, date of birth, language, postal address, email address, mobile phone number and/or landline phone number, 
  • Billing data, for example billing address, proof of address in case of suspected fraud
  • Order data: transaction number, purchase details, purchase date, purchase amount, invoice payment data (payments, unpaid amounts, discounts), product returns.
  • Data needed to carry out loyalty schemes and prospecting actions: purchase history.
  • An identity document, in the context of the exercise of your rights over your Data and in the context of banking regulations against money laundering and KYC ("Know Your Customer") procedures.
  • Communications between you and TSF through available communication channels, such as postal correspondence, email, SMS. 

With regard to the banking information required for the payment of products via the Site, it is collected and processed directly by Stripe, Alma or PayPal payment service providers via the online payment form made available on the Site. 

At no time does TSF have access to your banking information. You are invited to read the privacy policies of these service providers available via the following links: 

ALMA: https://getalma.eu/legal/data

PAYPAL: https://www.paypal.com/us/webapps/mpp/ua/privacy-full

STRIPE: https://stripe.com/en-ca/privacy

The personal data collected, which is essential to respond to your requests, is identified by an asterisk on the data collection form or specified orally as part of data collection in a shop or by telephone. If you do not complete these mandatory sections, TSF will not be able to respond to your requests. 

2.2 In connection with the use of the Site

When you access and/or register and/or use the web services offered by TSF, TSF collects and processes personal data about you provided that you have accepted the storage of the corresponding cookies on your device. 

The information that may be collected includes: the IP address assigned to you during your connection, the date and time of access to the Site, the pages visited, the type of browser used, the operating system installed on the device, the search engine as well as the keywords used to find the site. For more information on cookies, see Article 7..

2.3 Recording of telephone conversations

Telephone conversations between you and TSF staff may be recorded for training, quality control and /or evidence of business transactions. 

The personal data collected and/or that you communicate are exclusively intended for TSF. You may exercise your rights in respect of such recordings in accordance with terms stated in Article 9. 

2.4 Video surveillance

TSF has placed some of its shops under video surveillance to ensure the safety of its staff and property. The video recordings are kept by an external company and communicated to TSF managers only in the event of incidents. You may exercise your rights in respect of such video recordings in accordance with the terms stated in Article 9.

2.5 Collection of anonymous information 

TSF may automatically collect anonymised information, such as the type of Internet browsers you use. TSF may also collect in the form of anonymised statistics information that you have submitted to the Site (for example, the city where you live), your behaviour while using the Services (for example, clicks, time spent visiting a page, domain names and paths through which you use or access the Services). This data does not identify you directly or indirectly and is used solely to assist TSF in providing an effective service on the Site. 

3/ Legality and Data processing purposes

TSF collects Personal Data listed in Article 2 in order to respond to your requests and provide you with the best possible service. 

The table below gives you an overview of how your Data is processed.

Data

Processing purposesLegal basisRetention period
Surname, first name, email address, languageSending the newsletter and commercial offersConsentDuration of the business relationship and three (3) years from the last purchase
Surname, first name, email address, delivery address, billing address, purchase historyLoyalty scheme

Legitimate interest of TSF

Duration of the business relationship and three (3) years from the last purchase

Surname / First name, email addressn shipping address, products ordered (product type/ quantity / cost), selected carrier, payment method used

Management of orders, invoicing

Contract Execution (T&Cs) and Legal Obligations

Duration of the business relationship then archiving during the legal limitation period

Surname, first name, email address, shipping address, products ordered (product type/ quantity / cost), selected carrier, payment method used

Claims

TSF's legitimate interest and legal obligations

Duration of the business relationship then archiving during the legal limitation period

Surname, first name, transaction amount, last digits of the debit/credit card number, transaction status

Payment status trackingTax and accounting obligations and the legitimate interest of TSF

Duration of the business relationship then archiving during the legal limitation period (10 years for accounting obligations)

Surname, first name, email address, shipping address, project/desired products (type of product / quantity / amount)

Provision of a quote and commercial follow-up

Pre-contractual measures before signing a contract

Legitimate interest of TSF

3 years from the quote request date

Surname, first name, email address, shipping address, products ordered (product type/ quantity / cost)

Marketing analysis (performance analysis, order types, etc.)Legitimate interest of TSF

Duration of the business relationship

Satisfaction index, reviewsMeasuring the Customer experienceLegitimate interest of TSFDuration of the business relationship

Session data (#, duration, page views, etc.)

Data concerning demographics, interests and geography

Improvement of the site experience, analysis and promotionTSF's legitimate interest and consent

Tracker duration: maximum 13 months

Data retention period: maximum 25 months.

Surname, first name, email address, products viewed, shipping address

Personalised marketingConsent3 years
Email, logIS SecurityLegitimate interest of TSFDuration of the business relationship
Identity documentPrevention and fight against fraud

Legal obligation, legitimate interest of TSF

Duration of the legal obligation

Images of visitors visiting the shops

Safety of persons and assetsLegitimate interest of TSF1 month or the duration of the procedure in case of a dispute.
Telephone conversationsTraining, transaction verification, service quality improvementLegitimate interest of TSF3 months

In the event of processing based on TSF's legitimate interest, TSF has ascertained the strict necessity of the data collected with regard to its legitimate interest. Thus, TSF has weighed up the rights and interests in question and has verified in this context that its interests are not to the detriment of the rights and interests of the persons whose data is being processed.

4/ Data recipients and subcontractors

The personal data collected and processed by TSF may be communicated to the following recipients or categories of recipients:

- Natural persons authorised by TSF to process your Personal Data, after signing a confidentiality agreement, and in particular TSF employees;

- To the payment providers ALMA, STRIPE and PAYPAL, who act as separate data controllers;

- TSF's external advisors: lawyers, accountants, auditors, etc., bound by an obligation of confidentiality;

- To the authorities: your Personal Data may be disclosed to the competent authorities in accordance with the law, a regulation and/or a court decision;

- To any third party in the event of a merger/acquisition, total or partial disposal of assets, change of direct or indirect control, or any other form of restructuring implemented by TSF.

- Service providers to whom TSF subcontracts all or part of the processing of your Data, in particular:

  • The Site's hosting company and operator;
  • The email service provider;
  • The logistics provider for the preparation of orders and the monitoring of returns; 
  • Carriers;
  • The delivery tracking service;
  • The customer ticketing service provider for the management of complaints and calls to customer service;
  • The video surveillance service provider.

With regard to its subcontractors, TSF undertakes to verify that they provide all the necessary guarantees for the protection of personal data. Thus, TSF has put in place the necessary contractual measures to commit its subcontractors to strictly respect the security and confidentiality of personal data and to use them only according to the instructions provided by TSF.

TSF's subcontractors only have access to the data necessary for the performance of their services and are not authorised to process your data for other uses.

Personal data is never transmitted to any business partner of TSF, whether for free or for a fee, without first obtaining your consent.

5/ Transfer of data to a non-EU country

TSF may only transmit your data to a country that is not a member of the European Union if that country ensures an adequate level of protection within the meaning of the legislation in force or to the extent permitted by the legislation in force, for example by ensuring data protection through appropriate contractual provisions.

Thus, some TSF subcontractors and IT service providers are based in the United States. Pursuant to a judgment by the European Union Court of Justice of 16 July 2020, personal data can no longer be transferred to the United States on the basis of Privacy Shield. TSF has therefore put in place Standard Contractual Clauses and has ensured that the security and confidentiality measures applied by the subcontractors to personal data make it possible to guarantee a level of protection equivalent to the level of protection provided for by the GDPR. 

Similarly, if you require delivery to a country that is not a member of the European Union, TSF must submit your name, postal address and telephone number to the local carrier.

If you have any questions regarding the transfer of your personal data outside the European Union, please send an email to shop@thesocialitefamily.com.

6/ Security measures

TSF has put in place the necessary technical and organisational measures, taking into account the nature of the data processed, to ensure their security and confidentiality. 

When you enter your information on the Site, its transmission is secured by the SSL (Secure Socket Layers) protocol. SSL guarantees that the Data exchanged cannot be read by third parties.

Within TSF, access to your Data is strictly limited to those whose duties require it. These persons are bound by a confidentiality agreement.

TSF has put in place the necessary internal procedures to ensure the notification to the French CNIL service within 72 hours maximum of any personal data breach that may cause a risk to your rights and freedoms. 

In the event of a personal data breach that may result in a high risk to your rights and freedoms, you will be informed as soon as possible of the following:

  • the nature of a violation
  • the categories and approximate number of data subjects concerned
  • the categories and approximate number of files concerned
  • the likely consequences of the data breach
  • the measures taken to remedy the violation and, where appropriate, to mitigate the consequences of the violation

7/ Cookies

TSF recommends you consult its cookie policy, available below (see APPENDIX).

This section concerns cookies that may be placed on your device. It allows you to learn more about:

  • The origin and use of the browsing data processed during your browsing on the Site,
  • The origin and use of the browsing data processed during your access to the Site via TSF advertising content. 

When visiting the Site or when displaying TSF advertising content on third-party sites, data relating to your browsing may be recorded by so-called "cookies" files stored on your computer, provided that you have given your consent to the storage of these cookies depending on the purpose of the processing. Only cookies necessary for the operation of the Site may be stored without your consent.

What are "cookies" and "trackers"?

The term cookie covers all the trackers stored and/or read, for example during the consultation of the Site, the reading of an email, the installation or the use of a mobile or software application whatever the type of device used such as a computer, a mobile phone, a digital reader, etc.

For the sake of convenience, the term "cookie" covers all the technologies referred to in this Privacy Policy.

What cookies are used by the TSF Site?

Below you will find information about cookies that may be stored on your computer when you visit the Site, as well as ways which allow you to remove or refuse the storage of these cookies on your computer/device.

- Necessary cookies 

Cookies relating to the features of the Site: These cookies allow you to browse the Site and use our features such as shopping baskets. 

Customer preference cookies: When you browse or make purchases online, the Site records your preferences (for example, your username, language, or geographic location). This simplifies, facilitates and personalises your browsing experience.

- Audience measurement cookies

TSF uses these cookies to measure the Site's audience and analyse how you use it. They allow TSF to analyse your behaviours on the Site which are essential to improve the interest, ergonomics and your user experience. To this end, TSF uses the audience measurement service providers listed below (see APPENDIX).

These cookies are only stored with your consent. 

- Targeting cookies and advertising cookies 

These cookies are used to deliver adverts that may interest you. In addition, when you access a site containing advertising spaces that feature a TSF advertisement, the advertisement may contain a targeting cookie. This cookie may, subject to your express consent, be stored on your computer and allow TSF to recognise your device's browser during the period of validity of the cookie in question. These cookies are set by TSF and its partners, the updated list of which is available below (see APPENDIX) to offer you targeted content on the internet and in connection with your navigation. They also allow TSF to measure the effectiveness of its advertising campaigns.

When you browse our partners' websites, they can offer you relevant offers related to your browsing on the TSF Site.

These cookies are only stored with your consent.
 

- Cookies generated by social networks 

The Site uses third-party applications, which allow the user to share content via social networks listed below (see APPENDIX). For more information, please consult the privacy policies of these social networks.

How do you set your cookies? 

The storage of a cookie on your computer is subject to your consent via a cookie banner. You can accept or refuse cookies according to their purpose, and it must be as easy to refuse cookies as it is to accept them. Thanks to the settings of your browser software or through inter-professional platforms, you can, at any time, simply and free of charge, choose whether or not to accept the storage of cookies on your computer/device as well as withdraw your consent at any time.

You can configure your browser software to store cookies on your device or, on the contrary, to reject them, either systematically or depending on their issuer. You can also configure your browsing software so that each time a cookie is likely to be saved on your device you are asked for your preference.

To manage cookies and your choices, each browser configuration is different. It is usually described in the help menu of your browser software. We recommend you consult this information. You will then know how to modify your consent regarding cookies.

In addition, TSF invites you to connect to the Youronlinechoices website (Youronlinechoices.eu), offered by digital advertising professionals grouped within the European Association EDAA (European Digital Advertising Alliance) and managed in France by the Interactive Advertising Bureau France.

By doing so, this enables you to find out which companies have registered with this platform and offers you the option to refuse or accept cookies used by these companies to tailor adverts likely to be displayed on your device according to your browsing information: http://www.youronlinechoices.com/fr/controler-ses-cookies/.

This European platform is shared by hundreds of online advertising professionals and constitutes a centralised interface, enabling you to refuse or accept cookies that may be used for advertising related to the browsing on your device. Please note that this procedure will not prevent the display of advertising on the websites that you visit. It will only block the technologies that tailor adverts to your personal interests.

8/ Children's data

TSF encourages all parents or any person with parental authority to promote prudent and responsible behaviour on the part of minors when communicating their Data on the Internet and in particular on the Site. Please note that for a minor under 15 years of age, the parents must give their consent jointly with that of the minor for any processing of their Data based on consent.

If you are a parent of a minor who has communicated Personal Data to TSF on the Site or in the Shop and you have not authorised such communication and wish to have such Data deleted, you may contact TSF by following the procedure set out below.

9/ Your rights regarding personal data

The Site is operated by the company THE SOCIALITE FAMILY SAS with a capital of €138,950 registered under the sole French business registration number 797 641 131 RCS PARIS, whose registered office is located at 12 rue Saint Fiacre 75002 Paris, France.

Any request concerning your Data should be addressed to: shop@thesocialitefamily.com.

Your request must specify the rights you wish to assert. If TSF is in doubt about the identity of the person making the request, TSF may request a copy of your identity document.

TSF undertakes to respond to all requests within one (1) month of receipt of the request.

Any person whose personal data has been collected shall have the following rights:

9.1 Access to your Data:

To find out the Data concerning you in TSF's possession, you can request a copy of this Data in an electronic form in common use and ask TSF to obtain the following information in particular:

  • The purposes of the data processing;
  • The categories of personal data concerned;
  • The recipients or categories of recipients to whom your Data has been or will be communicated and the country concerned;
  • Elements related to the retention period of your Data;
  • The existence of the right to request from the controller the rectification or deletion of personal data, or a limitation of the processing of personal data relating to the data subject, or the right to object to such processing;
  • Where the Data has not been collected directly from you, any information available as to its source;
  • The existence of automated decision-making, including profiling, and information about its operation.

9.2 Data deletion:

If you are a TSF customer, you can delete your Data from your account. This action is irreversible and you will lose access to all of your Data, including your order history, loyalty points, promotional codes, etc.

You can also ask TSF to delete all or part of your Data by sending an email to the aforementioned email address.

9.3 Modification or rectification of your Data:

You can modify, correct or complete some of your Personal Data through your customer account by logging in using your login details (password and email address).

You may also ask TSF to update, rectify or complete your data, in particular if they are inaccurate or incomplete or if such Data cannot be updated by you.

9.4 Portability of your Data:

Where the processing of your Data is based on your consent or the implementation of the Terms and Conditions of Sale, you may ask TSF to receive your Data in a structured, commonly used and machine-readable format, and you may transmit said data to another controller. 

You may also ask TSF to transmit your Data directly to another controller where technically feasible.

9.5 Right to oppose Data processing:

You may ask TSF to not process your Data when such processing has as its legal basis the legitimate interest of TSF. 

TSF will cease to use your Data for these purposes unless TSF can demonstrate a legitimate and compelling reason for such processing or such processing is necessary for the establishment, exercise or defence of legal claims.

With respect to direct marketing you receive from TSF, you may refuse it at any time. You will be reminded of this option in all communications you receive from TSF (newsletter, SMS, etc.).

9.6 Limitation of the processing of your Data:

You may ask TSF to limit the processing of your Data in the following cases:

  • If you object to the processing of your Data, The Socialite Family will restrict the processing of such Data during verification as to whether the legitimate reasons pursued by TSF prevail over yours.
  • If you declare that your Personal Data is inaccurate, TSF must limit the processing of this data pending verification of its accuracy.
  • If TSF no longer needs the Personal Data but it remains necessary for the defence of its legal rights.

As part of a limitation on the processing of your Data, the latter are kept by TSF but may only be processed again in the following situations:

  • If you give your consent again,
  • For the establishment, exercise or defence of legal claims,
  • To protect the rights of another natural or legal person,
  • For important reasons of public interest of the European Union or of a Member State.

9.7 Right to lodge a complaint with the French CNIL:

In the event of difficulty in exercising your rights or in any complaint concerning the processing of your personal data, you have the right to refer the matter to the CNIL. 

If you would like more information on your rights, please consult the website of the French Commission Nationale de l’Informatique et des Libertés: https://www.cnil.fr/

APPENDIX

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