1. Introduction
MAISON LE CYGNE attach particular importance to the processing, confidentiality and security of your personal data. We are committed to offering you personalized services while respecting your privacy and personal choices.
The purpose of this privacy policy (hereinafter “Statement”) is to inform you in a clear, simple and complete manner of the processing carried out on the personal data that you provide to us, can collect from the various outlets contact you may have with us (e.g. shop, customer care, biocodeskincare.com, maisonlecygne.com, social networks, digital applications, events), their possible transfer to third parties as well as your rights and the options you have to control your information protect your privacy, in accordance with current regulations.
During your shopping experience, and in order to inform you in advance, you will go from maisonlecygne.com to biocodeskincare.com, or vice versa. Depending on the type of product ordered, the Data Controller will be MAISON LE CYGNE, within the meaning of the regulations applicable to personal data and in particular with regard to article 24 of the Regulations (EU) 2016/679 (hereinafter “GDPR”).
OUR 7 key engagements towards you and your personal data:
- MAISON LE CYGNE is engaged to respecting your privacy and your choices, particularly with respect to our commercial communications.
- MAISON LE CYGNE is engaged in seeking the best security and applying the appropriate protection standards in its systems.
- MAISON LE CYGNE will not sell your data.
- MAISON LE CYGNE will only work with trusted partners.
- MAISON LE CYGNE is engaged in updating its privacy notices and policies as regularly as possible.
- MAISON LE CYGNE undertakes to respond to your requests as far as possible and within the time limits set.
- MAISON LE CYGNE is engaged to applying data protection rights in a harmonized manner regardless of your location in the world.
In this Statement, you will find information about:
- Introduction;
- Who are we;
- What data do we collect about you;
- For what purposes is your data used. by Maison Le Cygne;
- How long can we keep them;
- Who can acces your data;
- How do we protect and ensure the confidentiality of your data;
- How do we process cross border data flows;
- How are consumer preferences and individual rights treated;
- What additional protections are provided for residents of certain regions;
- How to contact us if you have questions about use of your personal data.
2. Who are we
MAISON LE CYGNE
MAISON LE CYGNE (head office), a private limited company under Romanian law whose head office is located at 11 Sportiv Catalin Bercu, 77190 Voluntari, ROMANIA – Registration number and registry of commerce and companies where registered: RO 46 376 187 at the registry of commerce and companies of Ilfov (ROMANIA).
3. What data we collect about you
“Personal data” means any information that identifies you either directly (such as your name) or indirectly (for example, using a unique customer number).
The personal data we collect depends on the point of contact through which you interact with us, as well as the purposes of this interaction as described in this Statement and are also limited to those which are relevant and appropriate for this interaction. Visitors to the biocodeskincare.com website who view our products, information and offers can choose to do so without logging in, and the same is true for point-of-sale search and browsing on social media. Unless you choose to interact with us through these contact points:
a. by creating an account and connecting to it;
b. by making a purchase on our site;
c. by subscribing to one of our programs or services;
d. by writing to us via the consumer contact forms or by writing us a comment in the free online order fields.
Or else, our data collection is limited to the use of “cookies” (visitors) for website visitors whose conditions are specifically defined by our cookie policy and according to your preferences. For the sake of transparency and clarity, our cookie management policy is separate from this Statement.
For one thing, for customers and others who sign up for programs or services, we need to collect certain relevant information from you. The information we collect is related to a given transaction as well as in the context of our business relationship with you. For example, if you make purchases on biocodeskincare.com or our points, we must collect information to process (and, if necessary, execute and dispatch) your order, to ensure its tracking and invoicing, to be in order to respond to any after-sales inquiries you may have. For customers and others who sign up for our programs or services, we generally collect your contact information, contact preferences and information that allows us to make recommendations to you about our products or services that may be of interest to you. We can centralize information about our customers to organize it in one place, as this helps us manage our relationship with you as well as your choices and preferences. Finally, if you subscribe to our personalised newsletter, we collect your email address.
Depending on the data that you communicate to us or that you share with us, personal data may include information concerning:
a. Your identity and contact details: surname, first name, postal address, email address, telephone number;
b. Your interests;
c. A history of your purchases (in store or online, including your orders, tracking and invoices, amount and type of purchase);
d. Your requests via our Customer Care Service or our Public Relations Service;
e. Your date of birth in order to benefit from the Birthday offers eligible according to your program;
f. Your satisfaction and comments on our programs, services and products;
g. The information that you specify related to the possible undesirable effects that you could report to us;
h. Your publications and mentions of our products on social networks.
Regarding your purchases, payments are made via a secure payment platform, supplemented by control measures, including encryption of contact details, in order to guarantee the security of purchases made and to fight against fraud. Your bank details are therefore not accessible on MLC’ s servers.
We invite you to ensure that your data is regularly updated, either by modifying it directly on our sites or, by informing us in writing of any modification by referring to the dedicated section “How to contact us”.
As part of our relationships, the data we collect may be collected through the following contact points:
a. Exchanges with our advisors in MLC’ s stores as well as points of sale in department stores;
b. Relationship with our public relations services;
c. Contact with customer care;
d. Forms that you fill out (in store or online);
e. Digital applications with which you interact;
f. Third party data providers with whom you share information;
g. Retailers for whom you agree to receive our communications;
h. Satisfaction surveys or questionnaires to which you answer;
i. Publications/mentions on social networks.
We make sure to identify the personal data essential for the purpose for which it is collected by indicating it with an asterisk like this ‘(*)’ on each personal data collection form. If you do not fill in these mandatory fields, we will not be able to respond to your requests and / or provide you with the services requested. The other information is optional and allows us to know you better and improve our communications and services to you. Although not mandatory, we recommend that you fill them in to allow you to benefit from the best possible experience during our interactions with you.
During your purchase journey, you will be able to choose between:
- logging into your existing MAISON LE CYGNE account;
- creating a new account;
- paying as a Guest (or also called Guest Check out).
This last purchasing experience is thus summarized as follows:
Payment for purchases as a Guest refers to the possibility for any MLC customer or prospect to make a purchase in our online store without logging into an account. Your information is collected for the process of payment and delivery of items or for MLC in order to comply with applicable laws. Your information may also be used for analytical purposes by MLC and for communication purposes via its preferred channel (for example: sending a general newsletter relating to the news by email for which you have the right to object). For more information on these purposes, please go to the section below, under the “Analysis and personalization purposes” section.
4. For what purposes is your data used by Maison Le Cygne
We are required to use your data for purposes defined according to the nature of our relationships. Thus, depending on the context in which your data is collected, it may be used for one or more of the following purposes:
Managing your orders:
a. Management of personalized content and MAISON LE CYGNE communications (digital or not);
b. Managing your client profile (For example, in order to simplify your navigation through the different markets on our website: if you navigate to another market, your customer account will automatically be duplicated in that market. This means that it will not be necessary to create a new customer account);
c. Managing your requests in connection with MAISON LE CYGNE;
d. The management of alerts that you send us as part of our cosmetovigilance obligations.
The management of our website and our digital applications:
a. Management and improvement of our products and services, image and reputation;
b. Transaction management (securing online payments, prevention of fraud, incidents related to payments and debts);
c. Promoting our Maison on social networks;
d. The sending of a generic newsletter: you have the right to object if you no longer wish to receive it;
e. Analysis purposes: Analyse the performance of our brand on social networks in order to produce statistical analyses (studies of results by market, influence of the brand and analysis of the campaigns implemented).
Analyse your preferences and habits, anticipate your needs from of your consumer profile and your publications/mentions on social networks.
Personalised customer experience: we may provide you with personalised communications by means of email, postal mail, SMS or calls based on the communication preferences you have indicated and your consumer profile (where permitted) to channel preference manager if you have a customer account, otherwise you can contact our customer service (see section “how to contact us”). With your free, specific, informed and unambiguous consent (where required), we use your personal data to send you personalised communications based on your interests (newsletters, offers, invitations and surveys).
In the latter two interactions (‘analysing your preferences and habits’ & ‘providing you with a personalised customer experience’), when we send personalised communications or content, we may use so-called profiling techniques. For the sake of transparency within this Statement, profiling is defined as any kind of automated processing of personal data which consists of using that personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict elements relating to the preferences, interests, behaviour or location of that natural person. In these circumstances, you have the right of opposition, meaning the right to withdraw your consent.
We ensure the legal basis for the processing of your data according to the purpose (s) concerned, which may be, depending on the context in which it is collected:
Your explicit consent: for example, for the purposes of managing our personalized commercial offers, managing your browsing via cookies under the conditions defined by our Cookies Policy, or establishing your consumer profile in applicable cases:
a. The implementation of a contract, for example for your access to your customer account, the processing and follow-up of your orders;
b. A legal obligation when processing is required by law, for example, keeping purchase invoices to prevent fraud;
c. Our legitimate interest: for example, to improve our products and services, to defend ourselves, to secure our tools or to refine our customer knowledge via the tools of our third party partners and in particular to : o to define the personalised profile of our customers based on their interests and to offer them relevant offers from our brand on other websites; o identify audiences that are similar to our target audience (in order to deliver our offers to audiences of people who have similarities to our customers’ profiles).
5. How long we keep them
If you are a customer the data is deleted, either because of a deletion request from you or as part of our obligation to delete data after a certain period of retention, by MLC and not by the other, our e-commerce site, which is shared by the MLC, may recognize you when you create a new account. We keep your personal data only for the time necessary for the purpose pursued. In general, your personal data is stored in our database, as shown below:
a. Data subject: Regular customer (i.e.: having a Customer profile).
Duration: 5 years from the date of the first purchase or account creation.
Specificity: This period will be renewed each time you interact with Maison Le Cygne (for example a purchase or an update of your profile) or your consent to continue to interact at the end of this period.
b. Data subject:
Prospect:
Duration: 3 years from the date of data collection Specificity.
This period will be renewed each time you interact with Maison Le Cygne (e.g. participation in an event) or your consent to continue to interact at the end of this period.
c. Data subject: Client ‘Guest’ (i.e. not having a Client account)
Duration: 5 years from the date of first purchase Specificity.
This period will be renewed each time you interact with Maison Le Cygne (e.g. a purchase).
d. Data subject: customer care (i.e.: complaints or information)
Duration: duration of the processing of the request plus 5 years.
For exercises of rights, under GDPR, the request is kept during its treatment plus 6 years.
e. Data subject: cosmetovigilance:
Duration: duration of the processing of the request plus 10 years in archive.
When we no longer need to use your personal data, it is deleted from our systems and our registers or made anonymous so that it can no longer be identified, subject to retention for archival purposes, claims and litigation management as well as to meet our legal and / or regulatory obligations and / or to respond to requests from authorities authorized to make the request.
6. Who can access your data
Your data is intended for the services of MAISON LE CYGNE concerned by your requests. We ensure that only duly authorized persons can access your personal data when this is necessary for the aforementioned purposes.
We do not share your data on to third parties for commercial purposes.
We are only required to communicate your information if necessary, and if possible in a form that does not allow direct identification to:
a. Other MAISON LE CYGNE entities as well as department stores where you buy our products in order to provide you with identical personalized service worldwide;
b. Our trusted third-party providers, acting as subcontractors according to our instructions and on our behalf only.
For example, we entrust certain services to third parties responsible for delivering a product to you, payment service providers and transaction security against fraud, third parties who assist us in the organization of our events, third parties providing services IT, digital communication and public relations agencies, third parties who assist us in customer care, third parties who assist us in qualitative surveys of our products, programs or services.
a. Third parties, to know your preferences and consumption trends for our programs and services in order to improve visibility, accessibility and performance;
b. Our trusted third party partners assist us in the management of your orders. In particular, we entrust certain services to third parties responsible for delivering a product to you, to payment service providers and to providers ensuring the security of anti-fraud transactions.
Some key examples are listed below:
a. DHL | FedEx | FAN Courier, orders and deliveries (delivery) and any other service provider in management;
b. H88 Web Hosting (website host), Woo Commerce (eCommerce solution) and any other service provider in the management of your e-commerce shopping experience;
c. Payments and transaction security Stripe, Inc. (securing transactions against electronic commerce fraud and payment service provider) and any other payment service provider, verification, or banking provider.
Please note that these partners may act as data controllers; in this case, they have their own privacy policies. We illustrate some examples in the list below:
Third parties wishing to know your interests so that they can build similar audiences and target prospects corresponding to your profile. In the context of this specific processing, these partners may re-use the personal data made available to them to carry out autonomous and distinct targeting for commercial prospecting purposes, for which they are responsible, and are responsible for their legal and regulatory obligations.
Please note that in the context of re-use, these partners act as data controllers. You should therefore refer to their own privacy policies. We illustrate some examples below.
a. Facebook (Privacy policy accessible here https://www.facebook.com/about/privacy/);
b. . Google (Privacy policy accessible here https://policies.google.com/privacy);
c. Instagram (Privacy policy accessible here https://help.instagram.com/519522125107875/).
- Third parties conducting statistics on our performance on social networks on our behalf.
- Third Parties in the event of a change of control or of status or company name, for legal reasons, or with your prior consent.
- Public authorities within the framework of their functions and missions of public interest, such as the establishment, exercise or defence of legal rights.
You can also choose to disclose your personal data to our partners, advertisers and affiliates by following a link to and from their websites. Please note that these websites apply their own privacy policy.
We may also offer you the possibility of using your social media connection data. Please note that in this case, you are sharing your profile information with us. The personal data shared depends on the configuration of the social network platform. Please note that these social networks apply their own privacy policy.
7. How do we protect and ensure the confidentiality of your data
We take all the necessary precautions to guarantee the confidentiality and security of your data and to prevent it from being distorted, damaged, destroyed or from unauthorized third parties having access to it.
We ask our partners to maintain a level of protection similar to ours concerning your personal data. The security measures put in place are evaluated and updated to face new threats and new challenges, as well as new legal requirements in the countries where we operate.
8. How do we process cross – border data flows
Given the presence of MAISON LE CYGNE in many countries around the world and in order to provide you with personalized service worldwide, some of your data may be collected, accessible or stored outside your country of residence. You should be aware that data protection and security requirements differ from place to place and may not offer the same level of protection as those of your country of origin. However, MLC and our group companies have taken measures to guarantee an adequate level of protection of your data, regardless of their location, for example by using standard data transfer clauses, or any other method approved by the European Commission (where data protection legislation is considered to be the most effective in the world) and / or the National Data Protection Authorities. We also ask our third party partners to comply with the applicable data transfer.
9. How are consumer preferences and individual rights treated
In accordance with applicable laws and requirements, MAISON LE CYGNE have put in place measures to guarantee respect for the rights of individuals with regard to personal data that we (or our third parties) have about them. This includes, for example, the right to know the data that we hold about you or to obtain a copy, as well as the limited rights to modify your data, to request erasure or to object to the processing of your data. We encourage those who have given their data to us to keep it up-to-date (for example, if you change your email address, address or telephone number), so that we keep your correct information in our files. We also encourage consumers to update their preferences with us, for example regarding products and frequency of contact, so that we can customize our service to suit your expectations and needs. Finally, we offer individuals the right to withdraw their consent from our programs and offers at any time. To do this, or to exercise any of these other rights, please use or the contact possibilities in the section “How to contact us” below. For people wishing to access their data, we also need authentication to ensure that we do not provide personal data to an unauthorized person.
10. What additional protections are provided for residents of certain regions
MAISON LE CYGNE has adopted the data protection and security practices described in this Statement for all individuals concerned. In addition, we have also identified and taken in to account the data protection and security measures required at local or regional level. This includes, for example, those required for residents of the European Union / European Economic Area under the General EU Data Protection Regulation (GDPR) 2016/679.
In particular, the GDPR provides the following rights:
a. Right to information: you have the right to obtain clear, transparent and understandable information about how we use your personal data and about your rights. You will find all of this information in this Statement;
b. Right of access: you have the right to access the personal data that MAISON LE CYGNE holds about you;
c. Right of rectification: you have the right to have your personal data rectified if it is inaccurate or obsolete and / or to supplement it if it is incomplete;
d. Right to erasure / right to be forgotten: you have the right to have your data erased or deleted. However, this right may be limited by a legal reason or our legitimate interest in keeping your personal data;
e. Right of opposition: you can at any time request to no longer receive our communications relating to our offers, news and events. You can in particular use the hypertext link provided for this purpose in each email or communication that we send to you. You can also request to receive non – personalized communications about our products and services;
f. Right to withdraw consent at any time for data processing based on consent: you can withdraw your consent relating to our processing of your data when this processing is based on consent;
g. Right to data portability: you have the right to move, copy or transfer data from our database to another. This right only applies to the data you have provided, and provided that the processing is based on a contract or your consent and carried out using automated processes
If you wish to contact MAISON LE CYGNE regarding the exercise of your rights, please contact the us (See section “contact us” for contact details).
MAISON LE CYGNE has adopted practices aimed at avoiding collecting or storing information on children under the age of 15, in accordance with laws. If we learn that we have mistakenly collected information from people under the age of 15, we will purge it immediately, except to answer a single question or request from the person, their parent or legal guardian.
11. How to contact us
Please contact us in the manner below if you wish to exercise these rights or if you have questions or complaints regarding the processing of your personal data.
MAISON LE CYGNE
a. By email to:[email protected]
b. By online form: [email protected]
c. By phone: +40 (0) 374 925 749
You also have the right to contact the MAISON LE CYGNE lead data protection authority, the ICO (Information, Commissioner’s Office), at any time, in order to lodge a complaint against MAISON LE CYGNE data protection and privacy practices.
THE NATIONAL SUPERVISORY AUTHORITY FOR PERSONAL DATA PROCESSING
B-dul Magheru 28-30
Sector 1 BUCURESTI
Tel. +40 31 805 9211
Fax +40 31 805 9602
Email: [email protected]
Website: http://www.dataprotection.ro/
We also wish to inform you about the contacts of other authorities in Europe that you can find and contact on the website of the European Data Protection Board: https://edpb.europa.eu/about-edpb/board/members_en