1. PRIVACY POLICY

POLÈNE prioritizes respecting the right to privacy and protecting the personal data of individuals who visit, browse, and, where applicable, place orders for products on its website accessible at https://eng.polene-paris.com/ (hereinafter the "Website") (hereinafter referred to as "User(s)").

This document aims to inform Users about the conditions under which POLÈNE collects, stores, uses, and processes Users' personal data on its Website ,when you visit our points of sales, when you apply for a job at Polène or when you otherwise interact with or are displayed content about Polène, as required by the data protection laws in the territories in which we do business (hereinafter referred to as the "Privacy Policy").

POLÈNE reserves the right to amend the Privacy Policy at any time, particularly to comply with changes in legislation, regulations, case law, editorial or technical developments, or updates to its services that impact the collection and processing of personal data.

POLÈNE encourages Users to regularly consult the latest version of the Privacy Policy whenever they visit the Website or wish to place an order.

1.1 Data Controller

The processing of Personal Data is implemented by POLENE USA, POLENE USA, INC., a company existing under the laws of New-York, having its registered offices Road 1411 Broadway FL 16, NEW-YORK NY 10018, United States, (hereinafter referred to as "POLÈNE"). 

POLÈNE operates the Website and acts as the Data Controller.

1.2 Collected Personal Data

Personal data refers to information that identifies an individual directly or indirectly, particularly through reference to an identifier or a name.

Personal Data is collected by POLÈNE:

• Directly: when Users voluntarily fill out forms on the Website, such as when subscribing to newsletters or ordering products or even when Users apply for a job at POLENE or when they otherwise interact with POLENE ;

• Indirectly: during Users' navigation on the Website (e.g., connection and navigation data necessary to provide services by POLÈNE). For more information on Cookies and how to change preferences, please refer to the "Cookie Policy."

The Personal Data collected from Users may include:

• Identification Data: name, surname, email address, postal address, phone number;
• Personal Information provided by the User in their account: date of birth, shoe size;
• Order Data: billing information, delivery details, order history;
• Login Data: login credentials, passwords;
• Navigation Data: date and time of connection and/or navigation, browser type, browser language, IP address, location, and geolocation data;
• Financial Data: payment information (e.g., credit card number, expiration date, security code, authorization number);
• Other Information: any information Users provide to POLÈNE in the context of customer service or contact requests.

The provision of Personal Data is necessary to achieve the purposes described in section
1.3. Failure to provide such information may delay or prevent POLÈNE from delivering its products or services.

No sensitive personal data about Users is collected, such as data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sexual orientation

1.3 Purpose of Data Collection

Users’ Personal Data is collected and processed to enable POLÈNE to:

• Provide services available on the Website;
• Create and manage customer accounts;
• Fulfill orders and manage User-related operations (e.g., delivery, tracking);
• Respond to information requests;
• Send newsletters, promotional offers, and special deals;
• Comply with applicable legal obligations;
• Ensure the proper functioning and continuous improvement of services;
• Manage Users' requests to exercise their rights.
  
  

1.4. Data Retention

POLÈNE retains Users' Personal Data only for as long as necessary to fulfill the purposes described above.

1.5 Recipients of Personal Data

The individuals or entities who may access Personal Data include:

• POLÈNE Organization ; 
• Authorized POLÈNE staff;
• Companies hosting Personal Data;
• Authorized subcontractors: newsletter service providers, audience analysis providers, secure payment providers, anti-fraud service providers ;
• Third parties placing functional cookies;
• Judicial or administrative authorities upon request to meet legal obligations.

1.6 International Data Flows

Users' data may be transferred to jurisdictions not providing the same level of data protection as in their jurisdiction, in particular when Data is shared within the POLÈNE Organization. In any event, such data transfers are secured by the execution of data transfer agreements in compliance with applicable laws and regulations.

1.7 Security

As the Data Controller, POLÈNE commits to implementing all necessary technical and organizational measures to safeguard the security and confidentiality of Personal Data, ensuring protection against unauthorized access, alteration, or disclosure.

Users have the following rights regarding their Personal Data :

• Right of access Data
• Right to correct Data : to correct inaccurate, incomplete, or outdated data.
• Right to erasure : to request data deletion under specific conditions.
• Right to restrict processing 
• Right to data portability : to receive data in a machine-readable format or transfer it to another provider.
• Right to object : to object to processing, except where legitimate reasons prevail.
• Right to appeal : with the competent supervisory authority 
• Right to withdraw consent 
• Right to set post-mortem instructions

Users may exercise these rights by contacting POLÈNE via:

• Email: rgpd@polene-paris.com
• Postal Mail: LA CADETTE, 60-62 Rue du Louvre, 75002 Paris

POLÈNE may request additional information, such as proof of identity, to process such requests.

If Users believe their rights have not been respected, they have the right to lodge a complaint with the supervisory authority.

1.8 Links to Third-Party Websites

The Website may provide links to third-party websites. POLÈNE is not responsible for the processing of Personal Data by these third-party websites. Users should consult their respective privacy policies.

2. COOKIES POLICY

Polène and its related entities (collectively, “Polène”, “our”, “we” or “us”) take your privacy seriously and encourage you to understand our use of automated data collection mechanisms in connection with our website, www.polene-paris.com, and its related domains, platforms, social media channels, software applications, mobile applications, services, information, web postings, products and tools (collectively, “Service(s)” or "Website"). As discussed in greater detail within this Cookie Policy, our collection of data through the use of these technologies helps us to provide you with a positive experience and potential offerings when you browse our Services.

Polène uses cookies and pixels as automatic data collection mechanisms that collect information, including in some instances personal information, from users of its Services.  Third parties also place these tools on our Website to collect and process information about our users for various purposes, including for security, for analytics, and to facilitate targeted advertising.  These tools include without limitation: Google reCAPTCHA[AB1] , Google Analytics, Consentmo, Meta Pixel, Shopify, Google DoubleClick, YouTube, LinkedIn, and AdRoll.  Please carefully review the linked information associated with each tool, which is also set forth below.

By visiting our Website, or otherwise using our Services, you consent to Polène’s use of cookies and pixels as detailed in this Cookie Policy.  Please visit our Cookie Chart below for further details about which cookies and pixels we use in connection with our Services.  Except for essential cookies, all cookies and pixels will expire after the associated period identified in the Cookie Chart.  If you have any questions or concerns about our use of cookies, please send us an email at rgpd@polene-paris.com. 

What kinds of technologies are used?

Cookies. 

A cookie is a small text file that we store on your browser or the hard drive of your computer.  They are used to make websites function and to collect information to facilitate more secure, efficient, and customized user experiences.  Cookie use is standard for most websites.

Polène uses four types of cookies in connection with our Services:

·       Strictly necessary cookies. These are cookies that are required for the operation of our Services. These essential cookies are always enabled because our Services won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our Website.  

·       Analytics cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily.

·       Preferences cookies. These are used to recognize you when you return to our Services. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

·       Marketing cookies. These tools record your use of our Services, the pages you have visited and the links you have followed. We will use this information to make our Services and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.

Pixels.

Pixels – sometimes also called "pixel tags," "clear gifs," or "web beacons" – are very small graphic images that help Polène to analyze users' behavior in connection with our Services and to measure the effectiveness of our Services and related advertising.  Polène uses pixel tags on our Website to collect information about users' use of our Services, such as which Website pages you view, which features or links you use, or other such actions you take relative to our Services.  Types of information that pixels may gather includes the IP address of the device you use to access the Services, date and time information, immediate browsing history, and technical information about your device such as the browser type and operating system.  Pixels can also allow us, or third parties, to place cookies on your device.

What is the purpose of these technologies?

We use cookies and pixels in connection with our Services for the purposes of furthering security, customization, analytics, and advertising.  We, or our service providers on our behalf, use the technologies described above for the following purposes.

Security.

Cookies support our Services' security features, helping to make your experience with our Services more secure.  For instance, we can use cookie data to help identify malicious or illegal behavior or other activity which violates our Terms of Use.

Customization.

Cookies allow us to retain your preferred settings for our Services and deliver a customized experience to you, such as by saving your user name and other profile information, previous searches, and information regarding your previously viewed products or services.  By retaining this information, we can present you with information that is consistent with your prior use of our Services and likely interests.

Analytics.

We want to provide you with features that interest you.  Cookies allow us to determine which aspects of our Services are more (or less) popular with our users, including our websites, e-mails, advertisements, or other content.  We can use that information to understand and improve upon our Services, as well as to develop new features to serve you better.  Such usage information forms the basis for reports generated to provide us aggregated information about the utilization of our Services. 

Advertising and Social Media.

Marketing cookies and pixels permit more efficient delivery of advertisements to you, regarding products or services in which you are more likely to be interested.  They also help us track the effectiveness of our marketing efforts.  Social media cookies and pixels can track your browser activity across other sites and create a profile of things that are likely of interest to you.

Do third parties use these technologies relating to Polène’s products and services

Yes.  Please note that, as identified in our Cookie Chart, third parties also use cookies in connection with our Services. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services.  Select third-party technologies, as reflected in the comprehensive Cookie Chart, include, but are not limited to, the following:

Google reCAPTCHA v3.

We use “Google reCAPTCHA v3” (hereinafter “reCAPTCHA”), provided by Google, Inc. ("Google"), on our Website.  The purpose of reCAPTCHA is to keep our website as secure as possible by checking whether data that enters our system – for example, through a web form – is provided by a human individual as opposed to spamming software or other robot.  To make this determination for this purpose, reCAPTCHA collects and reviews various aspects of the Website user's activity.  This assessment automatically begins when our user enters the Website.  For the purpose of confirming human activity, reCAPTCHA assesses various information that it collects – including, without limitation, IP address, browser information cursor activity, and time spent on the Website.  reCAPTCHA will also place an additional cookie in your browser upon its assessment of your activity and take a snapshot of your browser window.  Data collected during the analysis is forwarded to Google.

Please note that the reCAPTCHA collection, assessment, and other processing runs completely in the background.  While reCAPTCHA processing is noted for our users both here, Website visitors are not informed that an analysis is taking place when it occurs.  As opposed to former CAPTCHA versions, which required website visitors to identify images, solve puzzles, or check a box, reCAPTCHA assesses and scores user input for human origin without any such affirmative behavior from the user. 

Our goal in using the reCAPTCHA tool on the Website is to protect the Services, and users of the Services, from bots, spam, and other such unapproved and potentially malicious activity.  If you want to prevent any data about you and your behavior to be transmitted to Google, you must log out of Google and delete all Google cookies before visiting our Website or using the reCAPTCHA software.  Please visit the following page to obtain more information about reCAPTCHA: https://developers.google.com/recaptcha/.  Additional information on Google reCAPTCHA be found here, https://www.google.com/recaptcha/intro/android.html, and Google's privacy policy can be found here: https://www.google.com/intl/de/policies/privacy/. 

Google Analytics.

Our Website uses Google Analytics, provided by Google. This web analytics program collects and generates information, through cookie placement, about your use of the Website.  Google will use this information to evaluate your use of our Website, to compile reports on Website activity and to provide us with other services related to Website activity and internet usage.  The IP address provided to us by Google Analytics will not be merged with other data that Google provides to us.[AB4] 

If you would like to prevent Google Analytics from collecting your data, you can prevent this collection by utilizing the opt-out tool that Google makes available at the following site: http://tools.google.com/dlpage/gaoptout. If you use this tool, an opt-out cookie will be placed to prevent Google Analytics from collecting your information.  Google's Terms of Use and privacy policy can be found on this page: https://policies.google.com.

Consentmo.

Our Website uses Consentmo, a cookie consent management platform provided by Consentmo. Consentmo places cookies on your device to manage and record your consent preferences for various types of cookies and tracking technologies used on our Website. These cookies remember your choices regarding which categories of cookies you have accepted or declined, ensuring that your privacy preferences are respected during your visit and subsequent visits to our Website. Consentmo also collects data about consent interactions, such as when and how you provided or withdrew consent, to help us comply with privacy regulations and maintain proper consent records. The platform may also gather analytics data about consent banner performance and user interactions to improve the consent experience. Consentmo's privacy policy, which details how they handle consent-related data, can be found at https://www.consentmo.com/privacy-policy-terms-of-service/en. You can modify your cookie preferences at any time through the cookie consent banner or privacy settings available on our Website.

Meta Pixel.

We use Meta Pixel, operated by Meta Platforms, Inc. ("Meta") on our Website.  Meta Pixel is a portion of code integrated into our Website which allows Meta to identify our Website users as targets for advertising that Meta offers (collectively referenced here as "Meta ads," which includes advertisements commonly known as "Facebook ads").  We use this technology to display our Meta ads only to users of Meta services (e.g., Facebook) who have shown an interest in our services or share interests in certain topics or products, which can be determined on the basis of which web sites you visit, which information we transmit to Meta through the Meta Pixel. Meta Pixel also helps us understand how effective (or not) our Meta ads are, by allowing us to see whether our users have been redirected to our Services after clicking on a Meta ad.  Where this occurs, Meta Pixel further allows us to identify, with Meta's help, broadcast audiences that are similar to users using our Services in this way.  It also helps us to obtain detailed statistics about the use of our Website for market research purposes.

When users visit our Website, the Meta Pixel directly connects to servers operated by Meta or its affiliated companies, such as Facebook. That server is then notified that you have visited our Website and Meta records this information to your personal Meta-associated account (e.g., your Facebook account).  Meta may also use this information for its own promotional purposes, for instance, allowing Facebook and its partners to show you advertisements on and outside of Facebook, in accordance with Facebook’s Data Usage Policy, available at https://www.facebook.com/policy.php.  You can disable this function as shown at https://www.facebook.com/settings?tab=ads.

Shopify.

Our Website uses Shopify, an e-commerce platform provided by Shopify Inc. Shopify cookies are placed on your device to enable essential e-commerce functionality, including maintaining shopping cart contents, processing payments, and managing customer accounts. These cookies allow Shopify to identify returning customers, remember their preferences, and provide a seamless shopping experience across sessions. Shopify also uses cookies to collect analytics data about customer behavior on our Website, including pages visited, products viewed, and purchase patterns, which helps us optimize our online store and improve our services.

When you interact with our Shopify-powered Website, information is transmitted to Shopify's servers to facilitate transactions and store management. This may include personal information such as your name, email address, shipping address, and payment details when you make a purchase. Shopify may also use this information for fraud prevention, security purposes, and to provide customer support services. Additionally, Shopify may analyze aggregated and anonymized data to improve their platform and services. Shopify's privacy policy, which governs their collection and use of your information, can be found at https://www.shopify.com/legal/privacy. You can manage your cookie preferences through your browser settings, though disabling certain Shopify cookies may impact the functionality of our online store.

Google DoubleClick. 

Our Website uses Google DoubleClick, an advertising service provided by Google. DoubleClick places cookies on your device to serve targeted advertisements and measure advertising effectiveness. These cookies collect information about your browsing activity across websites to create advertising profiles and deliver personalized ads based on your interests. DoubleClick also helps us track conversions and understand which advertisements lead to desired actions on our Website. You can opt out of DoubleClick's advertising cookies by visiting Google's Ads Settings at https://adssettings.google.com or by using Google's opt-out tool available at https://tools.google.com/dlpage/gaoptout.

YouTube.

Our Website embeds YouTube videos, provided by Google. When you view these embedded videos, YouTube places cookies on your device to track your viewing behavior, preferences, and interactions with video content. These cookies help YouTube provide personalized video recommendations and improve their service quality. YouTube may also use this information for advertising purposes, showing you targeted ads on YouTube and other Google services based on your video viewing history. YouTube's privacy policy can be found at https://policies.google.com/privacy, and you can manage your YouTube privacy settings at https://myaccount.google.com/privacy.

LinkedIn.

Our Website uses LinkedIn tracking technologies, including the LinkedIn Insight Tag, provided by LinkedIn Corporation. These cookies collect information about your visits to our Website and interactions with our content to enable LinkedIn advertising and analytics services. LinkedIn uses this data to show you targeted advertisements on the LinkedIn platform and to provide us with insights about our Website visitors who are LinkedIn members. The information collected may include your LinkedIn profile data when you're logged into LinkedIn. You can control LinkedIn's use of your data for advertising purposes through your LinkedIn privacy settings at https://www.linkedin.com/psettings/advertising, and LinkedIn's privacy policy is available at https://www.linkedin.com/legal/privacy-policy.

AdRoll.

Our Website uses AdRoll advertising services, provided by NextRoll, Inc. AdRoll places cookies on your device to enable retargeting and cross-device advertising campaigns. These cookies track your browsing behavior on our Website and across other sites in the AdRoll network to serve you personalized advertisements on various platforms and devices. AdRoll uses this information to help us reach potential customers who have previously shown interest in our products or services. You can opt out of AdRoll's advertising cookies by visiting their opt-out page at https://app.adroll.com/optout or through the Digital Advertising Alliance's opt-out tool. AdRoll's privacy policy is available at https://www.adroll.com/about/privacy.
 

Cookie Chart