Personal data protection policy

Concerned about the protection of the personal data of its customers and prospects, Les Tropéziennes par M. Belarbi undertakes to follow the provisions of Law No. 78-17 of January 6, 1978 as amended, relating to data processing, files and freedoms as well as those of Regulation (EU) No. 2016/679 of April 27, 2016. 

This Personal Data Policy informs you about the conditions under which DRESCO Company, as data controller, collects and uses your personal data.  

This policy applies to data that may be collected in-store, by mail, by email, by telephone, on our website, or indirectly. In the latter case, the data may, for example, come from partners of Les Tropéziennes par M. Belarbi who have themselves received an agreement for the data to be transferred to us to receive our newsletters or other information. 

Who manages processing your personal data ?

The company DRESCO with a capital of €1,064,910, whose registered office is in PARIS - 20 rue Jean-Baptiste Pigalle (75009), registered at the RCS of Paris under the number 612.045.864, hereinafter referred to as "DRESCO" or "Les Tropéziennes par M. Belarbi". 

What personal data do we collect ?

The data collected by the company DRESCO are the following :

*Mandatory data

Les Tropéziennes par M. Belarbi encourages its customers under the age of 16 not to create a customer account either in shop or on the website. 

Les Tropéziennes par M. Belarbi also undertakes to respect the principle of data minimisation and purpose limitation, which consists of collecting only the data necessary for processing. The data collected must not be reused later in a way that is incompatible with the purpose for which it was collected.

How is this data collected ? 

This data may be collected when you create a customer account on our website, when you order online, when you subscribe to our newsletter, when you contact our customer service, when you browse the Internet, when you take part in a contest, when you post on social media, or when you use our website. 

The information marked with an asterisk is mandatory and must be provided. This information is necessary for the provision of a service or the conclusion of a contract. For example, your postal address is necessary to deliver your order. 

Why is this data collected ? 

Your personal data is collected, used, and processed to: 

• Send advertising {"Purpose 1"}. 
• Conducting market research {"Purpose 2"}. 
• To enable a quotation to be drawn up {"Purpose 3"}. 
• Create a Personal Account on the Site {"Purpose 4"}. 
• Manage orders {"Purpose 5"}. 
• To manage customer and prospect relationships {"Purpose 6"}. 
• Make a sale (buy a product) {"Purpose 7"}. 
• To browse the Site and view products {"Purpose 8"}. 
• Supply after-sales service {"Purpose 9"}. 
• To conduct statistics and studies to personalise, evaluate and improve the services and contents {"Purpose 10"}. 
• To inform Users about our services and those of our partner companies, through targeted marketing and/or promotional offers, with their consent {"Purpose 11"}. 
• Participate in a lottery or competition {"Purpose 12"}. 
• To enable secure authentication {"Purpose 13"}. 

On what legal basis ?

Personal Data is only used to the extent that it is strictly necessary for the Purposes. 

The processing does not meet any regulatory requirement and is based, according to the Purposes, on the legal bases detailed below:

• Processing based on the execution of pre-contractual/contractual measures and Services to which the User has subscribed: Purposes n° 3, 5, 7, 9 
• Processing necessary for the pursuit of the legitimate interests of the Brand: Purposes 2, 4, 6, 8, 12, 13 
• Processing based on prior and express consent when creating the Personal Account and/or subscribing to the Services: Purposes n°1, 10 and 11 
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Where processing is based on consent, the User may withdraw it at any time. 

The same processing may be based on various legal grounds.  

All the information collected by Les Tropéziennes par M. Belarbi is necessary, depending on the purpose, to enable you to browse the Site and subscribe to Services. Failure to respond or inaccuracy in the content may result in the suspension of access to the Site as well as the non-performance or mediocre performance of the Services and other benefits. The Personal Data must therefore be transmitted to the Data Controller unless they are showed as optional. 

To whom is your data destined ?

Les Tropéziennes par M. Belarbi may have to communicate some of the Personal Data: 

 (i) to the internal departments of the Brand strictly authorised in the context of their missions; 

(ii) to advertising platforms and business partners, with your consent where proper; 

(iii) to our service providers, namely:  

• delivery, transport, and payment providers. 
• digital marketing providers. 
• e-commerce platforms. 
• IT outsourcing and cloud solution providers. 

(iv) to the tax authorities where required by the tax obligations applicable to the Sign. 

Subcontractors and service providers must respect the confidentiality and security of Personal Data that may be communicated to them and to use them only in the context of the execution of their subcontracting or service provision mission. 

Les Tropéziennes par M. Belarbi guarantees that the Customer's Personal Data will not be showed to any unauthorised third party without his consent. 

Les Tropéziennes par M. Belarbi does not sell or rent User Data to third parties. 

On the other hand, Personal Data may be transferred to commercial companies for statistical studies and the elaboration of profiles, provided that the User or Customer has given his/her consent. 

Under exceptional circumstances, Les Tropéziennes par M. Belarbi may have to show Personal Data when required by the legal authorities. 

What are your rights and how to exercise them ?

Following the regulations in force concerning the protection of personal data, you have the rights listed below: 

• a right of access, i.e., to obtain from the Data Controller confirmation as to whether Personal Data concerning you are being processed and, where they are, access to the said Personal Data, as well as various information including the purposes of the processing, the category of Personal Data concerning you, the recipient or recipients of the Data, etc. 
• a right to rectify, as soon as possible, Personal Data concerning you that are inaccurate, incomplete, out of date or equivocal, or whose collection and processing are prohibited. 
• a right to object to the processing of Personal Data by the controller or to a transfer of Personal Data, unless there are compelling legitimate reasons which override the interests of the User. 
• a right to the deletion of your Personal Data for the following reasons: 
  - The Personal Data are no longer necessary for the purposes for which they were collected or processed; 
  - You have withdrawn your consent on which the processing was based, and there are no other legal grounds for processing the Personal Data; 
  - You have objected to the processing of Personal Data and there is no overriding interest that justifies the processing; 
  - Your Personal Data has been processed unlawfully; 
  - Your Personal Data must be deleted in order to comply with any legal obligation to which Les Tropéziennes par M. Belarbi may be subject; 
  - Your Personal Data was collected when the data subject was under the age of 16. 
• a right to organise in advance and during your lifetime the conditions under which you wish the Personal Data that Les Tropéziennes par M. Belarbi has collected and processed to be kept and communicated after your death, 
• a right to the portability and recovery of Personal Data allowing you to receive the Personal Data you have transmitted to Les Tropéziennes par M. Belarbi in a structured, commonly used and machine-readable format, and to send them to another controller, without Les Tropéziennes par M. Belarbi, to whom the Personal Data was initially communicated, being able to prevent this. 
• the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you in an equivalent way. 
• the right to lodge a complaint with the CNIL, if you consider that the processing of Personal Data concerning you is a violation of the legislation and regulations in force. 
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If you wish to exercise any of the above rights, you may send your request either: 

*by e-mail to the following address: dpo@dresco.fr 

*by post to the following address: DRESCO SAS, 20 rue Jean-Baptiste Pigalle, 75009 PARIS. 

If you exercise any of these rights electronically, the Personal Data will be supplied electronically by Les Tropéziennes par M. Belarbi, where possible, unless you have specifically requested otherwise. 

How long will your data be step ? 

Personal data is kept by Les Tropéziennes par M. Belarbi for a period that does not exceed the time strictly necessary to achieve the purposes for which it was collected and, in any case, cannot be kept longer than the period showed in the table below: 

At the end of the retention period set by Les Tropéziennes par M. Belarbi, the data is either removed or anonymised for statistical purposes. Intermediate archiving data may be used in case of litigation or pre-litigation. 

When data is removed or anonymised, Les Tropéziennes par M. Belarbi is no longer able to recover it. 

Will you receive commercial offerts ? 

You will receive commercial offers only if you have accepted them. 

Without consent, no communication or solicitation will be sent to you. 

Is your data processed outside the EU / Data transfers outside the EU ?

Your personal data is hosted in France. Wherever possible, Les Tropéziennes par M. Belarbi makes every effort to ensure that personal data transferred to partners or subcontractors is done so within the European Union, or in countries considered "adequate" by the CNIL. 

If Les Tropéziennes par M. Belarbi communicates personal data outside the European Union, measures are taken to ensure that such data will receive help from the same level of protection as that imposed by the European Union in terms of data protection. 

In this respect, Les Tropéziennes par M. Belarbi will ensure that the processing is conducted following this policy and that it is governed by the standard contractual clauses of the European Commission, which make it possible to guarantee an adequate level of protection of the privacy and fundamental rights of individuals. 

Is your data shared with other companies ?

Les Tropéziennes par M. Belarbi will not sell your personal data to partner companies for commercial purposes. 

Your personal data may be shared with some of our partners, subcontractors to: 

• conduct advertising campaigns (send campaigns, optimize mailings, improve campaign targets …), 
• improve customer knowledge from a statistical and geomarketing point of view, 
• conduct satisfaction surveys, 
• improve navigation on the site if you accept the use of cookies, 
• invite you to events, 
• offer you added services such as the recycling of your shoes. 

How do we secure your personal data ? 

In its capacity as Data Controller, Les Tropéziennes par M. Belarbi undertakes to implement and keep at its own expense, proper technical and organisational measures for the processing and security of personal data, by Articles 32 to 34 of the GDPR. 

Les Tropéziennes par M. Belarbi adopts sufficient, proper, and relevant security measures to preserve the security of Personal Data and, to prevent them from being distorted, damaged, or accessed by unauthorised third parties: 

These measures include the establishment of procedures:

• identification. 
• authentication with password strength check, 
• management of authorisations: use of rights limited to the strict needs of the account, 
• Tests and Audit, 
• anonymisation of Personal Data, 
• encryption of Personal Data via an SSL protocol. 
• PAS Security 

Les Tropéziennes par M. Belarbi would like to draw your attention to the creation of an online customer account. 

The creation of a customer account can only be done by entering a personal login and password. Nevertheless, you must protect your account password and not communicate it to anyone. We recommend that you create a strong password (minimum 12 characters with 4 types of characters: upper case, lower case, numbers, punctuation). It is preferable not to reuse the same password for various sites. As a reminder, Les Tropéziennes par M. Belarbi will never ask you for your login, your password, or your bank details by sending you an email. If you receive such a request from us, please do not reply and delete the email at once. 

Delegate for the protection of personal data

Les Tropéziennes par M. Belarbi has a data protection officer who can be contacted at the following address: dpo@dresco.fr 

Right to file a complaint with the CNIL 

Any customer or prospect has the right to lodge a complaint with the competent authority. 

If after having contacted our company, you find that your rights " Computer and Freedoms " are not respected, you can send a complaint to the Commission Nationale de l'Informatique et des Libertés or CNIL, 3 Places de Fontenoy, 75007 Paris.

Data breach

Les Tropéziennes par M. Belarbi undertakes to notify the CNIL of any violation of personal data in the conditions prescribed by the regulations on the subject. 

The customer/prospect will be informed of any data breach that could have a significant impact on them, for example, infringing on their rights or involving a risk to them or those around them. 

How do we use cookies ? 

Browsing data (cookies) are small computer files that are sent to the browser and stored on the hard disk of the client's or prospect's computer, tablet, smartphone, etc. 

Cookies only store the identification code to the exclusion of any other personal information concerning the User. Thus, the deposit of Cookies carried out within the framework of the use of the Website does not make it possible to name the User personally, but it records information relating to the navigation of his/her terminal within the Website (pages consulted, dates and times of consultation, etc.) which Les Tropéziennes par M. Belarbi can read during the User's subsequent visits and send services and offers adapted to the terminal and to the centres of interest. 

Cookies are kept for a maximum of thirteen (13) months from their first deposit in the User's terminal. 

There are diverse types of Cookies that can be implemented in the User's browser by Les Tropéziennes par M. Belarbi to collect information. 

Cookies record and/or read files to obtain information relating to your interaction with the Site, and to your browsing and behaviour: your IP address, the pages visited, the brands you are interested in, the purchases made, etc. 

Thus, depending on the settings chosen and / or subject to consent : 

• Certain cookies known as "technical/functional cookies" are automatically deposited because they are necessary for the provision of the service and therefore essential for navigation. These cookies are not subject to any prior consent, as they allow the site to be displayed and to function correctly. They allow us to memorise data relating to customer accounts, to record shopping baskets, and to ensure the security of accounts or shopping baskets. 
• Advertising cookies, which allow the display of advertisements and targeted content based on the interests and products selected or viewed. 
• The performance analysis and personalisation cookies make it possible to measure and analyse the audience and visits to the site, to set up statistics and volumes of visits and use of the elements making up the site (sections, content visited, route, date and time of consultation, for example) to optimise services, improve the ergonomics of the site and/or improve customer knowledge. 
• Cookies from social networks allowing the sharing of site content with other people (the "like" or "share" button - over which the company has no control and for which the user is invited to consult the privacy policies of these social networks).
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These cookies also allow : 

• to record all information relating to its navigation within the Site, such as in particular all information relating to the pages consulted and the dates and times of consultation on the Site. 
• to improve navigation within the Site to be able to use its various functionalities, and in particular the identification and access of the User's Personal Account. 
• to recognise any User's browser as an earlier registered visitor, to remember any preferences that may be sent when using the Site by their browser. 
• to adapt the presentation of the Site to the display preferences of the User's terminal or any Internet user (language used, display resolution, operating system used, etc.) during their visits, according to the hardware and the display or reading software that their terminal has. 
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Setting cookies 

In this respect, and for Cookies that are not exclusively intended to allow or facilitate navigation or that are not strictly necessary to benefit from the Services, an information banner is displayed when the User/Visitor connects to the Website or when an Internet user visits, in order to inform them, prior to the deposit of these Cookies, (1) of their presence and (2) to allow them, if necessary, to oppose their deposit on their terminal by expressing their refusal in the same way as they are able to express their acceptance. 

Thus, if the User/Visitor does not wish to have data collected on his/her browsing, he/she may choose to deactivate all Cookies that are not essential to browsing the Site via the parameter setting tool provided. This choice will be recorded in the terminal via a Cookie whose purpose is to deactivate the deposit of cookies, which will last for thirteen (13) months. 

Furthermore, the User/Visitor may withdraw his/her consent at any time by configuring the preferences of his/her computer browser or other tools used to browse the Site. 

However, this may result in the deletion of all cookies used by the Internet browser, including those used by other websites, making it difficult or impossible to navigate the Internet. 

For the management of Cookies and its choices, the configuration of each browser is different. It is described in the help menu of the User/Visitor's browser, which will allow him/her to know how to change his/her wishes about cookies.  

Changes and updates to our policy

This policy is available on our website and accessible to all. 

It can be changed or completed by us at any time, according to the evolution of the legal framework, jurisprudential decisions, or recommendations of the CNIL. 

The most important updates may be the subject of a notice on the institutional website of Les Tropéziennes by Mr. Belarbi at the latest at the time of entry into force of the said modifications.

What is the applicable law ? Which courts have authority ? 

The privacy policy is governed by French law. 

Any dispute concerning it shall be brought before the competent French courts.