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This policy explains how CHIARA COLOMBINI collects and uses the personal data of visitors, customers and prospective customers of www.chiaracolombini.com, and the rights available to them.

1 DATA CONTROLLER

The data controller is CHIARA COLOMBINI, a French single-member limited liability company with share capital of EUR 10,000, registered with the Versailles Trade and Companies Register under number 797 711 744, whose registered office is at 18 rue au Bouët, 78490 Les Mesnuls, France.

Telephone: +33 (0)1 85 77 21 00

For any question or request concerning your personal data: contact@chiaracolombini.com.

2 PERSONAL DATA WE PROCESS

Depending on how you use the website, we may process:

·       identity and contact details, including title, name, company, postal address, email address and telephone number;

·       customer account, trade project and communication preference information;

·       orders, quotations, products, deliveries, returns, claims, invoices and customer-service correspondence;

·       information required to process payments and prevent fraud; CHIARA COLOMBINI does not retain your card security code;

·       online and technical data, including IP address, session identifiers, device and browser, pages viewed, events and interactions, subject to your cookie choices;

·       newsletter subscriptions, message openings and interaction with our communications, where permitted by law;

·       the contents of customer-service requests and, where relevant, photographs submitted in support of a claim.

We do not ask you to provide special-category data under the GDPR. Please do not include such data in free-text fields or attachments.

3 PURPOSES LEGAL BASES AND RETENTION PERIODS

Purpose

Legal basis

Main data

Indicative retention

Accounts, orders, quotations, payments, delivery, returns and after-sales service

Contract and pre-contractual steps

Identity, contact details, orders and correspondence

Contractual relationship, followed by archiving for applicable limitation periods

Invoicing and accounting or tax compliance

Legal obligation

Orders, invoices and payments

10 years for accounting records

Enquiries and complaints

Pre-contractual steps, contract or legitimate interests

Contact details and correspondence

Time needed to handle the matter, followed by applicable limitation periods

Fraud prevention, security and legal claims

Legitimate interests and legal obligations

Technical, order and incident data

Time needed to investigate, then for any dispute or limitation period

Newsletters and direct marketing

Consent or the applicable existing-customer exemption

Contact, purchase and engagement data

Until consent is withdrawn, or 3 years after the last active contact for prospects

Personalisation and non-exempt audience measurement

Consent

Online data and identifiers

As stated in the Cookie Policy and within applicable legal limits

Performance measurement, statistics and website improvement

Consent or legitimate interests for a strictly exempt solution

Online and technical data

According to tool settings and applicable legal limits

Data needed to establish or defend a right or comply with a legal duty may be placed in restricted intermediate archives. Retention may be extended where required by a dispute, legal obligation or competent authority.

4 REQUIRED INFORMATION

Fields marked as mandatory are needed to deal with your request or fulfil your order. Without them, we may be unable to create an account, issue a quotation, conclude a sale, arrange delivery or answer your enquiry. Other information is optional.

5 RECIPIENTS AND SERVICE PROVIDERS

Personal data may be accessed, on a need-to-know basis, by authorised CHIARA COLOMBINI staff and by providers required to operate the website and fulfil orders, including:

·       hosting, maintenance and PrestaShop technical providers;

·       payment and fraud-prevention providers;

·       carriers and logistics providers, including GLS, UPS, FedEx, Dachser, Colissimo and any carrier selected for the order;

·       search and customer-experience services, including Doofinder;

·       customer communication and relationship tools, including Klaviyo;

·       analytics, advertising and tag-management services, including Google and Meta, subject to your consent;

·       customer-review services, including Trustpilot;

·       legal advisers, accountants, insurers, banks and public authorities where required by law or necessary to protect our rights.

Recipients receive only the data needed for their role and act either in their own legal capacity or under our contractual instructions.

6 INTERNATIONAL TRANSFERS

Some providers may process data outside the European Economic Area. Where this occurs, CHIARA COLOMBINI ensures that the transfer is based on an adequacy decision, the European Commission’s standard contractual clauses or another safeguard recognised by applicable law. You may request further information using the contact details in section 1.

7 YOUR RIGHTS

Depending on the circumstances, you have rights of access, rectification, erasure, restriction, objection and data portability. Where processing relies on consent, you may withdraw it at any time without affecting processing that occurred before withdrawal. You may also give instructions concerning your personal data after your death, as provided under French law.

To exercise your rights, contact us using the address in section 1 and state the nature of your request. We may request proof of identity only where we have reasonable doubts about your identity. You may also lodge a complaint with the French data protection authority, the CNIL, at 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, or at www.cnil.fr.

8 DIRECT MARKETING

You may unsubscribe from newsletters at any time by using the link in each message or contacting us. Withdrawing from marketing does not affect communications strictly necessary to fulfil an order or provide after-sales service.

9 COOKIES

Non-essential cookies are used only after you have given consent. You may accept, refuse or change your choices at any time through the ‘Cookie settings’ link on the website. Please see our Cookie Policy for further details.

10 SECURITY AND UPDATES

CHIARA COLOMBINI uses technical and organisational measures appropriate to the risks to protect personal data. We may update this policy to reflect changes in law, technology or our processing.