Data Processing and Privacy Policy

DATA PROCESSING AND PRIVACY POLICY

Version: May 2018

INTRODUCTION

This Data Processing and Privacy Policy covers côte&ciel’s treatment of personal information that côte&ciel gathers when you are on our website.

We are committed to safeguard the privacy of individuals with respect to your personal data to maintain customer trust.

This Privacy Policy does not cover information collected elsewhere, including without limitation offline and on sites linked to and from the website as well as the practices of third parties that côte&ciel does not control or own, or individuals that côte&ciel does not employ or manage.

In addition to reviewing this Privacy Policy, please read our Terms and Conditions. Your use of our website constitutes agreement to its Terms and Conditions as well.

Continued access of our website by you will constitute your acceptance of the changes or revisions to the Privacy Policy.

This policy sets out the basis on which we collect and process your personal data through your use of our website and/or signing up for newsletters, competitions and other marketing activities either in-store or online.

Any changes we make to this policy in the future will be posted on this page and, if appropriate, notified to you by email so please check this page regularly.

INFORMATION ABOUT US

côte&ciel is the controller responsible for your personal data (referred to as "we", “us” or “our” in this privacy policy). Our registered office is at 3/F 102 Austin Road, Tsim Sha Tsui Kowloon, Hong Kong. If you have any questions about this privacy policy, the use of your personal information, or your dealings with our website you can contact us at info@coteetciel.com.

YOUR PERSONAL DATA

Information You Provide to Us

You will provide some or all of the following information to us when you purchase goods from our website, register a customer account with us, contact us or sign up for newsletters and other marketing activities, either in one of our shops or online:

• Your Identity and Contact Details - includes your name, email address, home postal address/billing address, delivery address (if different), and your contact telephone number;

• Your Payment Details - your credit card details or PayPal information; we will not disclose any information that you provide to us except in accordance with the provisions of this Privacy Policy

• Your Profile Data - if you register a customer account, this includes the profile you create to identify yourself when connecting to our website (including your username and password) and other data about purchases and your personal preferences; and

• Additional Personal Details - At your option, you can also provide additional personal information to us such as your date of birth, gender, product preferences and interests. This additional information would only be collected and stored by us for the purpose of analysing sales to help us understand and improve our business and for the purpose of any direct marketing which you may have expressly given your consent to.

  Please Note: It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

  We do not collect any categories of sensitive personal data and this website is not intended for children so we do not knowingly collect data relating to children.

  Information We Collect When You Use Our Website

  As you interact with our website we also automatically collect usage and technical data (described below) about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

  Usage Data - includes details of products and services you have purchased from us, and information about how you use our website.

  Technical Data - includes:

• your Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;

• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse- overs), and methods used to browse away from the page, mobile applications traffic data, weblogs and other communication data;

• if you use a mobile device to access our website, the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone settings);

Other - We may also receive information from third parties we work closely with such as online fashion retail platforms, delivery services, credit reference agencies and fraud prevention agencies.

COOKIES

In order to distinguish you from other users - especially other users on the same network as you - we need to use cookies to track your specific computer. Specifically, we use cookies to save your preferences, keep track of advertisements, and remember your shopping cart items.

Cookies and similar technologies are used to identify your device for the following purposes:

Strictly necessary cookies - These essential cookies are set throughout our website and are required for the operation of our website to:

• Allow our web server to determine whether the cookies setting on your web browser has been enabled or disabled. This allows us to know whether data can be collected from your web browser;

• Temporarily allow you to carry information between pages of our website to avoid having to re-enter that information;

• Temporarily identify your device after you have logged in to a secure page on our website so that our web server can maintain a dialogue with your web browser in order for you to carry out certain activities.

  Analytical/performance cookies - These are used to help us improve our website by:

• Tracking your visits to our website and recognizing your web browser when you are a repeat visitor so that we can gather statistics on new and repeat visitors to evaluate site effectiveness.

Functionality cookies - These are used to recognize you when you return to our website. This enables us to:

• Personalize our content for you and remember your preferences (for example, your choice of language and region);

• Store your login and other preferences so you do not have to re-enter that information when you return to the website.

  Targeting/advertising cookies - These cookies record your visit to our website, your response to our online advertisements, track the pages you have visited and the website links you have followed. We use this information to:

• Make our website more relevant to your interests;

• Provide online advertisements or offers on our website or third-party websites

which are most likely to interest you;

• Evaluate the effectiveness of our online marketing and advertising programs.
• The above cookies may be placed on your device by us or by third parties on our

behalf (for example, advertising networks and providers of external services like web traffic analysis services). No personally identifiable information about you is collected or shared with third parties as a result of this research.

Most web browsers are initially set up to accept cookies. You can choose to 'not accept' cookies by changing the settings on your web browser but if you block all cookies, including strictly necessary cookies, you may find that certain features on our website will not work properly.

WHAT WE USE YOUR PERSONAL DATA FOR

Data protection law allows us to collect, use, store and transfer personal information if we have one or more of the following purposes for doing so:

• To fulfill a contract with you; or

• Where necessary to comply with a legal or regulatory obligation; or

• Where necessary for our legitimate interests (or those of a third party) provided

  your interests and fundamental rights do not override these interests); or

• For other reasons where you have expressly consented to those purposes.

  Below are the ways we will use your personal data to fulfill your contract and/or for our legitimate interests:

• Processing your order, including taking payment, supplying products and any after sales services such as cancellations and returns;

• identify verification and credit checking;

• keeping you updated on the progress of your order, we will usually communicate with you about your order by email, but we or our couriers may also contact you by phone;

• where you have registered with us, processing and administering your account;

• processing information required for competition, promotion or survey entries by

  you;

• allowing you to participate in interactive features of our service if you choose to do

  so;

• analysing sales to help us understand and improve our business;

• administration, analysis and assessment of our website and its performance, to

  understand and develop our business and for the improvement and optimisation of

  our website and user experience; and

• as part of our efforts to keep our website and safe and secure.

  Direct Marketing We need your consent for direct marketing communications. If you have expressly given your consent to receive direct marketing from us, whether via our website or in store, we may use the information you have given us for:

• delivering direct marketing, advertising and updates from us to you, such as telling you about forthcoming events, products, services, offers, updates and information about us;

• measuring and understanding the effectiveness of advertising we serve to you and others; and

• making suggestions and recommendations to you and other users of our website and our apps about goods or services that may interest you or them.

  At any time you can opt out of direct marketing or change your preferences.

  WHO WE SHARE YOUR PERSONAL DATA WITH

  We may share your information with our selected third parties for the purposes referred to above. For example:

• Payment Acquiring Services to process your payment;

• Delivery and Courier Companies to supply your order;

• Credit Reference & Fraud Prevention Agencies for credit checking and identity

  verification;

• Analytics and search engine providers that assist us in the improvement and optimisation of our website and apps;

• Build and hosting service providers that help us to maintain the software that runs our website. They provide us with reporting statistics, and serve cookies on our behalf to enable any website or apps personalisation and sign-in functionality.

• Where you opted in to direct marketing, third party advertisers, affiliate marketing agencies and advertising networks engaged by us to select and serve relevant communications to you on our behalf.

  We require all third parties engaged by us to respect the security of your personal data and to treat it in accordance with the law. Such third parties are only allowed to process your personal data in accordance with our instructions, and not for their own purposes.

  From time to time, we may ask you if you would like to be contacted by other selected third parties, such as part of a joint promotion or a collaboration. If we do this, we will also provide you with a link to that third party’s privacy policy to help you decide whether or not you wish to be contacted by them. If you do consent to this (by an express opt in), that third party would be the data controller in respect of any activity by them that you have consented to.

  Links to Other Organisations

  Our website and/or apps may, from time to time, contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

  OPTING OUT OF MARKETING AND PREFERENCE UPDATES

If you no longer wish to receive direct marketing and updates from côte&ciel you can unsubscribe at any time by clicking on the link in the footer of the email. You can also amend your preferences within the email preference centre. Alternatively you can contact customers services vie email info@coteetciel.com.

OUTSIDE EEA - DATA STORAGE & TRANSFER

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) to work with third parties who we use to help us carry out the purposes referred to above or to comply with a legal duty.

Whenever we transfer your personal data out of the EEA, we will make sure an adequate level of protection is afforded to it by using one of the following safeguards:

• We may transfer your personal data to countries that have privacy laws which give the same level of protection for personal data as the EEA;

• We may use contract clauses with recipients which mean they must protect your personal data with the same level of protection as it has in the EEA;

• We may transfer personal data to organisations if they are part of the Privacy Shield framework which requires them to provide similar protection to personal data shared between European countries and the US.

  SECURITY OF YOUR PERSONAL DATA

  Our website has appropriate security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. All information you provide to us is stored on secure servers. We have also put in place procedures to deal with any suspected personal data breach.

  Where you have chosen a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you to choose an effective, secure password and not to share your password with anyone.

  We recommend only connecting to secure wireless networks that you trust to reduce the risk of unauthorised people intercepting your online activity. Beware of the risks of using public wifi.

  If you receive an email purporting to be from côte&ciel asking for personal data, please do not respond to the email but please let us know that this has happened so we can check whether the email is genuine.

  HOW LONG WE KEEP YOUR PERSONAL DATA

  We will keep your data for as long as you are a customer and thereafter we may keep it for longer in order to respond to any questions or complaints and to maintain necessary records to satisfy legal, accounting or reporting requirements. We may also keep your data for research or statistical purposes.

YOUR RIGHTS

You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using it if there is no need for us to keep it. Please let us know if you think we should not be using it, but please be aware that there may be legal or other official reasons why we need to keep or use your information.

Your rights under data protection laws in relation to your personal data are briefly summarised below, and you can exercise these rights by emailing us at info@coteetciel.com. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will tell you about, if applicable, after receiving your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

• Request restriction of processing of your personal data. You can ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; © where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time if we are relying on your consent to process your personal data (such as direct marketing and cookies). This won’t affect any processing already carried out before you withdraw your consent or processing under other grounds. If you withdraw your consent, we may not be able to provide certain products or services to you.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data and we try to respond to all requests within one month.

If you have any questions or require any more information please contact us at support@coteetciel.com