PRIVACY POLICY

AS PART OF YOUR BROWSING ON PIMKIE.COM AND FOR ANY ORDER YOU ARE LED TO MAKE WITH US, WE STRIVE TO GUARANTEE THE CONFIDENTIALITY AND PROTECTION OF YOUR PERSONAL DATA PURSUANT TO APPLICABLE REGULATIONS.

VIA OUR PIMKIE.COM ELECTRONIC TRADING WEBSITE, WE TRADE IN A LARGE NUMBER OF COUNTRIES IN THE WORLD. IN ORDER TO PROCESS YOUR ORDERS AND CLAIMS CONCERNING ORDERS, WE WORK WITH GLOBAL-E QUI EST WHO IS NOTABLY RESPONSIBLE FOR RECEIPT AND DELIVERY OF PRODUCTS WHICH YOU HAVE SELECTED.

THIS PRIVACY POLICY ONLY CONCERNS PROCESSING UNDERTAKEN BY PIMKIE AND/OR ITS SUB-CONTRACTORS FOR ITS OWN BEHALF WITH THE SOLE PURPOSE OF PROVIDING YOU WITH PRODUCTS AND SERVICES PURCHASED AND/OR FOR WHICH YOU HAVE GRANTED CONSENT. THE GLOBAL-E PRIVACY POLICY IS ALSO APPLICABLE FOR PROCESSING OPERATIONS FOR WHICH IT IS JOINTLY PROCESSOR, SUCH AS THOSE CONCERNING PURCHASES, DELIVERY, TRANSACTION AND ENQUIRIES PROCESSING. IT IS AVAILABLE ON THE FOLLOWING LINK. FOR ANY ISSUE CONCERNING PROCESSING WHICH IS NOT COVERED, WE REQUEST THAT YOU PLEASE CONTACT GLOBAL-E DIRECTLY AND/OR CONSULT THEIR PRIVACY POLICY.

THIS POLICY INFORMS YOU ABOUT THE MANNER IN WHICH PIMKIE AND ITS SUB-CONTRACTORS USE YOUR PERSONAL DATA.

ARTICLE 1: PERSONAL DATA

1.1 WHAT IS PERSONAL DATA?

The term "Personal Data" refers to all information which allows for direct or indirect identification of a natural person: name, postal address, telephone number, email address or IP address, date of birth, etc.

1.2 IDENTITY OF DATA CONTROLLER

Personal Data is collected and processed by DIRAMODE, a simplified joint stock company, with share capital of 9,752,365.50 Euros, entered on the Lille-Métropole Trade and Companies Register under number 301 571 931 and located at 1 rue John Hadley, 59654 Villeneuve d'Ascq as Data Controller, hereinafter referred to as "Pimkie".

1.3 COLLECTION AND PROCESSING OF PERSONAL DATA

- WHAT PERSONAL DATA IS COLLECTED?

PIMKIE may notably be led to collect your surname, forenames, date of birth, postal address, email address, telephone numbers, bank details (provided by the client in the event of a return), browsing data, order history, preferences and hobbies, products consulted, elements pertaining to order supervision.

Global-E may also be led to collect some of your data in the framework of the service undertaken on behalf of Pimkie. This notably concerns your order, delivery address, bank details (in the event of return of products purchased), information which you send when contacting the customer service team concerning any return request, reimbursement, claim, etc., your geographical position.

Web users or the Client undertake to provide PIMKIE and Global-E with true and sincere information which is not invalid. The communication of any incorrect data runs contrary to the general terms and conditions of sale.

- IN WHAT BASIS AND FOR WHAT PURPOSES IS DATA COLLECTED AND PROCESSED?

European data protection regulations allow Pimkie to use Personal Data of the Client or web user only if Pimkie has a valid legal basis. Consequently, to process the personal data of Clients or web users, Pimkie basis itself on either the consent of people concerned, or where necessary performance of a contract (e.g.: processing an order); or where it is in the legitimate interests of Pimkie (which may not run contrary to rights and liberties of the Client or the web user); or where it is necessary for respect of a legal obligation (e.g.: retention of invoices). Consequently, Pimkie uses your data indicated above for the following purposes

Where you give us your consent concerning operations offered (options may differ in line with the country):

  • - Subscription to and management of the loyalty programme;
  • - Electronic publication of the Client till receipt;
  • - Issuing commercial canvassing material: Advantages, commercial offers and information about PIMKIE may be sent to the Client or web user who grants consent, in respect of regulations applicable, in line with the Personal Data sent, by email, SMS/MMS, or via social networks. There is an exception in such instance as the Client or web user, without having given prior consent, may however receive commercial canvassing insofar as it has already made a purchase from Pimkie and that the object of canvassing is to offer similar products or services;
  • - The issue of emails inviting the newsletter subscriber to take part in surveys or competitions;
  • - The registration of cookies as supported by the Pimkie Cookies Policy;
  • - Sharing and populating Data with Pimkie Commercial Partners; subject to prior consent, the Client or web user may receive commercial offers from PIMKIE Commercial Partners (fashion firms for women, men and children) by email or sms; PIMKIE will be led to collaborate with Commercial Partners (fashion companies for men, women, children) for management of marketing and customer relations, so as to make personalised or generic offers. For this purpose, PIMKIE may receive and send its Commercial Partners and sub-contractors some of your personal data, as well as any modifications you have made concerning Personal Data for improvement of client knowledge. This exclusively concerns non electronic contact data (postal address) and profile information (notably purchasing habits, civil status, preferences, areas of interest) which you sent. PIMKIE will also be led to collaborate with advertisers (Facebook, Google, Critéo etc.) so as to make personalised offers and/or undertake analysis of statistics and studies. For this purpose, PIMKIE may notably send personal information such as purchasing habits or browsing data. This sharing of Personal Data is undertaken in strict respect of local and European regulations in force pertaining to personal data.
  • - Geographic location: PIMKIE may be led to process geographical location data notably to allow web users or Clients to locate their country, currency of the country, nearest stores or receive targeted advertising where the Client or web user is close to a Pimkie store. The geographic location function may only be activated with the consent of the web user or Client who expressly accepts to provide Data by correctly setting up the communication terminal.
  • - On other occasions, where we request consent.

Where processing is necessary in order to perform a contract or take measures in relation to the latter. This is notably applicable when you purchase our products or when you take part in a competition. This includes:

  • - Management of commercial relations between web users or the Client and PIMKIE;
  • - Approval of orders and payment receipt;
  • - Processing and supervision of Client order(s);
  • - Delivery of products;
  • - Management of client claims (comments, communication, returns and reimbursement) as well as customer satisfaction (collection of client opinions on products and performance of customer service);

Where processing is necessary for the legitimate interests of Pimkie, as listed below and where our interests are not replaced by your rights. This includes:

  • - Population of data: as well as the Personal Data we collect, we populate your profile in our databases in line with purchases made on our Website so as to make personalised offers;
  • - Performance of statistical analysis, studying purchase habits, and segmentation of clients for improvement and knowledge of Clients so as to make personalised offers to web users and the Client;
  • - Supervision of use and improvement of our website;
  • - Location of web users via browsing data so as to offer the latter the country of delivery as well as payment currency.

For legal purposes

  • - In response to requests from authorities in the framework of investigations;
  • - For all legal purposes which may be applicable.

Some Personal Data, indicated by an asterisk, must be collected by PIMKIE so as to offer you the very best client experience on the Website, to allow for processing of the Client order, and where applicable to complete subscription to the loyalty programme.

For processing indicated hereinabove and in particular those requiring consent, the Client or web user may withdraw its consent at any time. The Client or web user also has the right to object, at any time, to personalised canvassing and/or issue of Personal Data by Pimkie to third parties. In the event of withdrawing consent or opposition, the Client or Web user will no longer receive, depending on the case, commercial requests or personalised offers. The Client or web user may exercise its right of opposition in the following manner:

  • - for commercial emails by unsubscribing using the "unsubscribe" link present in each email;
  • - for commercial SMS by sending "STOP SMS" to the number indicated in the message;
  • - or upon simple request with PIMKIE in line with the following terms and conditions:
    1. To the following postal address:
    PIMKIE / DIRAMODE
    Customer Service/Personal Data Service
    1 rue John Hadley
    59654 VILLENEUVE D'ASCQ
    France
    2. Or to make a request via: Contact Us

1.4 RECIPIENTS OF PERSONAL DATA

Data is intended for DIRAMODE and companies held directly or indirectly by DIRAMODE as defined by article L233-3 of the Commercial Code, and notably SAS Promotion du Prêt à porter (PPP), to whom data may be sent for management or sub-contracting in the framework of commercial activities of PIMKIE group.

Data may also be transferred to sub-contractors of the Data Controller. The Client confirms acceptance that automated operations and processing of Personal Data undertaken at the time of client account creation and subsequent to client account creation as well as data processing operations in the event of order confirmation may be undertaken by PIMKIE and/or any other sub-contractor and/or any other jointly processor directly or indirectly related to PIMKIE. Sub-contractors and jointly processors concerned are notably payment service providers or payment security service providers and delivery agents so as to guarantee processing of the order and any other sub-contracting required for proper performance of various services proposed to the Client.

As indicated in this Privacy Policy, Pimkie confers orders validation, payment security services, order deliveries and customer claim processing (management of client claims, returns and reimbursements) to Global-E, as jointly processor. Consequently, in some instances, Pimkie is led to transfer data to the latter and in other cases, Global-E is led to directly collect this data from clients.

Finally, PIMKIE may be led to disclose information concerning Clients pursuant to legal requirements, to any administrative authority or legal authorities holding jurisdictional competence.

1.5 DATA TRANSFER OUTSIDE OF THE EU

Personal Data of the Client or web user is likely to be transferred outside of the EU to our sub-contractors so as to provide you with services for which you entered into contract with Pimkie and/or for which you have granted consent. You may object to the transfer of your Personal Data outside of the EU. In the event of objection to such as transfer, PIMKIE will no longer be able to provide services. Please note that Pimkie ensures that countries receiving data hold a suitability decision issued by the European Commission in terms of data protection and, if it is not the case, Pimkie ensure it obtains all necessary guarantees for the transfer of data outside the EU.

For any questions pertaining to the transfer of personal data outside the EU undertaken by Pimkie, you can contact the company at the details provided under article 1.9 of this privacy policy.

1.6 MEANS USED TO COLLECT PERSONAL DATA

Your Personal Data may be collected:

  • - Online at www.pimkie.com
  • - In store
  • - Via social networks during competitions.
  • - Pimkie may also indirectly collect Personal Data from partners to whom you have already given consent for the transfer of Personal Data for improvement of client knowledge.

1.7 SECURITY AND CONFIDENTIALITY OF PERSONAL DATA

PIMKIE makes all best efforts to take all technical and organisational measures to guarantee the protection, confidentiality and security of Personal Data which has been issued by any web user and/or client and in respect of legal provisions applicable. Pimkie also oversees respect of security commitments by its sub-contractors.

1.8 DATA STORAGE

Personal Data collected will be stored for the entire commercial relation between the Client and PIMKIE as well as for a period of 36 months from the final voluntary and positive act undertaken by it (by clicking on a link in a Pimkie email or the last purchase). However, Personal Data may be stored and archived for a longer term by virtue of respecting a legal obligation or for statistical purposes, and pursuant to national and European regulations in force.

1.9 PERSONAL RIGHTS

Pursuant to national and European legislations in force (articles 14 to 22 of the European General Data Protection Regulation (GDPR) 2016/679 of 27th April 2016), the Client has a right to access, amend, rectify, limit, oppose, move and delete Personal Data, with PIMKIE and after verification by PIMKIE if it believes necessary, of the identity of the Client by any currently valid ID document.

Right of deletion/right to be forgotten You can request that Pimkie delete your Personal Data when, inter alia, the Personal Data is no longer necessary for those purposes for which it was collected, if processing is illegal or if you have revoked your consent. However, this right does not exist if processing is required for exercising your freedom of expression and information, to respect a legal obligation, for reasons of public interests, or observation, exercising or defending legal rights in court.
Right to portability If collection of your personal data rests on your consent, you are entitled to receive Personal Data in a commonly used structured format which can be read by a machine, with a view to sending this to another Data Controller. You can also request that Personal Data be sent directly to another data controller, insofar as this is technically possible.
Right of opposition At any time, you can object to processing of your Personal Data, including in the event of profiling. Pimkie may no longer process your Personal Data unless Pimkie shows that there is a legitimate interest justifying processing (e.g.: this responds to a legal obligation) or for observation, exercising or defending legal rights in court.
Right to limitation You are entitled to request that your Personal Data be locked, or if this Personal Data is inaccurate, incomplete, equivocal, expired or if the collection, use, communication of this Personal Data is prohibited. In this instance, your Personal Data will no longer be processed, and this will only be stored for exercising or defending your rights in court or for protection of personal rights.
Right to lodge a claim You are entitled to make a claim with the National Data Protection Authority (CNIL)
Automated individual decisions You are entitled to not be the object of a decision based solely on automated processing, including profiling, which would have legal consequences for you. However, it will not be possible to exercise this right in the following instances: if the decision is necessary for performance of your order; if it is authorised for the law under the condition that appropriate measures be established to guarantee rights, liberties and legitimate interests; if it is based on your explicit consent.
Use of Personal Data after death You can also contact us to issue instructions as to the use of your Personal Data after death.

To exercise these rights, the Client and/or web user simply needs to make a request:

• either by letter to the following address:
PIMKIE / DIRAMODE
Customer Service/Personal Data
1 rue John Hadley
59654 VILLENEUVE D'ASCQ
France

• or by contacting DIRAMODE using the "contact" form available on the Website "Contact Us"

• or by contacting the Data Protection Officer at dpo@pimkie.com. Finally, you have a right to refer to any control authorities based in the European Union so as to indicate any infringement of your personal data about which you are aware,

1.10 PRIVACY POLICY UPDATE

This privacy policy may be updated regularly by us. Consequently, we invite you to regularly consult this policy. Any change which affects processing to which you have given consent will be the object of a new consent request.

ARTICLE 2: COOKIES POLICY

Gestion des cookies

The purpose of this "cookies" section is to inform the Client and Web user of processing undertaken on browsing data collected when you visit the www.pimkie.fr, www.pimkie.com, etc. sites, hereinafter referred to as the "Website", from any terminal allowing for access such as notably: computer, tablet, Smartphone.

2.1. WHAT IS A COOKIE?

A cookie is an information file stored on the hard disc of the Client or Web user by the server of the site that is visited. This file is sent to the computer, telephone or any other device of the Client or Web user. It contains several pieces of data, notably:

• The name of the server who stores the file;

• An identifier in the form of a unique number generated randomly so as to identify the session user (in the cookie itself);

• An expiry date.

This information is stored on the Client or Web user computer in a simple text file to which the server has access to read and store information.

2.2. WHAT COOKIES ARE USED?

The primary function of cookies is technical and allows for improvement of the browsing experience, to draft statistics, store information pertaining to constitution of a basket and its validation as well as client account login information (in such instance as the Client or Web user ticks the "remember me" box). To do this, the Website uses "internal" cookies and "third party" cookies, With the exception of cookies strictly necessary for operation of the Website, all cookies are only used after receiving consent from the client or Web user by continuing with browsing on the Website.

• Cookies strictly necessary for browsing on the Website:
These cookies are strictly necessary for proper operation of the Website. They are essential for basic services and functions, such as memorising information pertaining to constitution of the basket of articles selected.
• Cookies strictly necessary for browsing on the Website:
These cookies are strictly necessary for proper operation of the Website. They are essential for basic services and functions, such as memorising information pertaining to constitution of the basket of articles selected.
• Performance cookies:
These cookies allow for collection of anonymous information on Client or Web user browsing on the Website and are cross-referenced with those of other users so as to improve operation and optimise the service. Any problems encountered may also be resolved. These cookies allow PIMKIE to improve the browsing experience and draft statistics. Pimkie informs the Client or Web user that the Website uses Google Analytics, an internet analysis service offered by Google Inc. ("Google"). Google Analytics uses "Cookies", text files which are stored on your computer and authorise analyses of use of the website. Information concerning your use of this site generated by this Cookie is stored on a Google server hosted in the USA. Google operates this information so as to establish reports concerning activities on the website and intended for the site manager. Google will under no circumstances whatsoever establish links between your IP address and other Google data. You can prevent installation of these cookies by modifying your browser settings we would, however, like to draw your attention to the fact that by doing so, some functions of this website will not be available. Through using this site, you hereby authorise Google to use your data collected as previously described and for those purposes also indicated previously, Collection and registration of data may be prohibited at any time (with https://tools.google.com/dlpage/gaoptout?hl=fr). In light of discussions concerning the use of analytical tools with full IP addresses, we would like to draw your attention to the fact that this website uses Google Analytics "anonymizelp()". Consequently, only truncated IP addresses will be visible so as to avoid direct recognition of people. Use of these Web pages implies acceptance by the user of these provisions.
• Functional cookies:
These cookies allow the Client or Web user choices to be stored on the website, namely the language, country, search settings (type of products, size), delivery, recently consulted articles. Thanks to these cookies, browsing is personalised, the experience is more relevant and suitable for the areas of interest of the Client or Web user and their previous choices.
• Advertising cookies:
These third party cookies collect information pertaining to Client or Web user searches online and allow for targeted advertising. They retain the websites that the Client or Web user has visited, as well as their purchasing habits. These cookies are anonymous. Pimkie hereby informs the Client and Web user that it notably works with Criteo with a view to providing targeted advertising. Consequently, Pimkie invites Clients or Web users to read the Privacy Charter implemented and its related functionalities, notably the option to deactivate Criteo advertising cookies online at: http://www.criteo.com/fr/juridique/charte-de-la-vie-privee-services-criteo
• "Social Network" cookies:
These "social network" cookies are likely to be activated. They allow users to interact via social networks (E.g.: share, Like functions). When a page has these buttons, a direct connection is established with the social network in question and information may be sent in line with requests made by the latters. It is then necessary to refer to the privacy policies of each of these sites.

2.3. FOR WHAT PURPOSES ARE COOKIES NOT USED?

No information pertaining to bank details is stored in cookies. Cookies do not disclose any information to third parties for offers and services which do not concern the Pimkie brand, notwithstanding the consent of the user.

2.4. WHO IS THE INTENDED RECIPIENT OF INFORMATION STORED IN COOKIES?

Information stored in cookies on our sites is intended for PIMKIE and its related companies, with the exception of third party cookies identified hereinabove as "advertising cookies" and "social network" cookies, intended for partners.

2.5. WHAT IS THE TERM OF STORAGE OF COOKIES?

Data obtained using cookies is stored for a maximum term of 13 months.

2.6. SHARING USE OF THE TERMINAL WITH OTHER PEOPLE

If the Client or Web user's terminal is shared by several people, PIMKIE cannot guarantee that the services and adverts intended for the terminal correspond to use by the Client or Web user, and not those of another user. Consequently, sharing the terminal of the Client or Web user with other people and configuration of cookie settings on the browser is the free choice and responsibility of the Client or Web user.

2.7. HOW CAN YOU SET UP COOKIES ON A TERMINAL?

In addition to the ability to set up cookies that you wish using the "MANAGE COOKIES" button, it is possible to set up cookies directly on your terminal. Deletion of cookies may suspend browsing, the purchasing process, disconnection from the loyalty account, and lose the use of those functions implemented so as to facilitate browsing and purchasing. In these unlimited cases, DIRAMODE may not be held liable for improper functioning of the website or impeded functionality.
In this instance, all websites visited will be concerned. These settings may be changed at any time and using any internet browser, see the help menu on the browser concerned. Some examples are below:
For Internet Explorer™: open the Tools menu, then select Internet Options; click on Confidentiality and then select the desired level;
For Firefox™: open the Tools menu, then select Options; click on the Privacy tab and then select the desired options;
For Chrome™: open the configuration menu, then select Settings; click on Advanced Settings and then Content Settings, and then select the desired options;
For Safari™: choose Safari > Preferences and then click on Security; click on Display cookies and then select the desired options.