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Data Protection Policy

1The collecting of personal information

When you create your client account and place an order on the site www.spartoo.net (hereinafter referred to as the Site), SPARTOO SAS collects personal data about you. All data collected is adequate, relevant and limited to what is necessary for the purpose of treatment (points 2 and 3). The responsible party for the collection of this data is the company SPARTOO SAS, a joint stock company registered with the RCS Grenoble under the number 489 895 821, whose office is located at 16 rue Henri Barbusse 38100 Grenoble (hereafter known as : SPARTOO). The term "personal data" refers to any data that identifies an individual including name, phone number, date of birth, email address, postal address, IP address and any other information that you choose to communicate to SPARTOO about yourself. To fight against fraud (examples listed below under points 2 and 3), SPARTOO is also likely to temporarily retain information relating to transactions on the Site.

2The manager of the personal data

Your personal data is collection only for determined, explicit and legitimate purposes to answer one or more of the following :
(I)manage your orders on the site,
(II)develop business statistics, conduct market and behavior studies,
(III)build and manage sales leads, including particularly technical operations such as standardisation, optimisation and duplication,
(IV)perform customer management operations,
(V)select customers for sales leads or promotions,
(VI)send promotional information from SPARTOO. You can unsubscribe at any time to these offers by clicking on the link provided for this purpose at the bottom of the email concerned,
(VII)comply with our legal and regulatory obligations,
(VIII)fight against fraud in the conditions defined below in point 3.

3Examples of categories of personal data collected

What personal information does SPARTOO collect about its customers ?

- Information you give us
We collect and store all the information you give us about your SPARTOO account. You may choose not to provide us with certain information, however, this may result in you not receiving some of our services.

- Information collected automatically
When you browse the site SPARTOO, we automatically collect certain information, including information about your use of and interaction with the content of the site SPARTOO. This collection takes place mainly via "cookies".

- Information from other sources Our marketing partnerships also allow us to collect personal data about you, subject to your express prior consent to such partners.

The processing of personal data concerns in particular:

- Identity ;
- The data relative to payment ;
- Family, economic or financial situation ;
- Navigation data ;
- Data relating to the follow-up of the commercial relationship: order history, after-sales service information, order details, delivery incidents, complaints, exchanges, comments;
- Data relating to the regulation of invoices ;
- The data necessary to carry out loyalty and marketing actions;
- Data relating to the organisation and processing of competitions and all promotional operations;
- As part of the fight against fraud: proof of identity or residence and a shortened copy of your bank card;
- Telephone recordings of your calls to customer service. (You have the possibility to refuse the recording during your call).

4Purposes of data collection

Only our company and our contracted partners for order processing have access to the information you provide us. The categories of persons who have access to your personal data in SPARTOO are within the limits of their respective duties, the sales department, administrative services, technical services and monitoring agencies (auditor, internal quality control procedures, etc). Recipients of your personal information may also include public bodies in order to meet legal obligations such as court officers, public officers and debt collection agencies.

5Categories of recipients of personal data

The information that we collect is stored for time starting from the last transaction you have placed on the Site, or from the last update to your customer account. Some of your bank details, for instance the truncated account numbers and expiry dates on bank cards will be kept during thirteen months for anti fraud procedures. As part of the Premium service, you can consent to the retention of truncated bank card numbers and their validity dates for a period of thirteen months from the last transaction you made on the Site or last update day of your customer account. This consent is expressed when you check the "Remember" box. You may subsequently withdraw your consent to this retention at any time by giving the same notice. In the absence of a new transaction or update of your customer account during the five-year period, your personal data will be deleted automatically.

6The legal bases

A legal basis for a processing operation is defined as the legal basis for its implementation, which gives an organisation the right to process personal data. Les bases légales sont distinctes en fonction du type de traitement effectué :


- The contract: concerns the processing of all data necessary for the agreed contract.
- Consent: you choose to communicate your personal data by expressly giving your consent, which can be withdrawn at any time.
- Legitimate interest: the interest must meet the criteria of legitimacy, necessity, and not conflict with the rights and interests of the persons whose data are processed.
- Legal obligation: The processing of personal data results from a legal obligation.

7Set of implementations

To better serve you, we measure the number of pages viewed, the number of visits, as well as the frequency of returning visitor activity on the site. For this purpose, we use a technology called "cookies." A cookie does not allow us to identify you. Generally, it records information about the navigation of your computer on our site (the pages you visited, the date and time of visit, etc.) that we can consult during your subsequent visits.
Data collected by cookies is solely and strictly for internal use and will not be passed to third parties. The use of cookies, whether ours or a third party, which are not required to operate the site will require express consent from yourself. You can give your consent or object to use the cookies by configuring your browser appropriately. Refer to the user's guide for your browser to do this.
Some cookies called "advertising cookies" enable us to track and record your internet navigation and remember products seen; then, within a maximum delay of 90 days, present marketing banners to you that are related, or not, to your past navigation. These cookies are linked to your internet profile, but do not identify you. They also require your express consent in the same way as indicated above. If you do not or no longer wish to receive these "advertising cookies," click on the link below. :

Deactivate advertising cookies on my profile

8The duration of the retention of personal data

How long do we keep your personal information?
We retain your personal information for as long as is necessary for the fulfilment of the relevant purposes and for the fulfilment of legal obligations such as tax or accounting obligations, or for such other period as may be notified to you.

For the same processing, personal data undergo several storage phases. Depending on the type of processing and its purpose, the retention periods differ.
- The first phase of retention is the storage in an active database. Retention depends on the achievement of the purpose of the processing that justifies its collection. The data are accessible to the operational departments in charge of the processing.
- The second phase is intermediate archiving. The data collected are no longer used to achieve the purpose for which they were collected, but they are still of administrative interest, and authorised by law, such as the management of a dispute or an unpaid bill, or their retention is authorised or required by law. Intermediate archiving is carried out within the limits of the applicable prescription periods, or in accordance with the legal obligations of conservation. Access to this data will be restricted to a list of duly authorized by Spartoo SPARTOO employees.
- After this intermediate archiving phase, your data will be anonymised.

In order to determine the duration of the retention of your data, it is necessary to define the starting point. In accordance with the recommendations of the CNIL, this starting point is defined by the last positive action of the customer or prospect which implies a real approach showing an interest in SPARTOO; for example :
- clicking on a hyperlink,
- an order,
- logging into the customer account
- the site visit.

9Right of Access and Rectification

In accordance with the EU 2016/679 regulation, you have the right :
- to access
- to rectify
- to erasure
- to restriction of processing
- to data portability
- to object
You can exercise your rights to access, rectification and erasure directly once you are logged into your customer account. To exercise your rights to restriction of processing, portability and objection, please contact:
by email: to dpo@spartoo.com
by post: to SPARTOO SAS, 16 rue Henri Barbusse 38100 Grenoble
The customer can, if necessary, place a complaint using a controlling authority.

11Right to access and rectification

In accordance with EU Regulation 2016/679, you have many rights, namely:

- The right to access, modify, rectify and delete information about yourself.
- The right to request the portability of this information.
- The possibility to object to the processing of your personal information or to request to restrict the processing of your personal information in certain cases.

You can send your requests to:
- by e-mail: at dpo@spartoo.com
- by post: SPARTOO SAS – DPO - 16 rue Henri Barbusse 38 100 Grenoble

12Right to file a claim with the relevant authority

You also have the right to file a claim with the CNIL:
https://www.cnil.fr/fr/plaintes

13Changes to the personal data protection policy

This privacy policy is subject to change, particularly in accordance with changes in legislation and regulations.

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