PRIVACY STATEMENT - ORLOV PARIS
Confidentiality and security of your personal data are important to us. We would like to offer you personalized services while respecting your privacy and choices.
In this Policy you will find information on:
· What data we can collect about you;
· How we collect or receive your data;
· For what purposes we use it;
· How long we can keep it;
· Who can access your data;
· How we protect it and keep it confidential;
· How we address consumer preferences and individual rights;
· The additional protections that we provide for residents of certain region;
· How to contact us if you have questions about our use of your personal data;
· How we protect children’s privacy;
· The management of cookies on orlovparis.com website; and
WHAT data may we collect about you?
"Personal data" means any information that could identify you either directly (e.g. your name) or indirectly (e.g. through a unique client ID number).
The personal data we collect depends upon the touchpoint of our interaction, and is also limited to that which is relevant and appropriate for the interaction. Website visitors who browse orlovparis.com and view our products, information and offerings can choose to do so without identifying themselves, and the same applies to in-store and social media browsing. Unless you choose to interact with us via those touchpoints, such as by making a purchase on our site, signing up for one of our programs or services, or posting a comment or a like online, our data collection is limited to the use of ‘cookies’ for website visitors. Also our system doesn’t collect any data throught cookies unless you accept them by clicking on « OK » in the information banner that pop ups on our landing page.
For customers and other individuals who sign up for programs or services, we must collect certain relevant information from you. The information we collect is related to the particular transaction as well as our overall relationship with you. For example, if you make purchases from orlovparis.com or in our stores, we must collect information to process (and, if relevant, fulfill and ship) your order. For customers and other individuals who sign up for our programs or services, we generally collect your contact details, contact preferences, and information that will allow us to make recommendations to you about our products or services that may be of interest. We may centralize the information pertaining to our customers so that we have it organized in one place, as this helps us manage our relationship with you as well as your choices and preferences.
Depending on the data you provide or share with us, personal data may include information related to:
· Your identity and your contact details;
· Your interests;
· Your purchases (in store or online, including your orders, their tracking and your purchase invoices, the amount and type of your purchase) and any returns or exchanges;
Your online journeys (orlovparis.com, social media pages, partner websites and databases);
· Your requests through our customer department or our public relations department;
· The ORLOV PARIS events you attend; or
· Specific health data if you notify us of any undesirable side-effects concerning any of our products.
Regarding your purchases, your bank details are encrypted through ORLOV PARIS servers. Payments are made via a secure payment platform PCI-DSS certified, supplemented by control measures, to ensure the security of purchases made and to fight against fraud.
In the context of a job application with ORLOV PARIS , we may collect the following information:
· Your identity and your contact details
· Your Curriculum Vitae and your cover letter
We invite you to keep us regularly informed in writing of any change in your contact details.
HOW do we collect or receive your data?
As part of our relationships, we may collect certain data via the following touchpoints:
· Orlovparis.com journey;
· In-store relationship with our salesperson;
· ORLOV PARIS events you attend;
· Public Relations relationship;
· Contact with Customer Department;
· Forms you complete (in store or online);
· Digital apps you use;
· Relational program you benefit from;
· ORLOV PARIS social media pages you visit or comment/like;
· Social media pages on which you post ORLOV PARIS content or comments;
· Digital Media Advertising you click on;
· Search Engines Paid Advertising you click on;
· Retailers in which you consent to receive our communications; or
· Surveys or satisfaction questionnaire you answer.
In relation to our programs and events, the personal data essential to ORLOV PARIS is indicated by an asterisk on each personal data collection form. If you do not provide the data marked with an asterisk, this may affect the products and services that we can provide to you. Other information is optional and allows us to know you better and to improve our communications and services to you.
FOR WHAT PURPOSES are your data used by ORLOV PARIS ?
As part of our relationship, depending on the context in which your data is collected, we use your data for:
· the management of your orders;
· the management of the personalized content and communications with ORLOV PARIS (digital or otherwise);
· the management of your account and profile;
· the management of your relational program;
· the management of your requests linked with ORLOV PARIS ;
· the management of events which you register for / attend;
· the management of alerts you send us as part of our cosmetovigilance obligations;
· the management of your application for a job;
· the management of our website and our digital apps;
· the management and improvement of our products and services, image and reputation; or
· The management of payments (online transaction security, fraud prevention, payment incidents and debt collection).
· With your explicit consent, for sending you personalized newsletter and using third-party services to customize your profile.
In the context of your application for a job, we may use your data to manage and consider you and other candidates for our open positions.
The legal basis for the processing of your data can be, depending in which context your data is collected:
· Your consent (e.g. to manage our tailored services, managing your browsing via cookies);
· The performance of a contract (e.g. managing your access to your customer account, processing and tracking your orders);
· A legal obligation when processing is required by law (e.g. retention of purchase invoices, cosmetovigilance for Parfums ORLOV PARIS products); or
· Our legitimate interest: improve our products and services, prevent fraud, secure our tools or tailor our communications
FOR HOW LONG may we keep it?
We only keep your personal data for as long as we need it to fulfill the purpose of collection, to meet your needs, or to comply with our legal or business obligations.
As a general principle, your personal data will be retained in our client database:
· If you are a “client” (i.e. you have already purchased a ORLOV PARIS product): for no more than 10 years after your first purchase for customer relationship management, but no more than 5 years for business development; this period will be renewed each time you interact with ORLOV PARIS (e.g. a purchase)
· If you are a “prospect” (i.e. you have never purchased a ORLOV PARIS product but you are interested in ORLOV PARIS brand): for no more than 3 years; this period will be renewed each time you interact with ORLOV PARIS (e.g. when participating in an event)
· If you are in contact with the Public Relations department: for no more than 10 years after initial contact; this period will be renewed each time you interact with ORLOV PARIS (e.g. when requesting information from the ORLOV PARIS House)
· If you are a “job applicant” (i.e. you apply for a job offered by ORLOV PARIS ): for 2 years after your application
Where cookies are placed on your computer, we shall keep them for no more than 13 months.
When we no longer need to use your personal data, it is removed from our systems and records or anonymized so that you can no longer be identified from it.
WHO may access your data?
Your data are for ORLOV PARIS services dealing with your requests. We ensure that only duly authorized persons can access your personal data when necessary for the above-mentioned purposes.
We do not give your data to third parties for commercial purposes.
We communicate your information only where necessary, and if possible in a form that does not allow a direct identification to:
· Other ORLOV PARIS entities to provide you with the same personalized service worldwide
· Our trusted third-party suppliers, including other entities of the ORLOV PARIS management, acting as processors according to our instructions and solely on our behalf. For example, we entrust certain services to third parties in charge of managing cosmetovigilance alerts, third parties who assist us in the organization of our events, third parties providing IT services, digital communication and public relations agencies, third parties who assist us with customer care and logistics services.
· Department stores in which you buy our products
· Our distributors
· Our trusted third-party partners assisting us in the management of your orders. In particular, we entrust certain services to third parties in charge of delivering you a product, payment service providers and providers securing transactions against fraud.
Please note that these partners may act as data controller; in such case, they have their own privacy policies.
· Third parties in the event of a change of control, for legal reasons, or with your prior consent
Third parties wishing to know your main interests to constitute similar audiences and target prospects that match your profile. In the context of this specific data processing, ORLOV PARIS is not the Data Controller relating to prospecting and you will not be subject to prospecting, your data is only used to constitute profiles similar to yours
You may also choose to disclose your personal data to our partners, advertisers or affiliates by following a link to and from their websites. Please note that these websites have their own privacy policies.
We may also offer you the opportunity to use your social media login. Please be aware that in this case you are sharing your profile information with us. The personal data shared depends on your social media platform settings. Please note that these social networks have their own privacy policies.
Furthermore, on your request or with your consent, data regarding your job application may be shared with other employees of the ORLOV PARIS management worldwide for recruitment purposes.
HOW do we protect it and keep it confidential?
We have adopted reasonable and appropriate precautions to protect your data from loss, misuse, alteration, destruction or access by unauthorized third parties.
We also require our partners and group companies to uphold a similar level of protection for your data. The measures are evaluated and updated to address new threats and challenges, as well as new legal requirements in the countries where we operate.
HOW do we address cross-border protections?
Because ORLOV PARIS operates in many countries across the world, some of your data may be collected, accessible or stored outside of your country of residence. You should know that the data protection and security requirements differ from place to place, and may not offer the same level of protection as those in your home country. Nevertheless, ORLOV PARIS and our group companies have taken steps to ensure an adequate level of protection of your data irrespective of where it is located, such as by using data transfer methods approved by the European Commission (where the data protection laws are considered to be the strongest worldwide). We also require our third-party partners to fulfill applicable data transfer obligations in relation to the personal data that they receive on our behalf.
How are consumer preferences and individual rights addressed?
In accordance with applicable laws and requirements, ORLOV PARIS and its group companies have put in place measures to fulfill the rights of individuals in relation to the personal data that we (or our third parties) hold about them. This includes, for example, the right to know about the data we hold about you or to obtain a copy, and the limited rights to amend your data, request erasure, or object to the processing of your data. We encourage individuals who have entrusted their data to us to keep it current (such as if you change your email address, address or phone number), so that we have your correct information on file. We also encourage consumers to update their preferences with us, such as in relation to products and the frequency of contacts, so that we can personalize our service to your expectations and needs. Finally, we offer individuals the right to withdraw consent from our programs and offerings at any time. To do so, or to exercise any of these other rights, please use our Contact Us link on Orlovparis.com, or email us at email@example.com. For individuals seeking access to their data, we also require authentication to ensure that we are not providing personal data to an unauthorized person.
What additional protections are provided for residents of certain regions?
· In particular, the GDPR provides the following rights (with some exceptions):
· The right to be informed: you have the right to obtain clear, transparent and easily understandable information about how we use your personal data, and your rights. You will find all this information in this Policy;
· The right of access: you have the right to access to the personal data ORLOV PARIS holds about you;
· The right of rectification: you have the right to have your personal data rectified if it is incorrect or outdated and / or completed if it is incomplete;
· The right to erasure / right to be forgotten: you have the right to have your personal data erased or deleted. Please note this is not an absolute right, as we may have legal or legitimate grounds for retaining your personal data;
· The right to object to direct marketing: you can unsubscribe or opt out of our direct marketing communication at any time. You are able to do so by clicking on the “unsubscribe” link in any email or communication we send you. You are also able to request to receive non-personalized communications about our products and services;
· The right to withdraw consent at any time for data processing based on consent: You can withdraw your consent to our processing of your data when such processing is based on consent; and
· The right to data portability: you have the right to move, copy or transfer data from our database to another. This only applies to data that you have provided, where processing is based on a contract or your consent, and the processing is carried out by automated means.
You are also entitled to determine your personal data protection guidelines and directives in the event of death or extern circumstances.
You also have the right to contact the data protection authority of your country in order to lodge a complaint against the data protection and privacy practices of ORLOV PARIS .
We may require proof of your identity and full details of your request before we process it.
· United States Consumer Privacy Rights.
While ORLOV PARIS applies the GDPR benchmark globally, there are specifics, including from the California Consumer Privacy Act, which we wish to summarize under this section. To this effect, ORLOV PARIS complies with rights of consumers regarding the personal data that we collect and hold about them. Those rights vary by region, and by state within the U.S.
ORLOV PARIS does not sell personal data obtained about our customers or other consumers. Rather, when we entrust personal data pertaining to our customers to third party partners, those organizations are screened in advance to ensure that they are capable of upholding a similar level of protection for your data as that provided by ORLOV PARIS . They must also confirm in writing that they will only use the data for purposes of carrying out their services for ORLOV PARIS , and not for any separate purposes.
To the extent that ORLOV PARIS shares your personal data with other companies within the ORLOV PARIS management, we also require those companies to uphold similar data protection and security standards for your data, including in relation to any third party access and use of the data.
For California residents, please click here to see our California Consumer Privacy Act of 2018 (CCPA) Privacy Notice if you wish to know more about the CCPA beyond the points extracted from such notice for your information as follow:
- In a nutshell, the CCPA is a California law that gives California consumers additional rights relating to the personal information collected about them. The main rights under that law are:
· The right to request that a business do not ‘sell’ your personal information
· The right to know what personal information is collected about you (or request a copy);
· The right to request deletion of your personal information (with reasonable exceptions).
- These rights can be exercised by the California consumer or their designee (“authorized agent”).
- In addition to those main rights, the CCPA also includes certain additional rights, such as:
· The right to no discrimination, including in relation to exercising your other CCPA rights
· Additional protections for minors age 13-16 in relation to marketing activities
· Certain protections for individuals with disabilities to be able to exercise their CCPA rights
· Certain rights to file claims against companies that violate the CCPA
To exercise your consumer privacy rights in accordance with your state’s law, please email our customer care team at the contact details below. Please note that you may be asked to provide information to authenticate yourself in connection with fulfilling your request.
How does ORLOV PARIS protect children's privacy?
ORLOV PARIS has adopted practices that are designed to ensure that we do not to collect or maintain any information from children under the age of 13. If we learn that we mistakenly collected any information from anyone under the age of 13, we will purge it immediately, except for responding to a question or inquiry on a one-time basis from the individual or his/her parent or legal guardian.
If you have any general questions on about how we process and use your personal data, or concerns please contact us at firstname.lastname@example.org or via telephone at +33177194327 from Monday to Friday from 9am to 6pm CEST. If you would like to exercise any of your rights above, please contact us email@example.com
INFORMATION ABOUT COOKIE MANAGEMENT
This section presents our policy for managing cookies on the orlovparis.com website.
It aims to explain where the browsing information processed when you visit our website comes from, how it is used, and your rights.
WHAT IS A COOKIE?
When you visit our website, we might, depending on the choices you make, store a text file on your device (computer, smartphone, tablet, etc.) through your web browser.
This text file is a cookie. For as long as it is valid and stored on your device, it will enable ORLOV PARIS to identify your device when you visit the website in the future.
Only the issuer of a cookie can read or modify information stored in it.
Below you will find information on the cookies that might be stored on your device when you visit pages on the orlovparis.com website, either by ORLOV PARIS or by third parties, and how you can delete cookies or refuse to allow them to be stored on your device.
WHAT IS THE PURPOSE OF THE COOKIES ISSUED ON ORLOVPARIS.COM?
There are several categories of cookie. Some of them are issued directly by ORLOV PARIS and its providers, and some are issued by third-party companies.
· The following types of cookies may be issued by ORLOV PARIS and its providers
Various types of cookie might be stored on your device when you browse our website:
The "essential" cookies are essential for browsing our website, including to ensure that the ordering process runs smoothly. If you delete them it can cause difficulties when browsing our website and make it impossible to place an order. They might be stored on your device by ORLOV PARIS or by its providers.
"Analytical and Personalization" cookies not essential for browsing our website but making it easier for you to conduct searches, optimizing your buying experience.
"Advertising" cookies, not essential for browsing but allowing you a more relevant advertising offer.
If your device is used by several people and if one device uses several web browsers, we cannot be certain that the services and adverts delivered to your device are determined based on your use of the device and not on that of another user. It is your decision and responsibility whether you share use of your device and configuration of your web browser’s cookie settings with other people.
· Cookies issued by third-party companies
Cookies are issued and used by third parties on our website in accordance with these third parties’ privacy protection policies. These cookies are not essential for browsing our website.
We might include cookies on our website applications produced by third parties, which enable you to share our site content with other people or to tell other people what content you have been browsing or your opinions of it. This is true of the “Share” and “Like” buttons for social networks like Facebook, Twitter, Instagram and Pinterest.
MANAGING THE COOKIES STORED ON YOUR DEVICE
You can decide whether cookies are stored on your device.
You can also configure your web browser as you wish, so that cookies are accepted and stored on your device, or conversely blocked.
The configuration process is different for each web browser. It is usually described in the browser’s help menu. We urge you to find out how to configure your browser. This will allow you to find out how to change your cookie preferences.
· For Internet Explorer™: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
· For Safari: https://support.apple.com/kb/PH19214?locale=fr_FR&viewlocale=en_US
· For Chrome: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
· For Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
· For Opera™: http://help.opera.com/Windows/10.20/en/cookies.html
Please note: any changes you make to your web browser’s cookie acceptance or blocking settings may change your web browsing experience and the process of accessing services that require the use of these cookies. For example, if you block essential cookies you might no longer be able to place orders on our website.
What is the benefit of seeing special offers and advertising tailored to your browsing preferences?
The aim is to show you the most relevant offers and advertising. As such, cookie technology enables us to display content, in real-time, that is best suited to your fields of interest, as deduced from your browsing history on our website.
The interest you show in content displayed on your terminal when you consult a website often determines the advertising resources of this site, enabling it to provide its services, which are often supplied free of charge to users. You doubtless prefer to see offers and advertising that are relevant to you, rather than content that is of no interest to you at all. Similarly, both ORLOV PARIS and advertisers want their offers and advertising to be shown to Internet users that are likely to be interested in them.
In case of modification of this Policy, we will keep you informed of these changes by a notice on our site, or by a warning contained in our newsletters.
Version updated on January 1, 2020
NOTICE ABOUT COOKIE MANAGEMENT
This Notice about cookies applies when visiting the website available at Orlovparis.com or Orlovparis.fr (hereinafter the “Website(s)”).
WHAT IS A COOKIE?
Subject to your choices, when visiting the Website, a text file may be placed on your device (computer, smartphone, tablet), courtesy of your web browser.
This text file is a cookie. During its validity or registration period, it will allow the sender to identify your device on future visits.
Some cookies are essential for using the Website, others optimize and personalize the contents displayed.
WHO SENDS THE COOKIES ON OUR WEBSITE?
Cookies that may be saved to your device when you visit the Website pages are issued by ORLOV PARIS and/or third parties. Only the cookie issuer is likely to read or modify the information contained within it.
Cookies sent by ORLOV PARIS are mainly related to the operation of the Website.
The others are third party cookies sent by our partners or advertising agencies, via the advertisements shown on our Website. The examples below are for illustration purposes:
Role: When Twitter acts as a third-party host, it collects data via a range of plug-ins and integrations, which are primarily used for targeting and tracking.
Role: Doubleclick is Google’s real-time auction ad exchange
ORLOV PARIS makes every effort to ensure that third-party cookies are issued and used in compliance with the applicable regulations.
WHAT IS THE PURPOSE OF THE COOKIES ISSUED VIA THE WEBSITE?
Subject to your choices, various cookies may be installed on your device for the purposes detailed below. For the sake of transparency and in as much depth as possible, we inform you of the purposes of the third-party cookies that we are aware of, and the ways in which you can make choices about these cookies. All cookies may be cross-referenced with your customer data in order to personalize your experience, limit commercial interaction, ensure the proper functioning of your loyalty benefits, improve our services and guarantee your satisfaction.
· Essential cookies for Website operations
“Essential” cookies are necessary for Website browsing and allow you to use the Website’s main features.
For example, these cookies are intended particularly for:
- saving your choices or desire not to make a choice about tracker cookies;
- service authentication;
- saving the contents of a shopping cart;
- customizing the interface.
Removing them may make it hard to browse the Website or may make it impossible to place an order. These cookies may be installed on your device by ORLOV PARIS or its service providers.
These cookies enable or facilitate digital communications and/or may be strictly necessary for the provision of an online communication service at your express request. As a result, they do not require your prior consent. Saving or reading such cookies is necessary for provision of the service and will be based on ORLOV PARIS ’s legitimate interest in implementing such processing for the proper use of its Website.
· Personalization cookies
Personalization cookies allow us to personalize and improve your user experience, for example by making your searches easier and optimizing your shopping experience. They also allow us to adapt the look of the Website to your device display during your visits.
Such cookies are saved or read, subject to your prior consent. If you refuse these cookies, you will not be able to benefit from the functionalities described in this paragraph.
· Analytical cookies
Analytical cookies make it possible to gauge the audience for various Website content, to establish visitor statistics and volumes in order to evaluate and improve our service ergonomics. These cookies include those used to create similar profiles that will be prospected according to your information.
The information communicated to technical service providers is transmitted in the form of aggregate statistics and traffic volumes, excluding any personal information. These statistics are reconciled with the traffic statistics of other websites, as well as with your customer data.
Such cookies are saved or read, subject to your prior consent. Refusing the implementation of or deleting such cookies does not affect your Website browsing but is likely to prevent us from ensuring the best quality of service we wish to offer our visitors.
· Sharing cookies (social links)
Our Website may include third-party computer applications that allow you to share Website content with others, or to publish your visit or opinion of Website content to these other persons. This is notably the case for “Share” and “Like” buttons on social networks such as Facebook, Twitter, Instagram, Pinterest, etc.
The social network providing such application buttons is likely to identify you through this button, if you use the button, and even if you have not used this button but are signed in to the social network when you consult the Website (open session during your browsing). Share buttons will allow you to connect the contents consulted to your user account.
We have no control over the process social networks use to collect information about your Website browsing and associated with the personal data at their disposal. We invite you to consult the privacy protection policies of these social networks.
· Advertising cookies
Advertising cookies are not essential for browsing but allow you to see more relevant advertisements personalized to your interests on the Website as well as other websites you may browse. As such, advertising cookies allow, for example, the display of advertising, capping the display (not presenting the same advertising to a user in a repetitive manner), combatting click fraud, billing the display service, the measurement of targets more interested in the advertising to better understand the audience, etc.
Advertising content personalization can also be achieved by using our partner’s technology, to associate your device’s Website browsing information with the data you provided us when you registered.
Saving or reading such cookies is subject to your prior consent. Refusing these advertising cookies has no impact on your use of the Website, nor will it stop advertising on the Website. However, we will be unable to offer you advertising that takes your interests into account.
How long are the cookies kept?
Cookies saved on your device have a maximum lifespan of thirteen (13) months. At the end of this period, personal data collected through the cookies will be deleted.
HOW TO MANAGE COOKIES SAVED ON YOUR DEVICE
There are various ways to manage the implementation of cookies, as presented below.
If your device is used by more than one person and operates more than one browser, we cannot be certain that the services and advertisements sent to your device are appropriate for your personal use of your device, rather than of another user of your device. If you choose to share your device and browser cookie settings with others, you are responsible for doing so at your own discretion.
You can express your choices using:
· The cookie manager
You can decide whether cookies are saved on your device using the cookie settings tool by clicking here, in the cookie banner or in the Website footer.
Cookies are managed for cookie purposes.
· Your browser settings
You can also configure your browser to accept and save cookies on your device or to reject them.
Each browser has different settings. These are usually described in your browser help menu. We therefore recommend reading it. This will show you how to change your cookie preferences.
· For Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Please note: any choices in your browser settings concerning the acceptance or refusal of cookies will be likely to modify your Internet browsing experience and your access to the Website and certain services requiring the use of these same cookies.
· On the Youronlinechoices website
You can connect to the Youronlinechoices website (https://www.youronlinechoices.com/uk/your-ad-choices) built by digital advertising professionals. This website allows you to refuse or accept cookies that may be used to personalize the advertisements shown to you while you browse. This European platform is shared by hundreds of Internet advertising professionals. However, this will not prevent advertisements from being displayed on the websites you visit. It will only block technologies that allow advertising to be tailored to your interests.
ORLOV PARIS - CANDIDATE PRIVACY STATEMENT
Statement relating to the protection of your personal data collected in the context of recruitment
This Privacy Statement for Candidates (hereinafter the “Privacy Statement”) is intended to provide visitors and users (“You”) of the www.orlovparis.com website, as well as of all the ORLOV PARIS ’s websites with .com, .fr, .ru, .co, .jp, .cn domain names suffixes (hereinafter collectively the “Website”) with information relating to how the Maison ORLOV PARIS (hereinafter “ORLOV PARIS ” or “We/Us”) processes your personal data (hereinafter the “Personal Data” or “Data”) and about your rights in this respect.
ORLOV PARIS places the highest priority and takes the utmost care to protect your Personal Data.
1. Who are we? Who is the Data Controller of your Personal data?
During your recruitment experience, and in order to inform you in advance, the Data Controller will be ORLOV PARIS within the meaning of the regulations applicable to personal data and in particular with regard to article 24 of the Regulations (EU) 2016/679 (hereinafter "GDPR").
2. What is a “personal data”?
Personal Data refers to any information or pieces of information that could identify You either directly (e.g. your name, surname, email, home address, etc.) or indirectly (e.g. through pseudonymized data, such as a unique ID number, etc.). It may also include unique identifiers like your computer’s IP address.
3. Why and how do We use the Personal Data that We collect?
3.1 How do We collect your Personal Data?
We collect your Personal Data as follows:
· directly from You when You use our Website and our services (completion of various forms on the Website, direct communication with Us through our institutional departments, etc.);
· automatically when You access or use the Website (technical details, IP address, browsing information, etc.).
3.2 What Data do We collect?
We collect several types of Personal Data about You:
Personal Data that We collect directly from You
We collect Personal Data that You provide directly when You use our Website.
This is specifically the case when You:
· interact with Us through the contact forms,
· register to receive our newsletters or institutional documentation,
· apply to job offers.
The categories of Personal Data that We collect include:
· Identification and contact information: e.g., last name, first name, mailing address, contact details needed to identify You when You interact with Us,
· Application information: e.g., last name, first name, email address, telephone number, professional experience and all the information You provide by sending your application and/or your curriculum vitae: photo, skills, education level, spoken languages, salary expectations, home address, hobbies, family status, etc. We only collect and store this Data in connection with the management of our own job offers and do not use them for any other purposes, including for commercial purposes.
Personal Data that We collect automatically
We automatically collect certain Data about You when You access or use the Website, specifically:
· Technical information: We collect information about the device that You use to login, as well as your use of the Website (g., operating system, type of browser used, whether a proxy is used, location of the device inferred from your IP address that identifies your computer, access time, accessed pages and the link that enabled You to access our Website),
· Browsing information: We use tracking technologies to collect Data about You when You use our Website.
3.3 On what legal grounds and for which purposes do We use the Data that We collect?
In accordance with current personal data protection regulations, We only collect Personal Data when We have a legal basis to do so.
Personal Data is collected either:
i. based on pre-contractual measures
ii. based on your consent,
iii. in our legitimate interest, or
iv. to meet our legal obligations.
(i) We collect your Personal Data on the basis of pre-contractual measures, in particular in the context of the processing of applications (CV and motivation letter) and management of interviews.
(ii) We collect Personal Data based on your consent, for the following purposes:
· Share opportunities that can match your profile and keep you up to date on the life of Maison ORLOV PARIS ,
(iii) We collect Personal Data based on our legitimate interest, for the following purposes:
· to manage your requests and queries: We use your Data to send You the information You request,
· to defend our interests in the event of a dispute or court action,
· to manage cybersecurity of the Website,
· to prevent fraudulent acts in order to ensure the security of our assets and contents.
(iv) We may also store your Personal Data when the law requires Us to do so or to defend our legal rights.
3.4 Who has access to your Data?
3.4.1 Accessibility within ORLOV PARIS
Your Data is processed by the ORLOV PARIS for the purposes described above and are only accessible to ORLOV PARIS personnel who need to know it to perform their duties.
In this respect, your Personal Data is processed by the following departments of ORLOV PARIS .
3.4.2 Accessibility by third parties
Certain third parties may have access to your Data, specifically:
(i) our subcontractors and service providers acting for technical and logistical reasons (carriers, Website hosting, security and maintenance providers, fraud management service providers, technical service providers responsible for sending e-mails and newsletters, anti-spam and anti-bot services, recruitment agencies which may provide Us with advice on the management of our candidates’ databases and help with the selection of profiles within such databases, etc.);
(ii) other ORLOV PARIS management affiliates for recruitment purposes: when you apply to an ORLOV PARIS management affiliate’s job offer, this affiliate collects and processes your Data as independent data controller. In such case, your Data will be processed according to this affiliate’s personal data protection policy, which You may obtain by contacting it directly. Likewise, the rights You enjoy pursuant to personal data protection laws must be directly enforced against it;
(iii) any authority, court or other third party when disclosure is required by law, regulations or a judicial decision, or if such disclosure is necessary to protect and defend our rights.
3.5 Is any Personal Data transferred outside of the European Economic Area?
Your Data is processed in France by the Maison ORLOV PARIS . However, We may rely on certain service providers, which are located abroad or which themselves rely on processors located abroad, including outside of the European Economic Area (EEA) in countries where personal data protection laws differ from those that apply in the EEA.
With reference to the data relating to applications, the ORLOV PARIS management has adopted binding corporate rules ("BCR") which the French Supervisory Authority (the CNIL) has declared to be compliant with current legislation and suitable for offering an adequate level of protection in case of data transfer within the Group, also outside the European Economic Area.
3.6 How long do We store your Data?
Data is stored as long as required for the purpose for which it was collected and, in any case, will be destroyed at the end of such period.
Please see the list below for additional details about these periods.
Any transfer of your Data outside of the EEA will take place with appropriate safeguards in place that comply with applicable personal data protection regulations. Upon request, We will provide You with a copy of applicable safeguards.
· Purpose: Management of your requests and queries
· Data categories: Identification Data (last name, first name, mailing address, contact details needed to identify You when You interact with Us).
· Period of storage before erasure: Duration required to manage your requests and queries. Your Data will then be either deleted or anonymized, unless we need to keep it to meet our legal obligations for the applicable statutory retention period.
· Purpose: Sending You our newsletters
· Data categories: Your email address
· Period of storage before erasure: Duration of your subscription. Then, the Data will be destroyed or anonymized.
· Purpose: Management of your applications to job offers
· Data categories: Application information
· Period of storage before erasure: Duration of two (2) years from when the Data has been provided or from the last contact with You. At the end of this 2-year period, ORLOV PARIS may contact You to know whether You want ORLOV PARIS to keep retaining your Personal Data, for the purpose of informing You of an opportunity that may arise and match your career aspirations and skills. In any event, your Data will be erased at your request, within a maximum period of 1 month from your request.
· Purpose: Security of the Website
· Data categories: Technical information of your device (IP address, device type, browser ID, etc.)
· Period of storage before erasure: 6 months, then the Data is either deleted or anonymized.
· Purpose: Disputes/complaints
· Data categories: Data concerning the dispute/complaint
· Period of storage before erasure: Duration of the complaint + 5 years from the complaint.
· In the event of a court action: duration of proceedings through full enforcement of the legal decision or settlement agreement
4. What are your rights in relation to your Data?
4.1 Access, rectification and portability
In accordance with current regulations, You have the right to access your Data. You may also request correction of Your Personal Data should they be inaccurate. Depending on the purpose of processing, You also have the right to have incomplete Personal Data completed.
To respond to your request, We may ask You to provide Us with a proof of your identity. We may also need to ask You for additional information or supporting documents. We will make every effort to respond to your request as soon as possible.
You may, to the extent provided for by law, exercise your right to Data portability which allows You to retrieve, in an interoperable format, the Personal Data that You provided to Us.
4.2 Right to erasure of your Data and to limitation of the processing of your Data
You may request erasure of your Personal Data if:
· You believe that the processing is unlawful or You contest the accuracy of the Data We process about You,
· You withdrew your consent to the processing of your Data.
Alternatively, to the extent provided for by law, You may request limitation of the processing of your Data.
Please note that despite the exercise of your right to erasure or processing limitation, We will store some of Your Personal Data when the law requires Us to do so, or to exercise or defend our rights.
4.3 Right to establish instructions for the management of your Personal Data after your death
For France and when mandatory local provisions so provide, You may determine how You want Us to handle your Personal Data upon your death.
4.4 Procedure to exercise your Data protection rights
You can exercise your Data protection rights
· by using the following email address: firstname.lastname@example.org
· by mail at the following address: Data Protection Officer, ORLOV PARIS, 5 rue Quentin Bauchart, 75008 Paris, France.
You also have the right to contact ORLOV PARIS ’s lead Supervisory Authority, the CNIL, at any time in order to file a complaint against ORLOV PARIS ’s data protection and privacy practices. The CNIL can be contacted by using the following information:
Commission Nationale de l'Informatique et des Libertés – CNIL
3 Place de Fontenoy
TSA 80715 - 75334 Paris, Cedex 07
Phone. +33 1 53 73 22 22
Fax +33 1 53 73 22 00
We also wish to inform you about the contacts of other authorities in Europe that you can find and contact on the website of the European Data Protection Board: https://edpb.europa.eu/about-edpb/board/members_en
When the processing of your Data is based on your consent (e.g., subscription to the newsletter), You may withdraw your consent at any time without justification. This right can be exercised by changing your options regarding subscriptions to our newsletters by clicking on the hyperlink provided for this purpose in each email We send You.
5. How is your Personal Data secured?
ORLOV PARIS uses technical and organizational measures that comply with French and EU legal and regulatory requirements, to keep your Data secure and confidential. Under written agreements, ORLOV PARIS requires its service providers and processors to provide safeguards and implement sufficient security measures to protect the Personal Data they have agreed to process, in accordance with applicable requirements under personal data protection laws. However, ORLOV PARIS does not control all risks related to the operation of the Internet and draws your attention to the inherent risks of using any website.
6. Third party websites
There may be links to third-party websites (such as ORLOV PARIS management affiliates’ websites) that We do not control, and which are governed by their own confidentiality and personal data protection policies. This Privacy Statement does not apply to third-party websites. Please review the confidentiality and personal data protection policies of the third-party websites that You visit to understand how they process your Data. ORLOV PARIS shall not be liable for any use of your Data by any third parties.