chartedeconfidentialite

DATA PRIVACY POLICY

This Policy ("Policy") outlines the data privacy and cookie practices of Etam Lingerie SA, Etam SCE SAS, and ETAM USA and INVESTINT RETAIL subsidiaries of the Etam Group, also referred to as “we”, “our”, or “Etam”. This Policy aims to inform you of the conditions in which Etam collects your personal data, reasons for which this information is collected, the use of this data, and your respective rights. This policy applies to all the information provided by you or collected by Etam during your interaction(s) with us.

Etam places great importance on the protection and respect of your privacy. As this is a subject of significant importance, we urge you to read our privacy policy carefully and in its entirely to know and understand our practices regarding the collection of your personal data. This Policy establishes rules concerning the personal data of all our customers and prospects, regardless of the data collection channel.

When referring to our platform, we are mean to one of the digital and/or physical channels or means through which you can interact with us, such as the website, https://us.etam.com (the "Site"), mobile application, physical Etam stores, mail, or telephone.

In the course of using our Platform, Etam may process personal data concerning you, either collected directly from you or provided by you.

By using our Platform, you are bound by the currently effective Policy, signifying your acceptance of it. As we reserve the right to modify our Policy at any time in accordance with the conditions outlined in Article 7, we strongly recommend reviewing it before every use of our Platform.

1. GENERAL INFORMATION

The distinct entities responsible for processing your personal data are:

ETAM LINGERIE, Anonymous Company, with its registered office at 57/59 rue Henri Barbusse 92110 Clichy, France. Registered with the RCS of Nanterre under number 478 355 753
ETAM SCE, Simplified Joint-Stock Company, with its registered office at 57/59 rue Henri Barbusse 92110 Clichy, France. Registered with the RCS of Nanterre under number 450 966 445ETAM USA, a corporation with its registered office at 614 N Dupont Hwy, Suite 210, Dover, DE 19901, County of Kent under the number 38-4233150
INVESTINT RETAIL INC, a corporation with its registered office at 614 N Dupont Hwy, Suite 210, Dover, DE 19901, County of Kent under the number 30-1319048.

Etam stores in USA are managed by the American company INVESTINT RETAIL, marketing and e-commerce are both managed by Etam Lingerie, Etam USA and Investint Retail. Therefore, your personal data may be used by either or both companies. Etam SCE is the service provider for the Etam Group and manages the information systems of the Etam Group.

Together, we have established common directives and ensure the handling and protection of your personal data.

Through our platform, you may be prompted to provide Etam with personal data, for example, in the context of creating your online customer account, product orders, or subscribing to the newsletter.

Etam may also collect certain information about your navigation on the Site, as more extensively described in the “Cookies” section below.

In compliance with applicable regulations, POGGI AVOCAT IT, Anne-Sophie Poggi, lawyer at Court, 33 rue de l’Opéra, 75002 Paris, FRANCE has been appointed as the Data Protection Officer (DPO) for Etam Lingerie and Etam SCE.

2. CONCERNING DATA

The data we collect, and use varies depending on the products, services, or features you wish to access. The personal data we collect or that you decide to provide include, in particular:

Identification Data: Such as your first name, last name, phone numbers, home address for order delivery, email address for sending the newsletter, photographs you provide, or images when you visit our stores equipped with surveillance systems.
Electronic Identification Data: Available on or from your computer (such as “cookies” or “IP addresses”). Your electronic identification data allows the identification or geolocation (no more specific than the city) of your connection terminal, or the pages viewed on the Site during your navigation and are generally insufficient alone to identify you nominatively. For more information on the collected browsing information, please refer to Article 5 regarding cookies and connection tokens.
Data Related to Your Online or In-Store Purchases: For example, the type, quantity, and price of products purchased.
Data on Your Tastes and Preferences: Such as your preferences regarding our collections, color preferences, habits, and size.

3. YOUR RIGHTS

In accordance with the EU-US Data Privacy Framework, as well as the European Regulation (EU) 2016/679 dated April 27, 2016, relating to the protection of personal data, you hold various rights concerning your personal data. These rights can be exercised directly and at any time by contacting us at privacy@etam.fr, at the postal addresses indicated in point 1 above, simply indicating the reason for your request and the right you wish to exercise. Once we receive your request, we commit to processing and responding to it diligently within a maximum period of 30 days. In case of doubt about your identity, we may ask for a copy of your identity card or other supporting documents. The rights you are entitled to are as follows:

The Right of Access: The right to request a copy of the personal data we hold about you. If your request is unfounded or excessive, we may charge you fees related to this request.
The Right to Rectification: The right to request the correction of inaccurate personal data we have about you. We remind you that if you have a customer account, you have the opportunity to access the section responding to your personal data to modify or update them. You must ensure that this data is true and accurate. Similarly, you commit to inform us of any changes or modifications to this data. We also remind you that, in principle, you should only provide your own personal data and not those of a third party. Any damage or loss caused by the communication of inaccurate or incomplete information in our data collection forms is exclusively the responsibility of the use of our Platform.
The Right to Erasure: The right to request the deletion of your data when one of the following conditions is met:

o Your personal data is no longer necessary for these purposes.
o You have withdrawn your consent, and there is no longer a legal basis justifying the continuation of the processing of your personal data.
o You have validly exercised your right of objection.
o The processing of your data is not legal.
o Or your personal data must be erased to comply with a legal obligation.

However, there are cases where you cannot exercise your right to erasure, even if one of the conditions is filled (especially when the processing of your data is necessary for freedom of expression and information, in compliance with a legal obligation, the exercise/defense of a right in court, or for statistical, archival, public interest research, scientific or historical purposes). To delete your customer account, simply submit your request to privacy@etam.fr at the postal addresses in point 1.

• The Right to Object: The right to object, for reasons relating to your particular situation, to the processing of your personal data based on our legitimate interest. In this case, we will cease processing your data unless we have a legitimate reason to continue processing your data. If your data is used for commercial prospecting purposes, you have the right to object without having to justify yourself.
• The Right to Limit Processing: The right to request, in certain cases, the temporary suspension of the processing of some of your data or their retention, if necessary, for a longer period than necessary.
• The Right to Data Portability: If the processing of your personal data is based on your consent or the execution of the contract, and if the processing is carried out by automated means, you have the right to request the receipt of data concerning you in a structured, commonly used, and machine-readable format, to be able to transfer them to another entity, provided that this is technically possible.
• The Right to Define Directives Regarding the Fate of Your Personal Data in the Event of Death.

You also possess the right to file a complaint against a controlling authority, in particular in the Member State in which you reside, your place of work, or where the violation occurred, if you find that the processing of your personal data concerning you constitutes a violation of the applicable regulations.

In France, the controlling authority is the following: Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, phone number: 0033 1 53 73 22 22

In the USA, you may introduce a complaint before the Data Protection Review Court (DPRC): U.S. Department of Justice 950 Pennsylvania Avenue NW Washington DC 20530, phone number: +1 202-514-2000

You also possess the right to withdraw your consent at any time for any processing based on content. To simply unsubscribe from our newsletter, just click on the unsubscribe link in each email.

4. MANAGEMENT OF PERSONAL DATA BY ETAM

4.1 Purposes and Legal Bases for Data Collection

The following table elucidates the uses of your personal data by Etam (“Purpose”) and the legal basis (“Legal Basis”):

PURPOSE: WHY DO WE PROCESS YOUR DATA?	LEGAL BASIS: WHAT IS THE FOUNDATION OF THIS PROCESSING?	MORE PRECISE
Execution and Tracking of Your Product Orders Placed on the Site	To fulfill the contract	For the proper execution of a purchase contract or service agreement you have entered with us, we process your data through out point-of-sale software. This processing is carried out to manage payments for the products you purchase, as well as to generate associated invoices. Additionally, we process your data to successfully deliver your products and handle any potential returns after the purchase. When you opt for purchasing a product through our Try at Home service. Please refer to the “Try at Home Service Terms of Use” in our General Terms and Conditions of Sale for more information. In the context of the purchase, management, and the use of the gift card. Please read the “Gift Card” section of our General Terms and Conditions of Sale for more information.
Consent		Certain processing of your personal data associated with the purchase process, such as the storage of your payment card details for future purchases, is only activated when you explicitly consent to it.
Legitimate Interest		When you make a purchase, we can carry out the necessary verifications for the detection and prevention of potential fraud.
Execute and Track Your Product Orders Placed In-Store	To fulfill the contract	When you make a purchase in one of our stores, to allow the for the proper execution of your purchase order, our sales representatives will process all your information through our internal application called “App-Mag”. This application is used for placing orders and making purchases in-store, ensuring the proper follow-up of the customer relationship.
Allow and Manage Your Registration as a User of Our Platform	Consent	In creating a user account online, you are indicating certain necessary personal data for identification and to grant you access to various features, services, information, and products available to you as a registered user. The processing of your data is therefore required for the execution of the general conditions of our platform.
Carrying our Commercial Prospecting and Marketing Activities	Consent	If you decide to subscribe to our newsletter, you are consenting us to process your personal data to manage your subscription and/or send you information about our products and/or services, as well as commercial prospecting messages through various means, such as email or SMS. If you participate in a contest via our Platform or our social media networks, you are consenting to your data being used for the purpose of the contest and for the delivery of the prizes you have won. Unless expressed consented by you, the collected data is not used for advertising purposes by us or our business partners. If you accept the above applicable legal terms and conditions (especially on the social networks you use), we may publish on our Platform or various social media networks photographs that you have shared publicly or with us. Subject to obtaining your prior consent, we may record data related to your preferences (such as your size or color preferences) to further personalize your experience with Etam.
Legitimate Interest		We have a legitimate interest in contacting you by phone or by mail to inform you of our commercial offers, as long as you to not object to this during the collection of your data (please note that you can oppose at any time by sending an email to privacy@etam.fr ) Similarly, unless objected by you, we have a legitimate interest in sending you commercial communications through digital channels (e.g. SMS or e-mail) if you are already a client with us and if this communication uniquely concerns product or services similar to those we have already sent to you. Finally, to tailor our marketing strategies to your preferences and your needs to better serve you and respond to your inquiries (personalization of our services via our Platform and messages), we believe that, in certain cases, we have a legitimate interest to carry out profiling with the data provided by you and the information we have about you through cookies that you have accepted to install on your device, including your journey on the site, your preferences (language, colors, type of products, etc.) or the history of your purchases. The performance or strictly necessary cookies for your navigation to your site, notably improve its operation, and offer you a better browsing experience.
Responding to Your Questions, Requests, or Complaints Transferred via Customer Service Channels:	To fulfill the contract	If your inquiry is relative to your purchase or to the product(s) purchased through our Platform, the processing is necessary for the fulfillment of the contract and proper management of after-sales service.
Legitimate Interest		We believe that we have a legitimate interest in processing your strictly necessary personal data to properly manage your requests and complaints and to respond to your inquiries. The data we may process can include photographs if you have decided to send them to us as part of your request or complaint. For the completion of after-sales service procedures (e.g. commercial gestures), we may contact you by SMS or email. When you contact our Customer Service, telephone conversations may be recorded for quality control and training purposes.
Legal Obligation		If your inquiry concerns the exercise of rights outlined in Article 3 “Your Rights” or relates to a complaint about our products and services, we will need to process your data to comply with our legal obligations.
Generate anonymous statistics on the Site’s traffic	Legitimate Interest	We believe that we have a legitimate interest in analyzing the ergonomics and quality of our Platform to enhance the user experience and to offer a better-quality Platform to our clients. Please refer to Article 5 “Cookies and Connection Witnesses”, for more information.
Conducting satisfaction surveys and consumer studies	Legitimate Interest	We consider that we have a legitimate interest in conducting surveys and studies aimed at analyzing the level of satisfaction of our customers to improve the quality of our products and services.

4.2 Duration of Personal Data Storage

The duration of the storage of your data is determined in relation to the purpose that led to the collection of this data. Once this purpose is achieved, your data will be archived, deleted, or anonymized (especially for statistical purposes).

NATURE DES TRAITEMENTS	DUREE DE CONSERVATION
Management of Our Customer and Prospect File	Storage during a period of 3 years from your last contact with us (for example, for customers, a purchase, or for prospects, a click on a hyperlink in an email) or until the withdrawal of your consent.
Your Questions Addressed to Customer Service	Storage for the necessary period for the processing of your request. Regarding the recordings of telephone conversations with our Customer Service, they are kept for a limited period (up to 6 months at most), except in exceptional cases (for example, for investigation purposes, fraud, or for a legal reason).
Your Electronic Identification Data (Your connection logs collected, subject to your agreement and the settings of your device, through the use of cookies and other trackers placed on our Site)	Storage in accordance with the applicable regulation for a period not exceeding 13 months. For more details on cookies, their operation, and your ability to disable them, see Article 6 “Cookies and Connection Witnesses” below.

4.3 Data Recipients

Your personal data are intended for the relevant Etam services related to your requests. However:

When you order a product on our Site, the personal data that you have communicated in the context of the purchase are intended for the Etam Group, or for its subsidiaries in charge of executing the said purchase.
The processing of your personal data is authorized for third-party that we have used to provide certain services. These include: o Technical service providers and approved online payment services. o Service providers related to customer service and marketing. o Providers of fraud detection and prevention services.
Only when you have provided us with your consent, we may share your data with certain business partners.

The transfer outside of Europe of your personal data are carried out by putting into place the appropriate guarantees and in preserving the security of your data. Indeed, the transfers are or will be based on a decision of adequacy from the European Commission assuring a certain level of adequate protection. In the USA, the decision is named the Data Protection Privacy Framework and has been validated by the European Commission on Etam can also be required to relay your personal data concerning judicial and police instances, regulatory authorities, public bodies, or third-party companies to comply with a court order, summons, notice, search warrant, or all other legal or regulatory obligation or request. Such transfer may also be done to protect against fraud or in investigation potential of

4.4 Data Security

Etam has endeavored to put into place the reasonable precautions to preserve the confidentiality, integrity, and availability of all processed personal data and to prevent that the previous be distorted, damaged, destroyed, or accessed by unauthorized third parties. Organizational and technical security measures have been installed for this purpose. Etam does not control all the risks associated to the function of the Internet and draws the attention of users to the possible risks inherent in its use and operation. For the technical storage of your personal data, your data will be centralized with the following service providers.

• OXya – in Ile-de-France and Hauts de France,
• Salesforce Commerce Cloud - in Ireland,
• Amazon Web Service - in Germany and in Ireland
• OVH - in Hauts-de-France,
• OCI – in Ile-de-France in Paris,

Etam places the greatest importance to the protection and security of its information systems. Tools have been set into plays to permit Etam to detect potential security vulnerabilities. These tolls may incidentally lead in access to personal data by security teams. This data will be collected and processed exclusively for the management of its vulnerabilities and in respect to the applicable regulations regarding the protection of personal data.

5. MANAGEMENT OF YOUR PAYMENTS AND DELIVERY OF YOUR PRODUCTS

The current Policy concerns uniquely the use of personal data, as described in the above-mentioned Article 4, by Etam Lingerie, in its capacity as the data controller.

We inform you that although Etam Lingerie currently operates the website https://us.etam.com , all purchases on the internet must be made through the Global-e Payment Page and with Global-e France SAS (referred to as “Global-e”), out subcontractor and payment service provider. Global-e offers order processing preparation services and sells all products and services purchased on our site. The payment pages are provided by Global-e, and after successful verification by Global-e of the order and payment information, Global-e purchases merchandise from Etam Lingerie and resells them to the resells them to the customer in accordance with Global-E’s Terms of Use.

Therefore, when you make a purchase of products and services on the website https://us.etam.com, the transaction must be processed via the payment page of Global-e. Your personal data will be then collected and used by the company Global-e for the purpose of processing your order (payment and delivery of your products).

In your position as a customer, you should then refer to the privacy policy of Global-e for more details on how your personal data is used and stored.

6. COOKIES AND CONNECTION WITNESSES

6.1 What is a cookie?

A cookie is a text file susceptible to being saved in a dedicated space on your electronic device’s hard in the instance of the access of an online service using your web browser. A cookie file allows its issuer to identify the terminal in which is saved, during the cookies’ valid period or registration period.

6.2 Cookies issued on the site. When you connect to the site, Etam can be brought, in conformity with your decision, to install various cookies, allowing, in particular, the recognition of the browser you are using during the valid period of the relevant cookie.
The issued cookies have the following purposes:

• To establish statistics and volumes of attendance and use of various elements making up the Site (sections and contents visited, paths), allowing Etam to improve the intent and ergonomics of services, as well as the visibility of the published contents.
• To allow of facilitate you navigate of the site, or to provide you with the online communication services that you request during your navigation, and thus:
• To adapt the presentation of the site to the display preferences of your terminal (language used, display resolution, operating system used, etc.) during your visits to the site, according to the visualization hardware and software or reading that your terminal contains.
• To memorize information relative to a form that you have filled out on the site (registration or access to your account) or to products, services, and information that you have chosen on the site (subscribed service, content of a shopping cart, a wish list, etc.).
• To allow you to access reserved and personal spaces on the site, such as your account, using identifiers or data that you have previously confided.
• To put into place security measures, for example, when you are asked to log in again to content or a service after a certain period.
• To share information with advertisers on other websites to offer you relevant advertising in line with your interests. In this instance, we use advertising cookies.

6.3 Cookies issued on the site by third parties.

Etam is susceptible to including computer applications on the site, which allow you to share site content with other people or to inform these other people about your viewing or opinion regarding the site.

The issuance and use of cookies by third parties are subject to the privacy policy of these third parties.

Etam does not control the process employed by social networks to collect information regarding your browsing on the site. Etam invites you to consult the privacy policy of these social networks to better understand the terms of use, including advertising, of the browsing information they may collect through these application buttons. These privacy policies should allow you to exercise your choices with these social networks, including by configuring your user accounts for each of these networks.

The site may contain cookies issued by third parties (communication agency, audience measurement company, etc.) allowing these third parties, during the duration of the validity of these cookies, to collect browsing information about the Terminals consulting the site, particularly to measure the effectiveness of paid advertising campaigns with search engines.

6.4 Your choices concerning cookies.

Multiple possibilities are offered to manage cookies through our cookies management tool OneTrust. Any settings that you may undertake will be likely to change your internet browsing and your access conditions to certain services requiring the use of cookies. You can choose to make the choice at any moment to express and modify your cookies preferences through the means described below. You can configure your browsing software to allow cookies to be stored on your device or, on the contrary, to reject them, either systematically or depending on their origin. You can also configure your browsing software to accept or reject cookies on a case-by-case basis before a cookie is likely to be stored on your device. For more information, refer to the section “How to exercise your choices, depending on the browser you use?” For more details about the deposited cookies, follow this link. To modify your cookie preferences, check the “Cookie Settings” section at the bottom of the site page.

(a) Cookie Consent.
The storing of a cookie in a terminal is essentially subject to the user’s will, which the user can express and modify at any time and free of charge through the choices offered by their browser software. If you have accepted the storage of cookies in your browser software, cookies embedded in the pages and content you have viewed may be temporarily stored in a dedicated area on your terminal. They can only be read by their issuer.

(b) Refusal of Cookies.
If you refuse the storage of cookies on your device, or if you delete those that you have stored, you will no longer be able to benefit from several features that are necessary for navigating in certain areas of the site. This would be the case if you tried to access content or services that require identification. This would also be the case if Etam or its providers could not recognize, for technical compatibility purposes, the type of browser used by your terminal, its language and display settings, or the country from which your terminal appears to be connected to Internet. In this case, Etam declines all responsibility for the consequences related to the degraded operation of its services resulting from our inability to store or consult the cookies necessary for their operation and that you have refused or deleted.

(c) How to exercise your choices, depending on the browser you are using?
For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, that allows you to understand how to modify your preferences regarding cookies.

6.5 If you share the use of your device with others.

If your terminal is used by multiple people and when a single device has multiple browsing software, Etam cannot ensure with certainty that the services and advertisements intended for your device correspond to your own usage of the device and not to that of another user of the device. In such case, sharing the use of your terminal with multiple people and the configuration of your browser settings regarding cookies are your free choice and responsibility. For more information on cookies and their use, you may contact the file of the National Commission for Informatics and Liberties at the following address: https://www.cnil.fr/fr/site-web-cookies-et-autres-traceurs.

7. MODIFICATION OF THE POLICY

Etam may need to modify the Privacy Policy and will that you will be informed either by a special mention on the site or by a personalized notification, particularly in the newsletter communications.

8. POLICY ON PERSONAL DATA RELATING TO MINORS

Our Site does not target minors as its audience. Therefore, we do not knowingly collect, nor do we wish to collect, the personal data of user who are under the age of 16, unless consented or authorized by your legal guardian.

If you are under the age of 16 and you do not have authorization from your legal guardian, we ask you to not provide us with personal data and to only use our Site if you have informed your legal guardian and have their consent and assistance.

We ask the legal guardian of children under the age of 16 to contribute to the enforcement of our Personal Data Privacy Policy by ensuring that they never provide us with personal data without their prior authorization.

If information of collected about a minor, the legal guardian of the minor may contact privact@etam.com to correct, modify, or delete this information. The person concerned, if she was a minor in the moment that her personal data was collected, may also contact us so to have the relevant data erased from our databases.

If we become aware that the personal data of individuals under the age of 16 have been collected by our Platform without the consent or authorization of the legal guardian, we will take all necessary measures to delete this personal data from our servers.