PRIVACY POLICY
This privacy policy ("Privacy Policy") describes how SIMONE PERELE, S.A.S., a public limited company with a capital of 1,000.000 €, registered with the Nanterre Trade and Companies Register n° B622 041 713 713 and n° Siret 622 041 713 00117, whose registered office is located at 1, rue de Stockholm – 75008 Paris, as well as its subsidiaries in France and the European Union and its affiliated partners operating the Simone Pérèle brand (hereinafter referred to together as "SIMONE PERELE" or "WE"), use your personal data.
It applies as soon as SIMONE PERELE processes personal data concerning you, in particular during a visit to one of our points of sale under the Simone Pérèle brand or during your browsing on one of our commercial sites, in particular the one accessible at the address "https://www.simone-perele.com". (hereinafter collectively the "Site").
The list of Sites is at the top of the page.
This privacy policy aims to explain to you in a transparent manner how SIMONE PERELE collects and processes your personal data in accordance with the requirements of Act No. 78-17 of 6 January 1978 on data processing, data files and individual liberties, as amended, and European Regulation 2016/679 of 27 April 2016 (hereinafter referred to together as "the Regulation").
WHY WE COLLECT YOUR INFORMATION
We collect your Information only if it is required. When you shop from store owners we fulfill their orders (“Store Owners”), and use our Services, we need to process the transaction and make sure the products are delivered to you. For fulfilling the Services, will need your Information, such as your name, email address and delivery address. We will also need your payment details (e.g. credit card number) to have your payment processed by our contracted payment processors. If you contact customer support, other relevant information will be needed to help solve the inquiry. In some cases, we collect your Information following your consent, for our legitimate interests or if bound by a legal obligation, as detailed further.
INFORMATION WE COLLECT
For providing you with the Services, we collect your first name, last name, email, phone number, postal address and payment information including the payment method and payment details (or payment voucher details) that you provide us. We may also collect identity number (local ID, passport) if such information is required by your country for example to facilitate customs clearance or remittance of import taxes and duties. If you have contacted Global-e costumer services with enquiries, we will receive and process any Information that you provide us for resolving such matter.
HOW WE COLLECT INFORMATION
Purchases. We receive and collect Information directly from you when you interact with any of the Global-e, Borderfree or Flow checkouts. When you place an order for the purchase of merchandise offered on the Store Owners’ sites, we fulfill such orders and you provide us with the information required for processing your online transaction and for delivering the order to your chosen delivery address or providing costumer support in accordance with our Terms of Sale. If you have a Borderfree account, you already provided us with parts of your Information through your Borderfree user account. Please refer to the specific terms and policy that applies to such Borderfree user account.
Store Owners. In certain cases, where for example, you are pre-registered with the Store Owner or the payment method, we may receive part of the Information from the Store Owner to pre-populate transaction in forms for ease of completion by you.
Log Files. We use log files that, where permitted by applicable law, we collect automatically from your computer or device when you interact with the Services. The information contained in log files includes internet protocol (or IP, which is the unique address that identifies your computer or device on the internet), type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser sends us.
Cookies. We use cookies and similar tracking technologies to make sure that our Service is continuously improved and meets your needs. Please review our full Cookies Policy for more information on the types of cookies we use and their expiration dates. We use essential cookies for providing, improving, and optimizing our Services and your experience. Our cookies include cookies provided by third parties used to secure your transaction and to create statical reports based on aggregated and anonymized Data. We use standard analytics tools such as of Google Analytics, Hotjar, Heap and Fullstory (the full and current list is stated in the Cookie Policy).
Do Not Track (“DNT”)
Web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is a HTTP header field indicating your preference for tracking your activities on the Service or through cross-site user tracking. Our Service does not respond to DNT signals.
USING YOUR PERSONAL INFORMATION
By choosing to use the Services for the purchase of goods, you provide us with the legal basis to use and retain your Information as needed to provide you the Services and to improve them.
As a matter of legitimate interest, or business purpose, if applicable, and to the extent permitted by applicable law, we may use your Information to maintain our business relationships and operations, including to support Store Owners, testing new features and prevent and detect fraud and abuse of our Services. In addition, we may also create aggregated statistical data, inferred non-personal data or anonymize data for personalizing your user experience, troubleshooting and to ensure our content and Services are presented in the most effective and relevant manner for you and your device.
We may use the Information to communicate with you in relation to the Services, and in relation to security inquiries or other administrative communications related to transactions you have initiated or completed through our Services. Such communication might include request to identify or authenticate your access to the Service, and are required for maintaining the integrity and security of our customers and systems, Services and business. Please note that such communications are not related to marketing, and therefore, we do not rely on or require your consent.
Analyzing anonymous, aggregated and analytical Information
To the extent permitted by applicable law, we may share anonymize information, or aggregated information from multiple users with the Store Owners, marketing and public relations agencies, or other third parties including our subsidiaries and affiliated companies. This information does not contain Personal Information. We have secured procedure for de-identifying or anonymizing your Information. This ensure that this data cannot be re-identified. When using anonymized information, we will do so without notice to you. We will also disclose Anonymous Data (with or without compensation) to third parties, including advertisers and partners.
“Anonymous Data” means data that cannot identify an individual user, whether directly or indirectly, and such identification is irreversibly prevented, such as aggregated data about the use of our Service. Therefore, such data does not constitute “Information” and the use and disclosure of same would not affect any of your rights under applicable privacy laws.
Direct Marketing from Store Owner or Borderfree.com
You will be offered the ability to provide your specific consent via our Service to receive direct marketing materials by either email, telephone, text message or post, relating to consumer goods and services generally available via our Service, including offers by brands from which you may have previously purchased through us or which may be of interest to you.
Your Information may be used for direct marketing sent by Borderfree.com, provided your consent was duly given. You have the right to object to the processing of your Information specifically for direct marketing purposes.
If you wish to opt-out from direct marketing communication please contact us for any communication received from Borderfee.com. If you received communication from the Store Owner, please contact the Store Owner directly. Alternatively, you can use the ‘unsubscribe’ features made available through the relevant marketing communication.
SHARING YOUR PERSONAL INFORMATION
For providing you with the Services, we will share you data with the following third parties:
Store Owners. In connection with using our Services to make purchases of products available on webstores, we will share the Information with such specific Store Owner who operates the website through which you made your purchase. Such Store Owner will then be entitled to use your Information as if that Store Owner has collected this information directly, subject to the Store Owner’s own privacy policy. For instance, the Store Owner needs to know that you have made a purchase in order to process its delivery, to handle any requests with respect to the items you purchased or process returns/replacements. The Store Owner may also need to use the Information to validate your subscription or membership or otherwise allow you to take advantage of any loyalty scheme that it administers.
Using Global-e affiliates for Information processing. We will share your Information with our subsidiaries and group companies (listed <<here>>) if your purchases are made from locations which require such transfer for the performance of the Services or delivery of your order, or for such other data processing related to the acquiring of your order, customs clearance and import formalities or fulfilling tax filing obligations directly related with the fulfilment of your order. We will also share and transfer Information to our affiliated companies for storing or processing such information on our behalf in connection with our provision of the Services. Such information will be transferred to other jurisdictions around the world where our servers and systems are located, as described under the “Transferring Personal Information outside your Territory” below.
Using third party service providers. We will share (insofar as such sharing is necessary) your Information with our third-party service providers (such as hosting providers, payment processors, fraud detection and prevention service providers, licensed customs brokers, data and website analytics services and order fulfilment providers) whose tools, software, and services we use to process and complete your transaction(s).
We do not sell your information to others, and do not share your Information with third-parties other than as outlined under this Policy, or to the extent necessary for providing you with the Services.
Legal Obligation and necessary disclosure. We may use the Information to comply with any applicable legal obligations, to enforce any applicable terms of service and to protect or defend the Services, our rights, the rights of our users/customers or others. We will disclose your Information or any information you submitted if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; enforce the terms of sale, including investigations of potential violations thereof; detect, prevent, or otherwise address fraud or security issues; or protect against harm to the rights, property or safety of Global-e, its users, yourself or the public.
Sharing Information in case of a Structural Change. We will disclose or transfer your Information if we are acquired by or merged with a third-party entity, or if we are bankrupted or liquidated. If we will use your Information or disclose for any purposes not covered in this Policy in this regard, then we will make efforts to ensure that you receive prior notification of the new purpose and where relevant or required by applicable law, your consent obtained for those new purposes. We base such processing operations on our legitimate interest(s), as well as on certain legal obligations we may be subject to.
Data Protection Framework (DPF). Global-e US Inc. our US subsidiary, complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Global-e US Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/ and will be further liable in cases of onward transfers of your personal data to third parties (including our Service Providers).
Complaints about transfers of data from the EU or the UK to the US & dispute resolution: In compliance with the DPF Principles, we commit to resolve complaints about our collection or use of your personal data. EEA and UK individuals with inquiries or complaints regarding our DPF compliance should submit enquiries to dpo@global-e.com.
If a privacy complaint or dispute relating to personal data received by us in reliance on the DPF cannot be resolved through our internal processes, you did not receive a timely acknowledgement of your EU-US DPF-Principles related complaint from us, or we did not address your EU-US DPF Principles related complaint to your satisfaction, in compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Global-e US Inc. commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to JAMS, an alternative dispute resolution provider based in United States, If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Please note that under certain conditions (as described under the DPF Principles Global-e US Inc. adheres to) you can invoke a binding arbitration by delivering a notice to Global-e US Inc. Inc. via dpo@global-e.com. Please also note that Global-e US Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
TRANSFERRING PERSONAL INFORMATION OUTSIDE YOUR TERRITORY
Global-e adheres to applicable laws and regulation regarding the transfer of Personal Information across jurisdictions and geographical regions.
- Global-e data servers are located in the European Economic Area (“EEA”). If you used Global-e services, your data is stored and processed in Ireland.
- Borderfree services are located in the USA. If you used Borderfree services, your data is stored and processed in the USA.
For providing you with the Services, and as part of our cross-border operations, the Information we collect from you may be transferred to Israel, the United Kingdom (UK), the European Union and the United States, and shared between Global-e entities, and additional parties, including the Store Owner and other service providers and sub-processors for fulfilling our Services. We require such third parties to process such information in compliance with Global-e policies and procedures.
Global-e accepts full responsibility for the protection of your Information, according to the applicable privacy legislation and this Policy during these onward transfers to third parties.
If you are a resident of, or placing your order for fulfilment into one of the countries listed in the section of “Additional information for users of certain jurisdictions”, additional and specific terms may apply to you. Please review them.
PROTECTING YOUR INFORMATION
We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the integrity and security of the Information. For example, certain sensitive Information (such as data relating to fraud) is transmitted over a Secure Sockets Layer channel and is encrypted; our payment gateway is Payment Card Industry compliant. However, no method of transmission over the internet, or method of electronic storage, is 100% secure.
Your Information will also be retained by us as necessary to and relevant to our legitimate operations, including time necessary to identify, issue or resolve legal proceedings, enforce our terms of sale, to meet our reporting requirements and as otherwise required in accordance with applicable law obligations.
We will take appropriate steps to delete or permanently de-identify (as permitted by applicable law) or anonymize Information at the point such information is no longer needed by us for our legitimate business or legal obligations. While we strive to use generally accepted means to protect your Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Service, you can contact us at: dataprotection@global-e.com.
Your Choice
We request and collect minimal data needed for the purposes described in this Policy. At any time, you may opt to terminate your use of the Service. Thereafter, we will stop collecting any Information from you. However, we will store and continue using or making available certain Information that is related to you. For further information, please read the “Protecting Personal Information” section in this Policy.
YOUR RIGHTS UNDER DATA PROTECTION LAWS
In accordance with the laws applicable to you within your geographical region, you may have the following rights with regard to you Information.
Access the Information. If you are eligible for the right of access under the applicable law, you can obtain confirmation from us of whether we are processing Information about you and receive a copy of that data. We may need to ask you to provide us certain credentials to make sure that you are who you claim you are. At any time, you can request to access the Information that we keep about you in our privacy center. We will make good-faith efforts to locate your Information that you request to access.
Rectify the Information that we keep about you. If you find that the Information is not accurate, complete or updated, then you may provide us with the necessary information to rectify it.
Delete your Information. In some cases, you have the right to obtain the erasure of Information concerning you. We will review your request and use our judgment, pursuant to the provisions of the applicable law, to reach a decision about your request.
Restrict the processing of your Information. In some cases, you have the right to obtain restriction of the processing of your Information.
Transfer your Information in accordance with your right to data portability. You have the right to receive the Information concerning you which you have provided to us, in a structured, commonly used and machine- readable format, and you have the right to transmit that Information to another controller without hindrance from us. This right only applies when the processing of your Information is based on your consent or on a contract and such processing is carried out by automated means.
Objection to processing. In certain circumstances, for processing operations based on our legitimate interest(s), you have the right to require us to stop processing your Information that we hold about you. When your Information is processed for direct marketing purposes, you have the right to object at any time to the processing of the Information for such direct marketing purpose. Please contact us or the relevant Store Owner directly to opt out of their marketing activities, or use the ‘unsubscribe’ features made available through the relevant marketing communication.
Automated decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
CHILDREN'S PRIVACY
The Service is not structured to attract or be directed to anyone under the age of 16 years or the Minimum Age applicable in your jurisdiction. Accordingly, we do not intend to collect Information from anyone we know to be under 16 years or the relevant Minimum Age. In certain countries, as listed in the section of “Additional information for users of certain jurisdictions”, the Minimum Age may be different.
If we learn that we have collected Information from a person who is younger than 16 years or the applicable Minimum Age, we will delete that information quickly. If you believe that we have any such information, please contact us at: dataprotection@global-e.com.
OTHER SITES AND SERVICES
The Service contains links to third party websites and services that are not owned or controlled by Global-e including third party payment providers. We are not responsible for the privacy practices or the content of third party websites or services and your use of or connection to such links and websites is at your sole risk. You should review their privacy policies.
CHANGES TO THIS POLICY
From time to time, we will update this Policy. If the updates have minor to no consequences, they will take effect 7 days after we post a notice on the Service’s website. Substantial changes will be effective 30 days after we initially posted the notice.
Until the new policy takes effect, if it materially reduces the protection of your privacy right under the then- existing policy, you can choose not to accept it and terminate your use of the Services. Continuing to use the Services after the new policy takes effect means that you agree to the new policy. Note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required by law.
Update : 13/09/2023