CHARTE DE CONFIDENTIALITÉ

1. PURPOSE OF THE POLICY

The company BEVERLUX, operating under the brand SOPHIA DELLI, offers for sale its designer steel jewelry (hereinafter referred to as the “Products”) on its website www.sophiadelli.com (the “Site”) and in its physical store located at 153 rue du Temple, 75003 Paris.

In order to offer, sell and deliver its Products, SOPHIA DELLI collects personal data (“Data”) from users of its website and from its customers when purchases are made in its physical points of sale (the “Customer(s)”).

This privacy policy (the “Policy”) is intended to inform said Customers of the means implemented to collect, access, process and store their personal data.

2. DATA CONTROLLER

SOPHIA DELLI, in its capacity as data controller, undertakes to comply with the provisions of Regulation (EU) No. 2016/679 of April 27, 2016 relating to the protection of personal data.

When a Customer uses the Site www.sophiadelli.com, SOPHIA DELLI may collect personal data concerning the Customer such as:

• Their last name, first name and username
• Their postal and email addresses
• Their tax information
• Their telephone numbers
• Their date of birth
• Their transactions on the Site
• The details of their orders
• Their bank card numbers
• Their communications with customer service (“Customer Service”)
• And any other information that the Customer agrees to provide to SOPHIA DELLI

Information relating to the devices used by the user to access the Site is also collected, in accordance with applicable legislation, including IP address, connection data, types and versions of internet browsers used, types and versions of browser plugins, operating systems and platforms, data relating to browsing activity on the Site, and user preferences.

The Customer is informed that certain Data must be collected by SOPHIA DELLI in order to provide its services. Certain services may be impaired or unavailable in the absence of consent to the collection of the Data referred to in this Policy.

3. LEGAL BASIS

The legal basis for the processing is consent. The provision of personal data is necessary for the performance of the services offered by SOPHIA DELLI; failing to provide such personal data, the services provided by SOPHIA DELLI may not be able to be performed.

4. COOKIES

Cookies are text files, often encrypted, stored in the browser. They are created when a user’s browser loads a given website: the site sends information to the browser, which then creates a text file. Each time the user returns to the same site, the browser retrieves this file and sends it to the website’s server.

Two types of cookies can be distinguished, which do not have the same purposes:

• Technical cookies are used throughout browsing in order to facilitate navigation and to perform certain functions. A technical cookie may, for example, be used to store responses entered in a form or the user’s preferences regarding the language or the presentation of a website, when such options are available.
• Advertising cookies may be created not only by the website on which the user is browsing, but also by other websites displaying advertisements, banners, widgets or other elements on the page displayed. These cookies may notably be used to deliver targeted advertising, that is to say advertising determined according to the user’s browsing activity.

SOPHIA DELLI uses technical cookies stored in the Customer’s browser for a period of six (6) months. However, advertising cookies may be used in the future. Where applicable, the Customer will be informed in advance and may, if they wish, disable these cookies.

For information purposes, the Customer is reminded that it is possible to refuse the use of cookies by configuring their browser. Such refusal may, however, prevent the proper functioning of the Site. For more information on configuring cookies depending on the browser:

• Google Chrome
• Safari
• Internet Explorer
• Mozilla Firefox

5. PURPOSES OF DATA COLLECTION

The Customer’s Data collected in the course of using the SOPHIA DELLI website is processed for the purposes described in the table below:

*Customers’ bank details are not collected directly by SOPHIA DELLI.

*The Customer may unsubscribe from the mailing list at any time by clicking the unsubscribe link at the bottom of each newsletter email.

The Customer may modify their personal data and withdraw their consent at any time by logging into their customer account. The Customer also undertakes to provide only truthful, accurate, complete and up-to-date Data, without impersonating any third party.

6. DATA RETENTION PERIOD

Personal data shall not be retained beyond the period strictly necessary for managing the commercial relationship between SOPHIA DELLI and the Customer:

• So-called “cookie” Data is retained for a period not exceeding twelve (12) months from its placement on the Customer’s device;
• Data collected when the Customer registers on the Site is retained for the duration of the relationship between SOPHIA DELLI and the Customer;
• Data relating to orders placed on the Site is retained for a period not exceeding five (5) years from the date of the last Order.

However, data enabling proof of a right or a contract, which must be retained in order to comply with a legal obligation, shall be kept for the period provided for by applicable law. Furthermore, in the event of a dispute or non-compliance with the T&Cs, SOPHIA DELLI reserves the right to retain any data it deems necessary for the duration of the proceedings or the resolution of the dispute.

In order to allow the Customer to make recurring purchases or to pay related fees on the Site, data relating to their bank cards is retained for the duration of their registration on the Site and, at the latest, until the Customer completes their last transaction, without exceeding a period of thirteen (13) months. By ticking the box expressly provided for this purpose on the Site, the Customer gives their explicit consent to such retention.

7. DATA RECIPIENTS

SOPHIA DELLI undertakes not to share any personal Data with third parties without the Customer’s consent, nor for commercial purposes. The Data collected is shared with service providers and subcontractors solely to ensure the proper functioning of the Site and the proper management of orders placed on it (in particular deliveries).

Information relating to financial transactions is entrusted to a payment service provider who ensures their proper processing and security. SOPHIA DELLI does not have access to this information, and data relating to the card verification value (CVV2) on the bank card is not stored.

Data may also be communicated to any police or administrative authority in the context of legal requisitions relating to fraud prevention, as well as to customs services and providers in the event of international delivery.

8. CUSTOMER’S RIGHTS REGARDING THEIR DATA

In accordance with Articles 14 to 22 of the GDPR 2016/679 of April 27, 2016, any natural person using the SOPHIA DELLI website has the right to exercise the following rights:

• A right of access, rectification and deletion of the data collected
• A right to object to the processing of their data
• A right to restriction of processing
• A right to data portability
• A right to erasure and to the communication of personal data after death, in accordance with Article 40-1 of Law No. 78-17 of January 6, 1978.

The Customer may also at any time refuse that their Data be used by SOPHIA DELLI or its partners for the sending of advertising offers or other marketing purposes.

The Customer may exercise all of these rights by logging into their customer account, by contacting customer service at contact@sophiadelli.com, or by simple mail to SOPHIA DELLI – 153 rue du Temple, 75003 Paris, France. The Customer must attach proof of identity to their request.

In the absence of a response (beyond a period of one (1) month) or in the event of an unsatisfactory response, the user may refer the matter to the supervisory authority of their country of residence; for France, the CNIL: https://www.cnil.fr.

9. SECURITY

SOPHIA DELLI takes all appropriate precautions, as well as suitable organizational and technical measures, to preserve the security, integrity and confidentiality of Customers’ personal data and, in particular, to prevent it from being altered, damaged or accessed by unauthorized third parties.

In order to ensure the security of personal data, SOPHIA DELLI has implemented measures such as:

• Access management restricted to authorized persons
• Storage of Data on secure servers
• Access to the customer account via a username and confidential password

10. AMENDMENTS

SOPHIA DELLI reserves the right to modify this Policy at any time in order to comply with any regulatory, case law, editorial or technical developments. Users must refer to the latest version of the Policy before browsing the Site.