Version 1.0 of January 7, 2020
DISPEL attaches great importance to the processing, confidentiality and security of your personal data. We are dedicated to offering you personalised services while respecting your privacy and personal choices.
The purpose of this Charter is to inform you clearly, simply and fully about the use by DISPEL of the personal data of its customers and/or potential customers (“you” and “your”) as well as the rights and options that you have. We thus invite you to read it carefully and to take note thereof before every interaction with us.
This Charter applies to the customers and visitors of the DISPEL Website as well as the customers and potential customers visiting the Boutiques directly operated by DISPEL within the US.
DISPEL has appointed a Data Protection Officer responsible for ensuring compliance with this Charter and, more generally, compliance with applicable data protection regulations. Our Data Protection Officer can be contacted for any question concerning this Charter according to the modalities shown under heading 3 "Your Rights" of this Charter.
DISPEL can modify this Charter from time to time to take into account statutory and regulatory changes as well as to keep you informed of the modifications of our practices concerning the processing of your personal data. Every important modification materially affecting the way in which we use your data shall be notified to you by e-mail and/or information on the Website (for example, a banner, a pop-up window or a push notification), in order to allow you to review the changes made, asses them and, if necessary, object to them or withdraw from a service or functionality.
1. GENERAL INFORMATION – DISPEL’s ROLE AND RESPONSABILITY
Unless there are any other provisions that provide otherwise with regard to certain specific instances of processing of personal data, the processing of your personal data that is described in this Charter shall be performed by SSGRP LLC, a California limited liability company with its principal place of business in Los Angeles, California. This entity acts as data controller within the meaning of applicable regulations concerning personal data and is referred to hereinafter as “DISPEL”.
2. MANAGEMENT OF PERSONAL DATA BY DISPEL
- DISPEL collects, stores, processes, uses and communicates your personal data when you use our Website www.DISPELWEBSITE.com (the “Website”), you visit our pages on social networks, you make purchases at the DISPEL Boutiques located in the US, you contact DISPEL and, more generally, when you join the DISPEL community.
2.1 Objectives pursued by DISPEL
DISPEL collects your data to:
- Reply to your requests, questions and claims:
- Send you our DISPEL offers, news and events, according to the means of communication that you have chosen
- Notify you of the online availability of an out-of-stock product (availability warning)
- Inform you of the launching of an event
- Reply to you when you have contacted us (by means of the online contact form or by e-mail/telephone to the customer service).
- Manage your integration into the DISPEL community, the orders and purchases you make in a Boutique or online and fulfil our contractual and statutory obligations:
- Execution, delivery and monitoring of your orders/purchases (including customs clearance)
- After sales service for any purchase
- Execution of the guarantees applicable for any purchase
- Management of your personal account on the Website
- Management of your request(s) when exercising your rights (see the Section 3 “Your Rights”).
- For the legitimate interests of DISPEL:
- Ensure the management of our relations with you by keeping updated a centralised database which includes existing and potential customers
- Establish your customer profile in order to manage in a proactive and personalised manner the monitoring of the business relationship. This processing involves the analysis of your user or customer profile to determine what your preferences are and to offer you products that we believe may be of interest to you
- Allow users to recover a shopping cart in progress
- Carry out studies and statistics in order to better understand our clientele and improve our services (internet site, newsletter, effectiveness of advertising campaigns, etc)
- Ensure the security of online transactions as well as prevent fraud and payment incidents (both in DISPEL Boutiques and online)
- Ensure the security of goods and persons in DISPEL Boutiques (CCTV)
For all these purposes based on our legitimate interest, we make sure to take into account any potential impact that this processing may have on you and more generally on the users of the Website. If we think that your interest or your fundamental rights and freedoms override our legitimate interest, we will then not use your personal data on this basis, and may ask you for your specific consent.
- Additional note concerning automated decision-making in the framework of the fight against fraud on Internet
We use automatic fraud detection algorithms to control your online purchases in order to prevent fraudulent transactions and payment incidents. These algorithms analyse the transactional information concerning your order, as well as the information concerning the device from which the order was placed (see section 2.2 “Data collected by DISPEL” for more information) and can result in blocking the transaction. If we consider that the transaction may constitute an attempt at fraud, a manual analysis of the blocked transaction is carried out by our customer service and can lead us to collect additional personal data for the purposes of verifying your identity, the validity of the order, the payment method used, or the delivery envisaged.
2.2 Data collected by DISPEL
The term “personal data” means any information allowing you to be directly identified (your last name and first name) or indirectly (the customer identifier that we attribute to you in our systems).
For the purposes specified above, DISPEL collects and processes the following categories of data:
- Identification and contact data: for example, your identity, e-mail address, telephone number, the country from which you interact with us, your connection identifiers on the Website, your internal DISPEL identifier, etc.
- The information concerning your identity document in limited, specific cases (in particular: additional verification in the framework of the prevention of fraud, verification of cash payments in DISPEL Boutiques, verification of the identity of the person exercising the right)
- Data concerning the transaction: for example, the articles chosen, the order number, your postal address for delivery and invoicing, means of payment, banking details, etc.
- Data concerning the monitoring of our business relationship: for example, your customer profile, the history of your purchases, returns and exchanges of articles, the history of your contacts and claims or of your correspondence with our customer service, etc.
- Connection data concerning the terminal used: your IP address, location of the terminal, use or not of a proxy, type of browser and browser information, etc.
- CCTV recordings.
The information communicated directly by you and essential to DISPEL to fulfil the purposes pursued is indicated by an asterisk on the various forms that you fill in, both in DISPEL Boutiques and online. If you do not fill in these required fields, DISPEL cannot reply to your requests and/or supply you with the products and services requested. The other information of the various forms is optional and allows us to know you better in order to meet your expectations more accurately and to be able to send you, if you accept it, information about new DISPEL collections, promotions and private sales, events, etc.
In our Boutiques or during events that we organise (for example: fashion shows or private sales in your usual Boutique), we may gather additional personal data under the conditions and for uses that are specifically notified to you on this occasion.
2.3 Retention of your personal data
The data is kept for a period that does not exceed the necessary duration for the purposes for which it has been collected and which are specified above.
Your personal data is kept by DISPEL:
- The necessary time to reply to your request, question, or claim: for example, for the duration of registration for the newsletter (i.e. until your deregistration), until the sending of the availability notice of a product, or as long as you maintain your customer account on our Website
- Up to 10 years if you are a “customer”, i.e. you have purchased one of our products or services. This period will be renewed each time you interact with us
- 3 years if you are a “prospect”, i.e. you have never purchased one of our products or services but you are interested in the brand. This period will be renewed each time you interact with us
- 13 months for cookies placed in your computer
- 3 month for CCTV recordings. In the event where the recordings are necessary for the defence of DISPEL’s interests in the framework of criminal proceedings, the images are then extracted from the system and kept for the duration of the proceedings
- 48 hours to carry out the processing of abandoned shopping cart reminded
- The duration of judicial, criminal or commercial proceedings when the data is necessary for the defence of the rights and interests of DISPEL.
The data is then deleted definitively from our systems or anonymised so that you are no longer identified or identifiable.
2.4 Recipients of the data – Sharing of the data with third parties
Your personal data are addressed to DISPEL employees (including worldwide Boutiques employees) and can also be transmitted to/accessible by DISPEL affiliates. DISPEL employees are authorised to access the personal data solely in the course of their functions. Controls are put in place to ensure that the access granted matches the needs of their functions.
It will not be transferred or made accessible to any third party other than (i) subcontractors and service providers to DISPEL who are involved, mainly in a purely technical or logistical capacity (shipping partners, providers of hosting and maintenance services to the Website, payment and fraud prevention service providers, etc.), and (ii) upon any reorganisation of our company, including a total or partial disposal of our assets, merger, takeover, acquisition, de-merger, and in general any reorganization operation, in order to ensure the continuity of the Services provided.
Finally, DISPEL may disclose your personal data to third parties when such disclosure is required by a law (i.e. tax authorities), a regulatory provision or a court ruling, or if this disclosure is necessary to ensure the protection and the defence of its interests (for instance to our external agents and counsels in case of debt recovery; to our insurance companies in case of the loan of a product).
Note regarding transfer of your data abroad:
Some of these recipients are located outside of the US, and notably located in the European Union (and more generally the European Economic Area) and non-EU countries where a DISPEL Boutique is located. Note that the applicable data protection rules and regulations outside the United States differ from those that are applicable within the United States.
They shall only take place subject to appropriate guarantees designed to ensure a sufficient level of protection to your privacy and fundamental rights.
When we transfer your personal data, we ensure the continuous security of your data and subject the transfers to appropriate guarantees, by means of the signature of the standard contractual clauses of the European Commission.
Please note that when you access our DISPEL pages on social networks, your browser is subject to the confidentiality policies of these social networks, over which we have no control.
2.5 Security and confidentiality of the data
DISPEL has taken all the technical and organisational measures to protect the confidentiality and security of the personal data processed, in view of its nature and the risks of processing and to prevent that it is distorted, damaged, destroyed or that unauthorised third parties have access thereto.
DISPEL has, in particular, implemented the following measures:
- DISPEL’s information systems are subject to physical and logical protection in accordance with the state-of-the-art, regularly assessed and improved. Backup procedures of DISPEL’s information systems are regularly executed.
- Access to the data is limited to the sole employees of DISPEL authorised because of their functions, with these employees being subject, furthermore, to contractual confidentiality obligations.
- DISPEL’s service providers and sub-contractors are bound by written commitments to take security measures that are sufficient to ensure the protection of your personal data in accordance with the applicable legislation.
- DISPEL’s Website is protected by an SSL encryption process making the data illegible during its transmission on the internet.
We remind you that DISPEL does not control all the risks relating to the functioning of Internet and we draw your attention to the existence of eventual risks inherent to its use and its functioning.
3. YOUR RIGHTS
We undertake to guarantee the exercising of the rights that you have pursuant to the personal data protection regulations. You can thus exercise the following rights at any time:
- Right to information: you have the right to obtain clear, transparent and comprehensible information about the way in which we use your personal data and about your rights. You will find all of this information in this Charter. If you wish to have additional information, we invite you to contact our Data Protection Officer (see contact details below).
- Right of access: you have the right to obtain a copy of the personal data that we possess about you.
- Right of rectification: you have the right to have your personal data rectified if it is inaccurate or obsolete and/or to supplement it if it is incomplete.
- Right of deletion/ right to oblivion: you have the right to have your data deleted or suppressed.
- Right to objection: you have the right under certain conditions to object to the processing of your personal data.
- Right of objection to personalised marketing: you can at any time request that you should no longer receive commercial communications about our offers, news and events.
- Right to withdraw your consent: you can at any time withdraw your consent to the processing of your personal data when this processing is based on your consent.
- Right to the restriction of processing: you have the right under certain conditions to request that the processing of your personal data be temporarily suspended.
- Right to the portability of the data: you have the right to request that your personal data be transmitted to you in a format allowing it to be used in another database.
You can exercise these rights or ask any question concerning the management of your personal data by contacting:
- Our Data Protection Officer:
- By e-mail to info@DISPELWEBSITE.com
- By letter to:
For the attention of the Data Protection Officer (DPO)
- Our customer service:
- By e-mail to customerserviceusa@DISPELWEBSITE.com
- By means of the online contact form available here
If we consider it necessary to be able to identify you, we can ask you for proof of identity.
You can also exercise your rights of rectification and/or of objection to marketing directly:
- Under the dedicated heading of your personal DISPEL account
- By using the deregistration link shown at the bottom of each e-mail (“unsubscribe” link) or by sending back “STOP SMS”
- In the Boutique with the vendor.
Should you be unhappy about the way in which DISPEL collects and processes your personal data, you may (i) file a complaint with respect to DISPEL PARIS US with the Federal Trade Commission in the United States (visit ftc.gov/complaint, click on the FTC Complaint Assistant icon, and answer the questions).
A cookie or a tracer is a text file that can be stored in a dedicated area of your Terminal's* hard disk when viewing an online service using your browser. A cookie file enables its issuer to identify the terminal on which it is stored during the cookie's validity or registration period.
* the Terminal means the hardware (computer, tablet, smartphone, etc.) that you use to view or display a website, application, advert, etc.
Information about your browsing on our Website is saved in Cookie files installed on your Terminal and allow us to track your activity and to recall information, such as user preferences or information the user previously entered in forms.
4.2 Notice about Cookies
You can change the cookie settings at any time. Below you will find more information about cookies and how you can manage your cookie settings.
4.3 The Cookies we issue on our Website
We issue various types of cookies when you connect to our Website:
- Technical cookies that allow us to give you access to or facilitate your navigation on the Website, or to provide you with the online communication services you request when you navigate, and in particular:
- Adapt the presentation of the Website to the display preferences of your device (language used, display resolution, operating system used, etc...) during your visits to the Website, depending on the display or reading hardware and software that your device contains;
- Implement security measures, for example when you are asked to reconnect to content or service after a certain period of time;
- To allow you to access reserved and personal areas of the Website, such as your account, using identifiers or data that you may have previously provided to us;
- To store information relating to a form you have completed on the Website (registration or access to your account) or to products, services or information you have chosen on the Website (subscribed service, content of an order basket, etc...);
- Audience measurement cookies that allow us to establish:
- Statistics and volumes of visits and use of the various elements composing the Site (sections and contents visited, browsing journey), allowing DISPEL to improve the interest and ergonomics of our services, as well as the visibility of the contents we publish;
- The effectiveness of our marketing and communication campaigns;
- Advertising cookies, which allow us to associate the personal data you have provided to us (including your electronic contact details, when you register, place an order or access one of our services) with browsing information in order to send you electronic prospecting or to display personalised advertisements on your device within advertising spaces that are specifically intended for you;
- Payment security cookies that allow us to fight against Internet fraud (prevention of fraud in payment methods, identity theft...). As such, DISPEL and/or its service providers acting on its behalf may deposit, subject to your rights, tracers in order to collect information relating to the terminal that made it possible to carry out the Order (in particular the operating system used, the location of the machine, the use or not of proxy...). The information thus collected is analysed automatically by algorithm (see the section "2.1 Objectives pursued by DISPEL").
- Note on the "social networks" buttons: We may include on our Website computer applications from third parties, which allow you to track us on social networks. The social network providing such an application button is likely to identify you through this button, even if you did not use this button when you visited our Site. Indeed, this type of application button may allow the relevant social network to track your browsing on our Site, simply because your account on the relevant social network was activated on your Terminal (open session) during your browsing on our Site. We invite you to consult the privacy policies of these social networks in order to learn about the purposes of use, including advertising, of the browsing information they may collect through these application buttons. These protection policies must allow you to exercise your choices with these social networks, in particular by setting up your user accounts for each of these networks.
Your navigation data is associated regardless of the Terminal used, thanks to cookie exchange technologies, which makes it possible to track your journey regardless of the terminal used.
Some of the cookies used for the purposes described above are issued by third party companies. These "third-party cookies" are stored and managed by these external companies in order to provide us with the services we have requested from them in order to improve our services and your browsing experience.
4.5 Your cookie management choices
You can configure your browser so as to have the cookies recorded on your Terminal or, on the other hand, to reject them, either systematically or according to their issuer. You can also configure your browser so that a cookie can be proposed for acceptance or refusal individually, before a cookie can be stored on your Terminal. For further information, view the section "How do you make your management choices, depending on the browser you use?".
(a) Cookie consent
Storage of a cookie on a terminal is basically dependent on the wish of the Terminal user, which can be expressed and changed at any time, free of charge, through the choices afforded by the user's browser.
If you have configured your browser to accept storage of cookies on your Terminal, the cookies embedded in the pages and contents you have viewed may be stored temporarily in a dedicated space on your Terminal. They will be readable there solely by their issuer
(b) Cookie rejection
If you reject the storing of cookies on your Terminal, or if you delete those that are recorded there, you may thereafter be deprived of a certain number of functions, which are, nevertheless, necessary for browsing certain spaces on our Website. This would happen if you attempted to access our content or services requiring you to log in. This would also happen whenever we or our service providers are unable to 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 logged on to the Internet.
Where applicable, we decline all responsibility for any consequences arising from the degraded operation of our services due to our being unable to store or view the cookies you have rejected or deleted that are required for operating such services.
(c) How do you make your management choices, depending on the browser you use?
Each browser has a different configuration for managing cookies and your choices. This configuration is described in your browser's help menu, informing you how to change your cookie management choices.
For Internet Explorer 8.0 and above:
1. Choose the "Tools" menu, then "Internet Options"
2. Click on the "Confidentiality" tab
3. Use the cursor to select the level required.
For Mozilla Firefox:
1. Choose the "Tools" menu, then "Options"
2. Click on the "Privacy" icon
3. Locate the "cookies" menu and select the options you want.
1. Choose the "Settings" menu
2. Click on "Show advanced parameters" and go to the "Confidentiality" paragraph
3. Click on "Content parameters".
1. Choose the "File" menu, then "Preferences"
2. Click on the "Privacy" icon
3. Define your settings.
1. Tap the top right-hand key
2. Go to "Settings", then "Confidentiality and security"
3. Define your settings.
For Dolphin in Android
1. In the menu, go to "More", then to "Settings"
2. Choose the Confidentiality menu, then "Security"
3. Define your settings in the "Cookies" menu.
For Safari in iOS
1. In the "Settings" application, choose "Safari"
2. In the "Confidentiality" section, go to "accept cookies"
3. Define your settings.
4.6 If you share your terminal with others
If your Terminal is used by more than one person and a single terminal has several browsers, we cannot be certain that the services and advertising sent to your Terminal actually correspond to your own use of that Terminal, as opposed to the use of that Terminal by another user.
Where this is the case, sharing the use of your Terminal with others and the configuration of your browser's cookie settings are matters of your free choice and own responsibility.