August 30th, 2022
Sleek Chic SA (the “Company”) understands that the collection of Personal data involves a great deal of trust on your part. We take this trust very seriously and make it our highest priority to ensure the security and confidentiality of the Personal data you provide us with.
This is why we implemented privacy by design and privacy by default standards and undertake to store your Personal Data in a secured way as well as to process your Personal data with all appropriate care and attention in accordance with the Federal Data Protection Act (RS 235.1), the Ordinance on the Federal Data Protection Act (RS 235.11) and, where applicable, the European General Data Protection Regulation (“GDPR”). Data which is deemed to be personal consists of all the information relating to a person who is either identified or identifiable (“Personal data”).
Capitalized terms not defined in this Privacy Policy have the meanings set forth in the Terms and Conditions available at the following address: https://www.marinaanouilh.com/terms-conditions (the “Terms”).
Please read this Privacy policy (the “Policy”) carefully to understand our policies and practices regarding your Personal data and how we will treat and process them.
By using and/or registering on the Platform, you accept the data collection and processing described below:
Consent shall mean your express consent to the Processing of your Personal Data.
Processing shall mean any operation with Personal data, irrespective of the means applied and the procedure, and in particular the collection, storage, use, revision, disclosure, archiving, or destruction of data.
Service provider shall mean our suppliers, subcontractors, and business partners who help us to run the Platform, provide the Functionalities or process the Personal data.
Terms defined in the General Terms and Conditions shall be incorporated by reference.
While using the Platform, the Company may collect and process a certain number of Personal data related to you.
The Policy shall apply to any use of the Platform or use of the Functionalities, whatever the method or medium used. It details the conditions at which we may collect, keep, use and save information that relates to you, as well as the choices that you have in relation to the collection, utilization, and disclosure of your Personal Data.
By using the Platform or the Functionalities, you acknowledge that you have read and understood this Policy and agree to be bound by it and to comply with all applicable laws and regulations. You also acknowledge that you have read and understood the Terms that apply to the Platform and agree to be bound by them.
The Company may modify this Policy from time to time and will post the most current version on the Platform. You are responsible to verify the latest version of the Policy. If a modification meaningfully reduces your rights, a pop-up window requesting your Consent will appear when you will be browsing the Platform.
The Company uses Personal data mainly for the purpose of improving the User experience and the Platform and targeting the Functionalities to your needs.
We and our Service providers may use your information for our legitimate business interests. Our legitimate business interests are explained below, alongside examples of how your information may be used for these purposes.
The main reason why we collect Personal data about you is:
The Personal data will be freely provided by you to the Company or collected automatically while using the Platform, in accordance with this Policy. In addition to the information contained in this Policy, the Platform may provide Users with additional and contextual information concerning particular services or the collection and Processing of Personal Data upon request.
We may supplement the information you provide with information received from third parties.
Personal data transmitted to the Company are hosted by Marina Anouilh Gstaad, Promenade 6A, 3780 Gstaad, Switzerland.
Your Consent to this Policy followed by your submission of Personal data represent your agreement to the collection, Processing, and storage of Personal Data by the Company as described in this Policy.
When you register through the Platform or in any other way interact with us (including by email), you may be asked to communicate the number of information, including without limitation, your personal contact details:
We may collect the Personal data that you provide as part of the registration and personalization of your Customer account.
To create your Customer Account on the Platform, we will collect the following Personal data:
We do not collect nor process any Payment data on or through the Platform. Payment data will be exclusively collected and processed by our Payment Provider. The Company will not have access to your Payment data.
Your Payment data, including your credit card or bank number, expiration date, billing address, and payment amount, is collected on our payment page by the Payment provider and will be subject to the Payment provider’s terms and privacy policy. We have no control over and are not responsible for the Payment provider collection, use, and disclosure of your Personal Data. We receive information on Transaction price only; no other Payment data is stored or saved within our systems.
You may share your activities on the Platform with friends on other social media platforms, for example, sharing content through Facebook or Instagram. To do so, you must connect your Customer account with your social media account. In such case, you authorize us to share Personal Data with your social media account provider, and you understand that the use of the information we share will be governed by the social media platform’s terms & conditions and privacy policy. If you do not want your Personal Data shared with other social media users or with your social media account provider, please do not connect your social media account with your Customer account and do not use the social sharing features on the Platform.
You may voluntarily share Personal Data on message boards, chats, profile pages, blogs, and other services to which you are able to post information and materials (including the Marina Anouilh Gstaad pages on Facebook, Instagram, and other social media platforms). Please note that any information you post or disclose through these services will become public information and may be available to other Users, social media platform users, and to the general public. We urge you to be very careful when deciding to disclose any information about yourself via the social sharing features of our Platform.
On the basis of data processing agreements, we may share your Personal Data with our affiliates, which are entities under common ownership or control of the Company, for the purposes described in this Policy or with our Service provider. We have data processing agreements in place with our affiliates and/or Service providers, which prohibit them from sharing the Personal Data about you that they process or receive with anyone else or from using such Personal data for other purposes.
We may use and disclose your Personal Data as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
Fraud prevention: we may use and disclose the information we collect from and about our Users as we believe necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, privacy, rights, or property of us, our Users or others.
Law enforcement purposes: If requested or required by government authorities such as law enforcement authorities, courts, regulators, or otherwise to comply with the law (which may include laws outside your country of residence), we may have to disclose the information we have about our Users. We also may use and disclose information collected about you in order to exercise or protect legal rights or defend against legal claims.
The following paragraphs describe the various purposes for which we collect and process your Personal Data and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.
We process your Personal Data in order to provide you with the Platform and its Functionalities, to interact with you, including by means of telephone, to edit the Receipt and the Invoice, to allow the Boutique to deliver you the Products and to respond to your requests. Your Personal Data may also be processed for fraud detection purposes. By creating a Customer Account on the Platform, you agree that we may process and use your Personal Data so that we may contact you, in particular by sending an email containing general information, unless you choose to remain anonymous.
Your Personal Data shall also be processed in order to:
With your consent, we process your Personal Data in order to analyze your preferences and your patterns, to personalize your experience on the Platform, as well as to optimize the Platform. You Consent also that we may also suggest to you content which is best suited to your interests.
With your consent, we also process your Personal data for the following personalized features:
If you no longer wish to have your Personal data used by the Company to provide you with a personalized experience, you can at any time adjust your privacy settings in your Customer account.
You Consent that we process your Personal data for after-sales service purposes, including responding to your enquiries. This typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g., technical issue, question/complaint, general question, etc.).
You Consent that we process your Personal Data when you interact with third-party social networking features, such as to serve you with advertisements and engage with you on social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt-out by reviewing the privacy notices of the relevant third-party social networks.
Certain features (called plugins) offered by various third-party social media platform providers (for example, Facebook and Instagram) are incorporated into our Platform. These plugins allow you to share content available via social networks. If a plugin appears on the Platform during a browsing session, an automatic link with the servers of said platform is provided. The data relating to your Customer account may be sent to this third-party provider. If you are identified at the same time on the network of a said third-party provider, the visit to our Platform may then be linked to your network account (for example, Facebook). The Company has no influence over this type of data transfer. Please consult the information relating to data protection by your social network regarding the purpose and the extent of the collection of your data, the subsequent management and use of your Personal Data by said provider, as well as your rights and setting options in order to protect your privacy.
When you authorize a third-party social network (such as Facebook) to share information and data with us, we may receive any data which you publicly share on a said social network as well as any data which forms part of your profile. This may consist of basic data relating to your Customer account (e.g., your name, email address, gender, birthday, the town where you reside, your profile photograph, your user identifier, your list of friends, etc.) and all other information or activity which you have authorized the third-party network to share.
We also receive Personal Data relating to your profile when you use a social network function that is integrated into the Platform (such as Facebook Connect) or when you interact with us via a social network. In order to find out more about how we receive data regarding yourself from third-party social networks or to cease sharing your data on said social networks, we invite you to read the conditions of use of the relevant social networks. You should at all times be aware of the terms of use and privacy policy that applies to the third-party social network and are of its exclusive responsibility.
In accordance with applicable laws, we process your Personal Data for other general business purposes, such as conducting internal marketing. We also use your Personal Data to ensure our own security.
In the event that the Company or its assets are acquired by, or merged with, another company, including through bankruptcy, your Personal data could be shared with any of our legal successors.
We may also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreement or the Terms.
You can edit your privacy settings and the emails you receive from the Company at any time through our “My Account” page. If you want, you can ask us for the information we have about your Customer account and even ask us to delete it all.
If you no longer want to receive the newsletter from the Company going forward, you may opt-out of receiving these by following the instructions contained in any such email by logging in to your Customer account. We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails and/or the newsletter from us, we may still and reserve the right to send you important administrative messages (such as updates about your Customer account or service changes).
You can edit or remove the permissions you have granted to the Company to use information from your social media accounts by using your application privacy settings on your social media account. If you have signed in on Marina Anouilh Gstaad pages through Facebook Connect, you are likely to have been cookied by Facebook. You can modify or change those cookies through the settings on your Facebook account.
By using and/or registering on the Platform, you acknowledge and agree that Personal Data you submit to the Company will be hosted by the Company for an indefinite period of time.
Your Personal data will be stored in Switzerland by Infomaniak. You expressly Consent that Infomaniak may process your Personal Data on its servers for providing us with storage and hosting services.
The storage, as well as the Processing of your Personal Data, may require that your Personal Data are ultimately transferred/transmitted to and/or stored at a destination outside of your country of residence. Where permitted by law, by accepting the terms of this Policy, you agree to such transferring, transmission, hosting, storing, and/or Processing. You also agree that such activities may take place to or in countries offering a similar level of protection than your country of residence or a lower level of protection than your country of residence, provided standard contractual clauses or binding corporate rules are implemented, and you are provided with sufficient information as to the country with a lower level of protection to which your Personal data are to be transferred.
Your submission of Personal data and your explicit Consent to such international transfer represent your agreement to such international transfers and hosting abroad as specified above in accordance with the terms of this Policy.
In accordance with applicable laws and the principle of proportionality, we will use your Personal data for as long as necessary to satisfy the purposes for which your Personal Data was collected or to comply with applicable legal requirements. Personal data used to provide you with a personalized experience will be kept for a duration permitted by applicable laws.
When you delete your Customer account, your Personal data will be kept for a period of 12 (twelve) months in order to comply with legal requirements.
In addition to the purposes specified above, you Consent that the Company may collect information about your use of the Platform through electronic communications protocols. The Company may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (the browser type), referring Platform, and date and time. Collecting this automatic information helps us customize your experience as a user. It allows us to monitor and analyze the platform’s use and increase the Platform’s functionality and user-friendliness.
You Consent that the Company may re-associate the information provided by the technologies described above with your Personal data.
For operation and maintenance purposes, you Consent that the Company and any third-party services may collect files that record interaction with the Platform (System logs) or use for this purpose other Personal Data (such as IP address).
A Cookie is a piece of information that is placed automatically on your computer’s hard drive when you access certain websites. The Cookie uniquely identifies your browser to the server. Cookies allow the Company to store information on the server (for example, language preferences, technical information, click or path information, etc.) to help make the Web experience better for you and to conduct Platform analysis and Platform performance review. Most Web browsers are set up to accept cookies, although you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of the Platform may not work properly if you refuse cookies.
We use clear gifs in our email marketing communications which are used to track the emails that are opened by the recipients. This information allows us to have accurate reports and improve the effectiveness of our marketing and make our Platform and its Functionalities better for you.
The Platform (to the exclusion of cloud services available on the Platform) uses Google Analytics, an Internet platform analysis service supplied by Google Inc. (“Google”). Google Analytics uses cookies which are text files placed on your computer to help to analyze the use made of the Platform by its Users. The data generated by the cookies concerning your use of the Platform (including your IP address) will be forwarded to and stored by Google on servers located outside of Switzerland. Google will use this information to evaluate your use of the Platform, compile reports on Platform activity for its publisher and provide other services relating to the activity of the Platform and the use of the Internet. Google may release these data to third parties if there is a legal obligation to do so or when the third parties process these data for the account of Google, including, in particular, the publisher of this platform. Google will not cross-reference your IP address with any other data held by Google.
You may deactivate the use of cookies by selecting appropriate parameters on your web browser. However, deactivation of this kind might prevent the use of certain functions of the Platform. By using the Platform, you specifically Consent to the Processing of your Personal Data by Google under the conditions and for the purposes described above.
The Company expressly reserves the right, and you hereby Consent that the Company has the right to anonymized your Personal data, in particular for commercial purposes.
Once the Personal data is entirely anonymized, the Company is entirely free to process and use them at its sole and entire discretion without having to request your Consent.
The security of your Personal Data is very important to us. The Company processes your Personal Data in a proper manner and will take appropriate technical and organizational measures to prevent unauthorized access, loss, data breach, disclosure, modification, or unauthorized destruction of your Personal Data. We regularly review our security policies and procedures to ensure our systems are secure and protected.
Personal Data Processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Company, in some cases, the Personal data may be accessible to certain types of persons in charge, involved with the operation of the Platform (administration, sales, marketing, legal, system administration) or external parties (such as third party technical Service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by the Company. An updated list of these parties may be requested from the Company at any time.
You shall be solely responsible for keeping your password and other information relating to your Customer account confidential and not allowing any third party to access and use your Customer account.
In the event that your Personal data is unduly accessed or is reasonably believed to have been unduly accessed by an unauthorized person and applicable law requires notification, the Company shall without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the breach to the competent supervisory authority, unless said breach is unlikely to result in a risk to your rights and freedoms. If the breach is likely to result in a high risk to your rights and freedoms, the Company shall communicate this breach to you without undue delay.
You, however, acknowledge that the use of the internet is not safe and that there are certain inherent risks to your personal data. The company shall make reasonable efforts to protect your personal data, but it cannot guarantee or warrant that personal data you provide to the company is safe and protected from unauthorized third-party access and theft and, therefore, waives all liability in this respect. In no event shall the company be held liable for circumvention of any privacy settings, viruses, or security measures contained on the platform.
You have the right to request access to or information about the Personal data related to you which are processed by the Company.
Where provided by law, you, your successors, representatives, and/or proxies may (i) request deletion, correction, or revision of your Personal Data; (ii) oppose the data Processing; (iii) limit the use and disclosure of your Personal Data; and (iv) revoke Consent to any of our data Processing activities if we are relying on your Consent and do not have another legal basis to continue Processing your data.
These rights can be exercised by writing to Marina Anouilh Gstaad, Promenade 6A, 3780 Gstaad, Switzerland, or by sending us an email at the following address [email protected] attaching a copy of your ID. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.
The request is free of charge unless your request is unfounded or excessive (e.g., if you have already requested such Personal data multiple times in the last twelve months). In such a case, we may charge you a reasonable request fee according to applicable laws.
We may refuse, restrict or defer the provision of Personal Data where we have the right to do so, for example, if fulfilling the request will adversely affect the rights and freedoms of others.
Please note that any information that we have copied may remain in backup storage for some period of time after your deletion request. This may be the case even though no Personal data about your Customer account remains in our active databases. Please note that Personal data posted on third-party services, such as social networks, are not located on our servers and will, therefore, not be deleted from the Internet by the Company.
You also have the right to receive your Personal data, which you have provided the Company with, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller without hindrance from the Company.
This right can be exercised by writing to us at Marina Anouilh Gstaad, Promenade 6A, 3780 Gstaad, Switzerland, attaching a copy of your ID. If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.
The request is free of charge unless your request is unfounded or excessive (e.g., if you have already requested such Personal data multiple times in the last twelve months). In such a case, we may charge you a reasonable request fee according to applicable laws.
We may refuse, restrict or defer the provision of Personal Data where we have the right to do so, for example, if fulfilling the request will adversely affect the rights and freedoms of others.
The Company will, both at the time of the determination of the means for Processing and at the time of the Processing itself, implement appropriate technical and organizational measures, such as pseudonymization, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the Processing in order to meet the requirements of the GDPR and protect your rights.
The Company will implement appropriate technical and organizational measures for ensuring that, by default, only Personal data which are necessary for each specific purpose of the Processing are processed. This obligation applies to the amount of your Personal Data we collect, the extent of their Processing, the period of storage, and their accessibility. These measures will ensure that, by default, your Personal data are not made accessible without your intervention to an indefinite number of third parties.
The data controller of the file is Marina Anouilh Gstaad, Promenade 6A, 3780 Gstaad, Switzerland.
You understand and agree that the Company concluded an agreement with HelloFrenchy ltd, seated in London, UK. Subject to the terms of this agreement, HelloFrenchy ltd, acts as webmaster of the Platform. Therefore, you expressly agree that HelloFrenchy ltd, accesses your personal data and processes them as a data processor.
The data controller’s representative is HelloFrenchy ltd, seated in London. You may contact the data controller’s representative at the following email address: [email protected].
If any part of the Platform contains links to a third party’s platforms or pages, those third party’s platforms or pages do not operate under this Policy. If you choose to visit third-party platforms or pages, you will be directed to these third party’s platforms or pages. We do not exercise control over third-party platforms and therefore recommend you to examine the privacy statements posted on these other platforms or pages to understand their procedures for collecting, using, and disclosing Personal data. We reject any liability relating to the privacy policy in force on said third party’s platform, the collection and use of your Personal data by the latter, and relating to the contents of said platforms (whether the links are hypertext links or deep-links).
Your Personal Data may be accessed and stored as necessary for the uses stated above in accordance with this Policy. While the Company may share your Personal Data with agents and contractors in order to perform the functions listed above, including hosting services and Platform management, we require that they treat your Personal data and limit their use in accordance with the standards specified in this Policy.
When you use the Platform, you submit information to the Company that we store in order to offer you personalized features.
In any case, where a cross-border transfer is done, we ensure that adequate protection is guaranteed for Personal data to be transferred outside of Switzerland and the EEA. In some specific cases, when this level of protection is not guaranteed, we will obtain your prior Consent or establish with the recipient of Personal data a contractual framework or sufficient safeguards that ensure an adequate level of protection abroad. You may request access to a copy of these safeguards by contacting us.
Unless otherwise stated, the third parties who receive Personal Data from the Company are prohibited to use this Personal data beyond what is necessary to provide the service to you, directly or by participating to our activities.
For compliance, email [email protected].
The Company may share your Personal Data to relevant third parties, in particular, if we are requested to do so to comply with a court order or law enforcement authorities request, or if we find it necessary, as determined in our sole discretion, to investigate, prevent or take action regarding illegal activities, to defend our interest, in case of violations of the Terms or as otherwise required or permitted by law.
The Company may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization, or sale of assets or in the event of bankruptcy or insolvency event. Your Consent to this Policy followed by your submission of Personal Data represent your explicit agreement to such transfer.
This Policy and all matters arising out of or relating to it shall be governed by the substantive laws of Switzerland, without regards to principle of conflicts of laws thereof.
Any controversy, claim, or dispute between a user and the Company arising out of or relating to this Policy shall be subject to the exclusive jurisdiction to the ordinary courts of Lausanne, Switzerland, without prejudice to an appeal to the Swiss Federal Court.
We hope to be able to answer any questions or concerns you may have about your Personal data. Should you have any questions about this Policy, please contact us at: [email protected] or Marina Anouilh Gstaad, Promenade 6A, 3780, Gstaad, Switzerland.
You have the right to file a complaint if you feel your Personal data has been mishandled or if we failed to meet your expectations. You are encouraged to contact us about any complaints or concerns, but you are entitled to complain directly to the relevant supervisory authority.
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Latest date of issue: August 30th, 2022
