Version 2.0 of February 27th, 2020 KENZO 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 Policy is to inform you clearly, simply and fully about the use by KENZO 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 Policy applies to the customers and visitors of the KENZO Website as well as the customers and potential customers visiting the Boutiques directly operated by KENZO within the US. KENZO has appointed a Data Protection Officer responsible for ensuring compliance with this Policy and, more generally, compliance with applicable data protection regulations. Our Data Protection Officer can be contacted for any question concerning this Policy according to the modalities shown under heading 3 "Your Rights" of this Policy. KENZO can modify this Policy 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 – KENZO’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 Policy shall be jointly performed by KENZO PARIS USA LLC, a Delaware limited liability company with its principal place of business at 598 Madison Avenue, NY, NY 10022 and KENZO SA, an affiliated company, whose registered office is located at 18 Rue Vivienne, 75002 Paris – FRANCE (Paris Corporate Register under n°402.180.194). These entities act as joint data controllers within the meaning of applicable regulations concerning personal data and are referred to hereinafter as “KENZO”.
2. MANAGEMENT OF PERSONAL DATA BY KENZO
KENZO collects, stores, processes, uses and communicates your personal data when you use our Website www.kenzo.com (the “Website”), you visit our pages on social networks, you make purchases at the KENZO Boutiques located in the US, you contact KENZO and, more generally, when you join the KENZO community.
2.1 Objectives pursued by KENZO
KENZO collects your data to:
- Reply to your requests, questions and claims:
- Send you our KENZO offers, news and events, and other similar communications, subject to your consent and chosen channel or method of communication. You always have the right to opt-out of the use of your data for direct marketing-related purposes, and can do that by contacting our customer service department, or our DPO, directly or through this website;
- 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 KENZO community, the orders and purchases you make in a Boutique or online and fullfil 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 KENZO:
- 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
- Conduct online paid ads campaigns This means if you have agreed to the use of your contact details for marketing purposes, we may share these data with our service providers who perform remarketing services on our behalf
- 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 KENZO Boutiques and online)
- Ensure the security of goods and persons in KENZO 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
These algorithms analyse the data pertaining to your transaction (products, contact details and bank information) and to your use of the Website (visited pages and browsing on the Website) combined with anonymous data relating to the device used for browsing (such as the screen resolution or the operating system version) which can be used to reliably identify your device in the event of consecutive visits and enable us to analyse fraud risks.
This automated control may result in the transaction being blocked. Depending on the results of the control carried out, we may decide to take additional security measures and, if the security of the order cannot be guaranteed, we may choose to cancel it. For instance, a manual analysis of the blocked transaction may be 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.
- Additional note on KENZO's pages on social networks
2.2 Data collected by KENZO
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, KENZO 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 KENZO 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 KENZO 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 KENZO to fulfil the purposes pursued is indicated by an asterisk on the various forms that you fill in, both in KENZO Boutiques and online. If you do not fill in these required fields, KENZO 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 KENZO 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 KENZO:
- When purchasing Kenzo products, we keep your data for as long as necessary for the execution of the contract;
- In the event of the creation of a Client account (on the Website or in a Boutique), the data will be kept until you send a deletion request or after a certain period of inactivity;
- In the event of a registration to our newsletter/the use of your data for marketing-related purposes, your data will be kept until you opt-out, you ask for the deletion of your personal data, or after a period of three years with no interaction with KENZO;
- For as long as necessary to reply to your request, question, or claim: for example, until the sending of the availability notice of a product;
- 13 months for cookies placed in your device
- 3 months for CCTV recordings. In the event where the recordings are necessary for the defence of KENZO’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
In order to comply with our legal obligations and prove we comply with them (accounting and tax obligations for instance), but also in order to exercise some of our rights and defend our interests (e.g. to take legal action), certain personal data are kept longer than mentioned above, prescribed by the legal obligation or until the legal action prescription period ends.
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
Within KENZO. Your personal data are addressed to KENZO employees (including worldwide Boutiques employees) and are also transmitted to/accessible by KENZO affiliates. KENZO 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.
For compliance with the law. We may access, preserve, use, or disclose your personal data to meet legal, regulatory or treaty obligations, to respond to requests from recognized legal authorities, or if we have a good faith belief that the law requires us to do so or that it is reasonably necessary to detect, prevent, and address security, technical issues, or fraud. We may access, preserve, use, or disclose your personal information to protect the rights of the business, its property, its employees and others, or to enforce our billing or contracts
If KENZO is involved in a direct or indirect reorganization process, such as a merger, acquisition, sale, dissolution, bankruptcy or other change in ownership, your personal data may be among the transferred business assets.
Third-party services providers. KENZO uses third-party service providers to facilitate certain services on behalf of KENZO. Depending on your interactions with KENZO, your personal data may be shared with third-party service providers that help with the following:
- Logistic (preparing and shipping your order),
- Payment processing,
- Advertising, Marketing and sales,
- Social media/networks management
- Hosting/Maintenance of IT solutions and softwares used by KENZO.
However, this excludes the selling, renting, sharing or in any other way the disclosure of personal information for commercial purposes in violation of the commitments included in this Policy.
Finally, KENZO 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 KENZO 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.
These transfers 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 KENZO 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
KENZO 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.
KENZO has, in particular, implemented the following measures:
- KENZO’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 KENZO’s information systems are regularly executed.
- Access to the data is limited to the sole employees of KENZO authorised because of their functions, with these employees being subject, furthermore, to contractual confidentiality obligations.
- KENZO’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.
- KENZO’s Website is protected by an SSL encryption process making the data illegible during its transmission on the internet.
We remind you that KENZO 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/CCPA Right to know: 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 Policy. 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 can object to the processing of your data when the processing is based on the KENZO’s legitimate interest for reasons pertaining to your particular situation (which need to be specified in your request).
- Right of objection to direct marketing: you can at any time request to no longer receive commercial communications regarding 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 regarding the use of your personal data by contacting our Data Protection Officer:
- By e-mail to firstname.lastname@example.org
- By letter to:
For the attention of the Data Protection Officer (DPO)
18 Rue Vivienne
75002 Paris FRANCE
- By means of the online contact form available on the contact us page (click here)
If we consider it necessary to confirm your identity, we can ask you for proof of identity. In accordance with the law (both European Union’s regulations and U.S. States as applicable), KENZO allows individuals to exercise their rights via a third-party (an “authorized agent” under the CCPA). In those situations, KENZO requires authentication/verification of the third-party as well as the individual about whom the data relates, and we may deny the request if we are unable to obtain appropriate authentication/verification at either level. The authentication/verification requirements adopted by KENZO vary by right and take into consideration the potential risks to the individual of sharing their personal data with an unauthorized individual.
You can also exercise your rights of rectification and/or of objection to marketing directly:
- Under the dedicated heading of your personal KENZO account
- By using the deregistration link shown at the bottom of each e-mail (“unsubscribe” link - valid for the newsletter deregistration only) or by sending STOP to the number indicated in each sms (valid for sms deregistration only);
- In the Boutique with the vendor.
Additional rights for California residents
California regulations provides California residents with additional rights, including:
- The right to opt-out of the sale of your personal data to third parties, pursuant to the California Consumer Privacy Act (“CCPA”). We do not and will not ‘sell’ the personal information of California residents or those of other states as that term is defined in the CCPA. To the extent that your personal information is accessible to KENZO affiliated companies, or to third party who assist us with our services to customers (called “Service Providers” under the CCPA), they are also prohibited from “selling” your personal information as defined in that law;
- The right to no discrimination. KENZO does not discriminate against individuals, including those who choose to exercise their CCPA rights (right to know, right of access, right of deletion, right to opt-out of sale above-mentioned); and
- The right to make an annual request for information regarding the disclosure of categories of your personal data that KENZO has shared with a third party for the third party’s direct marketing purposes, pursuant to the California Civil Code Section 1798.83 (CA “Shine the light” law). Consistent with our commitment not to sell your data, please note that we do not share your data for this purpose.
- Clear GIFs : we use “clear GIFs” (aka “Web beacons” or “pixel tags”) or similar technologies, in the Website and in our communications with you to enable us to know whether you have visited a Web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail that communicates to us whether you viewed an email that we sent you or visited a certain page on our Website. A clear GIF may enable us to relate your viewing or receipt of a Web page or message to other information about you, including your personal data.
- Technical cookies essential to the Website’s functioning which give you access to or facilitate your browsing on the Website, or to provide the online communication services you require while browsing, and in particular:
- To store in memory the cookie settings you have chosen (via our cookie management tool) ;
- To adapt the presentation of the Website to your device’s display preferences (language used, screen resolution, operating system used, etc.) when you visit the Website, depending on the reading or visualization material and software your device carries;
- To put into effect security measures, for instance when you are asked to connect again to a content or a service after a certain amount of time;
- To allow you to access dedicated and personal spaces of the Website, such as your account, using logins or data which you have possibly entrusted to us beforehand;
- To save information pertaining to a form you filled on the Website (registration or access to your account) or to products, services or information you have chosen on the Website (Subscribed service, order basket content etc.);
- Functional cookies which allow us to improve the features and personalization of the Website, such as the use of videos.
- Audience measurement and optimization cookies which allow us to:
- Establish statistics and volume of visits;
- Follow and analyze your journey on the Website (visited sections and content, journey), allowing KENZO to improve the interest and ergonomics of the Website, as well as the visibility of the contents we publish (AB testing type cookie);
- Evaluate the efficiency of our paid search engine optimization campaigns;
- Analysis and personalization marketing cookies which allow us to:
- Improve your browsing and shopping experience on the Website;
- Recommend products that better meet your expectations and preferences, in particular by identifying products that may correspond to the interests deduced from the previous browsing of the concerned device.
- Send you emails to inform you of the status of your basket: you can opt-out of this targeting at any given time by using the unsubscribe link at the bottom of these emails (only valid for basket reminder emails).
- Advertising cookies which are installed on the Website by our advertising or affiliate partners. They are used by these companies to analyze your centers of interest and be able to offer you KENZO products or relevant advertisements on other websites (including social networks). They also allow to measure the impact of our media campaigns and to compensate the affiliates of affiliation programs to which KENZO is a party (an affiliate is a third party Website that references our products and sends web users on our Website to make their purchases);
To exercise those rights, you can submit a request to KENZO Data protection officer (see contact details above).
Additional right for Nevada residents
In Nevada, residents have the right to request that organizations do not sell their data, as that term is defined under the Nevada consumer privacy law (Section 630A of the Nevada Revised Statutes, or SB 220). KENZO does not sell the data of Nevada residents or other individuals, as defined under that law
Right to lodge a complaint
Should you be unhappy about the way in which KENZO collects and processes your personal data, you may (i) file a complaint with respect to KENZO 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) and/or (ii) file a complaint with respect to KENZO SA with France’s data protection authority, CNIL, by visiting https://www.cnil.fr/en/home or by writing to the following address: 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07, France.
4.1 What is a cookie?
A cookie 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.
You can modify the cookie settings at any given time. You will find more information regarding cookies and how to manage cookies settings below.
4.3 Cookies we issue on our Website
We and our partners issue various types of cookies when you visit our Website:
Some cookies used for the purposes described above are emitted by third party companies. These “third party cookies” are installed and managed by these third-party companies in order to provide the services we have requested from them. These companies act solely on our behalf as data processors.
However, these companies may reuse the data for their own purposes in order to improve their services. In that case, KENZO ensures that the adequate contractual obligations are imposed and requires complete anonymization and prior aggregation of the data.
Some of the data collected through the cookies listed above may be reused in order to detect and prevent fraud (see article 2.1)
4.4 Setting up cookies
You can set up your browsing software to save cookies on your device or, on the contrary, to reject them systematically, or reject them depending on their emitter. You can also set up your browsing software in such a way that it will occasionally ask you whether you want to accept or reject cookies before a cookie is saved on your device.
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.
You can also use our Cookie Consent Tool that gives you control over the way cookies are installed on your device when visiting our Website.
You will find more information on how to eliminate or control cookies on www.cnil.fr and on www.AboutCookies.org.
4.6 If you share your terminal with others
If your device 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 device actually correspond to your own use of that device, as opposed to the use of that device 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.