Privacy Policy

Updated on September 6, 2023 on its website www.etch-couteaux.com (the "Site")

ETCH (as defined in Article 1 below), operating under the ETCH brand, sells high-end ready-to-wear clothing and accessories on its website www.etch-couteaux.com (the "Site"), on its iOS and Android mobile applications, and in its physical stores. In order to offer, sell, and deliver its products, ETCH collects personal data ("Data") from users of its websites and mobile applications, and from customers making purchases in its physical stores (collectively referred to as "Users"). This privacy policy aims to inform Users about the methods used to collect, access, process, and store their personal data. ETCH, as data controller, undertakes to comply with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and French Law No. 78-17 of 6 January 1978, as amended (known as the "Data Protection Act"). The User is informed that certain Data must be collected by ETCH in order to provide its products and services. If the User does not wish to provide this data, ETCH will be unable to perform its services. This privacy policy ("Policy") may be modified at any time by ETCH, in particular to comply with any regulatory, legal, editorial, or technical developments. The User should consult the latest version of the Policy before browsing.

THE DATA CONTROLLER

The data controller, who collects personal data and implements data processing, is: ETCH, a simplified joint-stock company with a capital of €1,000, registered with the Paris Trade and Companies Register under number 920 468 154, whose registered office is located at 13 rue du Baigneur, 75018 Paris, France (hereinafter the " Publisher " or the "Data Controller"). For the purposes of this Policy, the terms "Process" or "Processing" refer to any operation or set of operations applied to Data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, restriction, erasure or destruction. The term “Data” means any information relating to an identified or identifiable User, in particular by reference to an identifier such as a name, an identification number, location data, or one or more specific elements specific to the User.

COLLECTION OF PERSONAL DATA

ETCH is required to collect Users' Personal Data on the Site etch-couteaux.com , as well as during purchases or events organized in ETCH stores. The following data may be collected: × User account data : namely, the data the User provides when creating an account by filling out the registration form (first name, last name, billing and delivery postal addresses, email address, mobile phone number, password for logging into the customer account); × User's personal data when entered into their customer account: date of birth, clothing and shoe sizes; × Transaction data : refers to the User's information relating to orders placed and returns, such as their phone number, address, email address, and payment information; × Exchanges with customer service; × Browsing data : refers to the data the Publisher collects when the User browses the Website and Applications, such as the date and time of connection and/or browsing, browser type, browser language, IP address, location and geolocation data; × Personal data of game participants Contests : When you participate in a contest on our social media, we may retain the winners' personal data. Payment information (credit card number, expiry date, authorization number, security code) is collected directly by our payment provider, Shopify Payments. ETCH never has access to its customers' payment information. Third-party application providers that link to our Sites and/or mobile applications, as well as the networks on which we publish content (such as Facebook, Instagram, and Pinterest), may also use automated tools to collect User data (online activity profiling). This data collection is carried out directly by these providers and/or third parties and is subject to their policies. To the extent permitted by applicable law, ETCH is not responsible for the practices of these providers and third parties. Certain services may be altered or inaccessible without consent to the data collection described in this Privacy Policy. Some personal data collected across different media (websites, mobile applications, social networks) may be combined.

Integration into the Google Customer Reviews program

ETCH participates in the Google Customer Reviews program to assess customer satisfaction. As such, Google may place cookies or use similar technologies to collect certain information related to transactions (e.g., product ordered, amount, purchase date) made on our site. This data is used exclusively for post-purchase satisfaction surveys, in accordance with Google's privacy policy .

By using the site, the User agrees that:

third parties may place cookies for the purpose of measuring customer feedback;
data relating to his order may be transmitted to Google for this purpose.

ETCH ensures that these processing operations comply with legal requirements regarding data protection.

PURPOSES OF COLLECTING PERSONAL DATA

The data collected through the use of the Sites, applications, or in physical stores is processed for the purposes described in the table below. Applicable regulations protect the privacy of Users and require all data controllers to demonstrate a legitimate basis for such processing. These regulations include the following legal bases for processing: - the performance of a contract to which the data subject is a party, such as a sales contract. Therefore, certain personal data of the User is necessary to deliver goods, manage the customer account, and process returns; - compliance with a legal obligation, particularly accounting obligations such as the retention of invoices; - the prior consent of the data subject; - the legitimate interest of the data controller, while respecting the rights and freedoms of users. Thus, improving the customer experience or preventing fraud may justify the collection of data.

Purposes of the processing	Data usage	Legal basis for processing
Order and sales management for products and provision of services; handling of complaints, cancellations and product returns	Use of data to provide products and services (shopping cart and orders; sale, return and refund of purchased products)	The execution of a contract concluded between the client and the professional
Processing transactions, including payments	Our payment providers (Shopify Payments) use payment information when processing each order. This data may also be used for fraud prevention during order payment and/or managing unpaid invoices after an order is placed.	The execution of a contract concluded between the client and the professional
Creation and management of the customer account	The personal data of a customer registered on the website is used (email address, password)	– The execution of a contract concluded between the client and the professional - Compliance with a legal obligation
Delivery of ordered products	Personal data (contact details, email address) is used to ensure deliveries.	The execution of a contract concluded between the client and the professional
Administering the website and fighting fraud	Personal data (cookies) to update and enhance our website and to combat internet fraud.
Customer service: exchanges with customer service	Personal data is used to interact with customers. As such, exchanges between customer service and the customer conducted by telephone or chat may be recorded to improve service quality. The customer may object to this at any time.	The execution of a contract concluded between the client and the professional
Participation in special events (such as contests, games, prize draws, offers) and participation in the loyalty program, excluding online gambling and games of chance subject to the approval of the French Online Gaming Regulatory Authority (ARJEL).	Personal data, including purchase information, is used to administer participation in various special events, as well as the loyalty program.	– The execution of a contract concluded between the client and the professional (game rules) - The legitimate interest of the data controller in order to offer preferential offers.
Exploiting, evaluating and improving products and services and the user experience (including developing new products and services, analyzing the customer base; performing data analysis, accounting and auditing), profiling.	Personal data is used to evaluate and improve products and services, and to enhance the customer experience of the products and services offered by ETCH, through statistical operations and analysis of anonymized customer behavior, and measurement of website and mobile application traffic.	The legitimate interest of the data controller in order to offer products and services tailored to customers' needs
Sending newsletters and special offers is subject to the user ticking the box indicating their acceptance, provided for this purpose, when registering for the Services.	Personal data is used to inform customers about our products and services and to personalize the products offered on social networks.	The legitimate interest of the data controller in order to offer products and services tailored to customers' needs
To fulfill the obligations arising from all contracts or agreements binding ETCH to its clients	Personal data is used to inform customers about our products and services and to personalize the products offered on social networks.	The legitimate interest of the data controller in order to offer products and services tailored to customer needs and consent (checkbox)
To analyze website visits and their frequency, audience measurements, studies, statistics, surveys (cookies) and to improve the user experience on the website and mobile application	Personal data, including cookies, is collected to understand the use of the Website and the mobile application.	The legitimate interest of the data controller in order to offer products and services tailored to customers' needs

ETCH does not share any personal data with third parties for commercial purposes. Users have the right to modify their personal data and withdraw their consent at any time by logging into their customer account.

SERVICE PROVIDERS WITH ACCESS TO USERS' PERSONAL DATA

The personal data collected is transmitted to ETCH's service providers, who may process it on behalf of ETCH (subcontractors) and/or for their own purposes (data recipients). Data recipients include: Shopify Payments, the payment provider; any police or administrative authority in the context of legal requests related to combating fraud; and customs services and providers in the event of international deliveries. ETCH's subcontractors may have access to the collected data for: preparing and shipping orders and processing product returns; improving the content of the Website and mobile applications; and performing technical maintenance and development on the Website, mobile application, and ETCH's internal applications, including entities that fulfill orders and host the Website and mobile applications, store information, provide email and customer support services, and offer analytics and tag management services, such as Google Analytics. For more details on these analytics services and how to opt out, please visit the following page: https://support.google.com/analytics . ETCH may also share User Data from customers with an account in its physical stores. Access to this data is limited to orders placed by the customer.

USERS' RIGHTS REGARDING THEIR PERSONAL DATA

In accordance with Articles 14 to 22 of the General Data Protection Regulation 2016/679 of April 27, 2016, any natural person using the site has the right to exercise the following rights: - The right to access, rectify, and delete collected data, - The right to object to the processing of their data, - The right to restrict processing, - The right to data portability, - The right to provide instructions regarding the storage, erasure, and communication of their personal data after their death, in accordance with Article 40-1 of the French Data Protection Act. Finally, if ETCH detects a data breach likely to result in a high risk to the rights and freedoms of its users, it undertakes to inform the users concerned as soon as possible and the competent supervisory authority, namely, in France, the CNIL. The User may exercise all of these rights by logging into their customer account, by contacting customer service at hello@etch-couteaux.com, or by mail to ETCH – Customer Service, 13 rue du Baigneur – 75018 Paris, France. The User must include proof of identity with their request. In the event of no response or an unsatisfactory response, the User may contact the supervisory authority in their country of residence; for France, this is the CNIL: https://www.cnil.fr/

DATA RETENTION PERIOD

User Data will not be retained beyond the period strictly necessary for the purposes stated herein, in accordance with applicable regulations and laws. In this regard, Data used for marketing purposes may be retained for a maximum of 3 years from the closure of the User's account or the last contact with the prospect in question. User data is deleted when the retention periods expire. However, certain Data may be archived beyond the prescribed periods for the purposes of investigating, establishing, and prosecuting criminal offenses, solely to allow, if necessary, the provision of this data to the judicial authorities. Archiving implies that this Data will be anonymized and will no longer be accessible online.

SECURITY MEASURES FOR COLLECTED PERSONAL DATA

As the Data Controller, ETCH is committed to taking all necessary precautions to ensure the security and confidentiality of data and, in particular, to prevent it from being altered, distorted, or accessed by unauthorized third parties. ETCH has entered into service agreements with partners possessing proven expertise in the field of data protection. All Data is hosted in France or the European Union. Payment Providers : Purchases on the Site are processed via Shopify Payments, specifically through the secure platform of our payment provider, Shopify Payments. ETCH never has access to customers' payment data. Users can choose to save their payment card details in their customer account. This data is not stored by ETCH, but by Shopify Payments. Users can modify or delete this bank information at any time by logging into their customer account.