1.2 The Policy concerns personal data through which you can be directly or indirectly identified. We will refer to this data throughout the Policy as « personal data ».
1.3 Please read this Policy to understand how the COSMOS CIRCLE Website can use your personal data.
1.4 For more information on the protection of private data, you can consult the website of the National Commission on Computer Technology and Freedoms (hereafter « CNIL ») www.cnil.fr
1.Who is responsible for the processing of your personal data ?
The COSMOS CIRCLE company is responsible for all processing defined in the present Policy. COSMOS CIRCLE is a simplified joint stock company with a capital of 500 euros, registered in the Paris Trade and Companies Register, under the number 851 524 439, with the headquarters located at 229 Rue Saint Honoré, 75001 Paris (hereafter designated « MADAME W »).
Intracommunity VAT number : FR5085124439
2.What personal data concerning you is collected by COSMOS CIRCLE ?
Which data ?
COSMOS CIRCLE collects your name, postal address, email address, telephone number, IP address, connection and navigation data, order history, information linked to after-sale services, preferences and interests, viewed products and claims.
You are informed of the mandatory nature of the data during its collection.
COSMOS CIRCLE collects the data that you provide when :
- You make an order on the Website
- You navigate and consult products on the website
- You contact the customer service
3.Why does COSMOS CIRCLE collect your personal data ?
COSMOS CIRCLE collects and uses your personal data for the following reasons :
3.1 The management of orders and customer relations
COSMOS CIRCLE requires your personal data to manage orders and follow-ups (for example, organisation of invoices, the management of customer accounts, the management of claism and customer services)
3.2 The payment of your orders
When you pay on the Website, your payments are securised. COSMOS CIRCLE does not collect your payment data, instead only an identification of the payment and a portion of the numbers on your bank card are identified, allowing for recognition of the bank card used for the payment. The integrity of your banking details are only collected by our payment service provider, certified PCI-DSS (banking security regulation), gauranteeing the security of payments.
3.3. The personalisation of services and messages addressed to you
Personal data allows COSMOS CIRCLE to improve and personalise the services and communications addressed to you.
3.4 Efforts against fraud
The personal data collected on the Website are processed in order to securise payments and to ensure an optimised quality of service.
3.5 Customer knowledge and the statistics and performance of the Website
COSMOS CIRCLE can use the data to better understand its customers, or for statistical purposes to analyse the Website activity, as well as to improve the services offered. COSMOS CIRCLE analyses the client’s navigation, conducts audience measuring, for example, measuring the number of pages viewed, the number of Website visits, and the activity of the visitors on the Website and their return rate.
4.Which communications am I likely to receive ?
Following your order, you will receive an email allowing you to track your order (confirmation of order, information about the shipping of your order, responses to claims, etc.) These emails are necessary for the successful execution of orders that you have made.
The legal basis for such processing is the contract.
The reception of the above informative communications is not dependent on the choice you made about receiving newsletters and commercial offers.
5.For how long is personal data processed ?
Your data will not be conserved for longer than the duration strictly necessary for the purposes stipulated in this Policy, in accordance with applicable regulation.
The majority of data (for example, your customer account data and order history) are conserved for as long as you are an « active » customer, and for a duration of 5 years counted from your last activity (for example, a purchase). Your data will then be archived with restricted access for a supplementary duration, and for limited purposes, as permitted by law (for payments, litigations, etc.).
When the duration of data conservation ends, your data will be erased or anonymised to the extent where it can be used without infringing on your rights. However, your data can be archived for longer than the prescribed duration for reasons of research, observation or for the prosecution of criminal offences with the sole purpose of permitting, as required, the provision of your data to judicial authorities.
6.On which legal grounds is personal data processed ?
The processing of your personal data is justified by different legal bases, depending on the way in which COSMOS CIRCLE uses the personal data.
In certain cases, COSMOS CIRCLE requests your consent in order to process your personal data.
However, under certain circumstances, the laws of data protection allow for the processing of your personal data without requiring your consent.
You will find the legal grounds and durations of data conservation that COSMOS CIRCLE applies to its principal data processing activities below :
- Consent : you accept to the processing of your personal data via express consent (select or tick a box, click…). You can withdraw your consent at any time ;
- Contract : the treatment of personal data is necessary to carry out the contract to which you consented ;
- Legitimate interest : COSMOS CIRCLE has a commercial interest for treating your data. This interest is justified, proportionate and does not infringe on your privacy. Save for exception, you can challenge data processing based on legitimate interest at any time, by notifying COSMOS CIRCLE ;
- Law : the processing of your personal data is rendered obligatory by the applicable rules and regulations.
Table summarising the processing :
|Purpose of processing||Legal grounds||Duration of conservation on operating base||
Type of data collected
|Management of jewelry orders||Contract||5 years counted from the date of the order||Contact details (name, address, postal code, telephone number), banking information (payment identification and a portion of your bank card’s numbers to allow for identification of the bank card used for the payment), delivery address|
|Management of customer relations, order tracking, after-sales service, and potential reimbursements||Contract||5 years counted from the last activity||Contact details (name, address, postal code, telephone number), banking information (payment identification and a portion of your bank card’s numbers to allow for identification of the bank card used for the payment), customer account credentials and order identifications.|
|Opening and use of customer account||Consent||5 years counted from the last activity||Contact details (name, address, postal code, telephone number, email address), date of birth|
|Customer knowledge, statistical analysis, commercial prospection||Consent / legitimate interest||5 years counted from the creation of the data||
Navigation data, data from the orders basket and orders, gender and postal address.
|Personalisation of services via cookies||Consent / legitimate interest||2 years counted from the creation of the data||Information about your device, IP address, navigation analysis via cookies, event monitors, tags and other technology
|Website security||Law / legitimate interest||5 years counted from the last activity||Connection credentials, navigation data|
|Exercise of rights relating to data||Law||5 years counted from the request||Name, contact details, purchase history and other information shared by the user|
|Fraud prevention||Legitimate interest||3 years counted from the date of registration on an alert list||Name, invoice address, email address, telephone number, payment information, purchase history
7.Who are the recipients of my data ?
Use of data by COSMOS CIRCLE
Data collected on the Website by COSMOS CIRCLE is first of all intended for COSMOS CIRCLE personnel to better get to know you and thus better serve you, as a COSMOS CIRCLE customer.
Sharing of data with subcontractors
The data collected can be shared to service providers (subcontractors) to which COSMOS CIRCLE depends upon for service delivery, in the context of the aforementioned purposes, for example, management, execution, processing, payments of orders and marketing operations.
When necessary, COSMOS CIRCLE shares, solely to these third parties, the data that they require to conduct their services. COSMOS CIRCLE requires the third parties not to use the data for other purposes. The third parties act in accordance to COSMOS CIRCLE’s instruction, and are contractually-bound to assure a standard of security and privacy regarding your data, identical to that of COSMOS CIRCLE, as well as in conformance to applicable rules and regulations of personal data protection.
Sharing data with third parties (other than subcontractors)
The categories of third parties able to receive personal data from COSMOS CIRCLE are :
- social networking sites ;
- police authorities in the context of judicial inquiry concerning efforts against fraud, or other authorised third parties.
8.How to withdraw consent regarding the use of your data ?
Using this basis, you can withdraw your consent of data processing or object to the usage of your data, at any given moment, through the channels listed below :
- By post to the address : 229 rue Saint Honoré 75001 Paris
- By email to the address : firstname.lastname@example.org
9.How is your data protected ?
COSMOS CIRCLE takes adequate technical and organisational measures to prohibit non-authorised access, modification, disclosure, loss or destruction of your data.
10.What are your rights concerning the use of personal data ?
In accordance with the law on personal data protection, you can exercise your rights (access, correction, deletion, objection, limitation and portability, where applicable) allowing you to decide the outcome of your personal data « after the fact » by post to the following address : 229 rue Saint Honoré 75001 Paris, or by email to the following address : email@example.com
In order to facilitate an efficient response, please indicate your name, email address, postal address, and if applicable, your customer reference and to which email address you would like a response. COSMOS CIRCLE will then proceed with identitiy verifications in order to guarantee the privacy and security of your data. In certain cases, a copy of an identity document along with your signature may be requested.
A response will be addressed to you within 1 month of reception of your request.
In addition, you have the right to present a claim to the National Commission on Computer Technology and Freedoms (CNIL), on its website : www.cnil.fr
11.Is your data shared beyond the European Union ?
COSMOS CIRCLE does not transfer your data outside of the European Union.
12.What about the data of minors ?
The services of COSMOS CIRCLE are not intended for minors. Consequently, COSMOS CIRCLE does not process data concerning minors.
13.What is the use of data in relation to social networks ?
Data concerning your navigation can be collected by social networks for the purpose of their own targeted advertisement via cookies dispensed during your navigation on the Website. The data shared is the navigation data (namely, pages visited, products viewed, category of viewed products) and purchases (namely, the products purchased or categories of products purchased).
COSMOS CIRLE brings your attention to the fact it is not responsible for the processing of your data by social networks acting on their own behalf. As such, COSMOS CIRCLE invites you to consult the personal data protection policies of social networks in order to familiarise yourself with the data collection of these third parties.
The feature ‘Social Connect’ allows you to connect to the Website using your social network accounts (for example, Facebook or Google), to facilitate your purchases and access to the services of the Website. When you connect to the Website using these third parties, COSMOS CIRCLE can access certain information allowing for a personalised, social experience. The data collected by COSMOS CIRCLE on the Website is not shared with social networks without your consent. It is up to you to manage your privacy parameters on social networks when you connect to the COSMOS CIRCLE services using your social network credentials.
14.What cookies are used ?
COSMOS CIRCLE can collect data when you use the Website, notably your IP address or other navigation data, using cookies or similar device technologies. Certain cookies are necessary for the proper functioning of the Website, and others are used for the purpose of analysis, which help to provide more personalised services and a better digital experience. For more information on these cookies, and to learn how to modify your preferences, please read the cookies management Policy.