For the purposes described in this policy, S.T. Dupont may collect the following categories of personal information:

a) Identification and contact information (such as name, address, phone number or email address), when you are willing to provide it, for example to create an online account or fill out an in-store customer information card, to participate in an event, to make a purchase, or identification information required when you request a VAT refund or an in-store "click and collect" service.

b) Payment information: for example: credit card details, bank account numbers, PayPal account details or other payment details that you need to provide to receive the products or services you have ordered from us.

c) Demographic information, when you are willing to provide it, such as your gender and date of birth.

d) Your image when you visit our stores (as surveillance cameras are in place), or your voice when you call S.T. Dupont Customer Service (as your call may be recorded).

e) Preferences and interests that you choose to disclose in the context of your privileged contacts or encounters with our customer advisors (which may include your preferences regarding our collections or other luxury brands, your size, your lifestyle or basic information about your family circle).

f) Information you submit or post in a public space, on our social media pages or on our websites, for example for a product review.

g) Information about your online or in-store purchases. This may include the products you have purchased and their prices.

h) If you use our websites, we may collect information about the browser you use and your browsing behavior.

i) If you use our mobile application, we may collect your GPS location, subject to your consent when required. We may also review the frequency with which you use the application and where you downloaded it. We may collect information about the browser you use and your browsing behavior.

j) If you use our connected products, we may collect information regarding your use of these products (such as the features of our product you use most or information about battery level), as well as geolocation information if necessary to provide you with the service you have requested.

k) We may also collect information posted on third-party websites or social media platforms about S.T. Dupont products and services, when necessary for the purposes defined below.

Your personal information is collected either directly from you (for example, if you create an account on one of our sites/applications or if you make a purchase or otherwise interact with our in-store customer advisors or with our S.T. Dupont customer services), or passively from you (for example, when you use tracking tools such as browser cookies), or from third parties (for example, through social media platforms).

If you choose not to submit personal information when requested to execute a contract or when required by law, you will not be able to receive the product or service you ordered or register on our websites, applications or other media.

We use the information described above for the purposes specified at the time of collection or later in this policy:

a) To improve our understanding of your interests and concerns, and to improve our understanding of your use of our products: we may use your information to make our website, apps, and products/services better. We may use your information to personalize your experience with us and tailor our marketing activities to your needs and interests, as we also believe it is in our legitimate interest to serve you better and meet your needs.

b) To provide you with our connected services, process your order, respond to your requests or questions, and manage your complaints: for example, we use your information to process your order and deliver your products. Or, we may use your information to send you information you have requested, or to communicate with you about your account or our relationship: we may contact you about changes to the website or service updates. We may also contact you for feedback or about this policy or the site's terms. In this case, your information is processed to perform the contract we have with you.

c) For security purposes: we may use information to protect our business, our customers, our associates and our websites or applications from fraud, theft or any other wrongdoing that could affect our business, as it is in our legitimate interest to ensure the security of our online and offline business.

d) To manage any adverse effects caused by our cosmetic products in accordance with our legal obligations as a cosmetic product manufacturer.

e) For anti-counterfeiting purposes as it is in our legitimate interest to combat online counterfeiting.

f) For marketing purposes: we may use your information to contact you, subject to your consent where applicable, about new products and special offers that we believe you will find valuable.

g) For analytical purposes, we may use your information to analyze the e-reputation of S.T. Dupont or our products and measure the effectiveness of our online or offline campaigns or events, as it is in our legitimate interest to preserve the image of S.T. Dupont and optimize our marketing campaigns.

h) Other purposes: we use the information to maintain records of transactions and other business activities for legal, administrative and auditing purposes. We also use the information to meet legal, insurance and processing requirements.

We share your personal information only when necessary for the purposes described in this Privacy Policy and when permitted by applicable law.

a) Companies within our group

We share your personal information with our parent company in France and with other companies within our group. Access is limited to authorized persons who need this information, particularly for administration, billing, internal audit, reporting, customer relationship management, and to provide you with a consistent level of service in the various countries where we operate.

b) Service providers

We share certain personal information with providers who act on our behalf in operating our business, including:

• customer service and request management providers
• hosting, e-commerce, and website maintenance platforms
• customer relationship management, email, SMS, and marketing communications providers
• IT, cloud hosting, cybersecurity, data analytics, audience measurement, and cookie management providers;
• order preparation, logistics, transport, delivery, repair, and after-sales service providers;
• marketing, communication, advertising, and content production agencies;
• providers responsible for fraud prevention, regulatory checks, or brand protection.

These providers only access the information necessary to perform their tasks and are subject to contractual obligations of confidentiality, security, and data protection.

c) Payment providers and financial institutions

We share the information necessary for transaction processing with banks, online payment providers, financial institutions, and providers responsible for fraud prevention and managing unpaid bills.

d) Business partners

Subject to your consent where required, we share certain personal information with the following categories of business partners:

• our authorized distributors, resellers, and stores, to track your purchases, requests, warranties, and your relationship with the brand;
• brands, organizers, co-organizers, sponsors, venues, and other partners participating with us in an event, collaboration, contest, promotion, or joint offer;
• partners offering complementary services, experiences, invitations, or benefits that may interest you;
• social media platforms, search engines, and advertising partners, particularly to measure our campaigns, personalize content, or build advertising audiences, in accordance with your choices regarding cookies and prospecting.

When these partners use your information for their own purposes, they act as independent data controllers and inform you of their own data protection practices.

e) Business reorganization

We share your personal information with advisors, acquirers, investors, or other relevant third parties in connection with a merger, acquisition, sale, restructuring, dissolution, liquidation, or transfer of all or part of our business or assets.

f) Authorities and legal obligations

We share your personal information with courts, administrative authorities, supervisory authorities, police services, tax authorities, customs, or other competent bodies when required by law, when an official request is made to us, or when necessary to protect our rights, our interests, or those of third parties.

We may collect, when you are ready to provide it, certain information through cookies, web beacons and other automated means. A cookie is a text file that is stored in a dedicated area of your device’s hard drive, for example when you visit an online service, read an email, or install or use a mobile application. A cookie allows its sender to identify the device on which it is stored for the period of validity of the consent, which does not exceed 13 months.

What types of cookies do we use?

a) Some cookies may be functional to collect information that will allow us to facilitate your navigation, such as language preferences, remembering login, or saving the contents of your shopping cart or wish list.

b) Other cookies also collect information about your behavior by collecting referrer URLs (where our visitors come from, what banners they clicked on and which directed them to our website), pages viewed, and times of visits to websites. This information will allow us to improve our websites and applications, to better understand the products and services you prefer, and to offer you more personalized communications and/or more personalized content on our website or applications.

c) We also use cookies for web analytics purposes to measure website activity and determine the areas of the websites that are most visited, thereby improving the visibility of our content.

d) We use cookies to ensure the security of online transactions/purchases through device digital fingerprinting, which makes it possible to identify certain aspects of the equipment used to place an order.

e) Our websites or applications may contain third-party cookies (provided by advertising agencies, analytics providers, etc.) allowing them to collect browsing information on your devices, including to measure the effectiveness of our advertising campaigns on third-party websites. Third-party cookies are subject to these third parties’ privacy policies. We inform you here of the purpose of these cookies and how you can manage them, as far as we are aware.

f) We may include on our website or applications the ability to share content with third parties or to let other people know that you have viewed our site. This is the case, for example, for the “Like” and “Share” features offered by social media platforms (Facebook, Twitter, etc.). Social networks offering these features may identify you even if you do not use these features on our site. Indeed, these features allow social media platforms to track information about your browsing on our site each time your social media account is active while you are browsing our site. We have no control over how these platforms collect your personal data when you browse our site. We invite you to read the privacy policies of these social networks to find out how they use the information they collect (including for advertising purposes) via these buttons. These privacy policies should provide you with information on how to manage your preferences on your social media account.

Acceptance of cookies

Except for functional or security cookies, the use of cookies on a device depends on the user’s choice, which can be made and modified freely and at any time. You can manage cookies by setting your browser to accept or reject cookies on your device, either globally or cookie by cookie. The settings you set may affect your ability to browse the Internet and may sometimes alter your ability to access certain services that require the use of cookies.

This is also the case if we or one of our business partners can no longer recognize the type of browser used by your device, such as the language, display settings, or country/region of connection. We cannot be held responsible for reduced access to our services due to cookies that you have previously deleted or rejected.

The information we collect about you may be transferred, stored, and processed in France to ensure that you can benefit from better services wherever you visit us and for the purposes defined in this policy.

We may also transfer your personal information to service providers involved in the maintenance of our websites, applications or social media or any other tool used for processing the information of our customers or prospects.

When we transfer your information, we will protect and provide adequate protection for the transfer of your personal information to recipients in these countries/regions by entering into data transfer agreements based either on the European Commission's Standard Contractual Clauses (as they may be revised or replaced by the EU Commission or supplemented by additional measures when necessary) with such data recipients, or on any other valid transfer mechanism that may become available in the future.

You can obtain a copy of these safeguards upon request.

Your personal data will not be kept in a form that allows you to be identified for longer than is reasonably considered necessary by S.T. Dupont to achieve the purposes for which they were collected or processed, or as determined by applicable laws relating to data retention periods. The retention period for your personal data collected by us is determined according to the purpose of data processing according to the following criteria:

Data collected for specific purposes defined in Article 2 will only be kept:

• For three (3) years from our last contact, if you are a prospect (i.e., you have not made a purchase from us but are interested in S.T. Dupont), or
• For the duration of your commercial relationship with S.T. Dupont and 10 years thereafter, if you are a customer (i.e., you have purchased our products or services),
  Except for certain specific processing operations that have a shorter retention period, such as images collected in stores by video surveillance systems, which are kept for the retention period specified in the store, and telephone conversations with our customer service, which are kept for the applicable legal retention periods.

Your personal data will then be archived for use:

• In the event of a dispute or disagreement during the limitation period applicable to the corresponding purpose,
• If legal action is initiated, personal information may be kept until the end of such action, including any appeal periods, and then will be deleted or archived in accordance with applicable law.
  Your personal data will then be anonymized or deleted.

You may request access to the personal information we hold about you. If you request such access, we will provide you with all information required by law regarding the purposes of the processing, the categories of data processed, the categories of recipients, the data retention period, etc.

You may also obtain a copy of all personal information we hold about you in our records in a compatible and structured format that will allow you to exercise your right to data portability when the processing is based on your consent or on the performance of an agreement between you and us.

You may also provide general or specific instructions on how your personal data should be processed and used after your death.

You may also request that we correct, amend, or erase any information that is incomplete, outdated, or inaccurate.

You may request the deletion of your personal information (i) if your personal information is no longer necessary for the purposes of data processing, (ii) if you have withdrawn your consent to data processing based exclusively on such consent, (iii) if you have objected to data processing, (iv) if the processing of personal information is unlawful, (v) if the personal information must be erased to comply with a legal obligation applicable to S.T. Dupont. S.T. Dupont will take reasonable steps to inform other entities in the S.T. Dupont group of this deletion.

You may request the restriction of processing (i) in case of a dispute over the accuracy of your personal information to allow S.T. Dupont to verify this accuracy, (ii) if you wish to restrict your personal information rather than delete it despite the processing being unlawful, (iii) if you want S.T. Dupont to retain your personal information because you need it for your defense in legal claims, (iv) if you have objected to the processing but S.T. Dupont is conducting a verification to ascertain whether it has legitimate grounds for such processing that may override your own rights.

You also have the right to lodge a complaint with the competent supervisory authority.

Where your information is processed to pursue our legitimate interests, you may object to such processing if our legitimate interests may be harmed by your interests and freedom.

To exercise these rights, please contact us at: service-client@st-dupont.com, and we will respond to you.

We will provide an adequate level of protection for personal data and will ensure that appropriate technical and organisational security measures are in place to protect personal information (including the training and awareness of relevant personnel) from accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access, and against all other unlawful forms of processing.

However, since the Internet is not entirely secure, we cannot guarantee that any of your personal information stored or sent to us will be completely secure. We encourage you to exercise caution when using the Internet to access our websites, applications or social media.

Our websites and applications are not intended for children. We do not knowingly collect personally identifiable information from children without parental or guardian consent unless permitted by applicable law.

You must be at least sixteen years old to provide personal information to us and eighteen years old to conduct transactions on our store or websites.

By engaging in transactions with us, you affirm that you are at least eighteen years of age and are fully able and competent to enter into and be legally bound by such transactions. If we are notified (by contacting us through “Contact Us”) or learn that a minor has submitted personal data to us through our media or otherwise, we will delete such personal information.

We may link to third-party sites or services that we do not control and that are governed by their own privacy policies. This Policy does not apply to these third-party sites. We strongly advise you to check the privacy policies of all third-party sites you visit to understand how they handle your personal information.

Our Policy may be modified from time to time to reflect changes to our handling of your personal information. We will notify you of any material changes as required by law. We will post an updated copy on the Site.

If you would like us to update the information we hold about you or your preferences, or if you have any questions about the protection of your personal information, please contact us by e-mail at rgpd@st-dupont.com.