CHARTER FOR THE PROTECTION OF CUSTOMER’S PERSONAL DATA
Our commitments for the protection of your personal data
The Compagnie de Phalsbourg Group (hereinafter “the Group”*) maintains a close relationship with the customers of its centres and today creates a Charter for the protection of personal data. This charter applies in particular to the website https://www.thevillageoutlet.com/ and to your visit to our village of brands, The Village.
This charter informs you of our commitments regarding the protection of your personal data: it presents within a single document clear, simple and sincere information concerning the Group’s data processing operations. This charter will enable you to understand what information and personal data (hereinafter referred to as “personal data”) we collect and how we use it to provide you with daily services, while respecting all your rights regarding your personal data.
The Group is committed to respecting the rights of individuals and all laws and regulations in force:
- Transparency: we provide you with all the useful information on the purposes and the recipients of your collected data
- Legitimacy and relevance: we collect and process only the data necessary for the stated purposes
- Confidentiality and integrity: we put in place all the technical and organisational measures necessary to protect your personal data against disclosure, loss, alteration or access by an unauthorised third party
- Retention : we retain your personal data only for the time necessary for the processing or the specific service
- Right of access: we offer you the possibility to access, modify, correct or delete your personal data by contacting us at the following address:
- Compagnie de Phalsbourg
- RGPD – Droits d’accès (GDPR Access rights)
- 22 Place Vendôme
- 75001 PARIS France
- Or by email: email@example.com
Our uses of your personal data：
2.1 On what occasions do we collect your personal data?
Your personal data can be collected as part of:
– The recruitment procedure
– Your membership of our loyalty programmes
– Your visit to our website
– Your visit to our online services
– Forms relating to services
– Our commercial relationship
Your purchases of products, including gift cards, and the use of services of The Village Centre or those of our partners
– Your contacts with our customer service
– Your participation in contests or surveys
– Your shopping trip in The Village centre, as it is equipped with Beacons,
– Your use of free wi-fi at The Village
2.2 What is the nature of the data collected?
The personal data collected is that provided by you as part of our commercial or institutional relationship, for example:
– Sending your CV
– The creation of your customer account and your loyalty programme membership
– The management of your orders
– The follow-up of commercial or promotional information from our stores or our online services
– Any exchange with the Group, for example with customer service
– Participation in contests
– Gift card purchase
– Use of free wifi
– Sign-up to our newsletters
This data is collected via forms that are computerised, paper or in response to questions asked for example by our staff and in particular our customer service.
Mandatory data is indicated by an asterisk on the collection medium.
Personal data relating to the Group’s products and services.
Exclusion of particular categories of personal data
In accordance with the law, we do not collect any data that would reveal racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic personal data, biometric personal data for purposes of identifying a person individually, personal data relating to health or personal data concerning the sexual life or sexual orientation of a natural person.
2.3 How do we use your data?
We use your data in accordance with the terms of this Policy in a constant concern for transparency and security.
Cases of use:
– When you apply for a job, the information you provide by submitting your CV will be forwarded to the Group’s Human Resources department and kept in our database to allow us to call you if a position is vacant.
– When you have consented, following clear, apparent and precise information concerning the processing carried out, for one or more specific purposes either by means of a written declaration, including by electronic means, or due to a lack of opposition of an oral statement
– When necessary for the execution of a sales contract, general conditions of sale or use or the performance of pre-contractual measures taken at your request
– To comply with the Group’s legal or regulatory obligations
– When the legitimate interests of the Group or of recipients may be such as to justify processing by the Group of your personal data (example: insurance…) ;
This processing is implemented taking into account your interests and your rights as a client and/or candidate. As such, they are accompanied by measures to ensure the protection of your interests and your rights
2.4 Why do we collect your data?
– For the purposes of the recruitment process
– To manage our commercial relationship
– To manage our loyalty programme
– To offer our services, process your purchases and orders and those of our partners
– To deliver products and services
– To communicate with you regarding your orders, invoices, products, services and promotional offers
– To keep and update our client files
– To provide adapted, personalised services especially in the context of the development of our products and services
– To improve your customer experience through a better knowledge of our customers
– Thanks to data analysis, we can customise our products and services to adapt them to the needs of our customers
– To suggest in a marketing framework innovative services and products or complementary or promotional offers or display relevant and targeted advertising based on past behaviour or any other useful information, after having obtained your consent
– For the prospecting and development of our activities
– To conduct analyses and collect statistics, and develop management, measurement and reporting tools to adapt our commercial and marketing activities
– For technical purposes (e.g. for access to your customer account, saving your personal data to avoid having to enter it again during your visit or during your next visits to the site).
2.5 What analyses do we perform on your data?
The Group and its subcontractors are likely to analyse the data collected for marketing purposes.
This data is then transformed into anonymous detailed profiles before any use in order to:
– Conduct targeted internet advertising campaigns for clients
– Ensure customers benefit from offers corresponding to their consumption habits.
If you do not want to benefit from cookies* and targeted advertising*, depending on your interests, you have several options to disable this feature:
– You can configure your browser settings to restrict or block cookies from the Website. Your browser may include information on how to adjust your settings.
– Alternatively, you may visit www.allaboutcookies.org to obtain general information about cookies and how to adjust the cookie settings on various browsers. This website also explains how to delete cookies from your computer. You can also opt out of targeted cookies from certain providers using the opt-out process presented by www.youronlinechoices.eu.
Restricting cookies may have an impact on the functionality of the Website.
Information about cookies
A cookie is a text file that contains small amounts of information that are downloaded to your computer or mobile device when you visit a website. On the Website, cookies do several different jobs. They allow you to navigate efficiently between pages, save your preferences, and, in general, enhance your experience on the Website. They also help make online advertising more relevant to you and your interests.
About targeted ads
We work with advertising partners to provide you with relevant advertising content.
2.6 Who are the recipients of your personal data?
Only authorised persons within the Group and its subcontractors may access your personal data when necessary for the execution of our commercial/institutional relationship and/or recruitment.
Our service providers may also be recipients of the personal data strictly necessary to perform the services we have entrusted to them (example: delivery address…).
Some personal data may also be sent to third parties strictly to meet legal, regulatory or contractual obligations or to legally authorised authorities.
2.7 Where is your personal data stored?
The data is stored by the Group and its subcontractors who collect them, in compliance with French and European regulations.
We may share with other companies personal data strictly necessary for the implementation of services you have contracted or subscribed to.
Transactions with a third party recipient of your data are the subject of an agreement with the said third party to ensure the protection of your data and the respect of your rights.
The information we collect about you is stored in the EU, except for certain information that is stored in England.
In the context of a transfer to a country outside the European Union, rules ensuring the protection and security of this data have been put in place.
2.8 How long do we store your personal data for?
The retention periods of the data respect the recommendations of the CNIL (France’s national data protection authority) and/or the legal obligations:
|Categories of personal data||Active retention rules|
|Data from your customer account||3 years after the last customer contact|
|Data from your loyalty programme||3 years after the last customer contact|
|Personal connection data from the websites (e.g.: IP address)||1 year|
|Cookies||Validity period 13 months maximum|
|Purchase data||3 years|
|Prospects data||Data retained as long as the client remains active and does not request deletion of their data.|
- How to exercise your access rights?
If you have any questions about the protection of your personal data please contact us at the following address: firstname.lastname@example.org.
You can unsubscribe at any time from any newsletter by clicking on the link in each newsletter.
You can exercise your access rights by mail with a copy of any identity document by sending a letter to the following address:
Compagnie de Phalsbourg
GDPR – Right of access
22 place Vendôme
75001 PARIS France
or by email: email@example.com
- Our data security measures
Respecting your right to the protection, security and confidentiality of your data is a priority for us.
The Group undertakes to implement security measures adapted to the degree of sensitivity of personal data to protect them against malicious intrusion, loss, alteration or disclosure to unauthorised third parties.
When developing, designing, selecting and using our services that rely on the processing of personal data, the Group takes into account the right to the protection of personal data from the outset.
For example, we make personal data anonymous as soon as this becomes necessary.
Since all personal data is confidential, access is restricted to Group employees and, where applicable, to our subcontractors and service providers acting on behalf of the Group, who require it for the performance of their duties.
All persons having access to your data are bound by a duty of confidentiality and are subject to disciplinary measures and/or other sanctions if they do not respect these obligations. Transactions with a third party recipient are subject to a contract to ensure the protection of your personal data and the respect of your rights.
“Collect”, collect personal data. This collection can be carried out, in particular, by using questionnaires or online forms
“Consent”, your consent means any expression of free, specific, informed and unambiguous will by which you accept, by a statement or by a clear positive act, that personal data concerning you is the subject of processing
“Personal data” refers to any information relating to an identified or identifiable natural person; who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to their physical, physiological, genetic, psychological, economic, cultural or social identity
“Right of access”: refers to all the fundamental rights as described in the European regulation (1), concerning:
– Right to information
– Right of access
– The right to rectification
– The right to erasure or the right to be forgotten
– The right to portability
– Opposition rights
– Right to restriction of processing
– The right to set guidelines for the storage, deletion and communication of personal data after death.
“Products or services” refers to all products and services including technology (websites, applications and associated services) that are provided or that will in the future be provided by the Group
“Commercial prospecting” refers to the search for customers, the fact that it is commercial means that it is relative to the trade, that it relates to it
“Business relationship” includes all relations between the Group and its customers, for example, when you purchase products or services, use of the after-sales service, your participation in online games, the return of your products, your claims, your participation in satisfaction surveys or as part of your loyalty programme
“Data controller” is the person or the organisation who, alone or jointly, determines the objectives and the processing methods of your personal data
“Online services” refers to the digital services offered by the Group such as the website, applications, related services or mobile services
“Subcontractor” refers to the person who processes personal data on behalf of the person, structure or body responsible for the processing
“Third party” refers to anyone other than the Group and yourself
“Personal data processing” refers to any operation or group of operations applied to your data, regardless of the online service support in question and the process used.
(1) REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27th April 2016, art. 15 to 21 and art. 23
*The “Compagnie de Phalsbourg Group” refers to any company owned directly or indirectly by Mr Philippe Journo pursuant to Article L233-3 of the French Commercial Code. To date, this concerns companies such as Compagnie de Phalsbourg, IQC Asset Management, Laurent Cabinet, Wishibam, Seed For Tec, Laurent Cabinet, Restokids, Tara, Elsa, CDP HOTELS.
 A beacon is a small sensor box that can “chat” on a small perimeter with smartphones or tablets via a Bluetooth connection. The technology used is mainly Bluetooth Low Energy. Placed at a point of sale, a beacon can send messages, promotions or record visits to credit loyalty points. The small radius of detection linked to a beacon makes it possible to contextualise the messages according to the radius in which the visitor is located.