The Kooples (“Us”) are extremely vigilant about the privacy of visitors to its online boutique (the “Website”), the physical The Kooples boutiques (the “Boutiques”), and more broadly to the privacy of people from whom it receives Personal Data (see definition below) when contacting its brand (“You”).

This Privacy Policy is an integral part of the General Terms of Sale. It is applicable each time you send The Kooples your Personal Data and when The Kooples processes any of these Data.

As such, you expressly agree to the use of your Personal Data in compliance with the Privacy Policy herein when you place an order on the Website, make a purchase at a Boutique, open a customer account or enter a contest; or when you contact our Customer Service department or consent to receiving marketing materials from us, and more generally, when you browse and/or log on to our Website or interact with The Kooples in any manner whatsoever.

In accordance with the personal data protection laws in force, we reserve the right to change our Privacy Policy at any time. You shall be informed by any appropriate means should such changes be made.


ARTICLE 1. The Controller and Our Commitments

The Controller of your Personal Data is THE KOOPLES Group, which includes THE KOOPLES PRODUCTION and THE KOOPLES DIFFUSION, located at 11 rue de Prony, 75017 Paris, France (“The Kooples” or “Us”).

We undertake to securely process your Personal Data in compliance with the regulations applicable in France and the European Union pertaining to personal data protection (“Applicable Regulations”), namely including:

• The French Data Protection Act No. 78-17 of 6 January 1978, as modified, and any updates

• 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 (the “GDPR”) and any other subsequent laws, including enforcement texts

• Laws enacted in the European Union and local laws pertaining to Personal Data, where applicable

• Laws and rulings issued by oversight authorities, namely the French Data Protection Agency (CNIL)

In an effort to ensure compliance with the Applicable Regulations and the provisions of the Privacy Policy herein, we have appointed a Personal Data protection officer.

You may send this officer any questions relating to your Personal Data via the Contact Form and selecting Personal Data as the purpose for contact.


ARTICLE 2. The Personal Data that We Collect

“Personal Data” refers to any information relating to you that can be used to personally identify you directly or indirectly.

As such, we are required to collect your:

• Title, surname, and given name

• Postal address and telephone number

• E-mail address

• Bank card number collected at the time of your purchase and processed by the banking service provider we have engaged to manage payments

• Username and password

• Date of birth

• Messages on e-mail, chat or social media networks, and/or telephone conversations with Customer Service, as well as any other data that enable the maintenance of business relations

• Images of you taken by CCTV cameras in the Boutiques, where applicable

• Cookies and other trackers comprising the information cited in the section OUR MANAGEMENT POLICY FOR COOKIES (TRACKERS), IP address and other information enabling your identification and that you provide to us at any time

• Any other information enabling your identification and that you provide to us at any time, such as on social media or via our chat service

When you log onto our Website with authentication via Facebook or Google, Facebook or Google sends us your personal information, in accordance with the options you have chosen on Facebook or Google, at the e-mail address you entered on Facebook or Google.


ARTICLE 3. When We Collect Personal Data

We may collect your Personal Data when you:

• Visit the Website

• Log on or open a customer account on the Website or at a Boutique

• Place an order on the Website, at a Boutique or by telephone

• Return an order

• Sign up for the Newsletter

• Enter a contest organised by Us or one of our partners

• Submit a complaint, ask a questions or send us your comments

• Transmit to us your Personal Data on the Website or by any other means whatsoever

• Interact with us on our official social media sites

We also use cookies and other trackers. For more information, please refer to the section titled OUR MANAGEMENT POLICY FOR COOKIES (TRACKERS).


ARTICLE 4. Why we collect your data

Based on the contract that binds us, a legal obligation, our valid interest or upon obtaining your consent, we are required to process your Personal Data to fulfil the following purposes:

Data processing purposes

Bases of data processing

To fulfil orders placed on the Website, by telephone or at Boutiques

To manage customer relations (telephone, e-mails, chats), new accounts, order tracking, product returns, and refunds

To manage customer complaints or product queries (warranties)

To execute the contract between a Customer and The Kooples

To manage payment transactions and issue invoices

To execute the contract between a Customer and The Kooples

To prevent fraud

Valid interest of The Kooples

To manage shipping operations

To execute the contract between a Customer and The Kooples

To manage customer complaints or queries about our products or brand

Valid interest of The Kooples

To manage and improve the customer account, namely by providing new features or services

Valid interest of The Kooples to improve service

To manage customer satisfaction via customer surveys about products and customer service performance

Valid interest of The Kooples to improve products and services

To record conversations between Customer Service and the customer by telephone or on the chat platform in order to improve service

Valid interest of The Kooples to improve quality of service

To conduct statistical, analytical, selective, and segmentation operations for customers to improve customer knowledge

Valid interest of The Kooples to become better acquainted with its customers, notably to customise its customer offers

To expand and enhance its Website

Valid interest of The Kooples to improve service

To manage requests so you may exercise your rights

Legal obligation

To electronically send targeted promotional offers relating to current or new products and services (e-mail, mobile or Website notifications, social media, other websites), by telephone (call or text) or at Boutiques

Customer consent

To send promotional offers relating to products and services via the post

Customer consent

To analyse Website traffic (mobile and desktop)

Customer consent

To provide sharing tools on social media

Customer consent

To analyse customer behaviour on the Website or at Boutiques, and customer responses to marketing campaigns to improve and personalise products and services, and to provide them as business communications and/or advertising

Customer consent

To personalise the browsing experience on the Website and for the ads posted, for us or our partners, on our Website or third-party platforms, based on customers preferences.

Customer consent


ARTICLE 5. Newsletter

You may sign up to receive our Newsletter when placing an order on the Website or at a Boutique, at which time you may opt whether to receive regular notifications about our promotions on the Website and/or at Boutiques.

You may unsubscribe at any time by clicking on the link provided for this purpose appearing on the bottom of each newsletter or by completing the Contact Form.


ARTICLE 6. Who We Share your Personal Data with

We may be required to share all or some of your Personal Data with the following groups:

1. The companies in the The Kooples Group as well as our franchisees and distributors, which may exclusively use your Personal Data to send you information and promotions about current or new The Kooples products, providing that you have given your consent.

2. Some of our service providers that process your personal data, on our behalf and per our instructions, to provide us assistance in rendering the following services:

• To fulfil your order, including preparing and shipping your products

• To securely process your payment

• To prevent fraud and collect, as required, overdue payments

• To send promotional sales e-mails and mobile notifications

• To store all of your Personal Data

• To personalise our Website to suit your preferences

• To manage the chat service and telephone calls, and to make any recordings

• To dispatch postal mailings

• To conduct technical maintenance and development of the Website and The Kooples information systems

• To collect customer ratings

• To analyse your use of the Website with a view to improving the quality and performance of the Website

You are reminded that the groups with which we share your Personal Data are bound by a confidentiality agreement and required to comply with the Applicable Regulations on Personal Data protection.


ARTICLE 7. Where We Send Your Personal Data

Your Personal Data are stored in Europe where the Website servers are hosted.

Some of the service providers or subcontractors with which we share your Personal Data, as listed in the section WHO WE SHARE YOUR PERSONAL DATA WITH, operate outside the European Union and may be located in countries not recognised by the European Commission as providing an adequate level of security. Pursuant to Applicable Regulations, in such cases we undertake to:

• Enter into cross-border data flow agreements with these companies in compliance with the European Commission’s standard contract clauses, or

• Partner with companies that have Binding Corporate Rules (BCRs) that enable cross-border transfers.

You can receive further details on this topic and, if needed, a copy of the cross-border data flow agreements we have signed with our partners by sending a request via the Contact Form.


ARTICLE 8. How We Secure Your Data

We have implemented internal procedures to secure your Personal Data when they are used, transferred and stored. We also monitor the procedures in place to ensure they comply with the Applicable Regulations.

In particular, these security procedures include:

• A commitment from our partners and subcontractors when we utilise their services to adhere to their contractual obligations on guaranteeing adequate protection for the Personal Data they can access when, in particular, providing you access to the Website and its content or fulfilling your orders (including telephone orders),

• Restricting access to your Personal Data to employees whom are bound by a confidentiality agreement and require access to your Personal Data to provide products and services, and/or whose remit justifies such access,

• Implementing precautionary measures that protect your Personal Data being destroyed, lost or modified, and preventing any unauthorised access to your Personal Data,

• Storing your Personal Data on fully secured servers. In compliance with the Applicable Regulations, the data are stored for the time periods indicated in the section HOW LONG WE KEEP YOUR PERSONAL DATA. These time periods do not exceed the durations needed to fulfil the purposes indicated in the section WHY WE COLLECT YOUR PERSONAL DATA.

ARTICLE 9. Your Rights and How to Exercise Them

• Pursuant to the Applicable Regulations, you have the option to exercise the following rights:

• The right to access your data

• The right to rectify and erase your data (right to be forgotten)

• The right to restrict the processing of your data

• The right to data portability

• The right to contest the processing of your data

• The right to set directives for your data after your death

To exercise these rights, please use one of the following methods to contact us:

• Complete the Contact Form and select Personal Data as the purpose for contact

• Post a letter with a copy of your ID to the attention of Customer Service, The Kooples, 11 rue de Prony, 75017 Paris, France

You also have the right to submit a claim with a competent oversight authority.


ARTICLE 10. Our Management Policy for Cookies (trackers)

When you visit the Website, we may place small pieces of data on your computer which are known as “cookies” that your browser will store on your hard drive. In particular, these cookies allow us to:

• Properly operate our Website and improve your buying experience

• Analyse our traffic and optimise the performance of our Website

• Provide personalised content that suit your areas of interest

• Post targeted ads on our Website and elsewhere, for example social media sites, as well as ads based on your location, and

• Enable logins to our Website via social networks and other third-party sites.

We use the following cookies:

• Technical cookies relating to the Website's functionalities (required)

These cookies are compulsory for the proper operation of our Website and cannot be reconfigured. These cookies allow you to browse the Website, use its functionalities, and record your preferences such as language, account access, products added to your cart, etc. and to use predictive analytics to safeguard our Website against attempted fraud. In the event our systems detect an act of fraud that prevents you placing an order on the Website, you will immediately be informed. You then have the option to contact Customer Service to request a review of your payment.

• Analytic cookies on the Website

These so-called performance cookies help us to measure visitor traffic on the Website (number of visits, pages viewed, traffic sources, etc.) and to analyse how you navigate the Website and react to our products in an effort to optimise their performance. They collect data on how visitors browse the Website so that we may improve the site’s navigation and functionalities. By accepting these cookies, you are assisting in improving our Website.

• Preference-related cookies (experience and relations)

When you browse or make purchases online, the Website saves your preferences. This serves to simplify, facilitate and personalise your browsing experience to best fulfil your preferences and needs. These cookies help us to offer you product recommendations, relevant services or content on the site, in e-mails that you receive or at shops that meet your needs and preferences. They may also be used to test and improve the site's navigation. Using the site without these cookies may result in slowing it down or viewing less relevant recommendations.

• Geolocation cookies:

These cookies help you use some features of services offered on our Website. Some of our service providers may also use these cookies to show you ads based on your location, for example, the days and times a boutique is open.

• Targeting or advertising cookies (marketing and social media):

These cookies are used for displaying promotions that are of interest to you on our Website and elsewhere, including social media sites. They also limit the number of times you see an ad, and help us measure how effective our ad campaigns are. They collect specific data to target ads based on your areas of interest. If you turn off these cookies, some ads (including ours) will continue to be displayed as you browse, but they will not be based on your areas of interest and thereby be less relevant.

• Social media cookies:

These cookies enable you to log on to our Website via social networks such as Facebook, Google, and other third-party sites.


ARTICLE 11. How to accept or deny cookies

You have the option to save cookies to your device, with the exception of operational and security cookies which are required to properly operate our Website. Cookies are saved for 13 months.

You may turn off cookies yourself by adjusting the settings on your browser. Be aware, however, that denying cookies may inhibit your ability to use all the functionalities on the Website. Below is some information on how to deny cooking on select Web browsers:


1. Click on the Menu ≡ button and select Options.

2. Select the Privacy & Security panel.

3. Under Enhanced Tracking Protection, select the Custom radio button to choose what to block.

4. Select the Cookies checkbox. Cross-site and social media trackers is the default setting.

5. To block all third-party cookies, select All third-party cookies (may cause websites to break) from the drop-down.

6. Close the about: preferences page. Any changes you've made will automatically be saved.

Google Chrome:

1. You can block or allow all cookies by default. You can also allow cookies from a specific site, while blocking third-party cookies in ads or images on that web page.

2. On your computer, open Chrome.

3. At the top right, click More and then Settings.

4. Under 'Privacy and security', click Cookies and other site data.

Select an option:

- 'Allow all cookies'

- 'Block all cookies (not recommended)'.

- 'Block third-party cookies in Incognito'

- 'Block third-party cookies'.

Important: If you block third-party cookies, all cookies and site data from other sites will be blocked, even if the site is allowed on your exceptions list.

Please note that we do not control the use of third-party cookies.


ARTICLE 12. How Long We Keep Your Personal Data

In order to process personal data for the purpose of managing e-commerce customers, Boutique customers and prospects, mainly including managing customer relations and marketing campaigns, tracking online reservations for the boutiques, handling defective products, and tracking shipments, we use the following data retention periods:

• Personal Data on customers: the duration of the contractual relationship plus legally mandated periods, or five years,

• Data on non-customer prospects: Three years from the last active contact with our brand

• Cookies on history of purchases and website visits: 13 months

• Bank card number and expiration date: 13 months from the debit date or 15 months for deferred debit cards

• Bank card security code: duration of the transaction

• Videos taken by CCTV cameras: 30 days

In order to meet our legal, accounting, and tax obligations, and to be able to manage any complaints or warranty requests you may have, once your Personal Data is deleted from our active database, some of the Personal Data is archived for an interim period, within the applicable mandated durations.

In the event your Personal Data need to be archived at a later time, they will be automatically and irreversibly anonymised.


ARTICLE 13. Links to Other Websites

On our Website, we may post links that redirect you to other websites. However, we shall not be held liable for the content or data collection policies of those websites. If you visit third-party websites, we recommend that you check their privacy policy before giving them your Personal Data. We cannot be held responsible for their actions.


ARTICLE 14. Contact Us

If you have any questions about our Privacy Policy or how we process your Personal Data, please contact us by:

• Completing the Contact Form and select Personal Data as the purpose for contact

• Posting a letter with a copy of your ID to the attention of Customer Service, The Kooples 11 rue de Prony, 75 017 Paris, France.