Privacy Policy

Last modified November 2023.

This Data Protection Notice describes how Trust Price Jewellers (together, TRUST PRICE) collects and further processes personal data. If the activities covered by this notice are governed by other data protection policies, are obvious in the circumstances, or are governed by laws applicable outside the European Union and the European Economic Area, then those laws and the resulting policies will prevail. The term "personal data" includes all information relating to an identified or identifiable person.

This Data Protection Notice describes, in Section I, the general arrangements for the processing of personal data by TRUST PRICE. Section II describes the specific provisions for particular applications (e.g. online shop, newsletters and advertising banners), and Section III describes the specific provisions for customer loyalty programmes.

If you provide TRUST PRICE with personal data about other people, such as the recipient of a gift, you should only disclose that personal data to TRUST PRICE if you are permitted to do so under applicable law, and only if that other person would consent to you providing their personal data to TRUST PRICE for collection and processing in accordance with our data protection notice.

I. GENERAL PROVISIONS

1. DATA CONTROLLER, DATA PROTECTION OFFICER

Each website (including online shops and mini-sites offering special offers), any presence on social networks, multimedia portals, chatbots and all TRUST PRICE applications (each of which constitutes a WEBSITE) is assigned to a data controller within TRUST PRICE, in accordance with the General Data Protection Regulation (GDPR) (or comparable provisions under applicable data protection laws). Unless otherwise indicated on the WEBSITE (legal notice, terms of use, etc.) or in sections II and III below, TRUST PRICE, 45 rue de Villeneuve , Immeuble PANAMA - Parc ICADE, 94150 Rungis, France, is the data controller for the online shops www.trustprice.fr.

The relevant affiliate or subsidiary is the data controller if TRUST PRICE communicates by other means of communication (e.g. e-mail, post, telephone, in person) and the communication is not in connection with an activity for which TRUST PRICE has designated a specific data controller in this Data Protection Notice or otherwise.

If a TRUST PRICE company or affiliate discloses personal data to another TRUST PRICE company or affiliate for the purposes of the receiving TRUST PRICE company or affiliate, then the receiving TRUST PRICE company or affiliate will be the data controller.

TRUST PRICE has not appointed a data protection officer in accordance with Article 37 of the RGPD.

HOW TO CONTACT TRUST PRICE

If you wish to exercise your rights concerning newsletter subscriptions, access to data or the deletion of data, please contact our Customer Service department, who will be happy to answer any questions you may have.

Any queries, complaints or concerns relating to data protection at TRUST PRICE can also be directed to the Group Data Protection Team at trustprice.france@gmail.com or by WhatsApp: +33 7 49 23 70 68.

2. PROCESSING OF PERSONAL DATA

TRUST PRICE collects and processes personal data concerning

- Users of INTERNET SITES registered by TRUST PRICE;
- registered users of a TRUST PRICE WEBSITE (e.g. if the individual creates a user account);
- individuals purchasing and receiving/benefiting from TRUST PRICE products and services;
- parties potentially or actually interested in TRUST PRICE products and services;
- recipients of TRUST PRICE newsletters;
- participants in TRUST PRICE research campaigns and opinion surveys;

Personal data concerning CUSTOMERS is generally collected directly by TRUST PRICE during the use of the WEBSITE, as well as in the context of direct communications (e-mail, telephone or other). TRUST PRICE also collects data when the CUSTOMER making the purchase is not the ultimate beneficiary or if the purchase is sent to another person (gift, for example), in the event of a recommendation by a third party (recommendation by a relative or friend of the CUSTOMER, for example), or by the acquisition of additional information from third party data sources (social networks, for example).

In particular, the following categories of personal data are processed by TRUST PRICE:

- Personal data and contact details, including but not limited to: first and last name, maiden name, address, residence, telephone number, e-mail address, age, date of birth, gender, marital status, family, emergency contact, photos;

- Data relating to orders and purchases, including, without limitation: payment information, credit card numbers and other payment details (in accordance with other applicable laws and regulations), billing and shipping addresses, order history and purchases of products and services, enquiries and complaints relating to products and services, contracts entered into in connection with warranty claims, after-sales services, repairs and customer services, terminations and disputes;

- Marketing data on products and services, including, without limitation: information relating to newsletters and other communication channels, prior consent and refusal (opt-ins/opt-outs), invitations and participation in special events and activities (insofar as they are not part of a customer loyalty programme), preferences and centres of interest, and customer segmentation information;

- Data relating to use of the WEBSITE, including, without limitation: IP address and other user identifiers (e.g. username on social networks, MAC address of smartphones or computers, cookies), date and time of visit to the site, sites and content visited, referring sites;

- Data relating to communication, including, without limitation: preferred means of communication, history of correspondence and communications with TRUST PRICE (including recordings of communications);

- Data collected as part of a customer programme, including, without limitation, : membership numbers, access codes (including passwords), language preference, gift voucher numbers, date and duration of registration, payment information of the CUSTOMER or potential third party, gift recipient information, number of visits to the WEBSITE, purchase history, products purchased (all WEBSITE accounts, activities and events for which a CUSTOMER is required to enter personal data and enter into a contract with TRUST PRICE shall be considered a customer programme for the purposes of this policy); hereinafter together referred to as CUSTOMER DATA.

TRUST PRICE also collects the following information:

- Data relating to users of the WEBSITE, who do not register with TRUST PRICE (VISITOR), but which may constitute personal data, for example with social networks (VISITOR DATA); the provisions of this notice relating to data collected from a CUSTOMER in the course of using the WEBSITE will apply accordingly even if identification of a VISITOR is not generally possible for TRUST PRICE.

In the course of their business relationship, CUSTOMERS will be asked to provide CUSTOMER DATA to enable the establishment and performance of the contractual relationship, the fulfilment of related contractual obligations and compliance with any applicable legal requirements. In the absence of such data, TRUST PRICE will generally be unable to enter into or perform the contract with the CUSTOMER concerned. Insofar as all access to the WEBSITE is logged, connection data (in particular concerning the IP address) is systematically recorded; this is done automatically during use and cannot be deactivated for individual VISITORS, CUSTOMERS or PARTNERS.

3. PURPOSE AND LEGAL BASIS OF PROCESSING

3.1 PURPOSE of processing

In accordance with applicable law, TRUST PRICE may process CUSTOMER DATA for any lawful PURPOSE, including, without limitation:

- as part of the services offered, the signing of contracts (e.g. purchases), the performance of contracts (e.g. purchase contracts and contracts relating to participation in customer programmes and events), the development and management of customer relations, communication, customer service and support, promotion, advertising and marketing (including newsletters and the sending of promotional material);

- management of WEBSITE users and other activities in which CUSTOMERS participate, operation and improvement of the website (including the provision of functionalities requiring identifiers or other personal data) and other IT systems, and identity checks;

- protection of CLIENTS, employees and other natural persons, protection of data, secrets and assets belonging to or entrusted to TRUST PRICE, and security of TRUST PRICE's systems and premises;

- compliance with legal and regulatory requirements, including TRUST PRICE's internal rules, enforcing and exploiting rights and claims, defending against legal complaints, disputes and other claims, combating abusive behaviour, contributing to investigations and legal proceedings, and responding to investigations by public authorities;

- the sale or acquisition of commercial entities, companies or parts of companies, other corporate transactions, and the transfer of CUSTOMER DATA associated with these entities; and

- other lawful purposes where the processing is obvious from the circumstances or announced at the time of collection; (hereinafter jointly referred to as the PURPOSE OF THE PROCESSING OF CUSTOMER DATA).

3.2. LEGAL BASIS for treatment

TRUST PRICE uses CUSTOMER DATA in accordance with the PURPOSE OF PROCESSING CUSTOMER DATA and the following LEGAL BASES:

- execution of contracts ;

- compliance with TRUST PRICE's legal obligations;

- consent of the CUSTOMER (only insofar as the processing responds to a specific request and can be withdrawn at any time, for example in the case of receiving newsletters for which the CUSTOMER has subscribed);

- legitimate interests of TRUST PRICE, including, without limitation :

•  purchase and dispatch of products and services, including to persons who are not direct contractual partners (e.g. recipients of a gift);
• advertising and marketing ;
• effective customer support, management of contacts and other communications with CUSTOMERS outside contract processing;
• understanding the behaviour, activities, concerns and needs of the CUSTOMER, market research ;

- effective improvement of existing products and services, and development of new products and services;

- protection efficace des CLIENTS, employés et autres personnes physiques, protection des données, secrets et actifs appartenant ou confiés à TRUST PRICE, et sécurité des systèmes et locaux de TRUST PRICE ;

- setting up and maintaining a secure and efficient organisation for commercial operations, including the operation and development of INTERNET SITES and other IT systems;

- governance and development of the company in accordance with reasonable principles ;

- sale and acquisition of commercial entities, companies or parts of companies, and other commercial transactions ;

- compliance with legal and regulatory requirements and TRUST PRICE's internal rules;

- prevention of fraud, misdemeanours and crimes, investigation of such offences and other misconduct, handling of claims and actions against TRUST PRICE, cooperation in legal proceedings or proceedings brought by public authorities, and prosecution, exercise of rights and defence in legal proceedings.

In accordance with applicable data protection laws, TRUST PRICE may process VISITOR DATA in order to maintain and develop the WEBSITE (including the provision of features requiring identifiers or other personal data), conduct statistical analyses of the use of the WEBSITE, combat abusive behaviour, cooperate in investigations or legal proceedings, and respond to requests for information from public authorities. VISITOR DATA will be processed in accordance with the principles set out for CUSTOMER DATA above.

In accordance with applicable data protection laws, TRUST PRICE may process PARTNER DATA to enter into and perform contracts and other business relationships with PARTNERS, to conduct promotional activities, advertising, marketing, communication, invitations to events and participation in promotions on behalf of PARTNERS, to organise joint activities, to ensure compliance with legal and regulatory requirements and TRUST PRICE's internal rules, enforce legal rights and remedies, defend against legal claims, disputes and other complaints, combat abusive behaviour, cooperate in investigations and legal proceedings, and respond to requests from public authorities, in connection with the sale or acquisition of business entities, companies or parts of companies and other related business transactions and transfers of PARTNER DATA. PARTNER DATA will be processed in accordance with the principles set out for CUSTOMER DATA above.

All purposes of processing apply to TRUST PRICE as a whole, not just to the company that originally collected the personal data. The personal data of CUSTOMERS, VISITORS and PARTNERS is collected on behalf of all TRUST PRICE companies subject to this Privacy Notice, any other policies established by TRUST PRICE and in accordance with applicable data protection laws.

4. TRANSFER AND DISCLOSURE OF DATA

In accordance with applicable data protection laws, TRUST PRICE may transfer CUSTOMER DATA, VISITOR DATA and PARTNER DATA to the following categories of third parties who process PERSONAL DATA in accordance with the PURPOSE OF THE DATA PROCESSING on behalf of TRUST PRICE or on their own behalf:

- service providers (internal to TRUST PRICE or external), ;

- clients of TRUST PRICE ;

- local, national and foreign authorities;

- media ;

- members of the public, including visitors to the TRUST PRICE Websites and social networks;

- organisations, associations and other sectoral representation committees ;

- other parties involved in potential or actual legal proceedings;

TRUST PRICE may disclose CUSTOMER DATA, VISITOR DATA and PARTNER DATA within TRUST PRICE and to THIRD PARTIES in any country in the world, including any country in which TRUST PRICE is represented by companies. If data is disclosed in countries that do not provide adequate protection, TRUST PRICE will ensure adequate protection for such disclosed data of CUSTOMERS, VISITORS or PARTNERS by putting in place appropriate contractual safeguards (e.g. by using the EU standard contractual clauses), by establishing internal company rules, by using the EU-US and Swiss-US data protection shields for transfers to THIRD PARTIES established in the United States, by transferring data by virtue of consent or the conclusion or performance of a contract, in the context of the determination, exercise or enforcement of legal claims, by virtue of overriding public interests, or in order to protect the integrity of these persons. The CUSTOMER or VISITOR concerned may obtain a copy of the contractual warranties from the contacts identified above (or will be informed of where they may obtain such copies from such contacts) (see paragraph 1 above). TRUST PRICE reserves the right to redact such copies for valid legal or confidentiality reasons.

5. DATA RETENTION

As a general rule, TRUST PRICE will only keep personal data for as long as is strictly necessary for the purposes for which it is processed. Notwithstanding this general principle, TRUST PRICE may process personal data for longer periods subject to the following rules and obligations: TRUST PRICE retains personal data for as long as it (i) is required to do so (by contract, law or otherwise) or (ii) has an overriding interest in doing so (e.g. submission of evidence as part of complaints procedures, documentation of compliance with certain legal or other requirements, non-personalised analysis). Different rules will apply with respect to anonymisation or pseudonymisation of personal data, subject to applicable law.

In respect of CUSTOMER DATA relating to contracts (this includes business records and communications), TRUST PRICE will retain personal data for as long as the contractual relationship exists, and for ten years after the end of the contractual relationship, unless (i) a shorter or longer statutory period applies (on a case-by-case basis), (ii) retention is required for evidential or other valid reasons under applicable law, or (iii) deletion of the data is required earlier (e.g. because the data is no longer needed or because TRUST PRICE is required to delete the data concerned).

In the case of operational data containing CUSTOMER DATA, VISITOR DATA or PARTNER DATA (e.g. protocols, logs), Trust price will retain personal data for a period of 3 to 12 months.

6. COOKIES, GOOGLE ANALYTICS AND SOCIAL PLUGINS

TRUST PRICE uses cookies on its WEBSITE. Cookies are a widely used technique which consists of assigning a means of identification to the browser of the user of a WEBSITE, which the said user saves and uses as and when required. TRUST PRICE uses session cookies, which are automatically deleted as soon as the user closes the WEBSITE and which enable the server to establish a stable connection with the user (for example to prevent the contents of a shopping basket from being lost) during the user's visit to the WEBSITE. On the other hand, TRUST PRICE uses permanent cookies which are only deleted at the end of a period defined for each WEBSITE. Permanent cookies make it possible to save certain settings (e.g. language) for several sessions or to ensure automatic connection. By using the WEBSITE and its functionalities (e.g. language settings and automatic login), the user consents to the application of permanent cookies. Users may block or delete the application of cookies on their browser, it being understood that this may affect their use of the WEBSITE.

In accordance with applicable law, TRUST PRICE may install codes in newsletters and other marketing emails to determine whether the recipient has opened a message or downloaded images contained therein. However, the recipient will be able to block this functionality in their e-mail application. In all cases, the user consents to the application of this technology, as soon as they receive newsletters or other marketing e-mails.

If TRUST PRICE places third party advertisements on its WEBSITE (e.g. banners) or places its own advertisements on a third party website, cookies from companies specialising in the use of such advertisements may be used. TRUST PRICE will not disclose any personal data to these companies, i.e. it will place a permanent cookie only on the users of the WEBSITE, and only in the interest of TRUST PRICE. This will enable TRUST PRICE to place targeted advertisements for these individuals on third party websites (e.g. relating to products in which these individuals have expressed an interest in the online shop). TRUST PRICE will not disclose personal data to operators of external websites.

TRUST PRICE may use Google Analytics or similar services on its WEBSITE. These applications are third-party services that allow TRUST PRICE to measure and analyse the use of its WEBSITE. The provider of these services may be located in any country in the world (in the case of Google Analytics, operated by Google Inc. in the United States, www.google.com). The service provider uses permanent cookies for these applications. TRUST PRICE will not disclose any personal data to the service provider (and the service provider will not store any IP addresses). The service provider may, however, monitor the user's use of the WEBSITE and combine this data with that of other websites which it also monitors and which the user has visited, and the service provider may use these results for its own purposes (e.g. control of advertising). The service provider knows the identity of the user who has registered with it. In such a case, the processing of personal data will be the responsibility of the service provider and the data will be processed in accordance with data protection and privacy laws and the service provider's data protection policies (for Google, see policies.google.com/privacy).The service provider will provide TRUST PRICE with data on the use of the WEBSITE.

TRUST PRICE may also use plug-ins from social networks such as Facebook, Twitter, YouTube, Google+, Pinterest or Instagram on its WEBSITE. In the default setting of the WEBSITE, plug-ins are deactivated. Users therefore have the option of choosing whether they wish to activate them. If they decide to do so, social network providers will be able to establish a direct connection with the user when they visit the WEBSITE, thus enabling a provider to be informed of their visit and to analyse the corresponding information. Further processing of personal data will be carried out under the responsibility of the social network provider, in compliance with data protection and privacy laws and in accordance with its data protection policies published on its website (e.g. www.facebook.com/; www.twitter. com/; www.youtube.com/; www.google.com/; www.pinterest.com/; www.instagram.com/).

You can find more information about the cookies used by TRUST PRICE and how to manage your cookie settings on our WEBSITE.

7. RIGHTS OF CUSTOMERS, VISITORS AND PARTNERS

Any data subject, including a CLIENT, VISITOR and PARTNER, may request information from TRUST PRICE about the processing of data relating to them. They may also request the rectification, erasure or restriction of their personal data and object to the processing of their personal data. If the processing of personal data is carried out on the basis of consent, the data subject may withdraw his or her consent at any time. In EU and EEA countries, the person affected may, in certain cases, have the right to obtain the data generated when using online services in a structured, common and machine-readable format, allowing subsequent use and transfer. The request in this respect shall be submitted to the contact identified (see paragraph 1 above). TRUST PRICE reserves the right to restrict the rights of the data subject in accordance with applicable law and, for example, not to disclose complete information or not to delete data.

If TRUST PRICE makes an automated decision about an individual that could have a legal or other serious impact on the individual, then the individual shall, in accordance with applicable law, have the right to contact a TRUST PRICE data controller and request a review of the decision or request a prior evaluation by such data controller. In such a case, the natural person affected may no longer be able to use certain automated services. The individual will be informed at a later date or separately in advance.

Any individual concerned may also lodge a complaint with the competent data protection authority, which in the case of a data controller is TRUST PRICE in France.

8. AMENDMENTS TO THE DATA PROTECTION NOTICE

TRUST PRICE reserves the right to change this Privacy Notice at any time without notice or announcement. The latest version published on the TRUST PRICE WEBSITE will apply.

If the data privacy notice is part of an agreement with CLIENTS, TRUST PRICE may inform them of an update or changes via email or through another appropriate means. The changes will be deemed accepted unless an objection is raised within 30 days of the notification. In the event of an objection, TRUST PRICE will be free to terminate the contract exceptionally and with immediate effect.

II. Specific provisions

The following provisions complement the general provisions of Section I for certain activities of TRUST PRICE. In case of any conflict, the following provisions shall prevail.

1. ONLINE STORES

The solvency of CUSTOMERS may be automatically assessed in online stores to offer a purchase on invoice based on this decision.

TRUST PRICE's online stores have the option to automatically decide to enter into purchase contracts. However, TRUST PRICE does not consider this to be an automated individual decision (within the meaning of Article 22 of the GDPR)

2. NEWSLETTERS AND ADVERTISING BANNERS

TRUST PRICE may send newsletters or other commercial communications regarding its products and services to CUSTOMERS. In accordance with applicable law, TRUST PRICE reserves the right to do so without prior consent from its customers. However, the respective customers and business partners will have the option to object to further sending of newsletters or other commercial communications at any time, through their open account on the relevant website or via the link provided in each communication. Unsubscribing from one newsletter, however, may not necessarily result in unsubscribing from other newsletters.

TRUST PRICE reserves the right to display personalized advertisements during visits to the WEBSITE. Such advertising banners shown to the CUSTOMER will focus on products offered on the WEBSITE that have already been viewed by the CUSTOMER. These ads are generated by TRUST PRICE using cookies (see Section I, paragraph 6 above).

III. SPECIFIC CONFIDENTIALITY NOTICE FOR CUSTOMER PROGRAMS

The provisions in this Section III specify the general provisions of Section I regarding TRUST PRICE's customer programs.