Personal data is any information about an identified physical person or a physical person that may be directly or indirectly identified via an identification number or one or more elements particular to them, such as their last name, first name, date of birth, customer number, order number, photo, etc.II. When do we collect your personal data?
We may collect your personal data when you:
• create a customer account on our website, apps, or in our stores
• order goods from our website
• make purchases in stores
• agree to receive marketing communications from us by email, telephone, SMS or post, depending on your selection
• answer surveys or satisfaction questionnaires based on your customer experience
• interact with our Company via its official page on social networks or when we suggest re-use of content that you have published on a social network
• contact our customer service
• send requests for information to our Company
• take part in an event we organize
• browse on the Internet using cookies or similar technology or when you click on advertisements for our productsIII. What personal data might we collect?
(i)As part of the services we provide, we may need to collect certain data directly from you using electronic forms on our website, mobile apps or in selected stores, or in paper form, for a range of purposes (see Section IV for a list of processing purposes).
Information we might collect includes:
• Your identity (e.g. first name, last name, date of birth
• Your contact details (e.g. email address, mailing address)
• Your personal preferences in relation to the products we market or to our website (language)
• Information relating to your orders, their tracking and your purchase invoices
• Information you may provide to our customer service center
• Specific health data if you notify us of any undesirable side-effects concerning any of our products
• Your credit card information if you place an order via our website
Important: your credit card information is encrypted on TLRservers. Payments are processed via a secured payment platform, involving additional verifications, in order to guarantee the security of purchases made on the Website, and combat fraud.
The details you provide of your Payment Card when placing an order are always encrypted prior to transit using an SSL (Secure Socket Layer) protocol.
Personal data essential to TLRis marked with anasterisk on all personal data collection forms on our website, in electronic form at some of our counters and stores, as well as off-line in paper form. If you do not fill in these compulsory fields, TLRwill probably be unable to respond to your request and/or provide you with the requested services. Other information is optional and enables us to get to know you better and improve our communications and services with respect to you.(ii)We may also collect certain data generated by your purchases of products or services, online or in stores, particularly information regarding the amount and type of your purchases.
(iii)We may collect information regarding the use of our website, especially with respect to your browsing (pages visited, links clicked, etc.). Some of this information may be collected using cookies placed in your web browser when you browse our website. For more information about cookies, read Section XI of this policy.
(iv)If you apply for a job with our Company via our website, we may collect the following information:
• Your identity
• Your contact details
• Your resume
• Your cover letter
As this data concerns your application, please inform us in writing of any changes to your contact details or, more generally, to your career and employment situation, to help us to manage your application efficiently.IV. For what purpose is your personal data collected and used?
TLRprocesses your data to:
• enable you to create a customer account on our website, at our counters and in our stores
• manage your access to your customer account
• process and manage your online orders and their delivery
• record purchases made at our counters or in our stores
• secure online transactions, prevent fraud and manage debt collection (see our terms and conditions for more details)
• manage customer relations with respect to any requests for information or complaints you may send us via our website, customer service or social network pages
• trace and manage any alerts you may send us as part of our cosmetic vigilance obligations manage and optimise your customer experience by improving our knowledge of our customers
• propose appropriate, tailored services, particularly when we enhance our products and services
• conduct statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing
• subject to your consent, send you information on our offers, news and events on your chosen communication media
• manage your participation in any events to which you have signed up
• manage any online job applicationsV. What legal grounds legitimize the processing of your data?
TLRprocesses your personal information:
• to perform the contract agreed between yourself and TLR, to manage your access to your customer account and to process and track your orders
• within the framework of its legitimate interest for the purposes of marketing management, securing its digital media (websites, applications, etc.) and preventing fraud
• when you have given your consent for the processing of your data, especially for the purposes of managing our sales prospection, and in connection with your browsing data via cookies, etc.
• to comply with our legal and regulatory obligationsVI. Who are the recipients of your personal data?
Your personal data is processed by the personnel of TLR. We ensure that only authorized persons within TLRhave access to your personal data and that such access is granted only as necessary for managing our commercial relations or meeting our legal obligations.
We may also share your personal data with:
• our corporate affiliates, including across Brands, and other entities in the Direct Holdings Global Group, with some of these entities acting as data processors
• the acquiring company in the event another company acquires our company, business, or our assetssubcontractors, such as:
- site hosting and maintenance service providers and the providers of our electronic personal data collection solutions at counters and in stores
- payment service providers
- anti-fraud service providers
- logistic service providers
- marketing solution service providers
- sales prospection and social network communication service providers
- customer service providers
- service providers for managing regulatory alerts or notifications
- event organization service providers
Lastly, TLR may need to share your personal data with third parties to meet its legal, regulatory or treaty obligations, or to respond to requests from authorized legal authorities.VII. Security Measures
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal data from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal data. In the event that we are required by law to inform you of any unauthorized access to your personal data we may notify you electronically, in writing, or by telephone, if permitted to do so by law.VIII. International Transfer of Personal Data
With respect to personal data collected on the website, TLRis the data controller for purposes of the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and the free movement of such data (hereinafter the "GDPR").
We store personal data about our website visitors and subscribers within the United States. If you are visiting our website from the European Economic Area or other regions with laws governing data collection and use, you are agreeing to the transfer of your personal information to the United States. By providing us your personal information, you consent to any transfer and processing in accordance with this Policy.
All data transfers are subject to appropriate guarantees, especially contractual, technical and organizational guarantees, that comply with applicable regulations relating to the protection of personal data.IX. How long do we keep your data?
Under current regulations, including the GDPR, you may have the right to access and correct your personal data, request erasure, object to processing on legitimate grounds and obtain limitation or portability, where applicable.
You can exercise these rights directly with TLR by sending an email to legal@TLretro.com or by mailing a non-registered letter with a document proving your identity to the below address:
LLC Legal Department, Privacy 8260
Willow Oaks Corporate Drive Suite 500
Fairfax, VA 22031
If, at any time, you no longer wish to receive details of our offers, news and events, you can unsubscribe using the hypertext link provided for this purpose in each mail we send you. You can also telephone us at 1-877-568-3857or send a letter to:
LLCLegal Department, Privacy
8260 Willow Oaks Corporate Drive Suite 500
Fairfax, VA 22031
California Civil Code Section 1798.83 permits customers of TLRwho are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the following address:
LLCLegal Department, Privacy
8260 Willow Oaks Corporate Drive Suite 500
Fairfax, VA 22031
California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing. If you are a California resident and would like a copy of such notice, please submit a written request to us using the contact information listed above.Online Tracking
We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.XI. Contact details of the Data Protection Officer (DPO) and your right to lodge a complaint
For all questions relating to the collection and processing of your data by TLR, you can contact the TLR Data Protection Officer at legal@TLretro.com. If you are not satisfied with our response and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.
XII.Information on Cookie Management
This section is dedicated to our policy for managing cookies on the website. It has been designed to provide you with information on the origin and use of browsing data processed when you use our website, together with your rights.What is a cookie?
When you use our website, we may, depending on your choice, place a text file on yourterminal (computer, smart phone or tablet) via the web browser.
This text file is a cookie. Throughout the period of validity or registration, it will enable TLRto identify your terminal during subsequent visits.
Only the entity issuing the cookies is able to read or modify the information they contain.
Below you will find information about the cookies that may be placed on your terminal when you visit the pages of the website, either by TLR, or by third parties, together with ways in which you can delete or refuse installation of these cookies.What is the purpose of the cookies issued on the website?
There are several types of cookies, some of which are issued directly by TLRand its service providers, while others may be issued by third parties.I. Cookies issued by TLRand its service providers
Different types of cookies may be placed on your terminal while you are browsing on our website:
These cookies areessential for browsing on our website, especially for the functioning of the order process.
Deletion of these cookies may cause problems with browsing on our website and make it impossible for you to place an order.
These cookies are also necessary for tracking the activity of TLR.
They may be installed on your terminal by TLR or by its service providers.
(ii)"Analysis and Customization" cookies
These cookies are not essential to browsing on our website, but may help you, for example, to search more effectively and optimize your purchasing experience and help us better target your requirements, improve our offer and optimize the functioning of our website.
Cookies may also be used for advertising purposes. These cookies ensure that the advertisements you see are the most relevant to you.What is the benefit of seeing special offers and advertising tailored to your browsing preferences?
The aim is to show you the most relevant offers and advertising. As such, cookie technology enables us to display content, in real-time, that is best suited to your fields of interest, as deduced from your browsing history on our website.The interest you show in content displayed on your terminal when you consult a website often determines the advertising resources of this site, enabling it to provide its services, which are often supplied free of charge to users. You likely prefer to see offers and advertising that are relevant to you, rather than content that is of no interest to you at all. Similarly, both TLRand advertisers want their offers and advertising to be shown to Internet users that are likely to be interested in them.Important information if you share your terminal with other users
If your terminal is used by several people or when a single terminal has more than one type of browser software, we cannot be sure that the services and advertising sent to your terminal will match your use of the terminal, rather than that of another user.
In this case, sharing use of your terminal with others and deciding your browser cookie settings are your free choice and your responsibility.II.Cookies issued by third-party companies
These cookies are not essential to browsing on our website.
On our website, we may include computer applications from third parties that enable you to share our website content with others, inform others that you have been consulting our website or notify them of your opinion concerning content on our site. This particularly concerns use of the "Share" and "Like" buttons featured on social networks such as Facebook, Twitter, Instagram, Pinterest, etc.
The social network providing these application buttons is likely to identify you via this button, even if you have not used it when browsing our website.
Indeed, this type of application button can enable the social network concerned to track your browsing on our website, simply because your account on the social network in question is enabled on your terminal (a session is open) while you are browsing our website.
We have no control over how social networks collect information regarding your browsing on our website and associated with the personal data they hold.
We encourage you to read the privacy policies of the social networks to learn about the purpose, especially advertising, of any browsing information they may collect via these application buttons. These privacy policies should enable you to exercise your choices with respect to these social networks, in particular by changing your account settings.
Visit the websites of the aforementioned social networks for more information about their privacy policies.III.Managing the cookies placed in your web browser
You can decide whether to allow cookies to be installed on your terminal.
By changing the settings of your browser software, you can choose whether to accept the installation of cookies on your terminal at any time, simply and free of charge.
a.Agreeing to Cookies
If your browser software is set to accept the registration of cookies on your terminal, the cookies embedded in the pages and content you have consulted will automatically be registered on your terminal.
You can set your browser software so that:
• you systematically refuse the registration of cookies on your terminal.Important: Any adjustments you may make to the settings in your browser software concerning the acceptance or refusal of cookies may modify your browsing on the Internet and your terms of access to certain services requiring use of these cookies.
For example, by refusing certain essential cookies, you may no longer be able to place orders on our website.
If you choose to refuse the registration of cookies on your terminal or if you delete cookies that are already registered, we decline all responsibility for any consequences relating to the degraded performance of our services resulting from the fact we are unable to register or consult the cookies required for their performance and which you have refused or deleted.
How to exercise your choice, depending on your browser
Settings vary from one type of browser software to another. Details can generally be found in your browser software help menu. We therefore encourage you to look at your settings to find out how you can make choices regarding cookies.
• For Internet Explorer:https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-files-in-internet-explorer
• ForIOS: https://support.apple.com/en-us/ht201265
• For Safari/Mac: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• For Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
• For Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored