Last update on: 4 March 2019
This policy complies with the requirements of the General Data Protection Regulations (GPDR) which came into force on 25 May 2018.
1.1 Aim of this Policy
lemlem is determined to respect your privacy and protect your personal data.
This confidentiality and data protection policy (the “confidentiality policy”) is designed to inform you about our use of your personal data that we gather when you access the lemlem websites, www.lemlem.com, www.lemlemeurope.com (the “sites”) or when you contact lemlem (the “services provided by lemlem”).
It will enable you to determine the origin and the use of the information that we gather, as well as your rights and options under the applicable data protection rules and regulations.
1.2 Modification of this policy
lemlem may modify this policy from time to time depending on the legal and regulatory context, and to keep you informed about changes in our personal data processing practices.
1.3 lemlem’s role and responsibility
Unless there are any other texts that provide otherwise with regard to certain specific instances of processing of personal data, the processing of your personal data that is described in this policy shall be performed by lemlem (Lalibelo LLC doing business as ‘lemlem’), which publishes the www.lemlem.com and www.lemlemeurope.com websites (the “sites”) and which is thus the “data controller” under the data protection laws.
1.4 Data Protection Officer
lemlem has appointed a data protection officer who is in charge of ensuring compliance with this policy and of ensuring compliance with the data protection rules and regulations in general. The data protection officer can be contacted for any question concerning this policy at email@example.com
The data that is gathered
To find out more (section 3.3)
lemlem gathers your personal data when you use the site and interact with lemlem customer service staff.
In addition to the information that you actively provide (e.g. when creating an account, registering for the newsletter), information is automatically gathered or generated by lemlem’s systems (e.g. determination of your lemlem order numbers).
How your data is used
To find out more (section 3.1)
The data we gather enables us:
- to perform the services provided by lemlem as requested
- to send to you information about lemlem’s products and events that we consider most likely to be of interest to you
To understand how you may oppose such a use and withdraw your consent, please consult section 3.11
Checks are moreover carried out in order to ensure the security of the site and of the payments made on the site.
For more information about these checks, please consult section 3.2
Who receives your personal data, and to whom is it transferred
To find out more (section 3.4)
Your personal data is only accessible to authorised personnel working for us at lemlem head office and only relevant information is available to lemlem’s third-party warehouses that fulfill customer orders.
To find out more (section 3.5)
In the instance that it is necessary to share your personal data with external entities located outside the European Union, we will enter contractual guarantees with that party to guarantee the security and confidentiality of your personal data.
How long is your data kept
To find out more (section 3.6)
In general, your personal data will be kept by lemlem for as long as you remain a client and until the expiry of the applicable warranties. It will only be kept beyond that time with your permission or to meet our legal obligations.
Your rights and options
To find out more (section 3.10 and 3.11)
Under the data protection laws and regulations, you have a right to access, to amend, to request the erasure and to exercise other rights over your personal data.
You may review your decision as to whether to receive the lemlem newsletter at any point in time. For more information, please see section 3.11.
To find out more (section 4)
For any question or claim regarding this confidentiality policy, you may contact lemlem:
- by e-mail: firstname.lastname@example.org
3.1 How lemlem uses your personal data
Your personal data is only gathered when lemlem has a legal basis for doing so.
We therefore only process your personal data when this is necessary:
1/ to deal with your requests, e.g.:
- To send you information about our offers, news and events (newsletter, invitations and other publications via the channels that you will have specified beforehand – post, e-mail, telephone, sms, instant messaging);
- To manage your requests for a meeting with a lemlem operative, to deal with your requests and complaints;
- To improve the operation of the site by generating statistics, to personalise the interface of the site based on your preferences, and for the purpose of targeted advertising or promotional material, in keeping with our cookies policy.
2/ to provide you with services and fulfill the orders that you place, and to comply with our contractual obligations, and in particular:
- To enable you to create a “my account” personal space and purchase lemlem products online;
- To manage your orders and their delivery as well as the corresponding warranties;
3/ to foster the legitimate interests of lemlem:
- To manage our relationship with you by keeping an up-to-date centralised database of our existing and potential clients, enabling us to proactively manage the monitoring of our commercial relationship;
- To ensure that we provide high-quality services by conducting surveys and by measuring the quality of the customer service response
- To create survey reports and statistics, after anonymising the underlying data or after implementing processes designed to prevent the erroneous attribution of data to an identified person.
- To ensure the security of your transactions online, to prevent fraud and payment defaults.
For all these purposes founded on our legitimate interest, we take into consideration any potential impact that the gathering of this data may have upon you and upon the users of the site in general. Should we believe that your interests or your fundamental rights and freedoms transcend our legitimate interests, we will refrain from using your personal data on this basis and may ask you for your consent on a case by case basis.
4/ based on your specific consent
When you subscribe to the lemlem newsletter, you agree that information relating to your purchases and interactions with lemlem may be used to understand your needs and preferences, establish your customer profile, and communicated to lemlem staff and entities, including outside of the European Union in order to deliver superior customer service
3.2 Note concerning the processing of personal data for purposes of prevention and management of payment defaults
In order to combat fraud over the internet, information concerning your order and concerning the terminal used to place the order (such as the operating system used, the location of the machine, whether or not a proxy was used, etc.) Is gathered automatically and used, subject to your consent, to analyse your transactions for purposes of fraud detection and prevention of payment defaults. The information may be transmitted to our payment service provider and to any third party that is duly authorised by law for the sole purposes of checking your identity, the validity of the order, of the payment method used and of the requested delivery address.
3.3 the categories of data gathered by lemlem
Information that you provide to us directly
We gather the information that you disclose to us directly when you use our site and our services.
This is for instance the case when you create an account online, you register to receive our news, or you make a website purchase.
The categories of personal data that we gather directly from you include:
- Your identification and contact data (such as your family name and first name, e-mail address, telephone number, date of birth, preferred means of contact) needed to identify you or to contact you when you use one of the services provided by lemlem;
- Transaction-related information needed to process your order (items chosen, delivery and billing address, telephone number, means of payment, including your bank card details in order to enable billing – account holder name, number and expiry date – in case of payment by bank card);
- Data concerning the monitoring of our commercial relationship (your order number, the chronology of your purchases, your contacts and requests or your correspondence with our customer service unit);
- Socio-demographic data (such as your age, your profession, etc.);
- Data concerning your preferences and your person (preferred style, size, favourite colours, etc.).
The personal data that is indispensable for lemlem to fulfill the purposes described above is highlighted in the various pages of the site. Should you not disclose this data in the mandatory fields, lemlem may not be able to respond to your requests and/or supply you with the products and services that you want. All other data is merely optional and enables us to know you better and to improve the way in which we communicate with you and the services that we provide to you.
During the events that we organise (for instance: trunk shows or private sales), we may gather additional personal data under terms and for uses that shall be specifically notified to you at that point.
The information that lemlem gathers automatically
Other data is gathered automatically when you access the site, use our services or perform a transaction with us:
- Connection data concerning the terminal used: your IP address, the type of browser you use and various information about your browsing of our site are also gathered for purposes of administration and/or to generate statistics, as detailed in our Cookies Policy
- Geo-location information: when you activate this option in order to find a lemlem stockist
Information regarding third parties
In some cases, lemlem will gather information that you provide about other people, for instance when you decide to buy and send products to someone else. This information is only used to fulfil your requests and never to send marketing material to your contacts, unless they personally choose to receive information from lemlem.
3.4 the recipients of your personal data
- Management of the site and the services
Your personal data is processed by lemlem. It will not be transferred or made accessible to any third party other than (i) lemlem’s subcontractors and service providers (for example, our customer service) who are involved in a purely technical or logistical capacity (carriers, providers of hosting and maintenance services to the site, payment and fraud prevention service providers, etc.), and (ii) upon any reorganisation of our company, including a total or partial disposal of our assets, merger, takeover, acquisition, de-merger, and in general any reorganisation operation, in order to ensure the continuity of the services provided.
- Personalised client management, prospecting
Your personal data is accessible to the authorised personnel working at lemlem head office and entities with which you are in contact, as well as to our customer service teams
You may thus receive from them, subject to your consent, information about the offers, news and events of our company
- Protection and defence of lemlem’s interests
Finally, lemlem may disclose your personal data to third parties when such disclosure is required by a law, a regulatory provision or a court ruling, or if this disclosure is necessary to ensure the protection and the defence of its interests (for instance to our external agents and counsels in case of debt recovery; to our insurance companies in case of the loan of a product).
3.5 transfers of your data abroad
Your personal data may be transferred to our entities and service providers located outside the European economic area in countries where the applicable data protection rules and regulations differ from those that are applicable within the European economic area, such as: Australia and the United States.
These transfers shall only take place where this is necessary to deal with your requests.
They shall only take place subject to appropriate guarantees designed to ensure a sufficient level of protection to your privacy and fundamental rights, such as the signature of the standard contractual terms adopted by the European commission. A document detailing the guarantees put in place by lemlem shall be disclosed immediately upon receipt of a request sent to lemlem.
Moreover, your personal data may also be transferred as part of your orders to our service providers based outside the European union that are involved in delivering your orders.
3.6 Duration of Retention
lemlem shall not retain your personal data beyond the duration that is strictly necessary for the accomplishment of the purposes for which it was gathered.
Newsletter, contacts and complaints
The identification data of the client that is used with the client’s consent to send out newsletters and other lemlem publications shall be kept for a period of three years as of its gathering or as of the last contact initiated by the client.
Any personal data and general information about your requests (for example, opening date, closing date, subject of the request) that is gathered and processed under the section entitled “contact us” or pursuant to contact with the customer service unit will only be kept for 5 years in our unique customer repository.
lemlem may also keep for archiving purposes, copies of its correspondence with the users of the site and any response to the questions or comments sent to the users by our customer service unit.
- Data concerning orders, past purchases and ‘know your client’
lemlem will keep the data concerning your orders for as long as you remain a client (i.e. have an active client account or are opted-in) and until the expiry of the applicable warranties. This data will only be kept beyond that time with your consent or for accounting and evidential purposes or to meet our legal obligations or, after having been anonymised, for purposes of studies and statistics.
- Payment data
Your payment data will be kept securely for the duration that is needed to confirm your order and payment and will then be immediately destroyed. In case of a problem with payment, your data will be kept throughout the duration of the management of the incident, then for a period of three (3) to five (5) years, depending on the severity of the incident.
- Client account data
Your client account on our site will remain active until you decide to close it and for as long as you make purchases on our site. In case of protracted inactivity on your part over a period of 3 years, this account will be deactivated.
Pursuant to the expiry of this timescale of three years, lemlem may get in contact with its clients to find out whether or not they want (i) to continue to receive newsletters and other publications from lemlem and/or (ii) to retain their client account on the site. Your data will be destroyed within 2 working days as of your sending us a request to unsubscribe.
Clients may close their accounts and/or unsubscribe from our newsletters at any point in time. In order to do so, please contact our customer service unit by sending an e-mail to email@example.com or by clicking on the unsubscribe link featuring in each newsletter.
Finally, the connection logs that are gathered with your consent by the cookies and other tracers implemented on our site will be kept in accordance with the applicable regulations for a period of time that shall not exceed thirteen (13) months. For more details, see our Cookies Policy.
The site may contain links to third party web sites. lemlem has no control over the content, the confidentiality policy and the data protection policy or the actions of these third party web sites. The use of the information that you may provide to third parties on other sites or that these third parties may gather on those other web sites is not governed by this confidentiality policy. You should carefully examine the confidentiality and data protection policies of any third party web sites and contact the publishers of these web sites should you have any questions about the way in which they use your personal data. lemlem hereby disclaims liability for any failure by a third party to use your personal data in accordance with their confidentiality policy or in accordance with any contractual or legal obligation that is binding upon them.
lemlem has implemented the appropriate technical and organisational measures to guarantee the confidentiality and the security of your personal data against any loss, destruction, alteration, unauthorised access or disclosure. For instance:
- lemlem’s computer systems are equipped with hardware and software protections that comply with the highest standards of the profession. Physical and electronic procedures for backing up the data gathered on the site are implemented, in accordance with the prevailing European regulations governing data protection.
- lemlem’s employees who, on account of their duties, have access to your personal data, are subject to strict confidentiality obligations.
- lemlem’s service providers and subcontractors are bound by written undertakings to implement adequate security measures to ensure the protection of your personal data in keeping with the applicable laws.
- All the payment data that you provide on the site is stored on the secure web site of the payment services provider chosen by lemlem. The transactions performed on the site are protected by ssl encryption.
3.10 Your Rights and Options
Access and rectification
You have the right to access your personal data and to request the rectification or the destruction of any data that should turn out to be inaccurate. Should you have a client account with lemlem, you may directly access the data contained in your online account and rectify/eliminate it where applicable, as well as access the chronology/log of your transactions and your choices in terms of marketing.
Where applicable, you must ensure that you disclose to lemlem any updates or changes to your personal data, including your postal and/or e-mail address, in order to enable us to dispatch your orders to the right address and to contact you about your orders in case of need.
Erasure. You may also request the erasure of your personal data provided that it is no longer necessary for lemlem to keep it.
Opposition. You can also oppose the processing of your personal data or request the imposition of limitations on such processing, unless the processing is necessary for the management of the services that you request.
Withdrawal of consent. Where the processing of your data is based on your consent, you may withdraw this consent at any point in time.
Portability. You may moreover exercise your right to portability, i.e. obtain, in a structured, machine-readable form, the personal data that you provided to us directly on the basis of your consent or of a contract drawn up and signed with you and that that is undergoing automated processing.
Directives. You may also let us know your instructions regarding the preservation, erasure and disclosure of your personal data after your death, and modify these directives at any point in time.
These rights may be exercised directly with lemlem in accordance with the terms of the section 4 entitled contact us “Contact Us”. You may be asked for proof of your identity.
3.11 Unsubscribing from our newsletters, requesting an end to targeted advertising
You may withdraw your consent at any point in time and request to no longer receive correspondence from us regarding our offers, news and events, by using the hypertext link that is included for this purpose in each e-mail that we send you. You may also contact us using the email firstname.lastname@example.org
You may also oppose lemlem’s use of your personal data for purposes of marketing or drawing up your client profile; in that case, however, you will no longer benefit from customised offers or services.
4 Contact Us
Should you have any questions about this confidentiality policy and lemlem’s data protection practices, please do not hesitate to us by sending an email to email@example.com
Should you have any problem or for more information about our data protection policies, please contact our data protection officer by e-mail at the following address: firstname.lastname@example.org
Should you be unhappy about the way in which lemlem gathers and processes your personal data, you may file a complaint with the data protection regulating body with jurisdiction over the place where your main residence is located, or the place where you have been dealing with lemlem.
Last update on: 4 March 2019
- What is a Cookie?
A cookies or tracer is a general term for a text file saved in dedicated space on the devices’ hard drive (for example computer, tablet, smartphone, etc.), when you view content or online advertising. This cookie file allows its issuers to identify the device on which it is stored for as long as the cookie is valid or stored, that means 13 months maximum. Therefore, cookies do not identify you directly.
Information about your browsing on our site are saved in cookies files installed on your device and allow us to track your activity and to recall information, such as user preferences or information the user previously entered in forms.
- Notice about cookies on our site
However, you can change the settings for these cookies at any time. Below you will find further information about cookies and how you can manage their settings.
- Cookies used on our site
When you connect to our site, we may install diverse types of cookies on your device:
Technical cookies to notably allow to:
- adjust the site’s appearance to your device display preferences when you visit our site, (depending on the materials and viewing software or player software your device contains)
- implement security measure, such as when you are asked to sign in again to a piece of content or service after a certain amount of time;
- give you access to reserved and personal areas of our site, such as your account, using IDs and dates that you may have given us previously
- storing information about a form that you have filled in on our site (account registration or access) or to products, services or information that you have chosen on our site (service subscribed, the content of an order basket).
Audience measurements cookies that allow to:
- obtain visitor statistics and volumes and use of the various elements that make up our site (sections and contents visited, journeys) to help us improve interest in and the user-friendliness of our services;
Advertising cookies that allow us to:
- to the extent that you have provided us with personal data, including your electronic contact information, during your registration, your order or your access to one of our services, associating this data with browsing information to, for example, send you electronic marketing messages or display on your device, within advertising spaces that we publish, personalised advertisements that are specifically intended for you that may be of interest to you personally;
Payment security cookies that allow us to:
- help fight against online fraud (payment fraud, identity theft, etc.). Therefore, in accordance with your rights, lemlem or service providers acting on our behalf may store trackers to collect information about the device that made the order (including the operating system used, the location of the machine, whether or not a proxy was used, etc.). These "fingerprint" trackers associated with your order data are used to confirm your order, the payment method used and your delivery method.
Your browsing data is linked to your profile no matter the device used thanks to cookie exchange technology so that your journey can be tracked whatever the device or medium used.
- List of cookies used:
Analytics cookies :
Cookies to improve user experience (for display and results customization purposes):
- Managing your choices about cookies
- Your choices about cookies
Any cookie placed on your terminal is subject to your consent which you may express and freely review at any time using the possibilities described above.
There are various ways to manage your cookie options:
You can deactivate each cookie with the specific deactivation link meant for that purpose or use advertising cookie management tools provided by third parties.
Your browser may allow you to choose to disable all or some cookies, either systematically or according to the publisher. You can also configure your browser software to accept or reject cookies (case by case or all).
If you consent to cookies files on your device, cookies embedded on the pages and contents you have viewed will be stored in a dedicated area of your device and will be readable and recognizable only by the issuer.
- Consequences of blocking the cookies
Disabling cookies will prevent you from using our site under normal conditions, except for basic functions:
Cookies needed: you may not be able to access the site or its services;
Personalisation cookies: the site’s presentation does not adapt to the display preferences of your device, your passwords and information about forms filled on the site are not saved,
Audience measurement cookies: has no consequence on the use of website;
Advertising cookies: has no consequence on the use of the website. However, deleting them does not stop online advertising. It will only cause advertising to be shown that does not take your centres of interest into account.
Online payment security cookies: has no consequence on the use of website. However, in case you are trying to buy something online using your credit card, your payment could be delayed because of the need for a manual validation.
- Cookie management tools
Using deactivation links
Using your browser
Each browser software allows you different types of configuration. It will be described the « help » section of your browser:
If you are using the Safari browser: click the settings button and then preferences. In the window that opens, select privacy/security then click on show cookies. Select the cookies that you want to disable then click on delete or delete all.
If you are using the Chrome browser: click the google chrome menu icon, then settings. At the bottom of the page, click show advanced settings. In the privacy section, click content setting. To deactivate cookies:
Select cookies, click all cookies and site data, then hover over the site that created the cookie, and click x in the right corner, or click remove all.
If you are using the Internet Explorer browser: click the tools button and then internet options. On the general tab, browsing history, click settings. Then, click view files and select it or the cookies that you want to disable. Then, close the window that contains the list of cookies and click ok twice to return to the internet.
If you are using the Firefox browser: click the Firefox menu icon, then the tools button, then options; in the window that appears, choose privacy and click remove specific cookies. Select the cookies that you want to disable then delete them.
In the event that you share the use of your terminal with more than one person, or if your terminal has several browsers, we cannot be sure that the advertising intended for your terminal are in keeping with your own use of this terminal and not that of another user of this terminal. In this case, sharing with others the use of your terminal and configuring the settings for cookies is your free choice and responsibility.
Transferring personal data outside the European Union
Please note that since some of our digital advertising partners are located outside the European Union, data collected using cookies may be transferred to non-EU member countries, whose personal data protection legislation differs from country to country. We strictly require our partners to use the information collected using cookies on our site solely to administer or provide the services requested and ask them to always act in accordance with applicable data protection laws and to pay particular attention to the confidentiality of the information transmitted. To find out more, please refer to their policy on protecting personal data.