This Privacy Notice applies to your Personal Data collected or otherwise processed by LE CLUB ELLE (“we”, “us”, “our”) through our Website www.leclubelle.com , our social media brand profiles, or with any other modality described herewith. For the purposes of this Privacy Notice, for “personal data” – in compliance with Article 4 of the GDPR -, we shall mean “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one 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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Please note that this Privacy Notice does not apply to the Personal Data collected through other websites belonging to third parties, even if those websites can be accessed by means of a link on our Website. Please refer to the privacy notice of such third parties’ websites for information on the processing of personal data carried out by them. The inclusion of a link on our Website or social media brand profiles does not imply endorsement of the linked site by us.
What personal data do we process about you?
- Contact information and personal data pertaining to your profession and profile: LE CLUB ELLE processes Personal Data such as your name, surname, e-mail address, telephone number, postal address or country of residence, that you actively and voluntarily provided to us by means of ad-hoc registration forms filled on our Website (e.g. subscription to our newsletter) or sent by e-mail or provided to LE CLUB ELLE or to its professionals or collaborators by you in some other way (for example: through the exchange of business cards, of emails or any other contact that shows through an active behaviour an interest towards the activity of LE CLUB ELLE).
- Payment details: when you purchase products/services from us, we will ask for your payment details in addition to your contact information, to secure payment and to authorize access to our products and services.
- Social Media Profile: when you interact with our social media brand profiles, we will receive your profile information and any other information you allow the social network to share with third parties such as your name, surname and pseudonym, number of followers/fans, level of engagement or your user-generated contents published on social media.
- Personal Data from publicly available sources: LE CLUB ELLE may process Personal Data from publicly available sources such as articles that mention you, interviews, videos, blogs entries or websites, whether they are yours or of third parties.
- Comments, requests and questions you submit to us.
- Net Surfing Data: Computer systems and software procedures in charge of the correct functioning of our Website may collect, during their normal activity, some personal data, whose transmission is implicit in internet communication protocols. This type of information is not collected in order to be linked to identified subjects, but by its own nature, through processing and in combination with third party’s data, such information might be able to be used to identify users. Such category of personal data includes, among others: IP addresses relating to the computer used to access the Website, URI (Uniform Resource Identifier) addresses of the requested resources, time of the request, the procedure used to forward the request to the server, the size of the answered file, the numeric code that points to the condition of the server’s answer (successful, error etc.) and any other parameter relating to the user’s operating system. This type of data is used only for the purpose of gathering statistics and anonymous information on the usage of the Website and to assure its correct functioning and is immediately erased after the processing. The above mentioned Personal Data could be used to determine possible criminal liability arising from computer crimes in prejudice of our Website.
- Online Identifiers: we collect information about your visits on www.leclubelle.com and any other services belonging to LE CLUB ELLE company such as for how long you’ve browsed, which pages you looked at, where you were when you visited us, the IP address and the type of device used, be that a tablet, laptop, smartphone or a desktop.
- Behavioural data: we might collect data related to the time spent on our website, the items you’ve clicked on, and the products or services you have bought from us. Also, when you register for our newsletter or participate in our studies, we might collect data about your interests, tastes, and preferences.
Please note that we do not process any sensitive personal data about you (such as data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union memberships, data about your health, genetic and, biometric data) unless you have voluntarily made that Personal Data manifestly public (for example, by posting it on your social media profile).
How do we use your Personal Data?
LE CLUB ELLE processes the above-mentioned Personal Data to:
- To send you promotional content and marketing communications: according to your legitimate interest.
- To invite you to events and meetings we believe are of interest to you: You may receive invitations to our events and meetings on the basis of our legitimate interest to keep business contacts with you when you have already subscribed to one of our events or newsletters (also considering your reasonable expectations). You have the right, at any time, to object to receiving such information.
- To respond to your requests for information on LE CLUB ELLE or contact requests: To respond adequately and in a timely manner to your requests, questions and concerns that you send to LE CLUB ELLE we rely on our legitimate interests.
- To send you communications relating to LE CLUB ELLE work and mission: You may be entered into a mailing list as a result of contacts with LE CLUB ELLE or with a professional or collaborator of LE CLUB ELLE (for example, exchange of business cards or other contacts that may constitute an active behaviour demonstrating interest towards LE CLUB ELLE); in such a case it constitutes a legitimate interest of LE CLUB ELLE to keep in contact with you by sending you communications concerning LE CLUB ELLE and which we believe could be of interest to you (also considering your reasonable expectations). You have the right, at any time, to object to receiving such information.
- To process orders and purchases made on LE CLUB ELLE.
How do we protect your data?
LE CLUB ELLE protects your personal data by adopting all security measures prescribed by the GDPR. LE CLUB ELLE shall process the personal data about you only for the time necessary for the achievement of the purposes above described. The processing may be carried out with or without the use of electronic means as well as with automated systems.
To whom will we be disclosing your Personal Data?
The Personal Data collected will be accessible to the employees and collaborators of LE CLUB ELLE duly appointed as data processors or to persons in charge of the processing. Some data may be communicated in anonymous and aggregated form to third parties for statistical purposes. In any case, such data shall not permit the identification of the data subjects. With the exception of cases allowed by the law, or provided in this Privacy Notice, personal data shall not be communicated or disseminated without your consent, which you can withdraw at any time.
Relevant Personal Data to the fulfilment of an order or purchase on LE CLUB ELLE will be shared with the relevant Seller.
We might share your data with any existing and future companies owned by LE CLUB ELLE. For example, if any/all of our assets were to be sold to another business, the data required to ensure the delivery of the goods (e.g. monthly subscriptions/ newsletters) would be transferred to the new business owner.
Data security and cross-border transfers LE CLUB ELLE ensures appropriate security measures to protect your data. For that, when we ask another organisation to provide a service for us, we ensure they have the relevant security measures, and follow the same high standards of security and data protection as we do.
If LE CLUB ELLE or any of our service providers transfer any information outside the European Economic Area (EEA), it will only be done with the appropriate protection in pace and conform to the UK law.
What are your rights in relation to our processing of your Personal Data and how can you exercise them?
With regard to our processing of your Personal Data described in this Privacy Notice, you have the right under certain circumstances:
- to obtain at any time confirmation as to whether or not there is personal data concerning him or her being processed,
- to access such personal data,
- to ask to receive the data in a structured, commonly used and machine-readable format in order to transmit the data to another controller,
- to request at any time the erasure of such personal data,
- to obtain the restriction of processing or
- to object, in whole or in part, on legitimate grounds, to the processing of his or her personal data, in particular where it is processed for direct marketing purposes. You may exercise such rights also by clicking in the section for such purpose below every communication.
The exercise of such rights, however, may be subject to some limitations and exclusions pursuant to the GDPR and the applicable regulations.
Where the processing is based on your consent, it shall be understood that you have the right to withdraw your consent at any time. Such withdrawal shall not affect the lawfulness of processing based on consent given before withdrawal.
Right to lodge a complaint
Without prejudice to any other administrative or judicial remedy, where you consider that the processing of your personal data relating infringes the law, you shall have the right to lodge a complaint with a supervisory authority.
Changes to this Privacy Notice
This Privacy Notice may change from time to time. LE CLUB ELLE can amend this Privacy Notice in order to comply with developments in national and/or European law, as well as to keep up with technology innovations and other similar reasons.
We will notify you of material changes to this Privacy Notice and change the “Last Updated” date above. So please check it periodically for updates.
Exercise of Users’ Rights and Request of Information
To exercise your rights and for any questions or requests concerning the processing of your personal data by LE CLUB ELLE and this Privacy Notice, please contact us at the following e-mail address: email@example.com.
The data controller is Dimitra Darra, e-mail address: firstname.lastname@example.org.
What are cookies?
Cookies are small text files that are sent to the browser and are stored on the user’s terminal device when he accesses a website. Cookies are used for different purposes (computer authentication, session monitoring, storage of information on specific configurations regarding users that access the server, storage of preferences, etc.).
Types of cookies used by the Website
The Website uses the following cookies:
- Technical and browser cookies: The website uses Google Analytics cookies provided by Google Inc., to ensure a correct use of the website by the users. The users’ IP addresses are anonymized before being saved by the Google Analytics services. These cookies allow the website to function correctly and allow the users to view the content on the website. Disabling the cookies would lead to a malfunctioning of the website. These cookies are not stored persistently on the users’ computers and are eliminated after the browser is closed. Other information on the Google Analytics services are available at the following link: https://policies.google.com/technologies/cookies.
Please find below additional information on the cookies used:
Type: Analytics and performance cookies
Cookie: Google Analytics
Function: Access statistics