- WHO WE ARE
BIENFAY S.A.M is a company registered in Monaco, (collectively referred to as “Bienfay”, “we” or “us” in this policy).
15 Rue Honore Labande
T: (+ 377) 93 30 25 32
VAT Number: FR2300003722
Maintaining the security of your data is a priority at Pro World Shoes, and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. BIENFAY is also dedicated to being transparent about what data we collect about you and how we use it.
This policy, which applies whether you visit our website or use your mobile, provides you with information about:
– what personal data we collect;
– how we use your data;
– how we ensure your privacy is maintained; and
– your legal rights relating to your personal data.
- WHAT PERSONAL DATA DO WE COLLECT?
BIENFAY may collect the following information about you:
– your name, age/date of birth and gender;
– job positions and employer
– your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and e-mail address;
– purchases and orders made by you;
– your on-line browsing activities on BIENFAY websites;
– your password(s);
– your communication and marketing preferences;
– your interests, preferences, feedback and survey responses;
– your location;
– your correspondence and communications with Pro World Shoes; and
– other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).
Our websites are not intended for children and we do not knowingly collect data relating to children.
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an on-line account on our website or send an email to our customer services team. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
- HOW WE USE YOUR DATA
BIENFAY (and trusted partners acting on our behalf) uses your personal data:
– to provide goods and services to you;
– to make a tailored website available to you;
– to manage any registered account(s) that you hold with us;
– to verify your identity;
– for crime and fraud prevention, detection and related purposes;
– with your agreement, to contact you electronically about promotional offers and products and services which we think may interest you;
– for market research purposes – to better understand your needs;
– to enable BIENFAY to manage customer service interactions with you; and
– where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
BIENFAY uses your personal data for electronic marketing purposes (with your consent) and may send you postal mail or e-mails to update you on the latest BIENFAY offers.
BIENFAY aims to update you about products & services which are of interest and relevance to you as an individual.
You have the right to opt out of receiving promotional communications at any time, by:
1. making use of the simple “unsubscribe” link in emails or the “STOP” number for texts; and/or
2. contacting BIENFAY via the contact channels set out in this Policy.
- SHARING DATA WITH THIRD PARTIES
Our service providers and suppliers
In order to make certain services available to you, we may need to share your personal data with some of our service partners. These include IT, delivery and marketing service providers.
BIENFAY only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to BIENFAY and to you, and for no other purposes.
Other third parties
Aside from our service providers, BIENFAY will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organizations for marketing purposes.
We may share your data with:
– credit reference agencies where necessary for card payments;
– governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so: –
– to comply with our legal obligations;
– to exercise our legal rights (for example in court cases);
– for the prevention, detection, investigation of crime or prosecution of offenders; and
– for the protection of our employees and customers.
Google Analytics (with anonymization function)
This website integrates a component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/
and under http://www.google.com/analytics/terms/us.html
Google Analytics is further explained under the following Link https://www.google.com/analytics/.
This website integrates a component of Metrillo. Metrillo is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising. Once the user provides information, it will be added to the anonymous profile
The operator of the Metrillo component is Metrilo LTD, 47A Cherni Vrah Blvd, fl.5, Sofia,Bulgaria
The purpose of the Metrillo component is to analyse the traffic on our website. Metrillo uses the collected data and information, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Further information and the applicable data protection provisions of Metrilo may be retrieved under https://www.metrilo.com/privacy-policy
On the website, users are given the opportunity to subscribe to Pro World Shoes. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter.
We use a third-party provider, E-Goi, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see E-Goi privacy notice under https://login.egoiapp.com/#/legal/anti-spam-policy
- INTERNATIONAL TRANSFERS
To deliver products and services to you, it is sometimes necessary for BIENFAY to share your data outside of the European Economic Area. This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.
If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure. Our standard practice is to use ‘standard data protection clauses” which have been approved by the European Commission for such transfers. Those clauses can be accessed here.
- HOW LONG DO WE KEEP YOUR DATA?
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is 10 years.
- HOW WE PROTECT YOUR DATA
BIENFAY is committed to keeping your personal data safe and secure.
Our security measures include:
– encryption of data via SSL (Secure Socket Layer).
– regular cyber security assessments of all service providers who may handle your personal data;
– regular scenario planning and crisis management exercises to ensure we are ready to respond to cyber security attacks and data security incidents;
– regular penetration testing of systems; and
– internal policies setting out our data security approach and training for employees.
- WHAT YOU CAN DO TO HELP PROTECT YOUR DATA
BIENFAY will never ask you to confirm any bank account or credit card details via email. If you receive an email claiming to be from BIENFAY asking you to do so, please ignore it and do not respond.
If you are using a computing device in a public location, we recommend that you always log out and close the website browser when you complete an online session.
In addition, we recommend that you take the following security measures to enhance your online safety both in relation to BIENFAY and more generally: -
– keep your account passwords private. Remember, anybody who knows your password may access your account.– when creating a password, use at least 8 characters. A combination of letters and numbers is best. Do not use dictionary words, your name, email address, or other personal data that can be easily obtained. We also recommend that you frequently change your password. You can do this accessing your account, clicking ‘your account”, clicking ‘your data” and selecting ‘change password”.
– avoid using the same password for multiple online accounts.
- YOUR RIGHTS
You have the following rights:
– the right to ask for a copy of personal data that we hold about you (the right of access);
– the right (in certain circumstances) to request that we delete personal data held on you; where we no longer have any legal reason to retain it (the right of erasure or to be forgotten);
– the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you (the right of rectification);
– the right to opt out of any marketing communications that we may send you and to object to us using / holding your personal data if we have no legitimate reasons to do so (the right to object);
– the right (in certain circumstances) to ask us to ‘restrict processing of data”; which means that we would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and
– the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organization (the right to data portability). If you wish to exercise any of the above rights, please contact us using the contact details set out below or via dataprotection@ProWorldShoes.com.
- LEGAL BASIS FOR USING DATA
We are required to set out the legal basis for our ‘processing” of personal data.
LEGAL BASIS FOR BIENFAY PROCESSING CUSTOMER PERSONAL DATA
BIENFAY collects and uses customers” personal data because is it necessary for:
– the pursuit of our legitimate interests (as set out below);
– the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer; or
– complying with our legal obligations.
In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers via email or text message.
Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
OUR LEGITIMATE INTERESTS
The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Pro World Shoes, including:
– selling and supplying goods and services to our customers;
– protecting customers, employees and other individuals and maintaining their safety, health and welfare;
– promoting, marketing and advertising our products and services;
– sending promotional communications which are relevant and tailored to individual customers;
– understanding our customers” behavior, activities, preferences, and needs;
– improving existing products and services and developing new products and services;
– complying with our legal and regulatory obligations;
– preventing, investigating and detecting crime, fraud or anti-social behavior and prosecuting offenders, including working with law enforcement agencies;
– handling customer contacts, queries, complaints or disputes;
– protecting Pro World Shoes, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Pro World Shoes;
– effectively handling any legal claims or regulatory enforcement actions taken against Pro World Shoes; and
– fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
- COOKIES POLICY
WHAT ARE COOKIES?
HOW ARE COOKIES MANAGED?
The cookies stored on your computer or other device when you access our websites are designed by:
– Pro World Shoes, or on behalf of Pro World Shoes, and are necessary to enable you to a make purchases on our website;
– third parties who participate with us in marketing programs; and
– third parties who broadcast web banner advertisements on behalf of Pro World Shoes.
WHAT ARE COOKIES USED FOR?
The main purposes for which cookies are used are: –
1. For technical purposes essential to effective operation of our websites, particularly in relation to on-line transactions and site navigation.
2. For BIENFAY to market to you, particularly web banner advertisements and targeted updates.
3. To enable BIENFAY to collect information about your browsing and shopping patterns, including to monitor the success of campaigns, competitions etc.
4. To enable Pro World Shoes, meet its contractual obligations to make payments to third parties when a product is purchased by someone who has visited our website from a site operated by those parties.
HOW DO I DISABLE COOKIES?
If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further details on how to disable cookies for the most popular browsers are set out below: – For Microsoft Internet Explorer :
1. Choose the menu “tools” then “Internet Options”
2. Click on the “privacy” tab
3. Select the setting the appropriate setting
For Google Chrome :
1. Choose Settings> Advanced
2. Under “Privacy and security,” click “Content settings”.
3. Click “Cookies”
1. Choose Preferences > Privacy
2. Click on “Remove all Website Data”
For Mozilla firefox:
1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options
For Opera 6.0 and further:
1. Choose the menu Files”> “Preferences”
WHAT HAPPENS IF I DISABLE COOKIES?
This depends on which cookies you disable, but in general the website may not operate properly if cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on our sites. If you disable all cookies, you will be unable to complete a purchase on our sites.
Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data.
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.