This Policy outlines the way in which the company DFS France SAS, a limited liability company whose registered office is at 21 RUE DE LA MONNAIE, 75001 PARIS, FRANCE (hereinafter, "DFS France") and DFS Group registered office is at 15/F One Taikoo Place, 979 King’s Road, Quarry Bay, Hong Kong and its affiliates as joint controllers (“DFS”), collect and process the personal data which concerns you (hereinafter, your “Data”).
The provisions of the Regulation (EU) 2016/679 of April 27, 2016 (the General Data Protection Regulation or "GDPR") apply to the processing of your Data by DFS. Terms used for the purposes of this Policy have the meanings given to them by the GDPR.
DFS has appointed an internal Data Protection Officer.
If you have any questions relating to the collection and/or processing of your Data by DFS, please contact the data protection officer at the following address: firstname.lastname@example.org
We collect personal information about you from various sources. For example, we collect and obtain information:
- Directly from you
We collect personal information you provide, such as when you make a purchase, register for an account or create a profile, sign up for one of our program(s), contact us, respond to a survey, book a reservation, make an appointment for in-store or virtual services, register for an event, interact with us in store (including in-store digital experiences) or via the DFS Customer Service, participate in a sweepstakes, contest, or other similar campaign or promotion, respond to a survey, apply for a job, or sign up to receive emails, text messages, and/or postal mailings.
Your Data is notably obtained from:
- DFS CIRCLE sign up and upgrade;
- Book an experience;
- Concierge and alteration services;
- Reservation and purchase of products,
- Product delivery;
- Click & Collect services;
- Refund tax services;
- Gift cards
- Loan of equipment
- in our stores : The staff in DFS stores may also collect your Data and carry out Data processing within the framework of their activities.
- Using cookies and other automatic data collection technologies
- via online through the website https://www.dfs.com/,
- via any mobile app or digital platform (including the DFS WeChat Mini Program or any other digital platform operated by us or on our behalf from time to time) we may make available (together, the "DFS Platform(s)")
When you visit our the website https://www.dfs.com/ (hereinafter, the “Website”), use one of our mobile app or digital platform (including the DFS WeChat Mini Program or any other digital platform operated by us or on our behalf from time to time) we may make available (together, the "DFS Platform(s)"), open or click on emails we send you, or interact with our advertisements, we or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please see Section 6 “Cookies” below.
- Through in-store and other offline technologies
In some cases, we record customer service calls for quality assurance. We also use Closed Circuit Television or CCTV in our stores for safety, security, fraud, loss prevention, and operational purposes. In addition, some of our stores utilize technology that transmits a Bluetooth signal to and/or works with your mobile device running DFS Website and/or DFS Platforms (eg the beacon). If you have enabled the beacon on your mobile device, we collect device information and other unique identifiers and Location Data when you visit our stores.
- From our third-party partners
We obtain information from third parties that we have partnered with, such as brands, application providers, third-party websites and other third parties we choose to collaborate or work with.
- From social media platforms and networks
If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks (including Instagram, Facebook, Twitter, Google, You Tube, and Pinterest) in connection with our Website or DFS platforms, we collect information that you share with us, or that the social media platforms share with us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.
- From Other Sources
For example, we may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources. We also create information based on our analysis of the information we have collected from you.
Protecting the safety and privacy of children is very important to DFS. We do not knowingly collect or use the Data of minors under the age of majority in accordance with local legislations in force.
If you are under the minimum age requirement, please do not submit any Data without the express consent and participation of your parent or guardian.
If you believe that we have collected Data about a minor without such consent, please contact us at email@example.com and we will delete this information.
The Data which relates to you and which is collected by DFS is mainly:
· First name and last name;
· Civil status;
· National ID;
· Country of residence;
· Company name;
· Email address;
· Mailing address;
· Mobile and telephone numbers;
· Contact preferences;
· Date of birth;
· Bank details in the context of sales;
· Purchase and reservation history;
· Preferences and interests;
· IP address;
· Cookies and trackers;
· Login data
· Chat conversations.
Where you provide us with any personal data relating to any other person (such as any person you nominate to complete your purchase and collect products from our stores on your behalf) you warrant and undertake that you have obtained and will maintain that person's consent to the collection and use of that person's personal data by us in accordance with this Policy and that you have explained to that person that their personal data must be processed by us in order to complete the purchase.
Your Data is either:
· collected based on your consent; or
· required for the completion of your orders according to a contract; or
· collected for the purpose of pursuing a legitimate interest of DFS (e.g. the development of our commercial activity or to prevent fraud and counterfeiting)
· collected to fulfil DFS legal requirements.
You have no obligation to provide any information requested by us. However, if you choose to withhold requested information, we may not be able to provide you with any goods and services that depend on the collection of this information (particularly where our collection of this information is required by law).
Your Data is therefore collected and/or processed notably for the following purposes: View Details
In the particular case where you wish to communicate with DFS staff through third-party instant messaging services, DFS cannot guarantee the confidentiality and security of your Data or any other information exchanged through such messaging services. Companies offering this type of messaging services are themselves responsible for processing of your Data and comply with their own data protection and confidentiality policies. In this specific context, the processing of your Data by third-party messaging services remains outside DFS’s control: DFS therefore declines any responsibility in the context of this use.
Your Data will be processed by DFS and its business partners. We may share or transfer your Data as follows:
- within the DFS Group, namely with the following departments :
· Concierge and alteration services;
· DFS Communication Department for the management of your requests and questions, and for sending you newsletters;
· DFS Security Department for managing the cybersecurity of the Website;
· DFS Legal and Internal Control Departments for the management of any possible fraudulent acts or legal actions.
- with agents, contractors, third party service providers (such as those providing delivery, recruitment, administrative, telecommunications, computer services and other services in connection with the managing, processing and storage of your Personal Data) who will process your data on our behalf and following our instructions based on specific arrangements;
- with brands whose products are sold on DFS Platforms or in our stores;
- with regulatory authorities, airport authorities, landlords and concession partners, and customs and tax authorities;
- if we or any member of the DFS Group is acquired or decides to sell or reorganize any relevant part of our business, to any actual or proposed acquirer, assignee, transferee or successor who agrees to assume our obligations to you under this Policy, including at the negotiation stage;
- with financial institutions, card or other payment instrument issuers, credit providers or debt collection agencies; or
- in order to comply with applicable laws or regulations (whether of your jurisdiction or elsewhere) or to protect our rights or property; in order to comply with a court order, subpoena or other legal process; in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); or where we believe it is necessary to comply with applicable laws or regulations.
Except for these cases, your Data will not be transferred or made accessible to any third parties, subject to any restructuring of DFS, including a total or partial asset transfer, merger, absorption, acquisition, demerger and in general any reorganisation operation, subject to appropriate security and confidentiality measures.
You consent to the processing and storage of your Personal Data in locations other than the location from which you access the DFS Platform.
Since DFS is an international group and works with data processors located abroad, the recipients of your Data may also be located abroad, in countries/regions where runs its activities such as Singapore, the People’s Republic of China (PRC), Hong-Kong, and Japan (this list is not exhaustive).
In order to provide better services, DFS stores around the world will be able to check my DFS CIRCLE account information and purchase records when I go to the store to make a purchase.
Any transfer of Data will be governed by appropriate guarantees, notably contractual safeguards, in accordance with the regulations applying to the protection of personal data. DFS has taken all reasonable steps to ensure the security and confidentiality of your Data when it is accessed or stored in locations other than the one from which you access the DFS Platforms.
In accordance with the regulations in force, you have the following rights:
· Information: you can ask DFS to be informed about the collection and use of your personal data as well as the ground for such processing.
· Withdrawal of consent: you can withdraw at any time your consent for of any processing of personal data based on your consent, without affecting the lawfulness of processing based on your consent before its withdrawal.
· Access: you can ask us to confirm whether we process your personal data and, as the case may be, inform you of the characterisics of such processing, allow you to access such data and give you a copy of it.
· Rectification: you can ask us to rectify or complete inaccurate or incomplete personal data. Taking into account the purposes of the processing, you also have the right to provide a supplementary declaration, if necessary, to ensure the integration of incomplete data.
· Erasure: you can ask us to erase your personal data in the following cases: when it is no longer necessary for the purposes of which it was collected; you have withdrawn your consent and there is no other legal basis on which your data are processed; you objected to the processing of your personal data and DFS has no compelling legitimate grounds to refuse it; your personal data has been processed unlawfully; or to comply with a legal obligation. We are not required to comply with your request notably if the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.
· Objection: (including to marketing) you can request not to receive direct marketing communications from DFS and for DFS not to disclose your Data to others for direct marketing purposes
· Restriction of processing: you can ask to restrict the processing of you personal data in certain circumstances:
o you contest the accuracy of your personal data, for the period necessary for the data controller to verify the accuracy (thus the processing is temporarily suspended);
o the data has been unlawfully processed and you oppose to erasure and request restriction instead;
o although the data controller no longer needs it for the purposes of processing, your personal data is necessary to establish, exercise or defend a legal claim;
o you object to the processing under Article 21(1), pending the verification whether the legitimate grounds of the controller override those of the data subject.
· Portability: You can request the transfer of your personal data. As part of such a request, you may request that your personal data be either returned to you or transferred to another data controller in structured, commonly used and machine readable formats.
Your request to exercise your rights will be processed as soon as possible and a reply will be given to you within 30 days at the latest (except for New-Zealand residents, see section above), except in the case of complex requests.
Please note that fees can be charged in some cases, and DFS’ DPO will inform you whether or not these fees apply.
You may contact any competent supervisory authority, such as the one in the State of your habitual residence, place of work or of an alleged infringement of the legislation with any claims concerning the way in which DFS collects and processes your Data.
You may also contact us at the details above if you have a complaint about how we have handled your information. We will investigate your complaint and will use reasonable endeavours to respond to you in writing as soon as possible. If we fail to respond to your complaint within a reasonable time or if you are dissatisfied with the response that you receive from us, you may have the right to make a complaint to the Commission nationale de l'informatique et des libertés i.
The complaints to the CNIL can be lodged via:
- registered mail with return receipt addressed to the headquarter of the CNIL (currently: P 3 Place de Fontenoy, TSA 80715 75334 PARIS CEDEX 07);