CHANEL Privacy Policy

FOR ADDITIONAL INFORMATION

For any privacy related questions, please contact privacy@chanel.com

CHANEL cares about your privacy and data protection. We are committed to offering the highest standards of products and services. Thus, we value each of our existing or prospective clients and aim at maintaining appropriate protection of your personal data/personal information (“Data”).

This CHANEL Privacy Policy explains how CHANEL collects and processes your Data when you use our websites, apps or other digital experiences (“Digital Services”), when you purchase CHANEL products via any of our Digital Services or via our points of sales, when you visit our points of sales, when you fill in and submit one of our Boutique Cards, when you apply for a job at CHANEL or when you otherwise interact with or are displayed content about CHANEL, as required by the data protection laws in the territories in which we do business.

Local-specific amendments referred to below also apply to consumers in those territories and may in some cases set out different standards due to applicable local laws, rules and regulations. If so, the local-specific amendment will govern in the event of a conflict. In compliance with U.S. state specific data privacy laws, for notice regarding CHANEL’s collection and processing of data from residents located in the U.S., please click here

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Executive Summary of CHANEL Privacy Policy

Part I. - General provisions

Provides the general provisions applicable to all CHANEL data processing, whether you visit us via any of the CHANEL Digital Services or in our points of sales, and irrespective of the jurisdiction from which they are operated or in which you are located or reside.

1. Who is responsible for the processing of your Data?

To know the entity acting as a data controller for the processing of your Data, please click here

2. What Data do we collect and how?

The categories of Data we collect about you depend on your activity and interaction with CHANEL. Your Data may be collected when you purchase a product at CHANEL (e.g. Basic Data, Purchase Data; After-Sales Data), when you use the CHANEL Digital Services (e.g. Log Data, Social Media Data, Live Chat), when you subscribe to the CHANEL newsletter (e.g. Marketing Data), when you apply for a job at CHANEL or when you otherwise interact with CHANEL (e.g. Request Data).

3. Why do we collect and process your Data and how do we justify the processing of your Data?

We may process your Data for various purposes, depending on your interaction with us, for example to enable you to purchase a product at CHANEL or provide you with CHANEL services, to process your requests, to keep you informed about our latest collections and events, to collect your opinion, to communicate with you, and generally to know you better in order to offer you a personalized experience. Each processing of your Data is legally based either on your consent, the necessity to carry out a contract with you, a legal obligation and/or our overriding legitimate interest depending on the purpose of the processing.

4. To whom could we disclose your Data?

5. International Data Flows

6. For how long do we keep your Data?

CHANEL keeps your Data as long as necessary to provide you with the requested services, or to comply with our legal obligations.

7. What are your rights?

You have several rights on your Data (e.g. right of access, rectification, erasure, objection, etc.) which are listed here and which you may exercise at any time.

8. How to Contact CHANEL for Privacy Queries?

You may contact CHANEL here for exercising your rights and for any question on this privacy policy.

Part II - Provisions specifically applicable to CHANEL Digital Services

Provides the specific provisions applicable to CHANEL data processing implemented only on CHANEL Digital Services.

1. What Cookies do we use and how can you object to such use?

2. What is the data processing carried out for digital adverstising ?

When you browse on our Digital Services, and upon your consent, where required by law, we will provide you with marketing content personalized to your needs and interests.

3. What is the data processing carried out when you apply for a job on our Digital Services?

CHANEL may process your Data if you apply for a job at CHANEL in order to process your application.

Part III. - Provisions specifically applicable to CHANEL points of sales

Provides the specific provisions applicable to CHANEL data processing implemented only via CHANEL points of sales.

1. CCTV

We may use CCTV when you visit CHANEL points of sales. Please click here to find out more on the processing of your image by CHANEL through our CCTV systems.

2. Other activities

Part IV. - Local specific provisions

This section provides for certain local-specific amendments or deviations which may apply depending on the CHANEL company operating the data processing or in which you are located or reside. These provisions supplement the general provisions set out in the CHANEL Privacy Policy. In case of a conflict or inconsistency, these specific local provisions prevail.

Part V - CHANEL Organization

Part I: - General provisions

Provides the general provisions applicable to all CHANEL data processing, whether you visit us via CHANEL Digital Services or in our points of sales, or otherwise interact with us, and irrespective of the jurisdiction from which they are operated or in which you are located or reside.

The data processing is carried out by or on behalf of the respective CHANEL entity (“CHANEL” or “we”) which collected your Data, as set out below. Such CHANEL entity may further share information with the whole CHANEL Organization in accordance with the safeguards foreseen in this policy (see Section 4).

Any online sales on the e-commerce section of the website are made by the respective CHANEL entity as set out in the applicable Terms of Sales.

If you want to contact CHANEL or its Global Data Protection Office, please see under Section 8. “How to contact CHANEL for privacy queries".

The categories of Data we collect about you depend on your activity and interaction with CHANEL. The following Data may be collected by CHANEL:

Data Categories

Data Collected

Basic Data

Title, last name, first name, middle name, maiden name, nickname, suffix, date of birth, age category, nationality, employee (yes/no), face photo (only for virtual try-on), linked account ID and relationship

Contact Data

Address type, primary (yes/no), street, number, city, zip/postal code, state, territory, territory of residence, email address, primary email (yes/no), phone number, phone number type, primary phone number (yes/no), phone number, communication language

Identification Data

Type of identification document (e.g., passport, national ID Card), document number, expiration date, date of issue.

Log Data (Information collected when you use the CHANEL Digital Services for informative purposes only - Information relating to your website use)

In line with cookie choice provided (if and when applicable), when you use our Digital Services for informative purposes only (e.g., even where you do not register on, purchase via or otherwise submit your Data through the relevant Digital Service), your internet browser and/or our app that you are using automatically collects, and transfers to us, certain basic information relating to your use of the Digital Service. Such Log Data may include your browser type and version, your operating system and interface, used device, language preference, the website from which you are visiting us (referrer URL), webpage(s) you are visiting on our Digital Services, date and time of your visit, part of your internet protocol (IP) address, your geographical location (to ensure the content and Digital Service you are being displayed is relevant for where you are), your actions taken on the Digital Services, your interaction with the Live Chat feature including a recording of any such sessions (which may be shared with third parties), and the name of your access provider.

Social Media Data (Information collected when you use the CHANEL Digital Services for informative purposes only - Information processed by external social media providers)

The mere use of our Digital Services does not generally involve data processing activities (including data transfers) in relation to third party media platforms and /or social networks (such as Facebook and Instagram, “External Platforms”). However, if you accept the targeting cookie provided (if and when applicable) or, for example, if you use the share buttons that enable you to share CHANEL content with your friends through these External Platforms, or log in to your accounts on such External Platforms via the Digital Services, the External Platforms may (subject to their own legal basis) collect and otherwise process personal data about you in order to provide you with personalized advertising.
For more information about the scope and purposes of the data processed by the External Platform provider, including your rights and setting options to protect your privacy, please see the privacy notice of the respective External Platform provider.

Purchase Data (Information collected when you purchase a CHANEL product)

If you purchase a CHANEL product, we will collect Data through the purchase form to process the purchase order, such as the date of transaction, customer ID, return (yes/no), transaction ID, boutique ID, channel, sales associate ID, total quantity, shipping amount, total amount local currency, total amount global currency, product ID, quantity, price, discount, sample (yes/no), taxes, net sales amount, net sales amount global currency, number of purchased products per type, segment allocation (incl. market, boutique, etc.) and keep your purchase history.

After-Sales Data

If you purchase a CHANEL product and/or seek after sale support, we will collect the following Data: Customer ID, Boutique location, creation date, last update, ticket ID, status, assignee ID, contact channel, reason, division, order no., number of previous requests, creation date, closed date, case ID, priority, case type, contact name, quantity, after-sales price, subject, description, proof of purchase (yes/no), date of purchase, boutique of purchase, product ID, communicated end, estimated end, comments for workshop, final action taken, segment allocation (incl. market, boutique, etc.), return date.

Marketing Data (Information collected when you subscribe to the CHANEL newsletter or other marketing communication)

If you subscribe to our newsletter or other marketing communication or give us permission to use your data for online advertising in order to receive information on CHANEL collections, products, campaigns, shows and other events, we will collect Marketing Data through the subscription form, such as consent to receive communications, consent to share / merge data, channel preferences, area of preference (Fashion, Watches & Jewelry, Fragrance & Beauty), boutique of preference, sales advisor of preference; event related data.

Interests Data

Languages spoken, favorite CHANEL products, interests, information saved to your CHANEL account, information from your interactions with different features and services that we offer digitally or instore (for example but not limited to: La Collection, Virtual Try On), and engagement with marketing campaigns.

When you interact with our digital or instore services, you might have the option to engage in different journeys:

If you have a CHANEL account and you sign-in as part of interacting with our digital or instore services, we will use the data collected during your instore or online digital experience to: (i) to send you product recommendations, advertising and relevant promotions, in accordance with your preferences (see the Marketing-Related Purposes below); (ii) to understand your preferences (see the Preference-Related purposes below); and (iii) to improve our tools, technologies and services.

Some of our experiences may enable individuals to participate in a “non-identifiable manner”, without providing their name and contact details, or without registering for or signing into a CHANEL account.

If you participate in one of our experiences, instore or digitally, in this way, we may retain certain personal data (including, for example, your contact information, results of your experience, Image Data, etc.) about you temporarily, for no longer than 48 hours. This is so that you can access the results of the experience after completing it, and save them to your CHANEL account, should you wish to do so. Once the temporary period has expired, we will delete your personal information, (e.g., your image data and email addresses) and will not be able to link the results of your experience to you.

During this temporary period, we will use a “session ID” to retrieve your experience information if you want to access it and link it to your account. A session ID is a random collection of letters and numbers, and will not relate to your personal information.

If you participate in one of our digital or instore experiences (including in this "non-identifiable” way), CHANEL will keep certain results from your participation in the instore or digital experience (e.g., skincare routine characteristics, product usage details, or qualitative skin expressions as vitality or smoothness) to be used by CHANEL for product development and service enhancement purposes. This information will not identify you.
Additional data may be collected for VIP clients (e.g. hobbies, food and beverage preference, boutique experience preference, etc., social influence (friend with other CHANEL clients, VIP client of other brands).
If you are involved in the creative, arts, or journalistic industries, including where you are in a corporate role in one of these industries, we may collect your personal data from publicly available sources, or through referrals, for the purposes of reaching out to you or building a relationship with you.

Third-Party Data

From time to time we may collect Data about you from third party partners or instruct such third party partners to provide their own Data about you to external platforms in order to (i) enrich our data sets so that we can provide you with tailored information about our products, services and events on external platforms or via such third parties, as well as (ii) to perform CHANEL brand monitoring.

When you have given a third party permission to share with CHANEL the information they hold about you either or directly or indirectly. For example, where you have been targeted with advertising content relating to CHANEL as a result of targeting criteria we have agreed with a third party publisher or social media provider.

Anti-Counterfeit and Anti-Infringement Data (Information on parties to fight counterfeiting and infringements of CHANEL's intellectual property rights)

In order to fight against counterfeit and infringement, CHANEL has set up processes to collect and store information on companies or individuals who commit or are likely to commit acts that violate our intellectual property rights. We collect and store the following Anti-Counterfeit and Anti-Infringement Data: identification data, postal address, email addresses, domain names, telephone numbers, social media handles and usernames, and other information related to counterfeit and infringing activities, together with any documents and information relating to court proceedings. This Anti-Counterfeit and Anti-Infringement Data may be collected by CHANEL or one of its agents on its behalf, from open sources, or provided to CHANEL by external parties, including government authorities. In addition, CHANEL periodically monitors social media sites and other online platforms/websites, as well as offline points of sales, to detect unauthorized sellers of CHANEL products.
CHANEL may share this Anti-Counterfeit and Anti-Infringement Data with third parties, including government authorities and its agents and advisors, for the purpose of investigating counterfeiting and infringing activity and taking action to prevent the infringement of CHANEL’s intellectual property rights.

Data for the management of CHANEL authorized/owned distribution networks

CHANEL needs to enforce its authorized/owned distribution networks, to protect the CHANEL brand and identify unauthorized resellers. To this purpose, CHANEL carries out profiling activities on customers by analyzing purchase behaviors according to objective criteria. CHANEL collects the following data for this purpose: identification data, name, purchase history (including products, volumes purchased and sizes), delivery address, location of boutique, payment method. In addition, CHANEL periodically monitors social media sites and other online platforms/websites, as well as offline points of sales, to detect unauthorized sellers of CHANEL products. Some Data is also collected from authorized resellers.
In the event an unauthorized reseller is identified, a flag may appear on its customer profile, which will restrict access on certain services and/or sales for a period of 2 years. There is no automated decision based on profiling.

Health Data linked to our products and services (e.g. cosmetics)

In order to comply with legal and regulatory obligations, and to address customer claims, CHANEL will collect through a dedicated questionnaire limited health information (e.g. skin type, allergies, previous reactions). A specific information notice will be provided to you in such case.

Image Data (may be categorized as biometric data differently depending on the jurisdiction)

Photographs: CHANEL may collect photographs and image data, for example at events or when you visit our boutiques, or where you send such image data to us.

Facial patterns and other image data: In the context of our digital or instore virtual try-on experiences, including Chanel Vitality Scanner and / or other experiences, image data will be used to determine whether facial or skin patterns are present, and the parameters of those facial patterns.

CHANEL does not store this type of data as standard. However, customers have the chance, if they choose to do so, and upon their consent, to store their image or recordings collected depending on the experience they had selected in their CHANEL account. This type of data is retained in accordance with local laws and guidelines. Users have the chance to delete it at any time.
Where you choose to save your image to your CHANEL account, we will store your image in order to provide you access to your image through your CHANEL account. No facial characteristics are measured or collected.

General Contact and Request Data(Information collected when you otherwise interact with us)

Type of relationship with CHANEL (e.g., customer, employee or other), last name, first name, type of request (e.g., personal information rectification or deletion request, or a request related to CHANEL products or services, including where you interact with us through our Customer Care Centre and any chat function), further request details necessary to process your request (e.g. identification details), and the content of your request provided to us (which may include recordings and/or transcripts of any phone calls, where applicable), and any responses you may provide to us through any questionnaires or surveys. CHANEL collects and processes this data in connection with its compliance obligations, to monitor our performance as a business, and in connection with any reporting that is required for legal reasons.

Important General Notice: When we collect personal data through forms, we will indicate the mandatory fields via asterisks. If you fail to provide the data marked with an asterisk, CHANEL will not able to process your Data according to this policy and this could prevent you from accessing our products and/or services. While submitting any Data, including multimedia content (photographs, videos etc.), please ensure it is accurate and do not transmit any sensitive data such as health information, political opinions, religious or philosophical beliefs, information on your sex life or sexual orientation, racial or ethnic origin, nor any content which is not expressly requested through a questionnaire or any other collection method (such as commercial information, advertising, personal creations, ideas, or concepts), unless this is required in exceptional cases (e.g. to report allergies).

Our Digital Services do not specifically focus on minors (i.e individuals under the age of 18). Nevertheless, if we were to inadvertently collect such information, the minor's legal representative can exercise the minor’s rights on his/her behalf and on his/her name at any time.

We may process, electronically or manually, your Data for the following purposes. Each processing of your Data is legally based either on your consent, the necessity to carry out a contract with you, a legal obligation and/or our overriding legitimate interest depending on the purpose of the processing.

Processing Purposes:

Categories of Data potentially involved:

Legal basis:

Digital Services-related Purposes

Enable you to browse through our Digital Services and to use your personal online account

• Basic Data
• Contact Data
• Log Data
• Purchase Data
• Social Media Data

• Consent
• Contract
• Legitimate interests

Interaction-related Purposes

Enable you to obtain information on our products and services from our Customer Care Center, or by contacting us through one of the methods in our “Contact us” section for instance. Enable you to interact with us through any of the communication channels listed in Section 8 of this Privacy Policy, or otherwise made available to you by CHANEL.

•Basic Data
•Contact Data
•Purchase Data
•General Contact and Request Data

•Contract
•Consent
•Legitimate interests

Purchase-related Purposes

Enable you to purchase CHANEL products through our Digital Services, in our CHANEL Points of sales and other points of sale. Enable us to manage your purchases, payments (including obtaining an electronic invoice) and deliveries

•Basic Data
•Contact Data
•Purchase Data

•Contract

Service-related Purposes (including after-sales)

Enable you to benefit from our warranties and after-sales, access CHANEL services in our CHANEL Points of sales and other points of sale or on our Digital Services – for instance, to book an appointment with a sales advisor, to create a CHANEL product wish list, use our in-store or online virtual try-on experiences, or to be able to identify you in-store. Enable us to manage the services CHANEL will provide post purchase and provide services for events.

•Basic Data
•Contact Data
•Purchase Data
•After-Sales Data
Image Data (may be categorized as biometric data depending on the jurisdiction)•Interests Data

•Contract
•Legitimate interests
•Consent (e.g., for our virtual try-on experiences and similar services)

Regulatory-related Purposes

Comply with our legal obligations, including inter alia cosmetics regulations, the fight against money laundering, corruption, sanctions screening, credit card fraud, the fight against counterfeit, security obligations and processing your data subject rights requests

•Basic Data
•Contact Data
•Log Data
•Social Media Data
•Purchase Data
•Request Data
•Anti-Counterfeit and Anti-Infringement Data
•Data for the management of CHANEL authorized/ owned distribution networks
•Health Data related to cosmetics
•After-Sales Data
•Identification Data
•Image Data

•Consent
•Legal obligation
•Legitimate interests

Management of CHANEL authorized/owned distribution networks and protection of CHANEL products and brand Purpose

Fight against diversion, selective distribution and brand equity protection, and detecting unauthorised resellers (to distinguish them from final consumers, authorized resellers or whitelisted personal shoppers (for Fashion articles only)).

•Basic Data
•Contact Data
•Social Media Data
•Purchase Data
•Request Data
•Data for the management of CHANEL authorized/owned distribution networks
•After-Sales Data
•Identification Data

•Legitimate interests (where applicable)

Product Improvement-related Purposes

Collect your opinion on our CHANEL products and services, in particular via surveys and questionnaires, and understanding how you use our services [via DCT] in order to improve our products and services.

•Basic Data
•Contact Data
•Log Data
•Request Data
•Social Media Data
•Marketing Data
•Third-Party Data
•Interest Data

•Consent
•Legitimate interests

Studies-related Purposes

Establish statistics, financial and commercial studies, perform analytics in order to provide you with personalised services

•Basic Data
•Contact Data
•Purchase Data
•Marketing Data
•Request Data
•Social Media Data
•Third-Party Data

•Consent
•Legitimate interests

Marketing-related Purposes

Keep you informed about our latest collections, products, campaigns, shows and other events by sending you our CHANEL communications (by electronic mail, by post or via your phone: calls, chat, SMS and MMS, instant messaging or social media). These communications may from time to time present non Chanel brands such as our Maisons d'Art (e.g. Maison Michel, Barrie, Goossens) and other acquired companies (e.g. Eres, Orlebar Brown). However, there will be no sharing of data with such companies.

•Basic Data
•Contact Data
•Marketing Data
•Purchase Data
•Interest Data
•Social Media Data
•Third-Party Data

•Consent
•Legitimate interests

Preference-related Purposes

Improve our understanding of your interests and preferences so that we can provide you with customized offers and services based your preferences that would correspond better to your needs and wishes.

•Basic Data
•Contact Data
•Log Data
•Purchase Data
•After-Sales Data
•Marketing Data
•Interest Data
•Social Media Data
•Third-Party Data

•Consent
•Legitimate interests

Business Contract management

Manage the relationship with our contractors or suppliers, perform the contract with such contractors or suppliers.

•Basic Data
•Contact Data
•Company/CV

•Contract

Global Chanel Account (as available)

You can create a CHANEL account in two ways; by registering for an account after any interaction or action at CHANEL points of sales or Digital Services, or by registering through a digital access point.
By registering for a CHANEL account, we will use your account (personal data and transaction history) to enable you to be recognised across the Chanel Boutiques network and benefit from a personalized CHANEL experience anywhere in the world.
If you are visiting a CHANEL point of sale in any country, our Advisors will be able to offer you a personalized experience.

•Basic Data
•Contact Data
•Purchase Data
•After-Sales Data
•Marketing Data
•Interest Data
•Data for the management of CHANEL authorized/owned distribution networks
•Request Data
•Image Data

•Legitimate Interest

We regularly review accounts to avoid duplications and improve the quality of the data, as such we may merge accounts where we believe they relate to the same individual, in order to improve the customer experience and protect the quality and security of the data on our systems. In order to help us keep the data accurate, you can update, modify, and access your data here

Within the CHANEL Organization. To the extent permitted by law and taking into account the protection of your rights and freedom in respect of the processing of your Data, and the consent you have given (if any), your Data will be accessible by a limited and defined number of recipients within the global network of CHANEL companies (“CHANEL Organization”). The full list is further detailed in Part V below.

Such Data access will strictly take place on a “need to know” basis in order for the recipients to fulfill the Processing Purposes in their capacity as data controllers (except for CCTV Purposes which are handled locally). We may transfer your Data to another legal entity for the purposes of a collaboration, joint venture, corporate reorganization, change of legal form or other similar event, and/or to provide you with the best possible service. In case of a merger or sale, your Data will be permanently transferred to the successor company.

If you are an existing or prospective client of CHANEL or otherwise interact with CHANEL via the Digital Services (except by way of a job application), only the CHANEL employees within the CHANEL Organization that are working within the teams that need to have your information (for example, Customer Relationship Management, Commercial Management, Legal, Compliance, IT, Client Customer Care and Digital Team) will access your Data for the purposes of customer relationship management.

Service providers (within and outside CHANEL): Your Data will generally not be disclosed to recipients outside the CHANEL Organization. In some cases, however, CHANEL makes use of external service providers acting on behalf of CHANEL on the basis of contractual arrangements which will include strict data protection obligations. We will in particular provide your Data to service providers or suppliers (this may include other CHANEL companies) as part of our normal business operations for example to carry out certain IT-related tasks, conducting our business, servicing you or protecting the security and integrity of our business. These include but are not limited to IT maintenance, security and support service provider, hosting provider, payment provider, logistics provider, marketing and advertising partners, data analytics companies, event providers, digital service tools providers (for example where we use tools or systems in connection with our boutiques and events, or to manage your access to our events, or appointments at boutiques), mailing or emailing services or customer care center. Some of the service providers that we use will be based in a different jurisdiction, and when transferring your Data to them, we ensure that the cross-border transfers are in line with any legal and regulatory requirements. See Section 5 below for further information about international data transfers.

Other Third Parties outside Chanel Organization. We may, in limited cases, transfer your Data to governmental agencies and regulators (e.g. tax authorities), courts, and government authorities, all in accordance with applicable law and to external advisors (e.g., lawyers, accountants, auditors etc.), all acting as controllers. In this context, CHANEL may also have to transfer your Data to third parties when it receives a request by an authority empowered by law to do so, pursuant to applicable laws and regulations. Anti-Counterfeit and Anti-Infringement Data and Diversion Data may be shared with third parties, including government authorities and companies legally authorized to use the CHANEL trademarks for the purpose of investigating infringing activity and taking action to prevent the infringement of Chanel's intellectual property rights.

Other Digital Partners. There may be digital partners which may process your Data for their own purposes, to the extent permitted by this policy. The processing by these entities is governed by their own privacy policies.

For instance, to share social media content, our Digital Services may use share buttons. Our Digital Services may include third-party links, icons or applications that allow you to share content with others, or to publish your visit or opinion of Digital Services content with others such as “Share” and “Like” buttons on social networks such as Facebook, Twitter, Instagram, Pinterest, etc. The provider of such application buttons may identify you via this button, if you use the button, and even if you have not used this button but are signed in to the social network when you visit the relevant Digital Service (open session during your browsing). Share buttons will allow you to connect the contents consulted to your user account. The processing by these entities is governed by their own privacy policies.

When Facebook is the digital partner (for example when using App Event by Facebook, WhatsApp, Instagram) Facebook Ireland is a joint controller of the processing and the information about the processing can be found in Facebook Ireland's Data Policy at https://www.facebook.com/about/privacy. Chanel and Facebook Ireland have entered into a joint controller agreement to determine the respective responsibilities for compliance with the obligations under the GDPR with regard to the joint processing.

If you choose to save your image data to your CHANEL account, you can delete it from your account at any time, otherwise it will be stored for the duration of your account registration, and in accordance with local laws and guidelines. 

If you choose not to save your image to your CHANEL account, the image is not retained outside the device you use to access the experience. Your image is deleted automatically when you close the experience page.

Data recipients as set out in Section 4 above may involve a transfer of your Data to territories that do not provide the same level of data protection. Applicable legal and regulatory requirements are taken into consideration before any cross border transfer of your Data.

•Data transfers within CHANEL Organization will ultimately be covered by CHANEL's Intragroup Data Transfer Agreement.
•Any Data transfers outside your jurisdiction that do not provide an adequate level of data protection will be secured through appropriate contractual guarantees which will also be in compliance with applicable laws and regulations, such as EU Standard Contractual Clauses.
•The transfer of Data may also be based on any available compliant mechanism according to applicable law.

You may receive relevant portions of the aforementioned documents upon request as required by applicable law.

This Section 5 also covers the CHANEL global account, which makes your account recognized internationally, across the Chanel Boutiques network regardless of where you are.

Alongside the commitment to offering the highest standards of services and products, we consider that our products should entitle you to personalized client treatment and incomparable after-sales services that may last for a lifetime for some products. For this purpose, and to ensure such services, we may need to keep your personal data for as long as it is needed for the provision of such services.

Categories of Personal Data / Processing Purpose

Global Retention Periods

Prospect personal data for marketing purposes

3 years from last contact with prospect.

Customer Personal Data for the purpose of managing the client relationship

10 years after the end of the commercial relationship.

Customer Personal Data for marketing purposes

10 years from the end of the commercial relationship.

Representatives of business contractors or suppliers

For the duration of the contract and then retained in an archived database with limited access for 5 years following the termination of the contract.

We may keep your data for as long as it is necessary to comply with applicable legislation regarding product guarantee and safety and in order to follow up with you on the results of the product and offer you continuous advice. Your Data will be further retained as long as required by applicable local law or to the extent we have a legitimate and lawful purpose to do so. Please note that the storage period provided by legislation may vary per jurisdiction, and separate information notices for specific data processing (e.g. cosmétovigilance) may provide different data retention periods.

Your image in the context of the virtual try-on (or other similar experiences) via our Digital Services is not stored, it is collected only to provide you with the service. Where you choose to save your image to your CHANEL account, it will be stored for the duration of your account registration, and in accordance with local laws and guidelines, although you will always have the opportunity to delete your image from your CHANEL account at any time. Where you choose not to save your image to your CHANEL account, your image is deleted automatically when you close the experience page.

You may have the following rights to the extent and as provided by the law applicable to you which you can exercise through the contact details provided in Section 8 below:

•A right of access and information: you have the right to be informed in a concise, transparent, intelligible and easily accessible form of the Data we hold and the way in which your Data is processed. You also have the right to obtain (i) confirmation as to whether or not Data concerning you is being processed, and, where that is the case (ii) to access such Data and obtain a copy thereof.
•A right to rectification: you have the right to obtain the rectification of your Data. You also have the right to have incomplete Data completed.
•A right to erasure: in some cases, you have the right to obtain the erasure of your Data. However, this is not an absolute right and CHANEL may have legal or legitimate grounds for keeping such Data.

In addition, further rights will apply in accordance with GDPR, and may also be applicable in your jurisdiction (see Part IV. - Local-specific provisions):

•A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your Data.
•A right to data portability: you have the right to receive your Data which you have provided to CHANEL, in a structured, commonly used and machine-readable format, and you have the right to transmit such Data to another controller without hindrance from CHANEL. This right only applies when the processing of your Data is based on your consent or on a contract and such processing is carried out by automated means.
•A right to object to processing: you have the right to object to processing of your Data when such processing is based on the legitimate interest of CHANEL. CHANEL may, however, invoke compelling legitimate grounds for continued processing. You also have the right to object at any time to the processing of your Data for marketing purposes. To unsubscribe from our marketing communications you may also use the above channels or simply by clicking on the “unsubscribe” link at the bottom of each communication.

If you have consented to any personal data processing activities, you can withdraw this consent at any time for future processing. Such withdrawal will not affect the lawfulness of the processing prior to consent being withdrawn.

You also have the right to lodge a complaint with a competent supervisory authority.

For any questions or comments relating to this Privacy Policy or the manner in which CHANEL collects and uses your Data, you may also contact our Global Data Protection Office at the following address:

Global Data Protection Office

CHANEL Limited
Time & Life
1 Bruton street, London W1J6TL
Attn: Head of Data Privacy

By email: privacy@chanel.com

To exercise your rights, please communicate your name, surname, e-mail and any other information necessary to confirm your identity in order for us to process the request (such as your postal address) and submit your request via any of the following means:

•By email: privacy@chanel.com
•by mail: CHANEL Limited Time & Life 1 Bruton street, London W1J6TL Attn: Head of Data Privacy
•by webform accessible here
•by addressing it to our CHANEL Points of sales or other points of sale
•by contacting our CHANEL Customer Care Service (via the form “Contact Us”).

Part II. - Provisions specifically applicable to CHANEL Digital Services

We may engage vendors to provide certain interactive features on our Digital Services. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on our Digital Services to respond to questions and otherwise provide customer service. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. We also offer certain tools which we use to manage your access to appointments at our boutiques, or to our events. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.

We, and our vendors, may use cookies, pixels, and other online tracking technologies (“Cookies”) on our Platforms to collect and analyze information about interactions with our Platforms.

Cookies are pieces of information that any website or other platforms may transfer to your browser that are then stored in your computer system. For example, the deposit of Cookies enhances your online experience by allowing us to save your preferences.

When you use the Digital Services, we, or vendors working with Chanel, send one or more Cookies to your device. We use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits of our Digital Services, unless you opt out of such cookies. Please note that if you choose not to accept certain Cookies, you may not be able to utilize the features of the services provided via the Digital Services to their fullest potential.

We use vendor Cookies in connection with the services provided via the Digital Services as well. For instance, we use Google Analytics to collect and process certain analytics data about how visitors use the Digital Services. We may use this information to implement Google advertising features such as interest-based advertising, audience targeting, and display advertising.

If you are using a browser that supports the Global Privacy Control (“GPC”), and have enabled the GPC, when you visit CHANEL Platforms, we will interpret that as a request to opt-out of Cookie based sharing, such that functional, performance, and targeting Cookies will be deactivated on our Platforms when you use that browser. We may not process or respond to all web browsers' "do not track" signals or other similar transmissions that indicate a request to disable online tracking of users who visit our Digital Services or use the services provided via our Digital Services. The Cookies set by third parties other than Chanel may be subject to the Privacy policies of those other companies.

We use Cookies and collected information for the following purposes:

(i) Strictly Necessary Cookies (Always Active): These Cookies are necessary for the website to function and are always active. They are usually only set in response to actions made by you, such as personalizing your privacy preferences, logging in or filling in forms, or to manage our website security. You can set your browser to block or alert you about these Cookies, but if you block these Cookies, some parts of the website may not function properly.

(ii) Performance Cookies: These Cookies allow us to count visits and traffic sources so the performance of our Digital Services can be measures and improved. They help us to know which pages are the most and least popular and see how visitors move around the Digital Services. These Cookies may be placed on our Digital Services by us (or by our vendors) to collect analytics, statistics, and other information about how you and others use the Digital Services.

(iii) Functional Cookies: These Cookies enable certain website functionality and personalization, such as recognizing your preferences (language, font size, general settings) or your last action. They may be set by us or by service providers whose services we have added to our Digital Services.

(iv) Targeting Cookies: These Cookies may be set by us or our advertising and social media partners. They may be used by us or those partners to build a profile of your interests and display more relevant advertisements on other websites If you do not allow these Cookies, you will experience less CHANEL targeted advertising.

We may also collect your shortened IP address on a non-readable basis, which does not allow us to directly identify you. We will also collect automatically other information concerning your device such as model, language software version etc.
We may combine automatically collected information with other Data we obtain about you, which may include Data we obtain from others. Cookies on our Platforms may be used to collect Data about your online activities over time and across different online services.

Cookies remained installed for a period of 12 months upon your consent.

Please be aware that restricting Cookies may impact your user experience and may prevent you from using parts of our Digital Services or services.

a) What Data do we collect and why ?

Processing Purposes:

Categories of Data potentially involved:

Legal basis:

Make Digital Services available to you, in a form and format based on the device and location you are accessing the Digital Services from. This collection may take place before you have registered on the Digital Service, to enable you to browse through the Digital Service, use its available features, and use your personal account.

•Log Data

•Legitimate Interest

Offer you or other clients a marketing personalized experience adapted to your or their needs and interests (e.g. provide clients personalized offers based on your Purchase Data, or use your Interest Data to analyse, evaluate, or predict your personal preferences or interests in order to tailor or market our services to you). This involves profiling activities, but no automated decision based on profiling is taken.

•Basic Data
•Purchase Data
•Marketing Data
•Interest Data

•Consent
•Legitimate Interest

b) To whom could we disclose your Data?

Your Data is shared within the CHANEL Organization and services providers as detailed in Part I Section 4 above.

To provide you with the best digital marketing experience, and in particular for marketing targeting purpose, upon your consent, your Data is transmitted to digital partners. Such partners will process your Data according to their privacy policy. You can withdraw your consent at any time, or object for the use of your Data by such partners, either directly by contacting the partners or by contacting us at privacy@chanel.com.

The other Sections of Part I (e.g. data retention, your rights, etc) will still apply to this data processing.

We welcome and value applications from talented candidates.

C) WHAT DATA DO WE COLLECT AND HOW?

Data Categories

Data Collected

Applicant Data (Information collected when you apply for a job at CHANEL or its affiliates)

If you apply for a job at CHANEL or its affiliates via the Digital Services, we collect the following Data relating to your application:

•title / gender,
•name (first name and surname),
•nationality,
•Territory and city of residence,
•Eligibility to work
•postal address,
•email address,
•phone number,
•educational level,
•school/university,
•spoken languages,
•work experience,
•certificates,
•further CV information,
•interview responses,
•references from past employers,
•your preferred entry date, and
•further Data you may submit.

If you are made an offer by us, we process Data such as information on your terms of employment including your hours and working patterns, your pay and benefits (such as your participation in pension arrangements, life and medical insurance) and any bonus or share schemes.

Additional checks Data

We may also process (or third parties will process on our behalf) the following Data if we carry out additional criminal background checks or credit record checks for your job role.

For example, if you have applied for a role at a CHANEL point-of-sale located in the restricted zones of UK airports which requires the issue of a security pass for authorised access to restricted zones, you are required to complete security interviews and background checks. To create the security interview form, we will collect date of birth, government identification numbers and your security review answers.

We use third-party agencies to carry out background checks on our behalf. The relevant background checks agency will collect certain Data directly from you (in addition to Applicant Data) such as place of birth and proof of identification.

We and the agencies will also process the following data either provided by you or which we receive from third parties, such as:

•criminal offence data provided by the UK DBS;
•criminal, police or court records,
•financial history, including credit history, bankruptcy and financial judgements,
•inclusion on watch or sanctions lists, and
•membership, registration or disciplinary action with regulatory or professional bodies, and
•social media searches

D) WHY DO WE COLLECT AND PROCESS YOUR DATA AND HOW DO WE JUSTIFY THE PROCESSING OF YOUR DATA?

Processing Purposes:

Categories of Data potentially involved:

Legal basis:

Application-related Purposes

Where it is in our legitimate interests to process your application, including assessing your suitability for open positions using our internal and external experts. We also use your data to communicate with you about the recruitment process.

We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including, without limitation, recruitment agencies and your referees.

If you are made an offer by us, we process your Data where it is necessary for performance of an employment contract with you or to take steps at your request to enter a contract.

•Applicant Data

•Consent (where applicable)
•Contract
•Legitimate interests

Recruitment background checks

Where it is in our legitimate interests to obtain a security pass for you for authorised access to restricted zones of UK airports where required for your role and necessary for the prevention and detection of unlawful acts.

We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including, without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.

We do not rely on your consent as a legal basis for processing your Data. Any mention of consent in the context of background checks carried out as part of our recruitment process refers to your agreement to participate in those background checks.

•Additional Checks Data

•Legitimate interests – prevention and detection of unlawful acts
•Consent (where applicable)

Future roles

We will also use your data to maintain an applicant pool in order to be able to match future positions with potential candidates.

•Applicant Data

•Legitimate interests
•Consent (where applicable)

E) To whom could we disclose your Data?

If you apply for a job through the Digital Services, the CHANEL human resources department will process your application (within the CHANEL Organization) and may forward your application to external recruitment firms as necessary. We may also share your data with right to work agencies and, depending on the role to which you have applied, we may share your Data with third parties such as UK Airports, background check providers and credit reference agencies. Those agencies will be required to share your Data with government departments and agencies such as the UK DBS, professional bodies and advisors, and past employers and educational institutions to complete the relevant checks.

F) FOR HOW LONG DO WE KEEP YOUR DATA?

We may keep your Data on file for up to 2 years following your last visit to our candidate space and contact you if another appropriate opportunity arises if your previous application on the “Careers” section of our Digital Services is not successful. In case you choose not to be contacted for future opportunities, your Data will be kept for up to 6 months after the end of the respective application process, unless shorter or longer retention is permitted or required by applicable local law. Notwithstanding the foregoing, in certain jurisdictions, we may keep your Data on file for a longer time period, subject to applicable law, as detailed in the specific provisions in Part IV below. If you become employed by us, we will keep your Data for the duration of your employment and for a period afterwards.

G) HOW TO CONTACT CHANEL FOR PRIVACY QUERIES

For any Applicant Data for your application to our “Careers” section, you may view and manage your Applicant Data directly within the CHANEL Career Site, or in any event you may contact CHANEL at privacy@chanel.com or as otherwise detailed in Part I Section 8 above.

Part III:- Provisions specifically applicable to CHANEL Points of sales

A) WHAT DATA DO WE COLLECT AND HOW?

Data Categories

Data Collected

CCTV Data
to view and record individuals at our sites, 24 hours per day, 7 days per week
Where CCTV is in use at our sites, and where legally required, we will ensure that signs are displayed at the entrance of the surveillance zone to alert employees, guests and contractors their image may be recorded.

Image

B) WHY DO WE COLLECT AND PROCESS YOUR DATA AND HOW DO WE JUSTIFY THE PROCESSING OF YOUR DATA?

Processing Purposes:

Categories of Data potentially involved:

Legal basis:

CCTV-related Purposes
Protect individuals as well as our property and assets, prevent, repress and prosecute crimes and offenses.
- to prevent or detect crime and protect buildings and assets from damage, disruption, theft, vandalism and other crime;
- for the personal safety of employees, guests and contractors and other members of public and to act as a deterrent against crime;
- to support any internal investigations in relation to the above

•CCTV Data

•Legitimate interests

C) TO WHOM COULD WE DISCLOSE YOUR DATA?

To achieve the aforementioned purpose, CHANEL will share your personal data with the Security Department and Legal Department of the CHANEL entity acting as a data controller, and its security services provider (within a secured restricted area or control room), and will give access to the private security companies providing installation and maintenance support services to the data controller,

Any employees using CCTV will be given training to ensure that they understand and observe the legal requirements relating to the processing of any CCTV Data gathered.

D) FOR HOW LONG DO WE KEEP YOUR DATA?

The images shall be kept for a maximum term of one (1) month after they were captured, unless they must be kept to evidence the perpetration of acts against the safety of persons, assets or facilities, in the latter case they are extracted from the systems and kept for the duration of the proceedings.

We will ensure that CCTV Data gathered from systems is stored in a way that maintains its integrity and security. This may include encrypting the CCTV Data, where it is possible to do so.

Other activities might be conducted in the points of sales you are visiting (e.g. facial recognition, measurement and analysis of Client's movements within the Boutiques, COVID-19 protection), additional and specific notices will be available in such points of sales.

Part IV:- Local-specific provisions

The above mentioned General Provisions applicable to your Data may be subject to local specific rules. To know more about any specific rules applicable to you, please select the related jurisdiction below.

If you visit us via any of the CHANEL Digital Services or in our points of sales within or from Australia, each processing of your Data is based on your consent or in compliance with applicable laws and regulations, not on the basis of necessity to carry out a contract with you, a legal obligation /or our overriding legitimate interest.

This document is a full Privacy Notice.

In relation to Section 1:

Controller Information

For the purposes of this Privacy Policy, the Controller of personal data is the company Europrestígio Distribuição e Comércio de Artigos de Luxo Ltda. (Chanel), registered in the CNPJ under n° 11.662.449/0001-31, with address at Av Brigadeiro Faria Lima, 1663 - 6º Floor, +5511 2620-0100.

Regarding Section 8:

Article 18 of the General Data Protection Law (Law 13.709/2018), grants you the following rights:

I. Confirmation of the existence of personal data processing
II. Access to personal data
III. Correction of incomplete, inaccurate or outdated data
IV. Anonymisation, blocking or deletion of unnecessary, excessive or processed data that do not comply with this Law
V. Portability of data to another service or product provider, upon express request, in accordance with the regulations of the National Data Protection Authority
VI. Withdrawal of consent and consequent disposal of the personal data processed, except in the cases provided for in art. 16 of the General Data Protection Law
VII. Information of public and private entities with which the controller has made shared use of data
VIII. Information on the possibility of not providing consent and on the consequences of refusal
IX - Revocation of consent, pursuant to § 5 of art. 8 of the General Data Protection Law

In the event that the right exercised is that of elimination or anonymization of personal data, the implementation will depend on 2 (two) stages: in the first, the request will be received and analyzed within the period described below (relative to Section 8). In the second step, if the request is approved, CHANEL will delete or anonymize your personal data within fifteen (15) days after the first step has elapsed. A request for deletion or anonymization may be rejected if there is a legal basis available under applicable law for maintaining such data.

Other applicable Section 8 information:

•The CHANEL Personal Data Handler, responsible for clarifying questions and attending to data subjects in Brazil is the CHANEL PRIVACY team. The local Data Protection Officer is GET GLOBAL CONSULTORIA LTDA represented by Ricardo Alexandre de Oliveira. For privacy queries please e-mail:privacy@chanel.com
•Please provide us with a copy of an official identification document if you wish to exercise any of your rights mentioned in Section 8.
•CHANEL will make every effort to respond to your request immediately and, if this is not possible, within 15 days of receipt of the request, which period may be extended as provided for by law or regulations.
•Means of Communication: If the need or opportunity arises, CHANEL may contact you by any means of communication available and not prohibited by law, such as, but not limited to, e-mail, SMS, MSM, or WhatsApp messages. CHANEL reserves the right to contact you, even without direct authorization, when the rights of CHANEL, third parties or yours are more important, such as to forward information about the progress of your orders or to report any occurrences.
•Database Management: CHANEL will manage its databases within the limits of the applicable legislation and may unify or divide them according to the needs of its business, preserving, in all cases, transparency with its customers.

If you visit us via any of the CHANEL Digital Services or in our points of sales within or from Canada, the processing of your Data is based on your consent or in compliance with applicable laws and regulations.

In addition to the rights listed in section 7 of Part 1 of this policy, the rights below will apply:

•You may vary or withdraw your consent to the processing of your Data, or opt-out of certain uses and disclosures, subject to legal and contractual restrictions. Such withdrawal will not affect the lawfulness of the processing prior to consent being withdrawn.
•You also have the right to object at any time to the processing of your Data for marketing purposes. To unsubscribe from our marketing communications, you may also use the above channels or simply by clicking on the “unsubscribe” link at the bottom of each communication.

If you visit the website chanel.cn operated by Chanel (China) Co. LTD, the following applies:

By using our website you consent to the processing activities described herein.

In addition to the matters provided in Part I. 2. “What Data do we collect and how?” of the Global Privacy Policy, Data that we process is as follows for purposes as stated above:

•information about your gender as a part of your Basic Data, and
•medical records as part of Health Data linked to our products and services (e.g. cosmetics)

For Mainland China, External Platforms referred to in Social Media Data also include WeChat, TMall, etc.

Information Security

CHANEL takes all the necessary measures to ensure confidentiality of your personal data. CHANEL has implemented a robust data protection compliance program, which includes the adoption of the high-standard data protection principles of the GDPR at a global level and includes the:

•creation of a Data Protection Office and a network of local data protection contacts;
•adoption of internal policies and procedures to ensure compliance with applicable data protection laws and regulations;
•implementation of appropriate legal, technical and organizational measures to implement the data protection principles.

However, there is no guarantee for absolute security or error-free for information transfer on the internet and that the stored information or data has no loopholes.

Protection on Children’s Rights

Websites are mainly for adults. Children cannot create their own user accounts without the consent of their parents or guardians.

In the case of collecting children's Personal Information with parental consent, we will only use or publicly disclose such information in the circumstances as permitted by laws, with the explicit consent of parents or guardians or with the need to protect children. Although local laws and customs define children differently, we treat anyone under the age of 14 as a child.

If we find that we have collected children’s Personal Information without prior verifiable parental consent, the data will be deleted as soon as possible.

The following statements will be exclusively applicable for Colombia and supersede any provisions therein that are contrary to this Appendix. For the avoidance of doubt, this section is in addition to, and supplements, the remainder of this CHANEL Privacy Policy:

1. About this notice

In the processing of the personal data made by or on behalf Chanel, COMPAÑIA UNIVERSAL DE PERFUMERIA FRANCESA, S. de R.L. (“Chanel”), a company located at Calle 74, PH MIDTOWN, San Francisco, Ciudad de Panamá, República de Panamá, with email address privacy@chanel.com and phone 2091700, is the data controller of personal data of consumers domiciled in Colombia (the “Data Subjects”). Chanel is the entity that determines why and how the personal data of Data Subjects is processed.

Chanel, directly or through data processors will collect from Data Subjects the personal data listed in section “What Data do we collect and how” of Part I, and “General Provisions” of the Chanel Privacy Policy. The personal data is collected as described therein.

2.1 Sensitive information

Chanel may collect from the Data Subjects sensitive personal information in exceptional cases, as provided in the Chanel Privacy Policy. Colombian Privacy Laws define personal sensitive data as information that relates to one or more data subjects domiciled in Colombia which improper use may generate discrimination, such as: the one that reveals racial or ethnic origin, political orientation, religious or philosophical convictions, data related to health, sexual life and biometric information.

Please note that you are not obliged to authorize the processing of your sensitive personal data. Therefore, the processing of the personal data considered sensitive information shall be based on the consent of the Data Subject or in compliance with applicable laws and regulations, and not on the basis of the necessity to carry out a contract with the Data Subject. Should you not consent to this collection, Chanel may be unable to deliver certain services that require your sensitive personal data.

3. Data processing

Data Subject’s personal data may be subject to collection, storage, use, circulation or deletion, in accordance with the provisions set forth in Law 1581 of 2012 and for the purposes described in section “Why do we collect and process your data and how do we justify the processing of your data” of Part I “General Provisions” of the Chanel Privacy Policy, section “What is the data processing carried out for digital advertising” of Part II “Provisions specifically applicable to Chanel digital services”, as applicable.

Chanel will directly or through data processors, obtain informed consent from Data Subjects prior to the collection and processing of their personal data, except where Law 1581 of 2012 and applicable Data Privacy Laws establish that Chanel will not require authorization from the Data Subjects, as described below:

4. Rights

In addition to the rights indicated in the section “What are your rights” of the Chanel Privacy Policy, the following are rights of Data Subjects as per Colombian Data Protection Law:
(a) To know and update their personal data.
(b) To request proof of the authorization granted to Chanel.
(c) To be informed by Chanel, upon request, regarding the use that has been made of their personal data.
(d) File complaints before the Superintendence of Industry and Commerce (the "Data Protection Authority") for potential violations of Colombian data protection law.
(e) Access free of charge to their personal data that have been subject to processing.
(f) To revoke the authorization and/or request the deletion of the data when the principles, rights and constitutional and legal guarantees are not respected in the data processing. The revocation and/or deletion will proceed when the Data Protection Authority has determined that in the data processing Chanel or the data processor has incurred in conducts contrary to the law and the Political Constitution of Colombia.

Chanel, as data controller shall comply with the following duties:
5.1 Guarantee to the Data Subject, at all times, the full and effective exercise of the right of habeas data.
5.2 Request and keep, under the conditions stablished in Law 1581 of 2012, a copy of the respective authorization granted by the Data Subject.
5.3 Duly inform the Data Subject about the purpose of the collection and the rights he/she is entitled to by virtue of the authorization granted.
5.4 Keep the information under the security conditions necessary to prevent its adulteration, loss, consultation, use or unauthorized or fraudulent access.
5.5 Ensure that the information provided to the data processor, if any, is truthful, complete, accurate, updated, verifiable and understandable.

5.6 Update the information, communicating in a timely manner to the data processor, all developments with respect to the data previously provided and take other necessary measures to ensure that the information provided to it is kept up to date.
5.7 Rectify the information when it is incorrect and communicate the correct information to the data processor, if any.
5.8 To provide to the data processor, as the case may be, only data whose processing is previously authorized in accordance with the provisions of Law 1581 of 2012.
5.9 To demand from the data processor, if any, at all times, respect for the security and privacy conditions of the Data Subject's information.
5.10 To process the queries and claims of Data Subjects.
5.11 Adopt an internal manual of policies and procedures to ensure proper compliance with law and, in particular, for the handling of queries and claims.
5.12 Inform the data processor, if any, when certain information is under discussion by the Data Subject, once the claim has been filed and the respective process has not been completed.
5.13 Inform at the request of the Data Subject about the use given to his/her data.
5.14 Inform the Data Protection Authority when there are violations to the security codes and there are risks in the administration of the information of the Data Subjects.
5.15 Comply with the instructions and requirements issued by the Data Protection Authority.

6. Procedure to submit claims

For the processing of requests queries and/or claims on the processing of personal data, the procedure established in articles 14 and 15, respectively, of Law 1581 of 2012 shall be followed.

In particular, when the Data Subject wishes to consult the personal information contained in any Chanel database, Chanel must provide all the information contained in the individual record or that is linked to the identification of the Data Subject.

The consultation shall be formulated to the Local Data Protection Office at privacy@chanel.com in accordance with Section 8. “How to contact CHANEL for privacy queries.

You have the right to define guidelines for the storage, erasure and communication of your Data after your death.

You also have the right to register with Bloctel, the French opt-out list for marketing phone calls.

If you visit us via any of the CHANEL Digital Services or in our points of sales within or from Hong Kong S.A.R, each processing of your Data is based on your consent or in compliance with applicable laws and regulations, not on the basis of necessity to carry out a contract with you, a legal obligation /or our overriding legitimate interest.

With respect to the retention period of CCTV images under Part III 1d “For how long do we keep your Data” of the Global Privacy Policy, for Hong Kong S.A.R. , the images shall be kept for a maximum of sixty (60) days after they were captured, unless they must be kept to evidence the perpetration of acts against the safety of persons, assets or facilities, in the latter case they are extracted from the systems and kept for the duration of the proceedings.

For any discrepancies and grievances, please refer to contact details given in Section 8 of Part I above.

Security Practices: Chanel India adopts reasonable security practices and procedures as mandated under applicable Indian laws and the companies belonging to Chanel Organization adopt similar security practices and procedures for the protection of Personal Data and to prevent unauthorized use or disclosure of Personal Data.

If you visit us via any of the CHANEL Digital Services or in our points of sales within or from Indonesia, each processing of your Data which is considered sensitive personal information under applicable laws and regulations shall be based on your consent or in compliance with applicable laws and regulations, and not on the basis of necessity to carry out a contract with you, a legal obligation /or our overriding legitimate interest.

With respect to the retention period of CCTV images under Part III 1d “For how long do we keep your Data” of the Global Privacy Policy, for Indonesia, the images shall be kept for a maximum of sixty (60) days after they were captured, unless they must be kept to evidence the perpetration of acts against the safety of persons, assets or facilities, in the latter case they are extracted from the systems and kept for the duration of the proceedings.

In the event of conflict between the English and Indonesia language versions of this Privacy Policy, the English version shall prevail.

i. Provision to Third Parties

CHANEL may provide your Data to third parties such as data analysis companies and advertising companies including social networking service providers for the purpose of conducting research, analysis, and targeted advertising distribution, etc. Such third parties may use your Data provided by CHANEL, such as e-mail addresses, in conjunction with the Data relating to you held by such third parties for CHANEL's research, analysis, and delivery of advertisements, etc.

ii. Joint Use

CHANEL jointly uses your Data with third parties as follows.

Joint users

CHANEL will jointly use your Data with CHANEL Organization including CHANEL entities outside Japan, authorized department stores with which you registered your Data ("Registered Department Stores"), and other authorized dealers of CHANEL products in Japan including Registered Department Stores.

Categories of your Data we jointly use with joint users

•Name
•Address
•Phone number (home/mobile)
•Gender
•Date of birth
•Email address
•Any other information which you provide to us in relation to our products and services

Purpose of use

a. CHANEL Organization

Please see Section 3 of Part. I., Section 1 and Section 2 b) of Part II and Section 1 b of Part. III.

b. Registered Department Store:

Your Data may be used for the purposes set out in Section 3 of Part I, especially for purchase -related, service-related, marketing-related and preference-related purposes.

c. Dealers other than Registered Department Store:

Your Data may be used for offering CHANEL products to you upon your request (including an implied request for offering CHANEL products by such as presenting your membership card) when you visit the dealers.

Responsible entity for management of your Data

CHANEL G.K.

Representative: Guillermo Gutierrez
Address: 3-5-3, Ginza, Chuo-ku, Tokyo 104-006, Japan

iii. Provision to Foreign Third Parties

As described in Part I, Section 5, CHANEL may provide your Data to third parties located in countries with data protection legislation different from that of your country of residence. If you would like to know more about the safeguards CHANEL has put in place in accordance with Japanese Act on the Protection of Personal Information in connection with the provision of your Data to such third parties, please contact us using the contact information in section vi below.

iv. Security Control Measures for Your Data

CHANEL shall take necessary and appropriate measures to prevent leakage, loss, or damage and to otherwise manage the security of your Data. For the details of the security control measures taken by CHANEL, please contact us using the contact information in vi below.

v. Disclosure, Correction, Suspension of Use, etc. of Your Data

For disclosure (including disclosure of records of provision to third parties), correction, addition, deletion, suspension of use, elimination, suspension of provision to third parties, etc. of your data in accordance with Japanese Act on the Protection of Personal Information, please contact us using the contact information in vi below. Please note, however, that depending on the sales floor where you registered, we may ask you to contact the department store where the sales floor is located.

vi. Contact Information

If you have any questions or concerns about the handling of your Data by CHANEL, please contact us using this contact form.

i. Why do we collect and process your Data and how do we justify the processing of your Data?

•Service-related Purposes (including after-sales): Where we process your Image Data for Service-related Purposes, we will only do so where we have obtained your explicit consent.
• Regulatory-related Purposes: Where we process your Image Data and Health Data, we will only do so where we have obtained your explicit consent.
• Business Contract management: Where we process your Data for Business Contract management purposes we will rely on our legitimate interests.

ii. To whom could we disclose your Data?

In addition to the information provided in the Part I. 4. "To whom could we disclose your Data" section of the Global Privacy Policy, please note that where we disclose your data to service providers within and outside Chanel, to recruitment firms when you apply for a job through the Platforms, or to external security services (with respect to CCTV Data) we have a legitimate interest in doing so.:

iii. What are your rights?

In addition to the rights of access, rectification and erasure set out at Part 1, Section 5 of the Global Privacy Policy, you have the right to request access to your Data in a clear and readable format.

This Section is applicable to the processing of personal data of customers and job applicants by Chanel Korea YH. Terms used in this Section shall have the same meaning as those provided in CHANEL Global Privacy Policy above unless otherwise defined. “CHANEL” or “we” referred to in this Section shall mean Chanel Korea YH.

i. What Data do we collect and how?

In addition to the matters provided in Part I. 2. “What Data do we collect and how?” of the Global Privacy Policy, Data that we process, purposes of collection, and the retention period thereof are as follows:

•Customer Registration (retention period: 3 months upon membership unsubscription):

-Purpose: Asia Pacific-wide Customer registration, identification and access, FBP (Fragrance and Beauty Products) and Fashion (including Watch and Fine Jewelry) Customer Registration, verification of registration qualification such as age below 14, Comprehensive customer management, Management of transaction history, Handling of order, payment and delivery, Customer analysis (including but not limited to analysis of purchase pattern and statistical data), notification, customer satisfaction survey, Notification on services such as appointment booking, repair, wishlist, notify me, Chanel Try On, Chanel Vitality Scanner and other related services, Provision of Personalized services, Receipt and handling of after-sales service and complaints, Analysis of attempts for transaction with unlawful or unjustifiable intent, Prevention of duplicate or wrongful customer registration, Prevention of inappropriate use of services, Keeping of records for dispute resolution

-In case of Offline Service: Name; date of birth; mobile phone number; email address; location of residence; purchase history; payment details; date of registration; customer identification number; the store at which registration is done; details of customer inquiries and complaints

-In case of Online Service: Name; date of birth; mobile phone number; email address; password; location of residence; purchase history; payment details; date of registration; customer identification number; the store at which registration is done; details of customer inquiries and complaints; membership tier/segment; type of browser; type of OS; date of login; IP address; Cookies.

-If additional information is provided: Gender; address; anniversaries; home phone number; preferred method of contact; nationality; occupation; individual traits; personal style and interests; photos; videos; body measurements; items of preference; hobby, participation in various events and services; personal data contained in product reviews; and location data (retention period: 3 months upon membership unsubscription)

Customer Care Center:

-Mandatory Items: Name; mobile phone number; email address, details of customer inquiries and response thereto (retention period: 3 years after completion of inquiry)

CHANEL.com:

a. Members:

-Same as “In case of Online Service” under Customer Registration above.

-Mandatory Items: Name; date of birth; mobile phone number, email address; password; gender; purchase history; payment details; customer identification number; address; store at which registration is made; details of customer inquiry and complaints; type of browser; type of OS; date of login; IP address; Cookies (retention period: 3 months upon membership unsubscription)

-Optional Items: Name; date of birth; mobile phone number; email address; purchase history; payment details; date of registration; customer identification number; gender; address; postal code; area of residence; nationality; age group; anniversaries; home phone number; preferred method of contact; occupation; individual’s traits; style and interests; photo; body measurements; items of preference; hobby; details of customer inquiry and complaints; type of browser; type of OS; date of login; IP address; Cookies; and personal data contained in product reviews (retention period: 3 months upon membership unsubscription)

b. Non-Member Customers (retention period: Unless otherwise required by law to retain the personal information, 5 years from date of purchase):

-Mandatory Items: Name; mobile phone number; email address; purchase history; payment details; address; whether customer is 14 years or older; type of browser; type of OS; IP address; and Cookies

c. Customer Inquiries through CHANEL.com (retention period: 3 years after completion of inquiry):

-Mandatory Items: Name; mobile phone number; email address, details of customer inquiries and response

d. Notify Me: email address or mobile phone number (retention period: 30 days from notification)

e. Virtual Try On: photo (retention period: unless client saves the data, immediately deleted)

f. Skincare Explorer: Skincare routine, email address or mobile phone number (retention period: unless client saves the data, immediately deleted)

CHANEL CODE Mobile App

a. Registration

-Same as “In case of Online Service” under Customer Registration above.

b. Location-based Push Messaging (upon consent of access to location data)

-Mandatory Items: Location data (retention period: immediately deleted without storage)

BA Express (telemarketing service):

-Name, mobile phone number, voice recordings from calls, delivery address, payment details (retention period: 3 months from the contract date)

Queue Management:

-Name, mobile phone number, whether data subject is over age 14, purpose of visit, category of purpose of visit (Fashion, Watch & Fine Jewelry), email address (optional) (retention period: 2 weeks from the date of collection)

CASS (Chanel After-sales Service; repair service):

-Name, mobile phone number, e-mail address (optional), repair details, repair time and date, date and territory of purchase (retention period: 3 months upon membership un-subscription)

Chanel Vitality Scanner

-name, location of residence, date of birth, mobile phone number or email address, photo, analysis results, contents of consultation (retention period: until purpose of use is achieved)

We do not collect any personal information from or allow customer registration for those under the age of 14 to comply with the Personal Information Protection Act (the “PIPA”).

Job applicants

-Mandatory Items: Personal identification information (name, gender, date of birth, address, postal code, nationality, telephone number, email address and password), Matters concerning veterans compensation (whether the job applicant is entitled to veterans compensation, classification, veterans compensation number, relation with a person entitled to veterans compensation, competent authority for veterans compensation), Educational background (name of school, highest level of schooling, major, location (territory) of school, year of graduation), Career information (years of experience, responsible duties, employment type, name of previous company, department name, location (territory) of previous company, date of commencement of previous employment, date of retirement), Other information (mother tongue, foreign language, foreign language ability level)

-Mandatory Sensitive Data: Disability, classification of disability and degree of such disability

-Optional Items: Possible date of commencement of employment, photo and portfolio

ii. For how long do we keep your Data?

Further to the retention period defined in Part I. 6. “For how long do we keep your Data?” in the Global Privacy Policy, Chanel Korea is subject to the following retention periods.

•Customer Inquiries through chanel.com or Customer Care Center: 3 years

Regardless of the designated retention period, certain Data may still be retained if required by applicable laws. Some major periods of retention are as follows:

•Commercial books and records (e.g., accounting books and balance sheets); material documents regarding business (including any agreements)

-Legal ground: Commercial Code

-Retention period: ten (10) years

•Books, evidentiary documents, tax invoices or receipts regarding transactions

-Legal ground: Framework Act on National Taxes, Corporate Tax Act, Value-Added Tax Act

-Retention period: five (5) years

•Records on agreement or withdrawal of subscription; records on payment and supply of goods

-Legal ground: Act on the Consumer Protection in Electronic Commerce, Etc. (“E-Commerce Consumer Protection Act”)

-Retention period: five (5) years

•Records on consumer complaints or dispute resolution

-Legal ground: E-Commerce Consumer Protection Act

-Retention period: three (3) years

•Records on website visits (in the case of CHANEL online boutique)

-Legal ground: Protection of Communications Secrets Act

-Retention period: thee (3) months

In addition to the foregoing, we implement deactivation system of personal information pursuant to the Personal Information Protection Act of Korea. With respect to customers registered as CHANEL members through online channels such as CHANEL.com and Chanel Code app, customers who have not used the relevant service for at least one (1) year will be converted to dormant customers.

-Online customers may freely choose a period of service validity for either one (1) year or until withdrawal from membership; and if they do not specify their choice, the one-year period will be automatically selected.

-The period of validity is counted from the date on which online customers use the service; and if the customer does not use the service over the period selected pursuant to the preceding paragraph, Data of such customers will be stored and managed separately from that of other customers.

-At least thirty (30) days prior to converting to dormancy, CHANEL will notify applicable customers of related Data by email or other communication channels.

-Once separated and stored, Data of the dormant customers will be retained for a certain period of time pursuant to applicable laws and destroyed after such period. Data of the dormant customers which have not been destroyed will be provided again at the customers’ request when they resume using the service.

III. What are the grounds for processing your Data?

In deviation of the matters provided in Part I. 3. of Global Privacy Policy, we lawfully process Data in accordance with the Korean law, specifically the Personal Information Protection Act, by obtaining express prior consent from data subjects in relation to the processing of Data.

IV. To whom do we delegate the processing of Data?

With respect to the matters provided in Part I. 4. “To whom could we disclose your Data” of the Global Privacy Policy, the processing of Data is specifically delegated as follows:

In case of customers:

•Global Passage: Reservation of hotel and flight

•Road Logistics: Delivery of products

•Shinsegae I&C Inc.: Operation of integrated management system of shopping mall (“SELPICK”)

•Anothercompany: Customer event RSVP and response, Staffing for promoter

•UPost DM Co., Ltd.: Home delivery sampling, Mailing of brochures and leaflets

I•llyang Logis Ltd.: Delivery of products

•TARA TPS Co., Ltd.: Production of name card, DM and variable data products

•Helena flower: Production and delivery of flower gift

•DIAMOND OGILVY LLC. (Verticurl): Transmission of kakaotalk messages, SMS, MMS, eDM and DM, Registration and receipt of sampling, Design of membership gifting page design

•Radica Systems Limited: Production of variable data, Transmission of mobile coupons, Transmission of SMS/MMS and eDMs, andfhem Combination and transmission of data collected

•Goldvision: Overall operation of the events and production and installation of fixtures

•GROVE: Production and delivery of flower gift

•NICE Information Service Co., Ltd.: Authentication using mobile phone or i-pin (to be introduced as early as the second quarter of 2024)

•Naver Financial Corp.: Provision of electronic payment method (Naver Pay easy payment)

•Ramarama: Production and delivery of flower gift

•Move&Alp: Design and production of various printouts

•Mirua: Production and delivery of flower gift

•SureM Co. Ltd.: Transmission of kakaotalk messages, SMS, MMS and eDM

•e.Form Works Co.,Ltd.: Provision of electronic signature service

I•nfinisoft Co., Ltd.: Provision of BA Express payment system

•Anchors Co. Ltd.: Development and maintenance of CHANEL Korea’s system

•EMFOPLUS: Transmission of SMS

•Kakao Corp.: Purchase and payment, authentication of consumers upon financial transaction and provision of financial services, and collection of payments

•Korea Payment Networks Ltd.: Electronic payment and escrow services

•Verint Systems (Asia Pacific) Limited.: Registration of queue for store visit, Transmission of international MMS and eDM

•Aftership Limited.: Processing of customer order and delivery

In case of job applicants:

•Cisive Hongkong Limited: Research for recruitment

Meanwhile, the processing of customer Data is delegated overseas as follows:

•CHANEL SAS ((33) 1 58 37 40 00, France)

-Purpose of transfer: Storage in and management of DB; maintenance of application and DB; production of variable data; and transmission of SMS/MMS and email

-Types of information transferred: Same as the personal information collected at Customer Registration indicated under Section i. “What data do we collect and how?” above

-Period of retention: For three (3) months after deregistration