PRAIVACY STATEMENT

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Confidentiality and security of your personal data are important to us. We would like to offer you personalized services while respecting your privacy and choices.

The purpose of this Statement is to inform you in a transparent and simple manner about the processing of the personal data that you provide or that we collect through the different touchpoints you use to interact with us, about possible transfers to third parties, as well as your rights and options to control your personal data and protect your privacy.

WHAT DATA MAY WE COLLECT OR RECEIVE ABOUT YOU?
"Personal data" means any information that could reasonably identify you either directly (e.g. your name) or indirectly (e.g. through a unique client ID number).

The personal data we collect depends upon the touchpoint of our interaction and is also limited to that which is relevant and appropriate for the interaction.  Unless you choose to interact with us via other touchpoints, such as (but not limited to) by making a purchase on our site, signing up for one of our programs or services, using our apps, communicating with us via email, phone or submitting online forms, or posting a comment or a like online, our data collection is limited to the use of ‘cookies’ for website visitors.

For customers and other individuals who sign up for programs or services or otherwise interact with us beyond browsing our site via the touchpoints described above, for example, we collect certain relevant information from you.  The information we collect is related to the particular transaction as well as our overall relationship with you.  For example, if you make purchases from fashion-blocnaion.com or in our stores, we must collect information to process (and, if relevant, fulfill and ship) your order. For customers and other individuals who sign up for our programs or services, we generally collect your contact details, contact preferences, and information that will allow us to make recommendations to you about our products or services that may be of interest.  We may centralize the information pertaining to our customers so that we have it organized in one place, as this helps us manage our relationship with you as well as your choices and preferences. Or, if you subscribe to our personalised newsletter, we collect your email address.

Depending on your interactions with us, personal data we receive may include information related to:

Your identity and your contact details (e.g., name, address, email address, date of birth);
Your interests and your preferences (as you may provide in creating your profile);
Your purchases (in store or online, including your orders, their tracking information, your purchase invoices, the amount and type of your purchase) and any returns or exchanges;
Your in store or online digital experiences
Your use of our online assets, including when you visit and interact with them, what pages you accessed, and your interaction with our features. We also receive information to help detect and prevent consumer fraud, including but not limited to browser and keyboard language settings, whether data is automatically filled or manually entered, whether data is manually entered or copy and pasted, and proxy detection (fashion-blocnaion.com, social media pages, partner websites (e.g. for events) and databases (e.g. for data storage and maintenance));
Your blocnation account log-in information;
Your financial information to process your orders (such as bank details);
Your requests through our client services or our public relations department;
Your publications and mentions of our products on social networks;
The blocnation events you attend; or
Any self-reported undesirable side-effects concerning any of our products.

We Collect and Use Limited Sensitive Information.

As described above, we collect personal data that is described under some laws as sensitive personal data,” special categories of personal data, sensitive personal information, or similar terms (collectively referred to here as “Sensitive Personal Data”).  Here, we provide more information about which categories of the personal data described above may be designated as Sensitive Personal Data, and how we use these categories of Sensitive Personal Data.  We only use Sensitive Personal Data to provide you goods and services, and do not use such information to infer characteristics about you. Depending on what you choose to provide and how we interact with you, we may collect:

Account log-ins to provide blocnation products and services. Account login information is used to identify an active user on any site that requires login. Login information includes first and last name and corresponding email for such account, as well as the associated account password.
Financial information to process your orders.  We collect and use credit or debit card information and required security or access codes in order to process payments and fulfill any order you make.
Passport-related information to process your orders.  We may collect passport or other government-issued ID information in connection with an order, including when you are purchasing a product in a country other than that in which you live, in order for you to make purchases free of value added tax (VAT).

HOW DO WE COLLECT OR RECEIVE YOUR DATA?
We may collect or receive data via the following touchpoints:

Use of blocnation.online;
In-store, including in communication with our salesperson;
blocnation events you attend;
Public Relations relationship and communication;
Contact with the Client Services;
Forms you complete (in store or online);
During your purchase journey, you will be able to choose between i) logging into your existing blocnation account, ii) creating a new account, or iii) paying as a Guest;
Digital apps you use;
Digital experiences in store (if you choose to use that technology where offered via a retailer), or our third-party vendors may receive data via virtual try-on online;
Loyalty or rewards program you benefit from;
blocnation social media pages you visit or interact with, or other social media pages on which you post blocnation content or comments;
Digital media advertising you click on;
Search engines’ paid advertising you click on;
Surveys or satisfaction questionnaires you answer.

FOR WHAT PURPOSES ARE YOUR DATA USED BY blocnation?
Depending on the context in which your data is collected, we use your data for:

the provision of blocnation products and services, including the management of your orders, the management of personalized content, communications and interactions with blocnation (digital or otherwise), and providing customer support;
the facilitation of showing you what your selected product would look like on you (in relation to using our virtual beauty and try-on technology, though when online, all processing for providing the feature is done by our third-party vendors’ proprietary technology), and for certain in-store virtual try-ons, offering you the option of receiving your photo via email;
the management of your account and profile (for example, in order to simplify your navigation through our different country-specific websites, if you navigate to another country your customer account will automatically be duplicated in that market. This means that it will not be necessary to create a new customer account);
the management of your loyalty or rewards program;
the management of your requests linked with blocnation;
the management of events which you register for or attend;
the management of our website and our digital apps;
the management and improvement of our products and services, image and reputation;
the management of payments (online transaction security, fraud prevention, legal and compliance related purposes, payment incidents and debt collection);
promoting our Maison on social networks;
marketing purposes. For example, we may use your data to contact you about new products and special offers we think you’ll find valuable based on your interests, or to subscribe you to a generic newsletter at your request (you have the right to opt-out if you no longer wish to receive it). We and our partners may engage in interest-based advertising using your data gathered across multiple websites, devices, or other platforms;
security and legal purposes to protect our company, our customers, our associates, and our platform. For instance, we and/or our service providers use your data to prevent and protect against consumer fraud and violations of the Terms of Purchase; and
analysis purposes:

> analyse the performance of our blocnation on social networks in order to produce statistical analyses (studies of results by country, influence of the blocnation and analysis of the campaigns implemented).

> analyse your preferences and habits, anticipate your needs from your consumer profile and your publications/mentions on social networks.

> personalised customer experience: we may provide you with personalised communications by means of email, postal mail, SMS or calls based on the communication preferences you have indicated and your consumer profile (where permitted) With your free, specific, informed and unambiguous consent (where required), we use your personal data to send you personalised communications based on your interests (newsletters, offers, invitations and surveys).

In the latter two interactions (“analysing your preferences and habits” & “providing you with a personalised customer experience”), when we send personalised communications or content, we may use so-called profiling techniques. For the sake of transparency within this Statement, profiling is currently defined as any kind of automated processing of personal data which consists of using that personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict elements relating to the preferences, interests, behaviour or location of that natural person.

The legal basis for the processing of your data can be, depending in which context your data is collected:

Your consent (e.g. to manage our tailored services, managing your browsing via cookies);
The performance of a contract (e.g. managing your access to your customer account, processing and tracking your orders, your subscription to our loyalty program
A legal obligation when processing is required by law (e.g. retention of purchase invoices, blocnation products); or
Our legitimate interest: improve our products and services, prevent fraud, secure our tools or tailor our communications.

FOR HOW LONG MAY WE KEEP IT?
Unless otherwise stated, we only keep your personal data for as long as we need it to fulfill the purpose of collection, to meet your needs, or to comply with our legal or business obligations, and to fulfill the purposes described above in this Privacy Statement.

When we no longer need to use your personal data, it is removed from our systems and records or anonymized so that you can no longer be identified from it.

We use the following criteria to determine how long to retain personal data:

Our relationship with you, and the products and services we provide to you;
Your requests to us regarding your information, or our products or services;
Any legal obligations to retain the data, or for our own legal purposes (such as enforcing our agreements or litigation);
Recommendations and legal requirements, including applicable international, national, federal and state statutes; and
Technical considerations and feasibility, and level of protections in place for your personal data.

WHO MAY ACCESS YOUR DATA?
We ensure that only duly authorized persons can access your personal data when necessary for the above-mentioned purposes.

We communicate your information, including if possible in a form that does not allow a direct identification, to:

Other blocnation entities, acting as processors according to our instructions and solely on our behalf, to provide you with the same personalized service worldwide.

Our trusted third-party service providers, including third parties in charge of managing our communications and alerts, third parties who assist us in the organization of our events, third parties providing IT services, digital communication and public relations agencies, third parties who assist us with customer care and logistics services, third parties who assist us with providing our apps, and our third parties who assist us in the management of your orders. In particular, we entrust certain services to third parties in charge of delivering you a product, payment service providers and providers securing transactions against fraud.

Third-party partners, who provide advertising, marketing, website performance, analytics, and similar services for blocnation, including  cookies or other trackers, including for the purposes of behavior-based targeted advertising. 

Please note that these third-party partners may act as data controllers; in such cases, they have their own privacy policies. These third parties include:

Third parties in the event of a change of control, for legal reasons, or with your prior consent
Third parties wishing to know your main interests to constitute similar audiences and target prospects that match your profile. In the context of this specific data processing, blocnation is not the Data Controller relating to prospecting and you will not be subject to prospecting, your data is only used to constitute profiles similar to yours

 We illustrate some examples below:
- Facebook (Privacy policy accessible here)
- Google (Privacy policy here)
- Instagram (Privacy policy accessible here)

Third parties conducting statistics on our performance on social networks on our behalf
Third parties such as IAS (International Accreditation Service), which assists us, for example, in finding out the exposure rate of our created formats. For more information, their privacy policy is available here.

We do not share or sell your data to third parties for separate commercial purposes. However, the meaning of “sale” and “share” under the California Privacy Rights Act (CPRA) is broad and may include sharing information with third parties through cookies and other trackers that we use for performance purposes, targeted advertisements, and social media purposes, as described above. Information disclosed to such third parties includes basic identification information, device information and other unique identifiers, internet activity, and commercial data. blocnation uses cookies, including third-party cookies, and other trackers, for strictly necessary purposes that allow our website to function, for performance reasons that allow us to measure and improve the performance of our website, for functional reasons such as to provide you with enhanced functionality and personalization, for targeted advertisements such as to provide you with marketing aligned with your previous choices and behavior, and for social media purposes that allow you to share our content with your friends and networks.

You have the right to accept or reject all cookies except strictly necessary cookies (this option will opt you out of all “sales” and “sharing” as defined by CPRA for cross-context behavioral or targeted advertising). To opt-out of all or selected cookies, please visit the Your Privacy Choices / Cookies.

You may also choose to separately disclose your personal data to certain partners, advertisers or affiliates by following a link to and from their websites. Please note that these websites have their own privacy policies which apply to the personal data that you may choose to entrust to them.

HOW DO WE PROTECT IT AND KEEP IT CONFIDENTIAL?
We have adopted reasonable and appropriate physical, technical and organizational security safeguards to protect your data from loss, misuse, alteration, destruction or access by unauthorized third parties. The Internet, wireless networks and information storage are not 100% secure. We cannot guarantee the security of your personal data stored or sent to us. We encourage you to take precautions to protect your personal data. For example, in creating your account on blocnation.online, entering a personal password complying with our security requirements is compulsory and part of this Privacy Statement.

The security safeguards that we have adopted are commensurate with the sensitivity of the particular data collected.  For example, credit, debit and other payment information is subject to stricter security measures.

We also require our partners and group companies to uphold a substantially similar level of protection for your data. The measures are evaluated and updated to address new threats and challenges, as well as new legal requirements in the countries where we operate. 

To the maximum extent allowed by applicable law, you agree and acknowledge that blocnation will not be liable or responsible for use or disclosure of your information that is the result of unauthorized or illegal access to our systems or those of our vendors, agents, contractors, affiliates, or partners.

HOW ARE CONSUMER PREFERENCES AND INDIVIDUAL RIGHTS ADDRESSED?
In accordance with applicable laws and requirements, blocnation companies have put in place measures to fulfill the rights of individuals in relation to the personal data that we (or our third parties) hold about them.  This includes, for example, the right to know about the data we hold about you or to obtain a copy, and the limited rights to amend your data, request erasure, or object to the processing of your data.  We encourage individuals who have entrusted their data to us to keep it current (such as if you change your email address, address or phone number), so that we have your correct information on file.  We also encourage consumers to update their preferences with us, such as in relation to products and the frequency of communications, so that we can personalize our service to your expectations and needs.  Finally, we offer individuals the right to withdraw consent from our programs and offerings at any time.

Updates to this Statement
blocnation reserves the right to change this Statement at any time at its sole discretion and will post the date it was last updated at the top of this Statement. Such changes shall be effective immediately upon posting them to blocnation’s website, or otherwise providing them to you. We will provide additional notice to you if we make any changes that materially affect your privacy rights.

Updated:  January 2023.