Last update : July 16, 2019
1. General statement
We take your privacy very seriously and are committed to protecting it. We believe that you should be able to easily know what personal data we collect and use, and understand your rights in relation to it.
2. Who are we? Who are we?
LUGO is a simplified joint stock company with a capital of 4,500 euros, whose registered office is 128, rue de la Boétie, 75008 Paris, France, registered in the Paris Trade and Companies Register under number 851 424 200.
3. What personal data do we collect and how are they collected?
Personal data are information relating to an identified or identifiable natural person. They include, for example, a person's name, address and gender.
We may collect personal data directly from you (for example when you purchase a product in a store) or indirectly (for example from your electronic devices that interact with our websites, electronic forms or mobile applications (the "Digital Platforms")).
3.1 Data that you provide directly to us
You can provide us with data:
- when you subscribe to our newsletter;
- when you use our Digital Platforms;
- when you purchase products or services on our Digital Platforms;
- when you participate in one of our events.
Depending on what you provide us, this information may include:
- your identity (including your first name, last name, gender, image);
- your contact details (including postal address, e-mail, telephone numbers);
- your personal status (including title of civility);
- your purchases and repairs (including purchase history, order details);
- your preferences (including your size);
- certain payment data (including billing data, type or means of payment, credit or debit card number);
- other information that you may provide by completing forms or contacting us (including your comments or other communications with us).
We will inform you when your information is necessary to process your request, to respond to your requests or to provide you with our products and services. Failure to provide this information may delay or make it impossible to process your request, answer your questions and provide the products or services.
We strive to ensure that the personal data we hold is accurate at all times. We therefore encourage you to update your data in case changes occur. We may also ask you to update your data from time to time.
We recommend that you provide only the data requested or necessary for your request, with the exception of sensitive data relating to race, ethnic origin, political opinions, religious or philosophical beliefs, and data concerning health, sex life or sexual orientation.
We remind you that we do not provide our services or products directly to persons under 18 years of age and that we do not collect personal data from them. We therefore ask you not to provide us with personal data of persons under 18 years of age.
3.2 Indirectly Collected Data
We may collect data when you use our Digital Platforms, including your IP address or other browser data (including browser, operating system, device model), through cookies or similar technologies placed on your device. Some cookies are necessary for the proper functioning of our Digital Platforms and others are used for analysis purposes that help us provide you with more personalized services and a better digital experience. For more information about cookies and how to change your preferences, please read our Cookie Management Policy.
We may also collect data about you from third parties, including a spouse who contacts us on your behalf or your friends who provide us with your contact information to invite you to events that may be of interest to you.
4. Why do we collect your personal data and how do we use it?
We collect and use your personal data on the basis of one or more of the following legal bases:
- we have obtained your prior consent (for example when you subscribe to our newsletter). Please note that with this particular legal basis, you have the right to revoke your consent at any time (see below "What are your rights to your personal data? ») ;
- the processing is necessary within the framework of a contract between LUGO and you (for example when you make a purchase);
- we have a legitimate interest in carrying out the processing and this legitimate interest is not overshadowed by your interests, fundamental rights or freedoms (e. g. prevention of fraud in means of payment);
- we must process your personal data in order to comply with the laws and regulations in force.
Depending on the context, we may use your personal data to:
- provide you with the products or services you have requested;
- perform verifications to identify you and verify your identity;
- send you marketing communications, with your prior consent (see section "Marketing Communications");
- provide you with after-sales service;
- answer your questions, requests and suggestions;
- manage the events you have registered for and/or attended;
- detect any fraudulent or illegal activity, including to secure your transactions by detecting and preventing fraud against yourself and LUGO;
- protect yourself, employees and others in our stores and our property;
- manage the stock of certain types of rare products in order to allow a fair distribution of the products we sell;
- monitor and improve our Digital Platforms;
- carry out statistical analyses;
- improve our products and services;
- provide information to regulatory authorities when required by law.
5. Marketing communications (newsletter, invitations, etc.)
With your express prior consent (usually obtained by checking a specific box in a form), you may receive information about offers, services, products or events sent by LUGO.
We rely on your consent to process the personal data you provide to us for this purpose. Therefore, if you no longer wish to receive such information, you may withdraw your consent at any time (see below "What are your rights to your personal data? »).
We may ask you to confirm or update your marketing preferences if you ask us to provide other products and/or services in the future, or if there are changes in the law, regulations or structure of our business.
6. How long do we keep your personal data?
Your personal data are processed for the period necessary for the purposes for which they were collected, to comply with legal and regulatory obligations and for the duration of any period necessary for the establishment, exercise or defence of legal rights.
In order to determine the most appropriate storage periods for your personal data, we have specifically taken into account the quantity, nature and sensitivity of your personal data, the reasons for which we have collected your personal data, the service you deserve and expect from us and the applicable legal requirements. For example:
- With regard to our prospects (potential customers): your data is kept for three years from your last action, then deleted or archived in order to comply with legal retention obligations;
- With regard to our customers: your data is stored for the duration of our business relationship and up to ten years, then deleted or archived in order to comply with legal retention obligations;
- With regard to cookies used on Digital Platforms: they are stored for up to 13 months from the time they are installed on your device.
7. How do we disclose and transfer your personal data?
We may only disclose your personal data to the parties named below and for the following reasons:
- We disclose your personal data to LUGO employees who need access to your personal data and who are authorised to process them for the purposes mentioned above and who undertake to respect their confidentiality.
As part of the fight against payment fraud, your personal data is communicated to LUGO in order to process your order and to fight against fraud attempts using online payment methods. As part of our legitimate interest in the fight against payment fraud, LUGO, as the data controller, can transmit your financial data to an external service provider with a fraud detection tool to authenticate a payment. The said service provider is bound by an obligation of confidentiality.
- We may also disclose personal data to third parties acting on behalf of LUGO. All these processing operations are based on our prior instructions set out in a binding contract that complies with the requirements of applicable law. Such disclosures are made for different reasons, including:
IT development and support
Hosting and conducting marketing and economic studies and marketing campaigns
Verifying your information, authenticating payments and processing orders and payments to third parties who provide credit reports, payment or order fulfillment services;
These service providers undertake to respect confidentiality and are not authorised to use your personal data for any other purpose. We also require them to apply appropriate security measures to protect your personal data.
- We may be required by mandatory provisions of applicable law or in connection with legal proceedings or other legal requests, to disclose your personal data to authorities or third parties.
- We may also disclose or process your personal data in accordance with applicable law to defend our legitimate interests (for example in civil or criminal proceedings). For example, we may disclose such personal data if necessary to identify, contact or take legal action against a natural or legal person who does not comply with our General Terms and Conditions of Sale and Use, or who disrupts or causes harm to other users of our Digital Platforms.
- In the event of an acquisition by LUGO, or of all or part of their assets, your personal data may be included in the transferred assets.
8. How do we protect your personal data?
All your personal data is strictly confidential and will only be accessible if necessary, only by LUGO staff duly authorised and independent contractors acting on our behalf as part of appropriate technical and organisational security measures.
LUGO has implemented security measures to protect your personal data.
9. What are your rights to your personal data?
In accordance with applicable data protection law, you may at any time request access, rectification, erasure and portability of your personal data, or restrict or object to their processing. A summary of these rights is set out below :
Your right of access: the right to receive a copy of your personal data.
Your right of rectification: the right to ask us to correct any errors in your data or to complete them.
Your right to be forgotten: the right to ask us to delete your personal data in certain situations.
Your right to limit processing: the right to ask us to limit the processing of your personal data, in certain circumstances, for example if you dispute the accuracy of the data.
Your right to data portability : the right to receive the personal data you have provided us with, in a structured, commonly used and machine-readable format and/or to transmit such data to a third party, in certain situations.
Your right to object to the processing: the right to object :
- at any time during the processing of your personal data for direct marketing purposes;
- in certain other situations, to the further processing of your personal data, for example the processing carried out on the basis of our legitimate interests.
You may at any time decide to withdraw your consent to the processing of your personal data. If your consent is withdrawn, this does not prevent us from processing your personal data on other legal grounds, if any, such as the execution of your orders and the storage of your order data in accordance with applicable law.
If you no longer wish to receive our advertising or promotional information, we remind you that you can revoke your consent to direct marketing at any time directly from the unsubscribe link included in each advertising e-mail message we send you. If you do, we will promptly update our databases and take all reasonable steps to respond to your request as soon as possible, but we may continue to contact you to the extent necessary in connection with any product or service you have requested.
You also have the right to file a complaint with your local data protection authority in the event of a suspected violation of the data protection rules applicable to you.
To exercise any of these rights, please contact us.
Please note that if you exercise any of the rights mentioned above, you will be asked to let us know which right you wish to exercise and to provide us with certain information (copy of an identity card, passport or other legally recognized identity document) for identification purposes to process your request and protect you against fraudulent requests from third parties.
10. How to contact us?
For any questions regarding your account, to revoke your consent, to ask general questions or to make a complaint, please contact our customer service department:
- By e-mail: firstname.lastname@example.org
- By phone: +33 (0)6 58 37 37 45 93
- By mail: LUGO, 128, rue de la Boétie, 75008 Paris
For questions specifically related to advertising emails, we remind you that you can unsubscribe directly at any time via the "unsubscribe" link in all advertising emails we have sent you.
What is a cookie?
You can change your preferences at any time by going to the "Manage your cookie preferences" section.
What cookies do we use?
Two types of cookies are present on our site:
- Cookies strictly necessary for the operation of the site
These cookies allow you to use the main features of the Lugoparis.com website such as storing your selection of products in your shopping cart. These cookies facilitate navigation and are necessary to make online purchases.
- Third-party cookies
These include statistical analysis cookies that collect information about how you navigate our site, allowing us to improve your user experience and tailor services to your preferences. There are also advertising cookies which aim to personalize and/or improve content and navigation by offering you services that may be of interest to you on other websites. All information collected is anonymous.
The cookies we use on our website are as follows:
Manage your cookie preferences
You can easily disable and/or delete cookies from your computer, tablet or mobile phone by managing your browser settings.
We recommend that you do not disable cookies that are strictly necessary for the operation of the site (cookie marked "mandatory" in the table "What cookies do we use?") as this would prevent you from ordering online and benefiting from the services of the Lugoparis.com site.
In order to manage cookies as close as possible to your expectations, we invite you to configure your browser to take into account the purpose of cookies.
Below are instructions on how to manage and disable cookies, depending on the browser:
Click on the Tools button, then on Internet Options.
Click on Privacy, click on Advanced.
In the Cookies window, select your preferences.
Click on the Menu button, then Settings.
Click on the Show Advanced Settings link.
In the Privacy section, click on the Content Settings button.
Then in the Cookies section, select your preferences.
Click on the Menu button, then select Options / Preferences.
In the History field, for the Retention Rules option, select use the custom settings for the history.
Check or uncheck the Accept cookies box, then select your preferences.
Click on the Safari menu, then on Preferences.
Click on the Security tab.
In the Block cookies section, select your preferences.