FOP Skumen (as defined in Article 1 below), operating under the Inshi.co trademark, offers high-end ready-to-wear items and accessories for sale on its website www.inshi.co, on its IOS mobile application and in its physical outlets.
In order to offer for sale, sell and deliver its products, FOP Skumen collects personal data from users of its website, its mobile application and its customers when purchasing from physical sales outlets.
The customer is informed that certain data must be collected by FOP Skumen in order to perform its services. If the customer does not wish to disclose this data, FOP Skumen will not be able to perform its services.
The controller, who collects the personal data and implements the data processing operations, is:
FOP Skumen, a simplified joint stock company.
Collection of personal data
FOP Skumen collects users’ personal data on the website www.inshi.co, on the IOS mobile application and from purchases made in Inshi.co outlets.
The personal data that may be collected are as follows :
– user account data: the data provided by the User when creating an account by filling in the registration form (name, surname, billing and delivery postal addresses, email address, mobile phone number, password for connecting to the customer account);
– personal data of the user when he/she enters it in his/her customer account: date of birth, clothing and shoe size;
– transaction data: means the data that the user provides when making purchases, information relating to orders placed and returned items such as telephone number, address, e-mail address and information relating to payment method;
– exchanges with customer service;
– browsing data: refers to the data collected by the Publisher while the User is browsing the Website and the Applications, such as the date, time of connection and/or browsing, browser type, browser language, IP address, location data and geolocation.
The data relating to the payment method (credit card number, expiry date, authorization number, security code) are collected directly by our service providers Adyen and Paypal.
Third-party providers of applications, tools, gadgets and plug-ins on our website and mobile application, as well as the networks on which we publish editorial and promotional content (such as Facebook and Instagram) may also use automated, context-based and interest related means to collect user data (interactions with functions and profiling of the online activity). This data is collected directly by such providers and/or third parties and is subject to their policies. To the extent permitted by applicable law, FOP Skumen is not responsible for the practices of such service providers and third parties.
Purposes of the collection of personal data
Data collected in connection with the use of the website, the application or in physical outlets are processed for the purposes described in the table below.
The regulations in force protect the privacy of users and require any controller to be able to provide legitimate grounds for such processing. The regulations thus provide, among the legal bases for treatment, the following:
– performance of an agreement to which the relevant person is a party, such as a sales contract. For example, certain personal data of the customer is necessary to deliver the item, manage the customer’s account and process any returned items;
– compliance with a legal obligation, in particular an accounting obligation by retaining invoices;
– prior consent of the relevant person;
– legitimate interest of the controller, while complying with users’ rights and freedoms. For example, improving the customer experience or preventing fraud may justify data collection.
|Purposes of the processing||Use of data||Legal bases for treatment|
|Management of orders and sales of products and provision of services; management of customer complaints, withdrawals and product returns||Use of data to provide products and services (from shopping cart and orders; sale, return and refund of purchased products)||Fulfilment of the agreement by and between the client and the seller|
|Carrying out transactions, in particular payment transactions||Our payment providers (Adyen and Paypal) use the information relating to the payment methods when performing the payment for each order. This data can also be used for the prevention of fraud upon payment of the order and/or management of any unpaid amounts after the order has been placed.||Fulfilment of the agreement by and between the client and the seller|
|Customer account creation and management||The personal data of a customer registered on the website is used (e-mail address, password)||– Fulfilment of the agreement by and between the client and the seller
– Compliance to legal obligations
|Delivery of ordered products||Personal data (contact details, email address) is used to ensure deliveries.||Fulfilment of the agreement by and between the client and the seller|
|Operating the website and fighting against fraud||Personal data (cookies) is used to update, enhance our Website and fight against Internet fraud||– Fulfilment of the agreement by and between the client and the seller
– Compliance to legal obligations
|After-sales support: exchanges with customer service||Personal data is used to interact with customers. As such, the exchanges between customer service and the customer carried out by telephone or chat can be recorded in order to improve the quality of service. Customers may refuse this at any time||Fulfilment of the agreement by and between the client and the seller|
|Taking part in special events (such as contests, games, random draws, offers) and participating in the loyalty scheme, with the exception of online gambling||Personal data, including purchasing information, is used to manage participation in various special events, as well as the loyalty program||– Fulfilment of the agreement by and between the client and the seller
– Legitimate interest of the controller in order to propose products and services adapted to the needs of clients
|Operating, assessing and improving products and services as well as user experience (including developing new products and services, analyzing the customer base; performing data analysis, accounting and auditing), profiling.||Personal data is used to assess and improve products and services, and to improve customer experience, the products and services offered by FOP Skumen, through statistical operations and analysis of anonymous customer behavior, and the measurement of website and mobile application traffic||Legitimate interest of the controller in order to propose products and services adapted to the needs of clients|
|Sending newsletters and special offers subject to the user checking the relevant box indicating his/her acceptance, when registering for the Services||Personal data is used to inform customers about our products and services and to customize the products offered on social networks.||Legitimate interest of the controller in order to propose products and services adapted to the needs of clients and consent (opt-in)|
|Analyzing website traffic and frequency, audience metrics, research, statistics, surveys (cookies)||Personal data, including cookies, is collected to understand how the Website and the mobile application are used.||Legitimate interest of the controller in order to propose products and services adapted to the needs of clients and consent (opt-in)|
FOP Skumen does not share any personal data for commercial purposes with third parties.
Users may edit their personal data and withdraw their consent at any time by connecting to their customer account.
Providers can access to users’ personal data
The personal data collected is transmitted to FOP Skumen’s service providers, who may process it on behalf of FOP Skumen (processors) and/or on their own behalf (recipients of the data).
The recipients of the data are :
– Adyen and Paypal, payment providers
– any police or administrative authority in connection with judicial requisitions concerning the fight against fraud
– customs authorities and service providers in the event of delivery abroad.
FOP Skumen’s processors may have access to data collected for the purpose of:
– preparing, shipping orders and returning products
– improving the content of websites and mobile applications
– technical maintenance and development of FOP Skumen’s website, mobile application and internal applications, including entities that perform orders and provide web hosting, information storage, email service providers, as well as analysis services, and tag management, such as Google Analytics. For further details on these analysis services and the opposition procedures, we invite you to refer to the following sites https://support.google.com/analytics/answer/6004245
FOP Skumen may also share the personal data of customers who have a customer account in its physical outlets. Their access is limited to orders placed by the customer.
Users’ rights over their personal data
In accordance with Articles 14 to 22 of Regulation 2016/679 of April 27, 2016, any natural person using the Inshi.co website or the mobile application has the right to exercise the following rights:
– a right of access, rectification and erasure of the data collected,
– a right to object to the processing of their data
– a right to the restriction of the processing,
– a right to the portability of the data collectedthe option to formulate instructions relating to the retention, erasure and transmission of his/her personal data after his/her death in accordance with Article 40-1 of Law 78-17 of January 6, 1978
Lastly, if FOP Skumen detects a violation of personal data likely to create a significant risk to the rights and freedoms of its users, it undertakes to inform the relevant users in the shortest possible time.
Users may exercise all these rights by connecting to their customer account, by contacting customer service at email@example.com.
Users must enclose proof of identity with their application.
Transfer of personal data outside of the European Union
The personal data of FOP Skumen customers may be transferred to FOP Skumen Inc. a wholly owned U.S. subsidiary of FOP Skumen, so that such customers may benefit from the same experience in the Inshi.co boutique located in New York. This transfer takes place within the scope of the standard contractual clauses of the European Commission.
Data retention period
User data will not be retained beyond the period strictly necessary for the purposes set out herein and in accordance with applicable regulations and laws. In this respect, the data used for canvassing purposes may be retained for a maximum period of 3 years from the termination of the user’s account or the last contact with the relevant prospect. User data is deleted upon expiry of storage periods. Nevertheless, the data may be archived beyond the specified periods for the purposes of investigating, establishing and prosecuting criminal offences for the sole purpose of making the data available to the judicial authority, where necessary.
Archiving implies that this data will be anonymised and will no longer be available online but will be extracted and stored on an autonomous and secure medium.
Security measures for the personal data collected
In its capacity as data controller, FOP Skumen undertakes to take all necessary measures to preserve the security and confidentiality of the data and, in particular, to prevent it from being altered, distorted or accessed by unauthorised third parties.
FOP Skumen has entered into service agreements with business partners who have extensive expertise in the field of data protection.
All data is hosted in Ukraine or in the European Union.
Payment service providers
The payment of the purchases on the website and on the mobile application is carried out either via Paypal, or via the secure platform of our payment provider ADYEN.
Paypal (Europe) S.à.r.l. et Cie is a Luxembourg limited partnership with shares, registered in the Luxembourg Register of Companies under number B118349, having its registered office at 22-24, Boulevard Royal – L-2449 Luxembourg. For further information, Customers may refer to the following website: https://www.paypal.com.
Adyen B.V. is a company registered in Amsterdam (Netherlands) under number 34259528, with registered office at Simon Carmiggeltstraat 6-50, 1011 DJ in Amsterdam, Netherlands. For further information, Customers may refer to the following website: https://www.adyen.com
FOP Skumen does not have access to customer payment data.
However, users may opt to save their payment card data in their customer account. This data is not stored with FOP Skumen, but with Adyen and/or Paypal. Users may edit or delete these bank details at any time by connecting to their customer account.
Cookies, TAGS and trackers
When browsing our website and the mobile application, information relating to the navigation of the user’s terminal (computer, tablet, smartphone, etc.) may be saved through files referred to as “Cookies”.
A cookie allows tracking the browsing or analysing user behavior, including:
– measuring the number of visitors to our website and application, as well as their content;
– saving customer account information when the user is logged in;
– saving the shopping cart for 30 minutes; customising the display of content accessible to the user.
The user can modify his preferences in terms of cookies, through the navigation software used:
– Internet Explorer : http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies ,
Users may also refuse to accept cookies on the follwing website: http://www.youronlinechoices.com/fr/controler-ses-cookies/.
FOP Skumen’s official Facebook and Instagram accounts can allow users to post their content. Users are informed that the content published on these social networks may be viewed by any third party, and that greater vigilance is required from users when they provide certain personal data on these sites or applications such as financial data, addresses or any sensitive data. FOP Skumen is in no case liable for any damage caused by third parties as a result of or resulting from the publication of their personal data by users.
Links to third-party sites
The website and the application may provide links to websites, applications and services other than those of FOP Skumen, which may be operated by third parties.
FOP Skumen is not responsible for the processing of personal data by these third party websites. Users should consult the relevant personal data protection policies.
Data protection officer or personal data manager
FOP Skumen’s data protection officer or personal data manager ensures compliance with the regulations and rules in force, and must in particular establish records of processing activities involving personal data.
Users may contact FOP Skumen’s data protection officer or personal data manager at firstname.lastname@example.org.