Personal Data Protection Policy

The purpose of the Personal Data Protection Policy is to inform you that your personal data is processed when you browse the Site published by Refashion. We hereby inform you of the nature of the personal information that is collected, how we use it, with whom we share it, how we strive to protect it, how you can access and/or correct your information and lastly, how you can contact us if you have any questions.  

The purpose of this document is to also communicate all information made mandatory by Article 32 of the French Data Protection Act and by Article 13 of EU Regulation EU 2016/679 of the European Parliament and Council of 27 April 2016 on the protection of individuals in regards to the processing of personal information and the free circulation of this information (“RGPD”). 

Lastly, attention is drawn to the fact that we may need to modify this document in particular to ensure that it meets new regulations or to adapt it to our practices.  

 

Article 1 – Processing Manager

Information collected via the different Personal Data collection forms on the Site are processed by Refashion in its capacity as Processing Manager.

 

Article 2 – Personal Data Collection by Refashion

Personal Data designates any and all information related to an identified or identifiable individual, i.e. a person who can be directly or indirectly identified.

Refashion collects and processes the Users’ personal data via forms created for this purpose on the Site.

The personal data collected by Refashion is as follows: first name, surname, email address and job title and function. 

By browsing on the Site, Refashion is also likely to collect login data (IP address, logins, login name, terminal identifiers, login identifiers, information, on date and time, etc.) and internet data (Cookies, trackers, browsing data, audience measurements, etc.)

It is compulsory to complete non-optional fields. If these have not been completed requests cannot be processed by Refashion.  

 

Article 3 – Purpose(s) of Personal Data processing and legal bases

Refashion is an eco-organisation approved by the State and whose main mission of general interest is to provide information and assist stakeholders in the CHF industry on the most environment-friendly production methods. It’s mission is to encourage the collection and recovery of clothing, household linen and footwear waste.  

As an eco-organisation approved by the public authorities, Refashion is obliged to report back to public authorities on the performance of initiatives undertaken, in particular in terms of information provided and awareness-raising measures.  

To measure the effectiveness of its initiatives and the communication of its Site’s contents, Refashion is obliged to gather User Personal Data and analyse the browsing behaviour and choices. Given its mission of general public interest, Refashion thereby has a legitimate interest in collecting personal data for these purposes. 
 

Personal Data may be used by Refashion to: 

  • Create Personal Accounts for Users and allow users to have access to the Site’s contents. The legal basis for processing this information is legitimate interest.

  • Send newsletters by email with the legal basis of this processing being legitimate interest and the right to refuse.

  • Send surveys/requests by email with the legal basis of this processing being legitimate interest and the right to refuse.

  • Analyse browsing and choices by the User on the Site in order to perform profiling for content customisation purposes: the legal basis of this processing being consent.

  • Compile statistics: the legal basis being legitimate interest.

  • Process all User questions/claims the legal basis being legitimate interest. 

  • Manage an individual’s right to exercise his/her rights (access to information, correction, deletion and portability of information): Personal Data processing is mandatory by law

  • Justify in the event of a dispute, that legal and regulatory obligations have been met: Personal Data processing is made obligatory by law.

 

Article 4 – Communications sent by Refashion

4.1 Communication categories sent by the User 

Users are likely to receive the following types of communications:  

  • Emails 

Following registration on the Site you will receive a confirmation email. The receipt of this information is not linked to the choices that you expressed in relation to newsletters.

  • Refashion Newsletters 

Following your registration on the Site, if you did not refuse receiving these, you may receive Refashion newsletters by email. In particular, these communications enable you to be kept updated with the latest news from Refashion and the latest, environmentally-friendly production new methods. You can refuse to receive emails and newsletters at any time. 

  • Surveys/requests for opinions 

We may also contact you via email for your opinion using questionnaires. You may also refuse these surveys or requests for opinions directly in the email that is sent or by informing us.

 

4.2 How to exercise your choices?  

At any time you can refuse that your personal data be used as described hereafter:  

  • When you register on the Site using a tick box; 

  • By directly contacting Refashion by email, telephone or by post;

  • By clicking on the link that appears in each email sent to unsubscribe yourself from the newsletter/notifications.

  

Article 5 - The recipients or categories of recipients receiving Personal Data

Your Personal Data is intended for Refashion.

It may also be communicated to subcontractors with whom Refashion works in order to carry out services for the above-mentioned purposes. Refashion ensures that its subcontractors comply to data protection requirements. 

Refashion may also provide your personal data when it is required to:

  • comply with law (or a subpoena or court order);

  • comply with legitimate requests from public or governments authorities; 

  • prevent a misdemeanor or carry out an inquiry, for example in the event of fraud or identity theft;

  • protect Refashion’s rights, property or security from Users or third parties.

 

Article 6 – Transferring your data to a country situated outside of the EU 

By data transfer, we are referring to any communication, copy or displacement of personal data likely to be processed in a third country, or any personal data that a third party located outside of France may have access to.

Your data is not transferred outside of the European Union by Refashion.

Should your data be transferred to partners of Refashion located outside of the European Union, we guarantee that:  

- We have obtained all of the eventual necessary authorizations with the competent authority to permit the said transfer to be carried out.

- We have regulated the framework for this transfer via standard European Commission contractual clauses or by any other framework mechanisms for transfers as recognized by the RGPD.

 

Article 7 - The rights of individuals

You have the right to access, rectify, delete your personal data and to its portability.

You can also request that the processing of your data is limited or refuse that it be processed.  

You have the right to communicate your instructions to Refashion concerning your personal data in the event of your death.

You can exercise your rights with Refashion: 

Refashion reserves the right to request the settlement of “reasonable costs” related to any administrative costs borne for supplying information if your request is clearly unfounded or unreasonable. Refashion shall endeavour to meet your request within the deadlines required by the GDPR.

To protect your privacy and ensure your security, Refashion will also undertake suitable measures to check your identify before granting you access to your personal information or to correct, modify or delete it. All requests shall be accompanied by a copy of your personal ID.

In the event that your rights have not been observed, you may file a claim with the CNIL (French Data Protection Commission).  

 

Article 8 – Data Security and Confidentiality 

You Data security:

We implement organisational and technical security measures to guarantee the confidentiality and integrity of personal data. In this regards, the purpose of administrative, organisational, technical and physical precautions is to protect your personal data from loss, theft, non-authorised access, non-authorised transmission and all modifications or deletion. In all cases, Refashion shall implement security measures that are suitable for the type of data collected.

Data that is collected is confidentially saved and is protected to a very high level of security. The servers on which this data is saved comply with security standards currently in force. They are protected against digital and physical attacks.

All of the Site’s pages on which you are required to communicate Personal Data are made secure in https. However, despite all efforts made, Refashion cannot guarantee that this protection is infallible due to unavoidable risks that occur during the transmission of personal data.

Security of data transmitted to our external service providers:

We always select service providers with the greatest of care and attach the greatest importance in the way that your data is made secure. Therefore, these service providers act on Refashion’s orders only and at no time use your data other than for carrying out the services that we have entrusted to them. A contract is systematically signed between Refashion and its selected service providers in which we request that the appropriate technical, physical, logical and organisational measures are implemented in order to ensure the confidentiality and the security of processed Personal Data and thereby prevent it from being deformed, damaged or that non-authorised third parties access it. 

 

Article 9 – Period that Personal Data is kept 

Refashion only keeps Personal Data for the time required for the operations for which it was been collected and complies with the regulations in force and the following policy on the period that data is kept:

 

Personal Data Categories

 

Period that data is kept

 

 

Identification Data required to process
       the different services offered by the Site        
(e.g. Creation of a personal account)
 

The time required to accomplish
the objective pursued during
data collection

Identification data for the purpose
of sending Newsletters 

 

Up to such a time when consent is
     withdrawn and 3 years maximum as from       
the date of the last activity
 

Data concerning information
requests or claims

 

3 years from the date that it was collected
or the last contact or the end of the
commercial relationship

  

Data proving a right or a contract

 

5 years as from the collection of the data
or the last contact or the end
of the commercial relationship
 

 

Some data may be kept for an additional period in order to manage claims and/or disputes as well as meet legal or regulatory requirements or to respond to any requests made by authorised authorities. Data shall be deleted when Refashion receives information on the death of the person.

 

Article 10 – Cookies 

When browsing the Site, information on your browsing behaviour may be recorded in files known as “Cookies” installed on your computer, depending on the choices that you made concerning Cookies, and that you can modify at any in time.

Cookies allow the Site visited to thereby manage, save and recover information about your browsing behaviour as well as obtaining technical communications on the Site’s browsability.  

For all additional information, please refer to our Cookie Policy  

 

©2021 Refashion. All rights reserved.

What is Eco design?

Eco design is a platform whose purpose is to provide information and assist textile and footwear brands to rise to the eco-design challenge. This platform is a Refashion initiative (formerly Eco TLC), a public authority-approved eco-organisation for the CHF industry (Clothing, Household linen and Footwear).

Our vision: a 100% circular textile and footwear industry.