Phoenix recognizes the importance of your privacy and transparency in its processing of your personal data.
Phoenix only processes personal data whose processing is based on a legal basis.b) We will only process your personal data if one of the following conditions is realized :
How, where and what data do we collect
Phoenix collects the personal data you provide.
(a) Phoenix collects, directly or indirectly via its subcontractors, the personal data that you provide us during your use of the Site, for example your name, address or email address when you fill in the registration form or order form for an item, or in the context of your correspondence with Phoenix when you communicate with us, for example in the context of after-sales service.
b) This information includes your name, e-mail address, telephone number, postal address, and any other data that may be used to identify you, or yours contact when ordering and purchasing items sold by Phoenix. This also includes the data necessary for the execution of our services, such as data relating to the size of the garments you order but also your payment data (credit card, stripe account, etc.) or more generally any other information that Phoenix and/or subcontractors, may ask you.
Some personal data is also collected automatically.
(c) Phoenix may also collect personal data in an automated manner, including through the use of tools and other active elements, for example in e-mails from Phoenix and/or subcontractors, such as IP addresses or other user identification data from the electronic devices you use, the geolocation of your electronic devices, data contained in the electronic devices, your preferences, web browsing data, or the links you click on when interacting with the Site.
d) In particular, we may include on our site computer applications from third parties, which allow you to share content from our site with others or to make your consultation or opinion about content on our site known to these other persons. This is notably the case of "Share" and "Like" buttons from social networks such as Instagram, Facebook, Twitter, etc.
(e) The social network providing such an application button may identify you by this button, even if you did not use this button when you visited our site. Indeed, this type of application button may allow the relevant social network to track your browsing on our site, simply because your account with the relevant social network was activated on your device (open session) during your browsing on our site.
f) We do not control the process used by social networks to collect information relating to your browsing on our site and associated with the data they have, but we invite you to consult the privacy protection policies of these social networks to find out the purposes of use, including advertising, of the browsing information they may collect through these application buttons.
g) In the context of our advertising network activity, the advertising content (graphics, animations, videos, etc.) broadcast in our advertising spaces may contain Cookies issued by third parties: either the advertiser at the origin of the advertising content in question, or a company that is a third party to the advertiser (communication consulting agency, audience measurement company, targeted advertising service provider, etc.), which has associated a Cookie with the advertising content of an advertiser.
h) Where applicable, cookies issued by such third parties may enable them, during the period of validity of such cookies, to (i) display advertising in all spaces reserved for third party advertising, (ii) count the number of displays of advertising content delivered via our advertising spaces, identify the advertisements so displayed and the number of users who clicked on each advertisement, (iii) to recognize your device when you subsequently navigate to any other site or service on which these advertisers or third parties also issue cookies and, if necessary, to adapt these third party sites and services or the advertisements they broadcast to the navigation of your device of which they may be aware.
It is possible to define certain authorizations and parameters in connection with the automated collection of personal data.
a) You can define certain authorizations in connection with the collection of personal data, in particular in relation to the geolocation and access rights of your device. electronics to the data contained in your device, depending on the features available. You can also set certain parameters for the automated collection of your personal data on your web browser or via the Site. You can also configure certain Cookies, see the chapter on Cookies accessible here.
Methods of treatment
Phoenix may process the personal data communicated to it in an automated way, but takes appropriate security measures to this effect.
a) Phoenix processes your personal data communicated to it in accordance with applicable law, in particular Swiss data protection law, and adopts appropriate security measures to prevent unauthorized access, disclosure, alteration, modification or destruction of such data.
Purposes for which Phoenix processes personal data
Phoenix processes your personal data to operate the Site and to provide you with any related services.
a) Your personal data is collected and processed with a view to operating the Site and/or providing related services, for example to interact with you, provide you with the information requested or carry out your orders, or in the manner expressly indicated when the personal data concerned is collected.
Phoenix may process your personal data for advertising purposes.
Phoenix may process your personal data for internal analysis and statistical purposes, as well as to improve our services or for other legitimate purposes.
Your personal data is not kept longer than necessary.
b) If you delete your User Account, we will delete your personal data within 30 days of that event, unless the data is retained for a valid reason.
Accessibility of personal data to third parties
Phoenix makes your personal data accessible to third parties to the extent necessary for the operation of the Site.
a) We may disclose your personal data to third parties in connection with the operation of the Site, as well as to subcontractors such as computer system providers, cloud services providers, database providers, automated marketing solution providers and consultants, etc. We may also disclose your personal data to third parties in connection with the operation of the Site, as well as to subcontractors such as computer system providers, cloud services providers, database providers, automated marketing solution providers and consultants.
c) We also transmit relevant personal data to our suppliers to enable them to carry out the service of delivering the products ordered or returning any repaired products. These suppliers may only use this data for the purpose of carrying out these services and only retain your data to the extent necessary to comply with their contractual or legal obligations.
d) We may also allow you to use third party services directly from the Site, in particular through social plug-ins from Google Maps and Google Analytics, but also from Facebook, Instagram or Twitter, in which case you acknowledge that the third party operators of these services may access some of your personal data in connection with the Site.
Phoenix can also disclose your personal data to third parties where we have a legitimate interest in doing so.
f) We may also disclose your personal data where we have a legitimate interest to do so, for example to (i) any third party to whom we assign or transfer our rights or obligations; (ii) to competent courts or regulatory or supervisory bodies, where we are required to disclose your personal data in accordance with any applicable law, regulation or ordinance.
Transfer of personal data abroad
Your personal data may be transferred to countries or destinations that do not provide a level of protection equivalent to Switzerland or the European Union.
(a) The personal data we collect from you may be stored and processed in your region, or transferred, stored or otherwise processed outside your country of residence, including, with respect to residents of a country of the European Economic Area ("EEA"), the "EEA", "EEA") or Switzerland, in a country outside the EEA or Switzerland, in particular the United States and Canada or any other country that does not necessarily offer an adequate level of data protection recognized by the European Commission or Switzerland. Your personal data may also be processed by staff operating within or outside your country of residence, including staff located outside the EEA or Switzerland who work for us or our service providers.
(b) Where we transfer your personal data outside the EEA or Switzerland, we will ensure that appropriate safeguards are in place to ensure that our third party service providers provide an adequate level of protection for your personal data, for example by relying on the Privacy Shield Framework between the EU and the USA as well as between the EU and Switzerland or on the standard contractual clauses adopted by the European Commission. You may request additional information in this regard and obtain a copy of the relevant guarantees upon request by sending a request to firstname.lastname@example.org.
c) By sending information and data to Phoenix, you expressly agree to such transfers.
Phoenix maintains physical, technical and procedural safeguards to ensure the security of your personal data.
b) Although we take appropriate steps to protect your personal data, no website is completely secure. As a result, we cannot guarantee that the data you provide us with is secure and protected against unauthorized access by third parties and against theft. We accept no liability in this respect.
d) If we have reasonable grounds to believe that your personal data has been acquired by an unauthorized person and applicable law requires notification, we will promptly notify you of the breach by email (if we have it) and/or by any other means of communication (including by posting a notice on the Site).
Cookies or other analytical tools
You have the right to know which personal data concerning you is processed by Phoenix and to request, under certain conditions, its deletion, correction or updating.
a) Subject to mandatory law to the contrary, you have the right at all times to know whether Phoenix is processing personal data about you. You may contact us to find out the content of such personal data, to verify its accuracy, and to the extent permitted by law, to request that it be completed, updated, corrected or deleted.
b) You may also ask Phoenix to cease any specific processing of personal data, which have been obtained or processed in violation of applicable law, and to object to any processing of personal data if there is a legitimate reason.
c) By accessing your Account (if applicable), you can view, update, correct or delete personal data available in your Account. If you wish us to delete your personal data from our system, please make a request to us using the contact details below and your request will be dealt with, unless we have a legal obligation to keep the record. Please note that any information we have copied may remain in backup storage for a period of time after your request for deletion.
d) When we rely on your consent to process your personal data, we will ask for your free and specific consent by providing you with informed and unambiguous indications regarding your personal data. You may revoke this consent at any time.
e) You also have the right to request portability of your personal data, i.e. that the personal data you have provided to us be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format, without hindrance to us and subject to our confidentiality obligations.
You have the right to file a complaint
f) If you are not satisfied with the way in which we process your personal data, you may lodge a complaint with the competent supervisory authority, in addition to your rights described above.
Date of last update: 22 November 2020