Last updated 01 Nov 2021
1. GENERAL STATEMENT
At Zoelle, we respect privacy and your rights to control your personal data, and we are committed to protecting it.
2. COLLECTION OF PERSONAL INFORMATION
Personal data is information relating to an identified or identifiable natural person. For example, it may include an individual’s name, address and gender.
We may collect personal data either 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.
2.1 PERSONAL DATA DIRECTLY COLLECTED
You may provide us with information:
- when you create an account online or in our stores;
- when you subscribe to our newsletter;
- when you use Zoelle.com;
- when you purchase products or services on Zoelle.com or in our stores;
- when you participate in one of our events;
- when you contact our customer service.
Depending on what you provide us with, such information may include:
- your identity (including your first name, last name, gender, image);
- your contact details (including your postal address, email address, phone number);
- your personal status (including your title);
- your purchases and repairs (including purchase history, order details);
- your preferences (including your size);
- certain payment information (including billing information, payment type or method, charge or credit card number);
- other information you may provide by filling forms or by contacting us (including your feedbacks, or other communications with us).
We will inform you when your information is required in order to process your request, to respond to your queries or to provide you with our products and services. If you do not provide this information, then it may delay or prevent us from processing your request, responding to your query or providing products or services to you.
We hope to ensure that the personal data we possess are accurate at all times and therefore we encourage you to update your information in case any changes have occurred. We also may ask you to update your information from time to time.
We recommend that you only provide the data requested or necessary for your query, with the exception of any sensitive information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning health, sex life or sexual orientation.
2.2 PERSONAL DATA INDIRECTLY COLLECTED
We may collect information when you use Zoelle.com, such as your IP address or other browsing information (including browser, operating system, device model), through cookies or similar technologies placed on your device. Some cookies are required for the proper functioning of our Digital Platforms and other are used for analytics purposes which help us to provide you with more personalized and customized services and a better digital experience.
We may also collect information about you from third parties, such as a spouse who contacts us on your behalf or from your friends who provide us with your information in order to invite you to events you may be interested in.
3. USE OF PERSONAL DATA
We collect and use your personal data based on one or many of the following legal basis:
- we have obtained your prior consent (for example, when you subscribe to our newsletter). Please note that for this specific legal basis, you have the right to withdraw your consent at any time (see below “What rights do you have on your personal data?”);
- the processing is necessary in connection with any contract between Zoelle and you (for example, when you make a purchase);
- we have a legitimate interest in carrying out the processing and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms (for example, to prevent payment fraud);
- we have to process your personal data to comply with applicable laws and regulations.
Depending on the context, we may use your personal data in order to:
- provide you with the products or services you requested;
- conduct checks to identify you and verify your identity;
- send you promotional communications - with your prior consent (see section “Promotional Communications”);
- provide you after-sale services and manage refunds;
- respond to your queries, suggestions and requests, including your data subjects’ rights exercises;;
- manage complaints and litigation;
- manage the events you registered and/or participated in;
- to detect, prevent and fight against any fraudulent or illegal activity, including to protect your transactions from payment fraud, to act against counterfeiting and against the resale of our products in violation of our terms and conditions of sale and/or outside our distribution network;
- protect you, employees and other individuals in our stores as well as our property;
- manage the stock of certain types of rare products to allow a fair allocation of the products we sell;
- monitor and improve our Digital Platforms;
- conduct statistical analysis, in particular to adapt our product offer (including the use of your nationality after anonymization);
- improve our products and services;
- respect our legal obligation, including providing information to regulatory bodies when legally required, in particular to comply with our legal obligations in terms of prevention and the fight against fraud, money laundering and the financing of terrorism.
4. PROMOTIONAL COMMUNICATIONS
With your express prior consent (usually obtained by ticking a specific box in a form), you may receive information, such as newsletters or invitations, concerning offers, services, products or events sent by Zoelle and/or by other Zoelle group companies (“Promotional Communications”). In such a case, you also accept that your contact information is shared with other Zoelle group companies for this purpose.
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 can withdraw your consent at any time (see below “What rights do you have on your personal data?”).
We may ask you to confirm or update your preferences regarding Promotional Communications if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
5. DISCLOSURE OF PERSONAL DATA
We share personal data for the purposes described below:
- With our Affiliates and Subsidiaries - We share your personal data with our holding company, subsidiaries and affiliates. Since our holding company, subsidiaries, and affiliates are located around the world, please note that these disclosures involve cross-border transfers of your personal data.
- With our Service Providers - We share personal data with unaffiliated companies or individuals we hire or work with that perform services on our behalf, including customer support, web hosting, information technology, payment processing, product fulfilment, fraud control, direct mail and email distribution, events, contest, sweepstakes and promotion administration, and advertising and analytics services. These third-party service providers have access to personal data needed to perform their services but may not use it for other purposes. Since our service providers are located around the world, please note that these disclosures involve cross-border transfers of your personal data.
- In Connection with a Corporate Transaction - Personal data may be disclosed or transferred as part of, or during negotiations of any purchase, sale, lease, merger, amalgamation, or any other type of acquisition, disposal, securitization or financing involving lululemon.
- With our Professional Advisors - We share personal data with our legal, financial, insurance, and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of lululemon’s business or operations.
- With Law Enforcement Authorities and Individuals Involved in Legal Proceedings - We disclose personal data when we believe doing so is reasonably necessary to comply with applicable law or legal process (including an enforceable request from authorities), to respond to claims (including inquiries by you in connection with your purchases from lululemon), enforce or apply our TERMS OF SERVICE, or to protect the rights, property, or personal safety of lululemon, our users, employees, or others.
- With Your Consent or at Your Direction - We share personal data with third parties when we have your consent to do so. For example, if you decide to participate in certain interactive areas or features of our events or Services, such as creating a public profile and posting your goals, you consent to the disclosure of this information to other users of our websites. We may also share your personal data with third parties when you intentionally direct us to do so or when you use our Services to intentionally interact with third parties.
- Aggregated, Anonymized or De-identified Data - We may also share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you.
6. DATA TRANSFER AND RETENTION
We retain personal data in accordance with applicable law. Unless otherwise required by applicable law, Zoelle will take reasonable steps to destroy or permanently de-identify personal data we hold if such personal data is no longer needed for the purpose for which it was collected.
7. CHILDREN'S PRIVACY
The Services are not intended for children under the age of 18. Zoelle does not target our Services to children under 18.
8. PROTECTION OF PERSONAL DATA
All your personal data is strictly confidential and will only be accessible, on a need-to-know basis, to duly authorized personnel of Zoelle and other entities of the Zoelle Group and third providers acting on our behalf with appropriate technical and organizational security safeguards.
The Zoelle group has implemented security measures to protect your personal data against unauthorized access and use. We follow appropriate security procedures in the storage and disclosure of your personal data so as to prevent unauthorized access by third parties and to prevent your data being accidentally lost. We limit those who access your personal data to those who have a genuine business need to access it. Those who do access your data will be subject to a duty of confidentiality towards Zoelle.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We also require those parties to whom we transfer your personal data to comply with the same. However, unfortunately, the transmission of information via the internet is not completely secure. So, we cannot ensure the security of your personal data transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorized use, distribution, damage or destruction of Your Information, except to the extent we are required to accept such responsibility under the law. Once we have received your personal data, we will use the security measures abovementioned.
9. YOUR RIGHT TO PERSONAL DATA
In accordance with the applicable data protection laws, you can, at any time, request access, rectification, erasure and portability of your personal data or restrict and object to the processing of your personal data. A summary of these rights is provided below:
Your right of access: the right to be provided with a copy of your personal data.
Your right to rectification: the right to require us to correct any mistakes in your data or to complete your information.
Your right to be forgotten: the right to require us to delete your personal data — in certain situations.
Your right to restriction of processing: the right to require us to restrict processing of your personal data — in certain circumstances, for example if you contest the accuracy of the data.
Your right to data portability: the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party - in certain situations.
Your right to object to processing: the right to object:
- at any time to your personal data being processed for direct marketing;
- in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
When the processing of your personal data is based on your consent, you may at any time decide to withdraw it. If your consent is withdrawn, it will not affect the processing of your personal data based on other legal bases, such as fulfilling your orders and storing your order data as required by applicable law.
If you no longer wish to receive our marketing/promotional information, we remind you that you may withdraw your consent to direct marketing at any time directly from the unsubscribe link included in each electronic promotional message we send to you. If you do so, we will promptly update our databases, and will take all reasonable steps to meet your request at the earliest possible opportunity, but we may continue to contact you to the extent necessary for the purposes of any products or services you have requested.
You also have the right to lodge a complaint with your local data protection authority in case of alleged infringement of the data protection rules applicable to you.
To exercise any of those rights, please contact us using the contact information below (see “Contact Us”).
Please note that upon exercising any of the rights listed above, you will be requested to let us know what right you want to exercise and provide information (copy of an identity card, passport or other legally recognized identity) for identification purposes in order to process your request and protect you against fraudulent requests from third parties.
10. SALE OF PERSONAL DATA
Zoelle does not sell your personal data.
11. CCPA PRIVACY RIGHTS
Under the CCPA, among other rights, California consumers have the right to:
- Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
- Request that a business delete any personal data about the consumer that a business has collected.
- Request that a business that sells a consumer's personal data, not sell the consumer's personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
12. GDPR Data Protection Rights
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
14. CONTACT US
15. INFORMATION ABOUT COOKIES
Like any other website, Zoelle.com uses 'cookies'. A cookie is a small text file stored on your computer, tablet or mobile phone that makes it possible to save and track data about your use of the website. These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information.
Cookies are managed by your Internet browser. You can decide whether or not to accept cookie in your computer settings or Internet settings. By continuing to use the Zoelle.com website, you consent to our cookie settings and agree that you understand the terms of our cookies policy.
Please note that turning off cookies may result in reduced functionality or the disabling of certain features of our website.