THE COUCOU CLUB B.V.

This Privacy Policy describes how The Coucou Club and its subsidiaries and affiliates (“The Coucou Club,” “we,” “us,” and/or “our”) handle personal data we collect online (e.g., through our websites) and offline (e.g., through customer support channels, our retail locations, and in-person promotional activities) (collectively, the “Services”).

For the purpose of the Data Protection Act 1998 (the Act) and from the 25 May 2018, the EU General Data Protection Regulation 2016/679 (the GDPR), the data controller is The Coucou Club B.V. (company no. 72095857), having its registered office at Herengracht 498, 1017 CB Amsterdam in The Netherlands.

At The Coucou Club we are committed to protecting your privacy. This Privacy Policy sets out our privacy practices for The Coucou Club website (www.thecoucouclub.com). Please take the time to review this Privacy Policy carefully as it tells you how your personal information will be treated by us.

By using The Coucou Club website (the “Site”) and our services, you unconditionally agree to be bound by this Privacy Policy and our Terms of Service.

The Coucou Club wants to offer you the best possible internet experience; consequently, additional functions, features, products or services are incorporated into the Site from time to time. This, and our commitment to protecting the privacy of your personal information, may result in periodic changes to this Privacy Policy. As a result, please remember to refer back to this Privacy Policy regularly to review any amendments.

Any questions regarding our Privacy Policy should be directed to The Coucou Club at hello@thecoucouclub.com or alternatively see the Contact Us page on this Site.

PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. This information facilitates your use of our Site and helps us to understand how our Site is used. You can erase or block cookies from your computer if you want to (your help screen or manual should tell you how to do this), but certain The Coucou Club services may not work correctly or at all if you set your browser not to accept cookies.

For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

- We may also collect information about your online activities over time and across third-party websites. The information we collect automatically may include: URLs that refer visitors to our websites;

Additionally when you set up an account, place an order, make a purchase, ask to receive emails and interact with us on social media we collect certain information from you, including your full name, billing address, shipping address, payment information and details (including credit card numbers, email address, age and/or Date of Birth, and phone number. We refer to this information as “Order Information”. Also, we collect ‘Account Information’; such as username and password.

We may ask you for this information through our Site, or via one of our telephone operators, or we may collect this information through your e-mail or other communications with us.

We may also ask you for other optional information such as what sort of device you use such as a mobile telephone or PDA or tablet, how you heard about our Site and what sort of subjects interest you, social handles, makeup and color preferences and information about your skin type. If you choose to give us this information, we will use it to help us to provide you with the best possible service that is personalised to your needs and preferences. Although we do not make it compulsory to give us every item of information we ask for, the more information you volunteer (and the more accurate it is), the better we can tailor our services for you.

We may pull content from you who share photos and videos on Instagram or other social media platforms using our brand hashtags, including, without limitation, #thecoucouclub, #coucou, #sharingglobalbeauty, (collectively, the “Coucou Club Hashtags”), or tagging the @thecoucouclub account (collectively, “Photos”). You acknowledge and agree that the Photos may be used in The Coucou Club’s showroom and office space, retail locations and emails and on the Site, and you hereby grant us permission to use and authorize others to use your name or social media handle in association with the Photos for identification, publicity related to our Services and similar promotional purposes, including after your termination of your Account or the Services. We refer to this information as “Shared Information”.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information, Order Information and Account Information and Shared Information.

REFERRAL PROGRAM
If you choose to use our refer-a-friend service (if applicable) to tell a friend about The Coucou Club, we may collect your friend's name and email address in order to send your friend an email and (if you so choose) one follow-up reminder email inviting him or her to shop with us. We store information about the individuals you refer in order to send these emails and to administer and track the success of our referral program.

INFORMATION WE COLLECT THROUGH SOCIAL MEDIA
When you access the Services through a social network, we collect information from the social network in accordance with your settings on the social network. If you interact with us on social media, we will collect information about those interactions. The information we may collect includes your name, picture, and email address. We may also collect information about you from third parties, including mailing list providers and publicly available sources, or friends that refer you to The Coucou Club.

HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

- Communicate with you, reply to your enquiries, requests for information, comments and suggestions

- Receive and process orders submitted by you;

- Offer contests, sweepstakes, or other promotions (based on your interests);

- Customise the service we provide to you;

- Anticipate and resolve problems with any goods or services supplied to you;

- Carry out market research and tracking of sales data;

- Send you newsletters, surveys or other information about our products and services by post, e-mail or SMS;

- To improve our services/ conduct or administer surveys and other market research; staff from The Coucou Club, or from our service providers, may contact you from time to time using the contact means you have supplied to us in order to get your views and comments on the service we provide to you.

- Screen our orders for potential risk or fraud; and

- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

NON-PERSONAL INFORMATION
We may automatically collect non-personal information about you such as the type of internet browsers you use or the site from which you linked to our Site. You cannot be identified from this information and it is only used to assist us in providing an effective service on our Site. We may from time to time supply the owners or operators of third party sites from which it is possible to link to our Site with information relating to the number of users linking to our Site from their sites. You cannot be identified from this information.

SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.  We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

We will only disclose and/or transfer your personal information to a third party either as part of a restructuring or a sale of the assets of The Coucou Club, or having ensured that steps have first been taken to ensure that your privacy rights continue to be protected.

The Coucou Club works with a number of national and international trusted suppliers, individuals, agencies and businesses in order to provide you the high quality goods and services you expect from us such as delivery companies, fraud prevention agencies, beauty and cosmetic brands and market research companies amongst others. Some examples of the categories of third parties with whom we share your data are:

Supplier partners
The Coucou Club works with a number of trusted partners who supply products and services on our behalf. We will only hold the minimum amount of personal information needed in order to fulfil the orders you place or provide a service on our behalf.

Delivery and logistic partners
In order for you to receive your goods, The Coucou Club works with a number of delivery and logistics partners. We only pass limited information to them in order to ensure successful delivery of your order.

Marketing companies
The Coucou Club works with marketing companies who help us manage our electronic communications with you or carry out surveys and product reviews on our behalf.

Payment processing companies
The Coucou Club works with trusted third party payment processing providers in order to securely take and manage payments.

BEHAVIOURAL ADVERTISING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

- Facebook: https://www.facebook.com/settings/?tab=ads

- Google: https://www.google.com/settings/ads/anonymous

- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

THIRD PARTY SITES
We cannot be responsible for the privacy policies and practices of other third party sites, or for advertisers on our site, even if you access them using links from our Site and we recommend that you check the policy of each site you visit. In addition, if you linked to our Site from a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and we recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

Unless expressly stated, we are not agents for these third party sites or for any third party advertisers on our Site, nor are we authorised to make representations on their behalf.

Third parties include companies to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Opting out of email marketing
You may unsubscribe from our promotional emails at any time by following the instructions included in those emails. If you opt out of receiving such communications, note that we may continue to send you non-promotional emails (such as order confirmation emails or emails about changes to our legal terms).

Restricting cookies
Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

DATA RETENTION/ HOW LONG WE KEEP YOUR INFORMATION
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired.

CHANGES
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CHILDREN
The Site is not intended for individuals under the age of under 16. Our Services are not designed for children and do not knowingly collect personal data from children.  No one under age 16 may provide any information to or on this Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site or on or through any of its features, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.

If you have reason to believe that a child has provided personal data to us, please contact us, and we will endeavor to delete that information from our databases. If you leave information under the age of 18 you have to ask prior permission to your parent(s) or legal representative.

CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at hello@thecoucouclub.com or by mail using the details provided below:

[Re: Privacy Compliance Officer]

THE COUCOU CLUB B.V.

Herengracht 498
1017 CB Amsterdam

Last Modified: August, 2018.

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