This Policy is a public document aimed at informing users and customers (“User(s)” or “you” or “your”) surfing this Site that the processing of their personal data (“Personal Data”), is conducted in compliance with all applicable laws and regulations (“Laws”).
Boucheron acts as operator for the Personal Data of its Users in accordance with Russian Federal Law no. 152-FZ, dated July 27, 2006 (“Operator”).
1. Our Policy
You are granted the full right to have your Personal Data protected. Boucheron respects your right to be informed in relation to the collection of (and other operations involving) your Personal Data. Moreover, upon processing data that may directly or indirectly allow to identify you personally, a principle of strict necessity is mandatorily applied. For this reason, this Site has been devised in such a way that the use of your Personal Data is performed without exceeding the purposes for which your Personal Data is collected and/or processed.
Your Personal Data is not processed when necessary activities can be carried out and services can be properly provided to you through the use of anonymised and/or browsing data (“Traffic Data”) or by other means that do not allow to identify you, apart from when it is strictly necessary or upon request by competent public authorities.
The first record of Personal Data collected through this Site carried out through the IT-facilities located in Moscow, Russian Federation.
2. Who processes your Personal Data, how and for what purposes?
Being an Operator in conformity with the Laws, Boucheron may collect and process your Personal Data through the Site for the following purposes ("Purposes"): (i) create your User profile on the Site upon performance of the relevant registration; (ii) provide the services you subscribed to (including those reserved to registered users); (iii) facilitate your navigation on the Site; and (iv) process all requests and perform all activities, including technical, relating thereto.
Boucheron collects your Personal Data through the Site (including, but not limited to: name, surname, email address and telephone number – Boucheron does not collect and/or process sensitive or biometric Personal Data) on your User account. Your Personal Data is mostly processed by electronic means and, in some circumstances, such as when the processing of your Personal Data is required for preventing fraud on the Site, by paper-based means. Your Personal Data is stored in a way that allows identifying you for the period that is strictly necessary for the achievement of Purposes but for no longer than the terms prescribed by applicable laws. Please report any modification of your Personal Data to Boucheron in order to ensure that your Personal Data is always registered accurately and up to date. Your Personal Data shall not be disclosed to third parties for any purposes that are not permitted by the Laws or without your consent if required.
Upon receipt of your consent and performance of relevant notifications if required by the Laws, your Personal Data may be processed by third-parties located inside and/or outside the Russian Federation and/or the EU, appointed by Boucheron in order to carry out relevant activities necessary for achieving the purposes for which Personal Data are collected in accordance with applicable laws ("Service Providers"). Service Providers, bound by the relative contractual obligations with Boucheron, are chosen because of their expertise in activities connected with Personal Data processing, provide sufficient safeguards regarding compliance with Laws (including the technical security measures governing the processing to be carried out) and are subject to non disclosure obligations. In processing Personal Data, Service Providers shall act only under the instructions received by Boucheron. To this purpose, Boucheron regularly checks that Service Providers comply with its instructions and that they keep providing sufficient guarantees regarding their full compliance with the Laws.
Thus, upon receipt of your consent and performance of relevant notifications if required by the Laws, Boucheron, acting as Operator, may lawfully transfer your Personal Data as well as Traffic Data to Service Providers for marketing and profiling purposes ("Marketing Purposes"), including to: (i) send you, e.g. through newsletters, information and updates on our products, events and similar initiatives organized by us, which we believe may be of interest to you; (ii) provide you with customized contents and offers; (iii) send communications about new commercial initiatives related to our activities and the services provided by us. You have the full right to require such marketing and advertising activities targeted to you to be ceased without delay. Personal Data and Traffic Data collected for Marketing Purposes is mostly processed by electronic means.
Upon receipt of your consent and performance of relevant notifications if required by the Laws, we may lawfully transfer your Personal Data to Boucheron subsidiaries and stores, located inside and/or outside the EU, for Marketing Purposes, as well as transfer your Personal Data and Traffic Data to corporate entities of Kering Group listed in Section 4 of this Policy, located inside and outside the EU, for the sole corporate purposes of information technologies and infrastructure management.
Your Personal Data may be also disclosed to relevant police or judicial authorities, according to applicable laws and upon formal request by such bodies, including, but not limited to, for the performance of antifraud activities.
Boucheron may have access to Personal Data belonging to third-party individuals disclosed by Users, for instance, when a customer purchases an item as a gift. In such cases, please make sure you receive the relevant consent of third-party individuals before disclosing their Personal Data to us and make sure you bring this Policy to their knowledge; you bear the liability for the disclosure of data regarding such third-party individuals if they have not provided you with their prior explicit consent for it and for any improper and unlawful use of such information. Nevertheless, where possible, reasonable efforts shall be used to inform third-party individuals of relevant law provisions and provide for the request of their explicit consent upon contacting them.
The purposes for collecting your Personal Data are expressly listed in the privacy statement appearing on the Site upon provision of your Personal Data. Your Personal Data is not collected for purposes other than those declared upon collection, and their processing may not be incompatible with lawful purposes of Personal Data collection. Your Personal Data are not processed for any longer than necessary and their processing shall be ceased if you expressly require it and, in any case, for no longer than 30 calendar days from the achievement of the declared purposes of data processing.
3. What happens if you do not disclose your Personal Data to us?
Your refusal to provide Personal Data necessary for performing the purposes listed above may hinder or impede the fulfillment of contractual obligations and of obligations provided for by the Laws. Therefore, the failure to provide Personal Data may constitute, in some cases, a legitimate and justified reason for not performing relevant activities.
The disclosure of further Personal Data other than that required for fulfilling legal or contractual obligations is optional and its performance does not have any effect on the performance of other relevant activities. You will be properly informed as to whether the disclosure of information is optional or not through the display of the symbol (*) next to the fields that need to be filled compulsorily upon registration or purchase.
4. To whom your Personal Data may be disclosed
In accordance with the Laws and the provisions of Section 2 of this Policy, your Personal Data may be disclosed to Service Providers performing relevant activities on behalf of Boucheron.
Your Personal Data may also be shared with Kering SA, a French public company with registered office at 40 Rue de Sèvres, 75007 Paris – France 1, and registered with the Paris Trade Registry under number 552 075 020 RCS Paris, belonging to the Kering Group, for purposes of information technologies and infrastructure management, including any of their Service Providers acting on their behalf.
Notwithstanding the foregoing, your Personal Data will not be disclosed/disseminated/transferred to any other third party or without informing you of such disclosure/dissemination/transfer, and, in any case, in conformity with Laws.
5. Security measures
Boucheron, acting as a registered Personal Data Operator, determines the necessary security measures in accordance with all relevant Laws and having regard to the level of protection under which Boucheron is required to process Personal Data. In addition, all necessary security measures have been adopted to protect Personal Data from accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access, and against all other possible consequences that do not comply with this Policy or with the Laws. To achieve a higher degree of protection of your Personal Data outside the scope of Boucheron’s control, we suggest you employ software devices for the protection of data transmission networks (such as updated antivirus systems, firewalls and antispam filters).
In some cases, anyway, the transmission of data over the Internet is not totally immune from access by unintended recipients. Boucheron cannot be held liable for any breach of security unless this is due to negligence.
The Site uses automatic data collection systems such as cookie files. Cookies are a set of information sent by the Web server to the user’s browser and navigation device. In the process of navigation, the user’s IP address and other information related to user data traffic or user preferences in the selection of services proposed by the website or goods proposed through the services provided may be automatically collected.
Data contained in cookies does not constitute Personal Data and are processed for commercial purposes in an aggregated and anonymised form. It is directly and automatically collected by the Site in the process of navigation as part of the execution of operational functions. Cookies may be used for Marketing purposes and are designed to improve navigation on the Site, reduce the time taken to place an order and also to improve the service level; namely, Cookies may be used to display goods corresponding to the User’s interests and preferences.
Third-party cookies are used to provide users with targeted commercial offers hosted on partner websites. The information received from third-party cookies is not controlled by Boucheron and is under the control of the third parties.
Information collected using cookie files is processed by Boucheron in anonymized form for the optimization of their services and the website according to user needs and preferences.
7. Your right to access Personal Data and further rights
In accordance with the Laws, you are always entitled to obtain: (i) the confirmation from Boucheron as to whether or not Personal Data relating to you are being processed; (ii) the communication of the composition of your Personal Data being processed; (iii) any information on the source of your Personal Data and on the purposes and methods used for processing your Personal Data, including the time frames of their storage; (iv) the contact information of the Operator and of Service Providers; (v) the information about entities to whom your Personal Data may be disclosed; (vi) the procedure through which you may exercise your rights related to Personal Data; and (vii) all information concerning a possible cross-border transfer of your Personal Data. You can easily find part of the above information in this Policy. For further information, send an email to Boucheron.
You are also entitled to obtain at any time:
a) the update/adjustment of your Personal Data;
b) the deletion or transformation into an anonymous form or blocking of your Personal Data that are being unlawfully processed, including data that does not need to be stored for the purposes for which it was collected and subsequently processed; and
c) the confirmation of whether operations under letters a) and b) have been performed.
You may freely exercise your rights at any time, provided that you do so in compliance with the Laws, by sending your request to Boucheron.
Each time your consent is required, you will be informed in advance and be provided with the option to either express or refuse your consent for the processing of your Personal Data, for the purposes listed in this Policy, by ticking the appropriate boxes.
We wish to inform you that, in accordance with the Laws, your Personal Data may be processed without your required consent in certain circumstances, such as when such processing is necessary for performing a legal obligation to which Boucheron is subject or when such processing is necessary for performing obligations undertaken in agreements stipulated with the User.
Boucheron does not collect data of visitors of https://ru.boucheron.com/ who do not provide their consent, if needed.
9. Links to other websites
This Policy provides you with all information needed to understand how your Personal Data is collected and further processed. For any request related to this Policy, please contact our Customer Service via email or phone call.
11. Applicable law
This Policy is governed by: the Russian Law, with regard to the collection, processing and protection of Personal Data of Users which are citizens of the Russian Federation.
This Policy may be amended and/or updated in whole or in part in conformity with the Laws. Each modification shall be properly announced on this Site and is immediately effective upon publication.
Last update January 2018