Privacy Notice

Personal Data

PRIVACY STATEMENT- BRACES

Last Updated: 10-2024

Confidentiality and security of your personal data are important to us. We would like to offer you personalised services while respecting your privacy and choices.

This Privacy Statement (“Statement”) is provided by Braces, a luxury retail and wholesale brand.

The purpose of this Statement is to inform you in a transparent and simple manner about the processing of the personal data that you provide or that we collect through the different touch points you use to interact with us (e.g. client services, bracesblack.com, social media, digital apps, events), about possible transfers to third parties, as well as your rights and options to control your personal data and protect your privacy.

It summarises at high level the processing of your personal data By Braces.

WHO ARE WE?

BRACES

Braces, a partnership company under Indian law.

Braces is a story of dreams and elegance, passion and excellence; it is also a story of know-how. The creations of Braces express the passion for beautiful gestures and exceptional objects. From tailor-made to ready-to-wear, including leather goods, watchmaking and jewellery, know-how is transformed into the art of making.

WHAT DATA MAY WE COLLECT OR RECEIVE ABOUT YOU?

"Personal data" means any information that could reasonably identify you either directly (e.g. your name) or indirectly (e.g. through a unique client ID number).

The personal data we collect depends upon the touchpoint of our interaction and is also limited to that which is relevant and appropriate for the interaction. Unless you choose to interact with us via other touchpoints, such as (but not limited to) by making a purchase on our site, signing up for one of our programs or services, using our apps, communicating with us via email, phone or submitting online forms, or posting a comment or a like online, our data collection is limited to the use of ‘cookies’ for website visitors.

For customers and other individuals who sign up for programs or services or otherwise interact with us beyond browsing our site via the touchpoints described above, for example, we collect certain relevant information from you. The information we collect is related to the particular transaction as well as our overall relationship with you. For example, if you make purchases from bracesblack.com, we must collect information to process (and, if relevant, fulfil and ship) your order. We generally collect your contact details, contact preferences, and information that will allow us to make recommendations to you about our products or services that may be of interest. We may centralise the information pertaining to our customers so that we have it organised in one place, as this helps us manage our relationship with you as well as your choices and preferences. Or, if you subscribe to our personalised newsletter, we collect your email address.

We invite you to keep us regularly informed in writing of any change in your contact details.

We Collect and Use Limited Sensitive Information.

As described above, we collect personal data that is described under some laws as sensitive personal data, special categories of personal data, sensitive personal information, or similar terms (collectively referred to here as “Sensitive Personal Data”). Here, we provide more information about which categories of the personal data described above may be designated as Sensitive Personal Data, and how we use these categories of Sensitive Personal Data. We only use Sensitive Personal Data to provide you goods and services, and do not use such information to infer characteristics about you. Depending on what you choose to provide and how we interact with you, we may collect:

  • Account log-ins to provide braces products and services. Account login information is used to identify an active user on any site that requires login. Login information includes first and last name and corresponding email for such an account, as well as the associated account password.
  • Financial information to process your orders. We collect and use credit or debit card information and require security or access codes in order to process payments and fulfil any order you make.
  • Passport-related information to process your orders. We may collect passport or other government-issued ID information in connection with an order, including when you are purchasing a product in a country other than that in which you live, in order for you to make purchases.

HOW DO WE COLLECT OR RECEIVE YOUR DATA?

We may collect or receive data via the following touchpoints:

  • Use of bracesblack.com
  • Braces events you attend
  • Public Relations relationship and communication
  • Contact with the Client Services
  • Forms you complete
  • During your purchase journey, you will be able to choose between i) logging into your existing Braces account, ii) creating a new account, or iii) paying as a Guest;
  • Digital apps you use
  • Digital experiences such as virtual beauty technology in store (if you choose to use that technology where offered via a retailer), or our third-party vendors may receive data via virtual try-on online;
  • Braces social media pages you visit or interact with, or other social media pages on which you post Braces content or comments;
  • Digital media advertising you click on;
  • Search engines’ paid advertising you click on;
  • Retailers (such as Department Stores) in which you have purchased a Braces product and in which you consented (e.g. via an iPad) to have your details shared with our Maison to receive its communications or
  • Surveys or satisfaction questionnaires you answer.

FOR WHAT PURPOSES ARE YOUR DATA USED BY BRACES?

Depending on the context in which your data is collected, we use your data for:

  • The provision of Braces products and services, including the management of your orders, the management of personalised content, communications and interactions with Braces (digital or otherwise), and providing customer support;
  • The facilitation of showing you what your selected product would look like on you (in relation to using our try-on technology, though when online, all processing for providing the feature is done by our third-party vendors’ proprietary technology), and for certain virtual try-ons, offering you the option of receiving your photo via email;
  • the management of your account and profile (for example, in order to simplify your navigation through our website.
  • Analyse the performance of Braces on social networks in order to produce statistical analyses (studies of results by country, influence of Braces and analysis of the campaigns implemented).
  • analyse your preferences and habits, anticipate your needs from your consumer profile and your publications/mentions on social networks.
  • personalised customer experience: we may provide you with personalised communications by means of email, postal mail, SMS or calls based on the communication preferences you have indicated and your consumer profile (where permitted). Otherwise you can contact our customer service (see "Contact Us" section below)). With your free, specific, informed and unambiguous consent (where required), we use your personal data to send you personalised communications based on your interests (newsletters, offers, invitations and surveys).

In the latter two interactions (“analysing your preferences and habits” & “providing you with a personalised customer experience”), when we send personalised communications or content, we may use so-called profiling techniques. For the sake of transparency within this Statement, profiling is currently defined as any kind of automated processing of personal data which consists of using that personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict elements relating to the preferences, interests, behaviour or location of that natural person. In these circumstances, you have the right to opt-out, meaning the right to withdraw your consent by unsubscribing or see the “Contact Us” section below.

FOR HOW LONG MAY WE KEEP IT?

Please note that each brand has its own retention periods that include the requirements regarding the products each brand offers.

Unless otherwise stated, we only keep your personal data for as long as we need it to fulfil the purpose of collection, to meet your needs, or to comply with our legal or business obligations, and to fulfil the purposes described above in this Privacy Statement. By way of example, we keep your data for up to 10 years from the date of your last purchase if you are a client and up to 3 years if you are a prospect from the date of your last interaction with us.

When we no longer need to use your personal data, it is removed from our systems and records or anonymized so that you can no longer be identified from it

Weuse the following criteria to determine how long to retain personal data:

  • Our relationship with you, and the products and services we provide to you;
  • Your requests to us regarding your information, or our products or services;
  • Any legal obligations to retain the data, or for our own legal purposes (such as enforcing our agreements or litigation);
  • Recommendations and legal requirements, including applicable international, national, federal and state statutes; and
  • Technical considerations and feasibility, and level of protections in place for your personal data.

WHO MAY ACCESS YOUR DATA?

We communicate your information, including if possible in a form that does not allow a direct identification, to trusted third-party partners for services like:

  • Other Braces entities where you buy our products in order to provide you with identical personalised service worldwide.
  • For example, we entrust certain services to third parties responsible for delivering a product to you, payment service providers and transaction security against fraud, third parties who assist us in the organisation of our events, third parties providing services IT, digital communication and public relations agencies, third parties who assist us in customer care, third parties who assist us in qualitative surveys of our products, programs or services
  • Our trusted third-party partners assist us in the management of your orders. In particular, we entrust certain services to third parties responsible for delivering a product to you, to payment service providers and to providers ensuring the security of anti-fraud transactions.
  • Third-party partners, who provide advertising, marketing, website performance, analytics, and similar services for Braces, including cookies or other trackers, including for the purposes of behaviour-based targeted advertising.

Please note that these third-party partners may act as data controllers; in such cases, they have their own privacy policies. These third parties include:

  • Third parties in the event of a change of control, for legal reasons, or with your prior consent
  • Third parties wishing to know your main interests to constitute similar audiences and target prospects that match your profile. In the context of this specific data processing, Braces is not the Data Controller relating to prospecting and you will not be subject to prospecting, your data is only used to constitute profiles similar to yours
  • We may also offer you the possibility of using your social media connection data. Please note that in this case, you are sharing your profile information with us. The personal data shared depends on the configuration of the social network platform. Please note that these social networks apply their own privacy policy

HOW DO WE PROTECT IT AND KEEP IT CONFIDENTIAL?

We have adopted reasonable and appropriate physical, technical and organisational security safeguards to protect your data from loss, misuse, alteration, destruction or access by unauthorised third parties. The Internet, wireless networks and information storage are not 100% secure. We cannot guarantee the security of your personal data stored or sent to us. We encourage you to take precautions to protect your personal data. For example, in creating your account on bracesblack.com, entering a personal password complying with our security requirements is compulsory and part of this Privacy Statement.

The security safeguards that we have adopted are commensurate with the sensitivity of the particular data collected.

We also require our partners and group companies to uphold a substantially similar level of protection for your data. The measures are evaluated and updated to address new threats and challenges, as well as new legal requirements where we operate.

To the maximum extent allowed by applicable law, you agree and acknowledge that Braces will not be liable or responsible for use or disclosure of your information that is the result of unauthorised or illegal access to our systems or those of our vendors, agents, contractors, affiliates, or partners. If you have reason to believe that the security of your communications or personal data has been compromised, please notify us immediately using the contact information.

CONTACT US

If you have any general questions or concerns about how we process and use your personal data or would like to exercise any of your privacy rights, you may contact us at the following details:

  • By email to: bracesblackk@gmail.com
  • By Client Service Centre

NOTICE ABOUT COOKIE MANAGEMENT

This Notice about cookies applies when visiting the website available at bracesblack.com, which belongs to hereinafter “Braces”.

The purpose of this cookie policy is to inform you of the source and use of browsing information collected during your visit to the Website and the tools provided to allow you to express your choices about cookies.

WHAT IS A COOKIE?

Subject to your choices, when visiting the Website, a text file may be placed on your device (computer, smartphone, tablet), courtesy of your web browser.

This text file is a cookie. During its validity or registration period, it will allow the sender to identify your device on future visits.

Some cookies are essential for using the Website, others optimise and personalise the contents displayed.

WHO SENDS THE COOKIES ON OUR WEBSITE?

Cookies that may be saved to your device when you visit the Website pages are issued by Braces and/or third parties. Only the cookie issuer is likely to read or modify the information contained within it.

Cookies sent by Braces are mainly related to the operation of the Website.

The others are third party cookies sent by our partners or advertising agencies, via the advertisements shown on our Website.

Braces makes every effort to ensure that third-party cookies are issued and used in compliance with the applicable regulations.

WHAT IS THE PURPOSE OF THE COOKIES ISSUED VIA THE WEBSITE?

Subject to your choices, various cookies may be installed on your device for the purposes detailed below. For the sake of transparency and in as much depth as possible, we inform you of the purposes of the third-party cookies that we are aware of, and the ways in which you can make choices about these cookies. All cookies may be cross-referenced with your customer data in order to personalise your experience, limit commercial interaction, ensure the proper functioning of your loyalty benefits, improve our services and guarantee your satisfaction.

Essential cookies for Website operations

“Essential” cookies are necessary for Website browsing and allow you to use the Website’s main features.

For example, these cookies are intended particularly for:

  • saving your choices or desire not to make a choice about tracker cookies;
  • service authentication;
  • saving the contents of a shopping cart;
  • customising the interface.

Removing them may make it hard to browse the Website or may make it impossible to place an order. These cookies may be installed on your device by Braces or its service providers.

These cookies enable or facilitate digital communications and/or may be strictly necessary for the provision of an online communication service at your express request. As a result, they do not require your prior consent. Saving or reading such cookies is necessary for provision of the service and will be based on Braces’ legitimate interest in implementing such processing for the proper use of its Website.

Personalization cookies

Personalization cookies allow us to personalise and improve your user experience, for example by making your searches easier and optimising your shopping experience. They also allow us to adapt the look of the Website to your device display during your visits.

These Cookies are issued by Braces and/or by our service providers. The issue and use of cookies by third parties on our Website may also be subject to the privacy protection policies of these third parties.

Such cookies are saved or read, subject to your prior consent. If you refuse these cookies, you will not be able to benefit from the functionalities described in this paragraph.

Analytical cookies

Analytical cookies make it possible to gauge the audience for various Website content, to establish visitor statistics and volumes in order to evaluate and improve our service ergonomics. These cookies include those used to create similar profiles that will be prospected according to your information.

These Cookies are issued by Braces and/or by our service providers. The issue and use of cookies by third parties on our Website may also be subject to the privacy protection policies of these third parties.

The information communicated to technical service providers is transmitted in the form of aggregate statistics and traffic volumes, excluding any personal information. These statistics are reconciled with the traffic statistics of other websites, as well as with your customer data.

Such cookies are saved or read, subject to your prior consent. Refusing the implementation of or deleting such cookies does not affect your Website browsing but is likely to prevent us from ensuring the best quality of service we wish to offer our visitors.

Sharing cookies (social links)

Our Website may include third-party computer applications that allow you to share Website content with others, or to publish your visit or opinion of Website content to these other persons. This is notably the case for “Share” and “Like” buttons on social networks such as Facebook, Twitter, Instagram, Pinterest, etc.

The social network providing such application buttons is likely to identify you through this button, if you use the button, and even if you have not used this button but are signed in to the social network when you consult the Website (open session during your browsing). Share buttons will allow you to connect the contents consulted to your user account.

We have no control over the process social networks use to collect information about your Website browsing and associated with the personal data at their disposal. We invite you to consult the privacy protection policies of these social networks.

Advertising cookies

Advertising cookies are not essential for browsing but allow you to see more relevant advertisements personalised to your interests on the Website as well as other websites you may browse. As such, advertising cookies allow, for example, the display of advertising, capping the display (not presenting the same advertising to a user in a repetitive manner), combatting click fraud, billing the display service, the measurement of targets more interested in the advertising to better understand the audience, etc.

Advertising content personalization can also be achieved by using our partner’s technology, to associate your device’s Website browsing information with the data you provided us when you registered.

Saving or reading such cookies is subject to your prior consent. Refusing these advertising cookies has no impact on your use of the Website, nor will it stop advertising on the Website. However, we will be unable to offer you advertising that takes your interests into account.

How long are the cookies kept?

Cookies saved on your device have a maximum lifespan of thirteen (13) months. At the end of this period, personal data collected through the cookies will be deleted.

HOW TO MANAGE COOKIES SAVED ON YOUR DEVICE

Cookies saved on your device result from the settings you have chosen during your visit, which can be modified at any time under the conditions detailed in this cookie policy.

There are various ways to manage the implementation of cookies, as presented below.

If your device is used by more than one person and operates more than one browser, we cannot be certain that the services and advertisements sent to your device are appropriate for your personal use of your device, rather than of another user of your device. If you choose to share your device and browser cookie settings with others, you are responsible for doing so at your own discretion.

You can express your choices using:

The cookie manager

You can decide whether cookies are saved on your device using the cookie settings tool in the cookie banner or in the Website footer.

Cookies are managed for cookie purposes.

Your browser settings

You can also configure your browser to accept and save cookies on your device or to reject them.

Each browser has different settings. These are usually described in your browser help menu. We therefore recommend reading it. This will show you how to change your cookie preferences.

Please note: any choices in your browser settings concerning the acceptance or refusal of cookies will be likely to modify your Internet browsing experience and your access to the Website and certain services requiring the use of these same cookies.

NOTICE ABOUT SOCIAL LOGIN

Privacy Notice – Register using social providers

For what activities personal data are processed

By creating a Braces account, logging on bracesblack.com via Google, Facebook, Line, Kakao or by binding your Braces account to your Google, Facebook, Line, Kakao accounts, in this case, you are sharing your profile information with us. The personal data shared depends on the configuration of the social network platform

In order to facilitate the account creation process, we can pre-fill the account creation form with information retrieved from the social provider account.

What data are exactly involved :

The types of information that Braces can collect depends on the settings selected for that provider and is subjected to the processing details under their own established privacy policies. Here are the types of information per

  • Google : first name and last name, e-mail, language preferences (not used), profile picture (not used)
  • Facebook : first name and last name, e-mail, profile picture (not used)
  • Kakao login : fullname (not used), e-mail, phone number
  • Line : first name and last name, e-mail, phone number, profile picture (not used)

Who is the Data controller: is Braces, a partnership company under Indian law, and all the affiliates of Braces with whom you share your information. Please note that as displayed in the section “Who may access your data” referred to in our global Privacy Statement your social media connection data is administered and managed by the above listed social media platforms acting on your social media account and may act as Data Controller. Please note that these social networks apply their own privacy policy, settings and standards.

Where can I find further information? Please contact us as below if you wish to exercise your rights under applicable Data Protection Laws or if you have any questions or complaints regarding the processing of your personal data.

  • - By email at bracesblackk@gmail.com
  • - By Client Service Centre

What are your rights in relation to your Data?

4.1 Access, rectification and portability

In accordance with current regulations, You have the right to access your Data. You may also request correction of Your Personal Data should they be inaccurate. Depending on the purpose of processing, You also have the right to have incomplete Personal Data completed.

To respond to your request, We may ask You to provide Us with a proof of your identity. We may also need to ask You for additional information or supporting documents. We will make every effort to respond to your request as soon as possible.

You may, to the extent provided for by law, exercise your right to Data portability which allows You to retrieve, in an interoperable format, the Personal Data that You provided to Us.

4.2 Right to erasure of your Data and to limitation of the processing of your Data

You may request erasure of your Personal Data if:

  • You believe that our processing of your Personal Data is no longer needed for the purposes described in this Privacy Policy,
  • You believe that the processing is unlawful or You contest the accuracy of the Data We process about You,
  • You withdrew your consent to the processing of your Data.

Alternatively, to the extent provided for by law, You may request limitation of the processing of your Data.

Please note that despite the exercise of your right to erasure or processing limitation, We will store some of Your Personal Data when the law requires Us to do so, or to exercise or defend our rights.

4.3 Right to establish instructions for the management of your Personal Data after your death

When mandatory local provisions are provided, You may determine how You want Us to handle your Personal Data upon your death.

4.4 Procedure to exercise your Data protection rights

You can exercise your data protection rights in the following ways or if you have any questions or complaints about the processing of your personal data.

When the processing of your Data is based on your consent (e.g., subscription to the newsletter), You may withdraw your consent at any time without justification. This right can be exercised by changing your options regarding subscriptions to our newsletters or by contacting the Client Service Centre.