PRIVACY STATEMENT OF G-STAR

Date: 08/2018

G-Star Raw C.V., G-Star eStore B.V., Erno’s B.V.  and their operating groups, subsidiaries and divisions (hereafter “G-Star”, “we” or “us”) are committed to protecting the privacy and security of personal data.  G-Star has created this Privacy statement to explain about how G-Star collects and uses personal data. 
Many G-Star stores are owned and operated by independent entrepreneurs. This Privacy statement does not apply to the collection and use of your personal data by independent entrepreneurs. Please see the privacy notices of the independent entrepreneurs for information on how they use your personal data.

Contact information
G-Star Raw eStore B.V.
Joan Muyskenweg 39
1114 AN Amsterdam

service.cy@g-star.com
www.g-star.com

For the contact details of our operating groups, subsidiaries and divisions, please see here.

Overview
This Privacy statement explains how G-Star processes you personal data by answering the following questions:
1. Does this Privacy statement apply to you?
2. What personal data does G-Star process and for which purpose?
3. Who has access to your personal data?
4. How long will G-Star keep your personal data?
5. What measures does G-Star take to protect your personal data?
6. Where does G-Star store and transfer your personal data?
7. What rights can you exercise in relation to your personal data?
8. What if you have other questions or complaints?
9. Will there be updates to this Privacy statement?

1. Does this Privacy statement apply to you?

This Privacy statement applies to you if you:
  • are a customer of G-Star;
  • have a subscription to the G-Star newsletter or participate in a promotional activity of G-Star;
  • visit the website of G-Star (www.g-star.com) or one of the underlying sub-pages (“Website”);
  • visit a G-Star store.

2. What personal data does G-Star process and for which purpose?

In the course of its business activities and offering and providing the products and services, G-Star will need to process personal data. “Personal Data” is any information that can directly or indirectly be used to identify a natural person. You provide most of your personal data directly to G-Star. In some cases, the personal data is collected automatically by G-Star, or obtained from a third party source. 
Below, we will explain per category as indicated in paragraph 1 which personal data is processed by G-Star, for which purpose(s) and on which legal basis. It is possible that you fall in more than one category, for instance if you are a customer of G-Star and also participate in G-Stars promotional activity. 

a. You are a customer of G-Star

G-Star processes personal data of its customers to enable the sale of products, for which G-Star needs to be able to enter into an agreement with you, process your payment and ship the product to you. Furthermore, it is necessary for G-Star to conduct related processing such as provide security, fraud prevention and credit checks and registration.
In this context, G-Star processes the following personal data:
  • Contact information, including your name, (invoice and delivery) address, e-mail address and phone number;
  • Personal information, including your date of birth and preferences;
  • Order information, including product, size, payment method, shipping method, order history;
  • Financial information, including your bank account number, credit card number, invoice specifications, order amount, payment status;
  • Optional information, such as your gender, company information and account details.  
Furthermore, you can make use of the following related services of G-Star:
Account: to optimize and simplify your shopping experience, you can create an account on the Webiste. To create an account, G-Star needs the following information:
  • Contact information, including your name, address, e-mail address and phone number;
  • Account information, including your e-mail address and password.
In addition, you can provide the following optional information in your account:
  • Personal information, including your gender, date of birth and company information; 
  • Preferences, including your preferred store, product categories and size.
Customer Service: if you have questions or complaints regarding the products or services of G-Star, you can contact G-Stars customer service. The customer service can be reached by telephone or by using the contact form on the Website. Before G-Star can process your question or complaint, G-Star may need to verify your identity based on you personal data. In the course of the customer service activities, G-Star may receive the following personal data:
  • Contact information, including your name, address, e-mail address, age, gender, data of birth, nationality and phone number;
  • Content, including the subject of the message, remarks, images and screenshots, the content of the telephone conversation;
  • Optional information, such as order number. 
The legal basis for this processing of personal data is that processing is necessary for the performance of the contractual relationship with you, for the legitimate business interests of G-Star to provide and improve their products and services, and/or to comply with statutory legal obligations of G-Star.

b. You have a subscription to the G-Star newsletter or participate in a promotional activity of G-Star

G-Star would like to keep you informed of news relating to G-Star and send you special offers. If necessary we will ask your consent before sending you our newsletters and offers. To send you our newsletter, G-Star processes the following information:
  • Contact information, including your name, address, e-mail address, age, gender, data of birth, nationality, phone number, Social Media details;
  • Order information, including order history, preference history, products in basket;
  • Preferences, including preferred store (location), size;
  • Technical information, including subscriber key, account type, customer sentiment.
If you have indicated your preferences in your account, we will tailor our communication to what we think you will be interested in and provide you with personalized offers. Each communication will include an opt-out link to allow you to unsubscribe from the newsletter. You may also adjust your preferences in your account. 
Promotional activity. G-star may also organize a promotional activity in which you may participate. To conduct the promotional activity, including for instance to select a winner and communicate the results, G-Star may require the following information:
  • Contact information, including your name, address, e-mail address, age, gender, data of birth, nationality and phone number;
  • Promotional information, including the content you provide in order to participate in the promotional activity;
  • Technical information, including a promotional code.
The legal basis for this processing of personal data is consent, unless that processing is necessary for the performance of the contractual relationship with you, for the legitimate business interests of G-Star to provide and improve their products and services, and/or to comply with statutory legal obligations of G-Star.

c. You visit the Website 

If you visit the Website, G-Star will - after obtaining your consent where legally required -  automatically collect information by means of cookies and similar technologies. This information may consist of:
  • Identifiers, including IP-address, cookie-id or device-id;
  • Information about your connection to the website, webpages and/or the ad server, including the date, time and type of the connection;
  • Internet browser details, including browser type and language settings;
  • Operating system details, including OS type and language settings;
  • Device details, including location and (in case of mobile device) longitude, latitude, model and carrier;
  • Use of and interaction with the website, webpage or advertisement, including your interests and click-trail;
  • Information on the advertisements presented to you;
  • Social Media details, such as account details.
G-Star uses this personal data for the following purposes:
  • To perform our obligations under our agreement with you; 
  • To help us and third parties obtain information about your visits to the Website;
  • To analyse your use of the Website to improve our Website;
  • To deliver advertising, communications and content from us and third parties, on our Website and those of third parties, specific to your interests;
  • To remember your language and other preferences;
  • To help you obtain information you are looking for;
  • To provide a safe and secure service and transactions;
  • To measure how many people use our sites, and how they use them, to keep our sites running efficiently and to better understand our audiences;
  • To secure, amend and improve our Website;
  • To provide your information to third parties in accordance with this Privacy statement.
We will analyze your information to build individual profiles. These profiles will be used to predict future interests and display targeted (online) advertisement. The aim is to provide you with offers that are relevant and interesting for you. The profiling is based on your (surfing) behaviour on the internet. This includes the viewing of advertisements, any interaction with it and the overlap between desktop and mobile usage. As your name is not collected, we expect that our profiling will have no further impact, other than providing you with a more pleasant user experience.
To learn more about the use of these technologies, please consult our Cookie Statement.
The legal basis for this processing of personal data is consent, unless that processing is necessary to provide for the legitimate business interests of G-Star to provide and improve the Website and show you relevant offers, and/or to comply with statutory legal obligations of G-Star.

d. You visit a G-Star store

When you visit a G-Star store, either owned and operated by G-Star or by an independent entrepreneur, G-Star may process your personal data for the following purposes.
Protecting rights and security. In order to protect the rights and security of our organization, employees and visitors and in order to investigate crimes or violations of our policies we have a legitimate interest to process the following personal data:
  • Video images.
Improving product and services. In order to improve our products and services, for example by counting the number of visitors to G-Star stores and optimizing the lay-out of products in G-Star stores, we may process the following personal data:
  • First and last name;
  • E-mail address;
  • Identifiers such as your MAC address or IP address;
  • Time and location of your visit to a G-Star store.
The legal basis for this processing of personal is consent, unless the processing is necessary for the purposes of the legitimate business interests of G-Star to improve its products and services. We may for example ask for your consent when you log-in to Wi-Fi in G-Star stores. Some of the personal data mentioned above may be provided to G-Star by third party service providers, such as SO WIFI.
Signing up for the newsletter. When you visit a G-Star store, you may be provided the opportunity to sign up for our newsletter. Please see the information above where we explain which personal data we may process when you have signed up for the newsletter. When you decide to sign up for the newsletter during a visit to a G-Star store, we may process the following personal data:
  • First and last name
  • E-mail address
The legal basis for this processing of personal is consent, unless the processing is necessary for the purposes of the legitimate business interests of G-Star to improve its products and services.

3. Who has access to your personal data?

G-Star may share your personal data with third parties in the following circumstances:
  • G-Star may share your personal data with its affiliates, operating groups, subsidiaries and divisions, or with third parties if such is necessary for the purposes as listed above. If appropriate, G-Star will require third parties to conduct activities in a manner consistent with G-Star policies and guidelines in relation to data protection.

  • G-Star may share your personal data with data processors, i.e. parties processing personal data on our behalf. In such cases, these third parties may only use your personal data for the purposes described above and only in accordance with our instructions. G-Star will only use processors which provide sufficient guarantees to implement appropriate technical and organizational measures and ensure the protection of the rights of data subjects.

  • G-Star employees may have access to your personal data if necessary for the performance of their tasks. In such a case, access will be granted only if necessary for the purposes described above and only if the employee is bound by confidentiality. 

  • G-Star may share your personal data if required to do so by law, court order, or other legal process, for example, with law enforcement agencies or other governmental agencies, to establish or exercise our legal rights or in connection with a corporate transaction, such as a divesture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

4. How long will G-Star keep your personal data?

G-Star retains your personal data for a limited amount of time and will delete your personal data after it is no longer necessary for the purposes of the processing.  The exact period of time is based on the type of the personal data and the legal obligations or business purposes for retaining it. After the retention period, the personal data will be either destroyed or anonymized.

5. What measures does G-Star take to protect your personal data?

G-Star has taken appropriate technical and organizational measures to protect your personal data against accidental or unlawful processing, including by ensuring that: 
  • your personal data is protected against unauthorized access;
  • the confidentiality of your personal data is assured;
  • the integrity and availability of your personal data will be maintained;
  • personnel is trained in information security requirements; and
  • actual or suspected data breaches are reported in accordance with applicable law.

6. Where does G-Star store and transfer your personal data?

Due to the nature of our business and the services we provide to our clients, G-Star may need to transfer your personal data to locations outside the country where you reside. In any case where we transfer personal data, G-Star shall ensure that such a transfer is subject to appropriate safeguards. 
For the European Union, such transfers to third parties may for instance be governed by a contract based on the model contractual clauses for data transfers approved by the European Commission as set out in article 46(2) of the General Data Protection Regulation. You can obtain an extract or copy of these documents by making a request using the contact details above.

7. What rights can you exercise in relation to your personal data?

Based on the law applicable to the use of your personal data, you may be able to exercise a number of rights in relation to your personal data. Note that in many cases, your rights are not absolute and we may not be required to comply with your request.  A number of such rights, as may be applicable in the European Union, are explained below. 
Right of access 
You are entitled to a copy of the personal data we hold about you and to learn details about how we use it. Your personal data will usually be provided to you digitally.
Right to rectification
We take reasonable steps to ensure that the information we hold about you is accurate and complete. However, if you believe this is not the case, you can ask us to update or amend it.
Right to erasure
In certain circumstances, you have the right to ask us to erase your personal data, for example where the personal data we collected is no longer necessary for the original purpose, where personal data has become obsolete or where you withdraw your consent. However, this will need to be balanced against other factors. For example, we may not be able comply with your request due to certain legal or regulatory obligations.
Right to restriction of processing
In certain circumstances, you are entitled to ask us to (temporarily) stop using your personal data, for example where you think that the personal data we hold about you may be inaccurate or where you think that we no longer need to use your personal data.  
Right to data portability
In certain limited circumstances, you may have the right to ask that we transfer personal data that you have provided to us to a third party of your choice.
Right to object
You have the right to object to processing which is based on our legitimate interests. Unless we have a compelling legitimate ground for the processing, we will no longer process the personal data on that basis when you file an objection. Note however, that we may not be able to provide certain services or benefits if we are unable to process the necessary personal data for that purpose.
Rights relating to automated decision-making
You have the right not to be subjected to automated decision-making, including profiling, which produces legal effect for you or has a similar significant effect. If you have been subject to an automated decision and do not agree with the outcome, you can contact us using the details below and ask us to review the decision. 
Right to withdraw consent
We may ask for your consent to process your personal data in specific cases. When we do this, you have the right to withdraw your consent at any time. G-Star will stop the further processing as soon as possible after the withdrawal of your consent. However, this does not affect the lawfulness of the processing before consent was withdrawn.  
Please use the contact details above if you would like to exercise any of your rights.

8. What if you have other questions or complaints?

Questions or complaints regarding the processing of your personal data can be directed at G-Star by using the contact information as provided at the top of this Privacy statement. 
You also have the right to lodge a complaint with local data protection authority in the jurisdiction where you work, where you live or where an alleged infringement takes place. A listing of the European Data Protection Authorities can be found here.

9. Will there be updates to this Privacy statement?

G-Star may update this Privacy Notice from time to time. If an amendment will have a serious impact, G-Star will endeavour to actively inform you about such amendments. G-Star will publish an up-to-date Privacy Notice on the Website at all times, indicating the latest amendments.
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