1Collection of personal data
When creating your account and placing orders on the website www.spartoo.com (hereinafter referred to as the Website), SPARTOO collects personal data. The protection of your personal data is at the heart of SPARTOO’s concerns, which is committed to constantly improving its compliance with the General Data Protection Regulation (GDPR), as well as the Data Protection Act No. 78-17 of 6 January 1978 (LIL).
The term “personal data” is defined by the CNIL as “any information relating to a natural person who can be identified, directly or indirectly”.
2The person responsible for processing personal data
The person responsible for processing personal data is defined as a company determining the purposes and means of processing.
Personal data collected on the Site is processed by:
SPARTOO Société Anonyme
Registered with the RCS of Grenoble under number 489 895 821,
Whose head office is located at 16 rue Henri Barbusse 38100 Grenoble (hereinafter: SPARTOO)
SPARTOO has appointed a personal data protection officer (hereinafter: DPO).
You can contact the DPO by:
– Email: at [email protected]
– Postal mail: SPARTOO – DPO -16 rue Henri Barbusse 38100 Grenoble
3Examples of categories of personal data collected
What personal information does SPARTOO collect about its customers?
– Information that you communicate to us
We collect and record all the information that you communicate to us on your SPARTOO account. You can choose not to communicate certain information to us, this decision could however deprive you of some of our services.
– Information collected automatically
When you browse the SPARTOO site, we automatically collect certain information, in particular relating to your use, your interaction with the content of the SPARTOO site. This collection occurs mainly via “cookies”.
– Information from other sources
Our marketing partnerships also allow us to collect personal data about you, this collection being conditional on your express prior consent expressed to the attention of said partners.
The processing of personal data concerns in particular:
– Identity;
– Payment data;
– Transaction data;
– Family, economic or financial situation;
– Browsing data;
– Data relating to the monitoring of the commercial relationship: order history, after-sales service information, order details, delivery incidents, complaints, exchanges, comments;
– Data relating to invoice payments;
– Data necessary for carrying out loyalty and prospecting activities;
– Data relating to the organisation and processing of competitions and any promotional operation;
– As part of the fight against fraud: proof of identity or address and a truncated copy of your bank card;
– Telephone recordings during your calls to customer service. (You have the option of refusing recording during your call).
4Purposes of data collection
For what purposes does SPARTOO process my personal information?
SPARTOO processes personal data in order to provide and improve its services and customer experience.
These purposes include in particular:
– Orders, delivery of products
SPARTOO processes personal data mainly for the purpose of: processing orders, enabling delivery of products, making payments and communicating with customers regarding their orders, products, services and promotional offers.
– Personalizing your SPARTOO customer experience
We use your personal information to recommend products and services that may be of interest to you by identifying your preferences and personalizing your SPARTOO experience.
– Compliance with our legal obligations.
In certain cases, we have a legal obligation to collect and process your personal information.
– Enabling optimized communication with our customers
– Fraud prevention
Some personal data processing operations require your consent for a specific purpose. When you consent to the processing of your personal information for this specific purpose, you can withdraw this consent at any time and it will be terminated.
If you do not wish to receive the SPARTOO newsletter, you can unsubscribe from the my subscriptions tab in your account.
If you do not want us to use your personal information to display advertisements based on your interests, simply notify us in the my cookie settings section.
If you wish to browse our websites anonymously, you can do so by logging out of your account and disabling cookies on your browser.
5Categories of recipients of personal data
The categories of recipients of your personal data are:
– SPARTOO’s internal services
Access to your personal data within the SPARTOO company will be limited to categories of employees within the limits of their attributions and depending on the purpose of the processing of this data.
(The data we collect may be transmitted to some of our subsidiaries and some of our external service providers, they concern in particular: the processing of product orders, the delivery of products, the processing of payments. These third-party service providers have access to the personal information necessary for the performance of their services and are not authorized to use them for other purposes and are also required to comply with the laws applicable to the protection of personal data.
– Some personal data is transferred to a country outside the European Union. When we transfer personal information to countries outside the European Economic Area, we ensure that this information is transferred in compliance with the laws applicable to the protection of personal data.
Example: a subcontracting contract with a company domiciled in Madagascar which takes charge of part of SPARTOO’s customer service activity; All necessary measures and guarantees to secure such transfers have been taken.
– Your personal data may also be received by public bodies, exclusively to meet legal obligations, legal assistants, ministerial officers and bodies responsible for debt recovery.
6The legal bases
A legal basis for processing is defined as the element legally authorizing its implementation, which gives an organization the right to process personal data. The legal bases are distinct depending on the type of processing carried out:
– The contract: concerns the processing of all data necessary for the contract entered into.
– Consent: you choose to communicate your personal data by expressly giving your consent which can be withdrawn at any time.
– Legitimate interest: the interest must meet the criteria of legitimacy, necessity, and not conflict with the rights and interests of the persons whose data is processed.
– Legal obligation: The processing of personal data results from a legal obligation.
7All treatments implemented
| Customer management | |
| Purpose of processing | Management of commercial relations, orders, delivery, customer account. |
| Legal basis for processing | Necessary for the conclusion and performance of the contract |
| Recipients | Internal services SPARTOO Subsidiaries Subcontractor |
| Duration of retention in active database | 3 years * |
| Management of prospects with and without SPARTOO account | |
| Purpose of processing | Create and manage prospect files, carry out prospecting and promotion operations for SPARTOO and partner products. |
| Legal basis for processing | Consent |
| Recipients | SPARTOO internal services |
| Duration of retention in active database | 3 years * |
| Fight against fraud | |
| Purpose of processing | Fight against fraud |
| Data processed | Supporting documents requested as part of the fight against fraud |
| Legal basis for processing | Legitimate interest which consists of preventing fraud |
| RECIPIENT | SPARTOO internal services |
| Duration of retention in active database | 6 months |
| Storing invoices | |
| Purpose of processing | Storing invoices |
| Legal basis for processing | Legal obligation |
| Recipients | SPARTOO internal services |
| Interim base retention period | 10 years from the date of issue of the invoice |
| New Life User Management | |
| Purpose of processing | Allow intermediation between private buyers and sellers of second-hand items |
| Legal basis for processing | Necessary for the conclusion and performance of the Contract |
| Recipients | Internal services SPARTOO Subsidiaries Subcontractor |
| Duration of retention in active database | 3 years* |
| Competition management | |
| Purpose of processing | Participation in competitions, winning prizes, collecting prospect data |
| Legal basis for processing | Necessary for the conclusion and performance of the contract, consent |
| Recipients | SPARTOO internal services Commercial service providers |
| Duration of retention in active database | 3 years* |
| Management of access rights, rectification, opposition, deletion, limitation, portability | |
| Purpose of processing | Allow customers and prospects to exercise their rights regarding the processing of their personal data |
| Legal basis for processing | Legal obligation |
| Recipients | Legal services |
| Duration of storage in database | in intermediate base: 5 years* in active base: 24 hours for identity documents communicated as part of the exercise of the right to portability |
| Storage of payment data in the context of a one-off payment (in encrypted form [B-crypt]) | |
| Purpose of processing | On-time payment |
| Legal basis for processing | Necessary for the conclusion and performance of the contract, Legal obligation |
| Recipients | SPARTOO internal services |
| Duration of storage in database | on an intermediate basis: 13 months from validation of payment (Article L.133-24 of the French Commercial Code) on an active basis: until validation of payment |
| Cookie management | |
| Purpose of processing | Sending targeted advertising and establishing statistics |
| Legal basis for processing | Consent |
| Recipients | SPARTOO internal services |
| Duration of storage in database | 13 months after cookie deposit |
* from the last active step: click on a hyperlink, order on the Site, connection to the customer account, visit to the Site.
8The duration of storage of personal data
How long do we keep your personal information?
We keep your personal information for a period necessary to achieve the relevant purposes and to fulfill legal obligations such as tax or accounting obligations, or for any other period that may have been communicated to you.
For the same processing, personal data undergoes several phases of conservation. Depending on the type of processing and its purpose, the conservation periods differ.
– The first phase of conservation is storage in an active database. Conservation depends on the achievement of the purpose of the processing that justifies its collection. The data is accessible to the operational services that are in charge of the processing.
– The second phase is intermediate archiving. The data collected is no longer used to achieve the purpose for which it was collected, but it retains an administrative interest, such as the management of litigation, unpaid debts, or its conservation is authorized or required by law. Intermediate archiving is carried out within the limits of the applicable limitation periods, or in accordance with legal conservation obligations. Access to this data will be restricted to a list of duly authorized Spartoo employees.
– After this intermediate archiving phase, your data will be anonymized.
To determine the retention period of your data, it is necessary to define the starting point. In accordance with the recommendations of the CNIL, this starting point is defined by the last positive action of the customer or prospect which assumes a real step demonstrating an interest in SPARTOO; for example:
– clicking on a hyperlink,
– an order,
– logging into the customer account
– visiting the site.
9Security
SPARTOO takes all necessary precautions to preserve the security of your personal data.
It ensures physical and electronic security measures and backup procedures in relation to the collection, storage and communication of customers’ personal information. These measures may include, in particular, requesting proof of your identity as part of a request for portability of your personal data.
SPARTOO notably encrypts, pseudonymises and anonymises personal data and implements a binding password management policy. SPARTOO
uses a data breach processing register, in accordance with Articles 33 and 34 of the GDPR and undertakes to prevent any data breach, to react appropriately, and to notify breaches to the CNIL and the persons concerned in strict compliance with the deadlines established by the GDPR.
SPARTOO also reminds you of the importance of protecting yourself against unauthorised access to your customer account and the confidentiality of your password.
10Cookies*
In order to allow our systems to recognize your browser or device and to provide you with SPARTOO services, we use “cookies”.
These “cookies” are set up in order to better serve you.
We measure the number of pages viewed, the number of visits, as well as the activity of visitors on the Site and their frequency of return. For this purpose, we use “cookie” technology. A cookie does not allow us to identify you. Generally speaking, it records information relating to the navigation of your computer on our site (the pages you have consulted, the date and time of the consultation, etc.) that we can read during your subsequent visits.
The data collected by cookies is solely and strictly intended for internal use and is never transmitted to third parties. The use of cookies, whether our own or third parties, is not necessary for the operation of the site and requires your express consent.
You can express your consent or object to the use of cookies by setting your browser appropriately. For this, refer to your browser’s user guides.
Some cookies called “advertising cookies” allow us to track your browsing and record the products viewed, then within a maximum period of 90 days to present you with advertising banners related, or not, to your past browsing. These cookies are linked to your internet profile (but do not allow you to be identified). They also require your express consent in the same way as indicated above. If you do not wish to receive or no longer wish to receive these “advertising cookies”, click on the following link:
Disable advertising cookies on my profile
*We are also in the process of updating our Privacy Policy regarding cookies and trackers.
11Right of access and rectification
In accordance with EU Regulation 2016/679, you have several rights, namely:
– A right to access, modify, rectify and delete information concerning you.
– The right to request the portability of this information.
– The possibility of opposing the processing of your personal information or asking us to restrict the processing of your personal information in certain cases.
You can also send your requests:
– by email: to [email protected]
– by post: SPARTOO – DPO – 16 rue Henri Barbusse 38 100 Grenoble
12Right to lodge a complaint with a competent authority
You also have the right to lodge a complaint with the CNIL:
https://www.cnil.fr/fr/plaintes
13Evolution of the personal data protection policy
This privacy policy is subject to change, particularly in light of legislative and regulatory developments.