Privacy Statement

At Stella Luna, we are committed to protecting and respecting your privacy.

This notice sets out key information regarding Stella Luna and how any personal data you provide to us will be processed and used.

A: WHO ENSURES THAT YOUR DATA IS HELD SECURELY?

Under the data protection law, the Data Controller is responsible for ensuring that your data is held securely, that you are given accurate information about how your data is used, and that your rights regarding your data are respected.

For the purposes of both the UK Data Protection Act 2018 and the European Union's General Data Protection Regulation of 2016, the Data Controller for any personal data that we hold about you is Stella Luna, 38 Rue du Mont Thabor, Paris 75001, France, which may be referred to in this text as 'we', 'our', 'us.'

If you use our services, we may refer to you in this text with the terms 'user', 'visitor', 'you', 'your', 'yours' in this policy.

If after reading this, you would like more information about how we collect, use and store your personal data, please e-mail us at: info@stellaluna.paris or write to: The Privacy Team at Stella Luna, 38 Rue du Mont Thabor, Paris 75001, France

B: WHAT PERSONAL DATA DOES STELLA LUNA COLLECT?

We collect and process only the data that is required to allow us to provide the very best service for you. When you browse or shop at stellaluna.co, we collect the following types of data:

1. We process the personal data required to prepare and deliver your order, including your name, billing address, delivery address, payment details, mobile number, telephone number and e-mail address. We ask for your e-mail address in order to send you confirmation of your order; we ask for your telephone number so that we can contact you if there are any issues with the order.

2. We collect your e-mail address when you sign up to receive Stella Luna’s newsletter.

3. If you register for a Stella Luna account, we will collect your name, e-mail address, Stella Luna account password, country and additional data regarding your shoe preferences.

4. When you contact our Customer Care team, we may collect additional data to help us resolve any questions relating to your order, delivery, payments, marketing, the website or other queries.

5. In order to best serve you and build a better website, we will collect and process data about your browsing on StellaLuna.co, including which pages you visit and how you interact with these pages. If you have registered for an account, we collect browsing data about your access to the dedicated areas of the website.

6. If you are a customer of StellaLuna.co or if you have given us your consent, we collect and process your personal data for direct marketing activities.

7. If you provide us with someone else's data, (for example, if you purchase a product to be delivered to a friend or as a gift), we will collect and process the personal data required to complete the transaction including the name, delivery address and other contact details for your friend.

8. If you are receiving an item as a gift, we will process your data only to fulfil the gift request and our contractual obligations.

9. If you ever use any future app versions of Stella Luna, we will ask for your consent to collect personal data from you in order to send you brief messages, 'push notifications' about products and services that we believe might be of interest to you. With your consent, we will also collect data regarding your use of the App and your IP address, in order to improve our service to you. Of course, you can disable push notification at any time by updating the app settings on your mobile device.

10. When you call our Customer Care team, your call may be recorded for training and fraud prevention purposes.

C: HOW DO WE USE THE PERSONAL DATA WE COLLECT?

Stella Luna collects and processes your personal data for the following purposes:

11. When you purchase a product from StellaLuna.co, we will ask you for the personal data necessary to allow us to fulfil our contract with you including taking payment, running related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery of the product and possible handling of the return.

12. When you visit StellaLuna.co, we will collect the minimum personal data necessary to allow us to provide you with the services of the website, such as placing and holding items in your shopping bag.

13. When you visit StellaLuna.co, we will use some data about your use of the website to help us improve the website and our promotion of the website. This will include data about how you came to the website; the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

14. We also collect data about your use of StellaLuna.co by using cookies. More information about how we use cookies and how you can, if you wish, turn off cookies is included in our Cookie Policy.

15. When you register on StellaLuna.co, we will collect the data necessary to ensure that we can recognise you on return visits and provide you with the services registration offers, such as creating a Wish List or subscribing to emails about your favourite designers. If you would prefer not to continue receiving these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team.

16. When you sign up for our marketing communications, we will ask you for your email address. If you would prefer not to receive these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team.

17. If you have purchased from StellaLuna.co, we will use the personal data we hold about you, including your purchase history, to contact you regarding products and services that may be of interest to you. This contact will normally be via email, but in certain circumstances we may contact you via other methods e.g. we may call you if an item we know you have been eager to purchase comes back into stock. If you would prefer not to be contacted in this way, you can unsubscribe from emails at any time using the link on the bottom of the email, or update your contact preferences on StellaLuna.co or by contacting our Customer Care team.

18. We analyze contact data, purchase history, web browsing data and lifestyle data to tailor our marketing communications, web site presentation and internet advertising to meet your preferences. For example, if you have been browsing or have previously purchased a particular shoe designer, we may send you an email to tell you that these are now on sale or display similar products to you as part of our internet advertising.

19. When you contact our Customer Care team, we will use the personal data you provide and that we have collected to respond to your requests for help or information.

20. When you use any future App versions of our website, we may collect data regarding your use of the App and your IP address, in order to send you push notifications about products and services that we believe may be of interest to you.

21. When you shop at a Stella Luna boutique, we ask you for the personal data necessary to allow us to fulfil our contract with you, including taking payment, any related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery. You have the option to provide us with your birthday and to subscribe to marketing communications and those from our partners.

22. When you call our Customer Care team, your call may be recorded for training and fraud prevention purposes.

23. We will use the contact information that you provide to deliver service messages such as any change to our Terms and Conditions or Privacy Policy, delivery updates or other non-marketing communications.

D: WHAT IS OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

We are required by law to have a valid reason for using your personal data. We may not collect, store or use data about you that is not compatible with that valid, legal reason.

In sum, there are four valid reasons for our use of your personal data:

1. Most of the data we collect from you is necessary to allow us to fulfil our contract with you or to enter into a contract with you— for example, you provide a billing address and email address when your purchase an item from StellaLuna.co, allowing us to process your payment and send you your order confirmation.

2. In certain circumstances we will ask for your permission or consent to use your personal data — for example, if we would like to send you marketing information about items we believe may be of interest to you via e-mail. If you have given your consent to our use of your personal data, you are entitled to withdraw this consent at any time.

3. We may also have a legitimate interest in using your personal data — for example, to ensure that the content of our website is presented to you and your device as effectively as possible, or to ensure that our marketing communications are relevant to your interests. If this is our reason for using your data, we must make sure that our interests do not override yours and you are entitled to object to this use of your data.

4. Finally, we may be required to use your data to meet a legal obligation or to protect your interests— for example, we may exchange data with other organizations for the purposes of fraud detection and credit risk reduction and we will retain financial data for as long as is needed to meet our statutory obligations.

E: WHO WILL PROCESS YOUR DATA?

Your personal data will be processed by the internal staff of Stella Luna. The employees have been specifically trained and authorized for this processing.

Your personal data will also be transmitted to third parties that we rely on to provide our services; these parties have been rigorously assessed and offer a guarantee of compliance with all legal standards regarding the processing of personal data. These parties have been designated as data processors and will always carry out their activities according to the instructions given to them by Stella Luna and will always be under our control.

The third parties in question belong to the following categories: banking operators, internet providers, companies specialising in IT and telematics services; couriers; companies that carry out marketing activities, including social media organizations; companies specialising in market research and data processing; companies offering contact centre services; companies providing publishing and distribution services.

Under some circumstances we may be required to disclose or share your data without your consent, for example if we are required by the police, the court system or for other legal reasons. Your data may be transmitted to the police, judicial and administrative authorities, in accordance with the law, for the investigation and prosecution of crimes, the prevention of and protection from threats to public security, to allow Stella Luna to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.

We may also transfer your personal data to a buyer or potential buyer in the event that our assets are acquired by another organization. The purchaser will be required by law to use your personal data only as described in this Privacy Policy.

F: SAFEGUARDING ANY DATA TRANSFER OUTSIDE THE EUROPEAN UNION

Some of the third parties listed in the previous paragraph 'Who will process your data?' may be located in countries outside of the European Union —but they are, nevertheless, required to offer an adequate level of data protection, as established by specific decisions of the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)

The transfer of your personal data to countries that do not belong to the European Union and that have not been assessed as offering adequate levels of protection will be performed only:

1. After the completion between Stella Luna and said parties of specific agreements containing safeguard clauses and appropriate guarantees for the protection of your personal data (known as 'standard contractual clauses' and approved by the European Commission), or

2. if the transfer is necessary for the completion and execution of a contract between you and Stella Luna (for the purchase of goods offered on our website, for registration on the website or use of services on the website), or

3. for the management of your requests.

G: HOW LONG DO WE KEEP YOUR DATA?

Stella Luna will hold on to your personal data for only a limited period of time, in line with our data retention policy. The specific retention period will vary according to the reason for processing your personal data. After this period, your data will be permanently erased or otherwise irreversibly rendered anonymous.

Your personal data are retained in accordance with the following criteria:

1. When you have purchased goods from StellaLuna.co, we will retain the billing data until the end of the relevant accounting period, normally seven years from the billing date;

2. When you make a payment, we will retain your payment details up to the certification of the payment and the completion of the relevant administrative-accounting formalities regarding your right of withdrawal and the terms applied for the disputing of the payment;

3. When you provide us with personal data in order to use the services of Stella Luna, such as marketing communications, we will keep your data for this purpose until the termination of the service or until you cancel your subscription to the service;

4. When you give us your consent to send you marketing communications, you can withdraw your consent at any time. We will consider your consent to be current for five years from your last interaction with any e-mail that we send you, with our App or with StellaLuna.co. In any case, we will reduce the number of marketing contacts after six months, if you don't interact with us;

5. When we use your personal data and browsing history to analyze your behaviour in order to customize the website and to show you personalized sales offers, we will keep the data for analytical purposes until you ask us to delete it;

6. When we use personal data for market research and satisfaction surveys, we will keep the data until you ask us to stop.

7. When you contact our Customer Care team, we will keep any additional personal data you provide that is specific to your inquiry for as long as you remain an active customer of StellaLuna.co

8. When you contact our Customer Care team, we will preserve the call recording for six months. Please note that credit card details are not recorded as part of the call.

H: YOUR RIGHTS

You have the right to request a copy of the data that we hold about you (and we will provide this to you free of charge once we have confirmed your identity).

If you would like a copy of some or all of your personal data, please e-mail us at: info@stellaluna.paris or write to: The Privacy Team at Stella Luna, 38 Rue du Mont Thabor, Paris 75001, France

If we do hold data about you, we will:

1. Give you a description of it

2. Tell you why we are holding it

3. Tell you who it could be shared with

4. Tell you how long we will keep the data

5. If the data was not provided by you, we will give you any available information such as the source of the data

6. Tell you if the data has been used for automated decision making

7. Tell you if the data is stored outside of the European Economic Area, and if so what safeguards are in place to protect your personal data

8. Let you have a concise and clear copy of the data

You have the right to ask us to correct any inaccuracies in the personal data we hold about you and to stop us from using your data until it has been corrected. We do want to make sure that your personal data is accurate and up to date and we will be happy to correct or remove data you think is inaccurate.

If you have given us your consent to use your personal data for marketing, you have the right to withdraw your consent at any time by calling our Customer Care team, clicking 'unsubscribe' on a marketing email or replying STOP to a text message. Alternatively, you can sign into your account on StellaLuna.co and update your account preferences. You may receive a small number of further communications immediately after unsubscribing, but we will implement your request as quickly as possible.

You have the right at any time to oppose our processing of your personal data on the basis of our legitimate interest. You will need to explain the reasons behind your request and allow us to consider your request and respond.

You have the right to request the deletion of your personal data. After receiving and reviewing your request, if legitimate, it will be our responsibility to promptly cease processing and to delete your personal data.

You have the right to receive a copy of your data that we process based on your consent or on the basis of a contract with you in a standard format. If you wish, where technically possible, we can transfer your data directly to a third party indicated by you.

To exercise any of these rights, you can sign in to your account and/or e-mail us at: info@stellaluna.paris or write to: The Privacy Team at Stella Luna, 38 Rue du Mont Thabor, Paris 75001, France

To ensure that the data of our users are not subject to breaches or illegitimate use by third parties, we will need to ask you to confirm your identity before carrying out your request.

I: SECURITY

We protect your personal data with specific technical and organizational security measures aimed at preventing your personal data from being used illegitimately or fraudulently.

J: COMPLAINTS

If you believe that Stella Luna is not complying with the law in the processing your personal data, you can file a complaint with the supervisory authority responsible for compliance with the rules on personal data protection.

K: CHANGES TO THIS NOTICE

Stella Luna keeps its Privacy Policy under regular review in order to reflect changes in our services and in privacy regulation. This Privacy Policy was last updated on May 20, 2018

L: COOKIE POLICY

When you view our website, information relating to your browsing may be stored in 'Cookie' files stored on your device, depending on the Cookie preferences that you may have selected and which you can change at any time. Only the sender of a cookie can read or modify information stored in it.

When you connect to StellaLuna.co, we may, depending on your selected browser preferences, install various cookies on your device.

The Cookies that we send enable us to:

1. Recall information relating to a form that you filled in on our website (sign-up or access to your account) or to products, services or information that you have previously selected on our website (service subscribed to, contents of a basket, etc.)

2. Enable you to access private and personal areas of our website, such as your account, using usernames or data that you may previously have sent to us

3. Implement security measures, for example when you are asked to sign in again after a certain period has elapsed

The cookies that Stella Luna may use on our online services can be grouped into the following categories

Essential cookies: Some of the cookies on our online services are essential for us to be able to provide you with a service you have requested. An example of this would be a cookie that enables you to log into your account on the website, or one which allows communication between your browser and the website. Our cookie-preference cookie, described in the section 'How to reject or opt out of receiving cookies’, is also an essential cookie. You may not be able to use our website without these cookies.

Website functionality cookies: These cookies enable you to browse our online services and use features such as shopping baskets and wish lists.

Website analytics cookies: We use these cookies to measure and analyse how our customers use our online services. An example is counting the number of different people visiting our website or using a particular feature, rather than the total number of times the site or feature is used. This allows us to continuously improve our online services and your shopping experience.

Customer preference cookies: When browsing or shopping online, our online services will remember preferences you make (for example your user name, language or location). This improves your experience and makes your browsing simpler, easier and more personal to you.

Social sharing cookies: When browsing or shopping online, our online services will remember preferences you make (for example your user name, language or location). This improves your experience and makes your browsing simpler, easier and more personal to you.

Interest-based advertising cookies: You will have noticed, when visiting other websites, that you are shown adverts for products and services you may wish to buy. The money made by website owners for showing third-party adverts on their websites often pays for the cost of running the website, and therefore often allows you to use the website without having to pay a registration or usage fee. Like many businesses, we may place ads for our products on partners’ websites. However, to try and ensure that the ads that you see are relevant to you, we might use cookies to collect information about the types of things that interest you, for example websites that you visit and your geographic location. Having these cookies will not increase the number of adverts you will be shown, but simply make the ads you see more relevant for you. In addition, they will limit the number of times that you see any ad, as well as helping us to measure the effectiveness of our ad campaigns.

How to reject or opt out of receiving cookies

If you want to delete any cookies that are already on your computer, please refer to the help and support section on your internet browser for instructions on how to locate the file or directory that stores cookies.

Please note that our online services cannot always control third-party cookies stored on your machine from our online services and that setting your cookie preferences with us will not stop those third-party cookies from being stored on your machine. Therefore you must manage these cookies directly with the relevant third party. Please see our 'Third party cookies’ section below for more information.

Information on deleting or controlling cookies is available at www.AboutCookies.org. Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our site.

How to choose your cookie settings, depending on which browser you use

To manage cookies and make choices, each browser is configured differently. Your browser's configuration will be described in its help or preferences menu, which will show you how to change your cookie preferences.

If you want more details on about how cookies work and how to manage or delete them, visit the World Wide Web Consortium's website (or, for third party cookies, visit http://www.youronlinechoices.com/).

For Internet Explorer™:

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

For Safari™:

https://support.apple.com/kb/PH21411?viewlocale=en_US &locale=en_GB

For Chrome™:

https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop &hl=en-GB

For Firefox™:

https://support.mozilla.org/t5/Protect-your-privacy/Enable-and-disable-cookies-that-websites-use-to-track-your/ta-p/2784

For Opera™:

http://help.opera.com/Windows/11.60/en/cookies.html

Note: if you block the storage of cookies on your device, or if you delete cookies stored on it, you will no longer be able to enjoy a certain number of features which are nonetheless necessary for browsing a number of areas of StellaLuna.co. This would be true if you tried to access our content and services that require you to sign in. It would also be true when we – or our providers – cannot recognize, for the purposes of updating our technical records, the type of browser used on your device, its language and display settings, or the country from which your device seems to be connected to the Internet.

When cookies have been blocked or deleted, visitors may experience less than ideal performance of our services resulting from an inability to store or consult the cookies which are needed for these services to function. Among the services most affected by a blocking of cookies may be:

• Secured Payment

• Fast Delivery

• Satisfied or money back

• Click & Collect