RECRUITMENT PRIVACY POLICY

1.     WHAT IS THE SCOPE OF THIS RECRUITMENT PRIVACY POLICY AND DO OTHER POLICIES ALSO APPLY TO YOU?

This Recruitment Privacy Policy (“Privacy Policy”) applies to situations where we, (as defined in the next paragraph), access, collect, store, process, use, disclose or transfer your personal information in paper or electronic form for the purpose of our recruitment process. It also applies to situations where approved partners or other members of the Kering Group use your personal information on our behalf.

We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the applicable data protection law with respect to the management of personal information. We are equally committed to ensuring that all our employees and agents uphold these obligations.

For the sake of clarity, any reference to “we,” “our” and “ours” in this Privacy Policy refers to the entity offering the position you are applying for. You can find additional details on each of these entities in Schedule 1 (List of Kering entities acting as controller) below.

When applying to one of our subsidiaries’ job offers, the subsidiary will, access, collect, store, process, use, disclose or transfer your personal information in paper or electronic form for its own recruitment process.

In some cases, other policies apply to you. This may be the case when you use certain specific services, and in this event: 

·       You will be notified of other policies when using services they apply to

·       Such policies will supersede this Privacy Policy unless they expressly refer to it

This Privacy Policy does not apply to services you might use where provided by other companies acting on their own account.

Our Privacy Policy does not extend to services provided by other companies acting on their own account, for example where you share information through job boards or social media (e.g., LinkedIn, etc.), or other online platforms owned and managed by other companies. These other companies have their own privacy policies in place, therefore any personal information you give them will be subject to their rules and not ours.

Lastly, in the event your application is successful and you accept an offer of employment from us, please note that any processing of your personal information carried out from this moment on is subject to a separate privacy policy (i.e., the privacy policy dedicated to our employees). In particular, any processing of your personal information related to your onboarding with us is subject to a separate privacy policy dedicated to employees and this policy will be provided to you in due time.

2.     WHO COLLECTS AND USES YOUR PERSONAL INFORMATION?

The entity processing your application and offering the position you apply to (as listed in Schedule 1 [List of Kering entities acting as controller]) is considered acting as “data controller,” which means this entity determines “why” and “how” your personal information is processed.

Where the entity offering the position you have applied to is not Kering S.A. (a French corporation [“société anonyme”], located at 40 rue de Sèvres, 75007 Paris, France and registered under number 552 075 020, with the Paris Trade and Company Register), then the latter is considered acting as “data processor” on behalf of the entity offering the position.

Please be aware that when you make an application through our approved partners’ websites, such as job platforms or social media, these partners determine “why” and “how” your personal information is processed. They have their own privacy and cookies policies, so the personal data processed by them may be subject to their policies and not ours.

Your local legislation may not refer to the terms “data controller” or “data processor,” but respectively to terms such as “data user,” “owner,” “business,” “responsible party,” etc., and as “data intermediary,” “operator,” etc.

In order to understand our role, please note that we are the entity deciding on the methods and purposes of the processing of your personal information by determining “why” and “how” your personal information is processed. Our “data processors” are entities who use your personal information on our behalf by receiving instructions from us on “how” and “when” they are allowed to use it.  

3.     WHY DO WE COLLECT YOUR PERSONAL INFORMATION?  

We will collect, hold, use and disclose your personal information for the purposes described in this section. The processing of your personal information will comply with your privacy legislation and rely on the legal basis set out in this section.  

If you would like more information on the purposes and legal basis, you can contact us using the dedicated email address provided in Schedule 1 (List of Kering entities acting as controller)  or see Section “How can you contact us?”.  

To manage our recruitment campaign

Our recruitment process is divided into several successive steps that start at the moment we define our job offer and end at the moment your application is accepted or declined. These steps correspond to the various purposes described below.

We process your personal information for the following purposes:

To automatize certain recruitment campaigns

We receive a large volume of candidate information for certain opportunities within Kering S.A and subsidiaries (as listed in Schedule 1), and therefore we may use data analytics and algorithms to help us review the large quantities of applications received. These algorithms help us prioritize the application review process and sort candidates based on the information available on your resume that suggest capabilities and skills necessary to perform the position.

The automated results are always considered jointly with, and not instead of human judgment. This automatic analysis will not automatically exclude applications.

To manage your candidate profile  

Once you have requested that we create your candidate profile, your personal information will be linked to this profile, and this is where we will keep all the information we have on your application. This could include personal information we obtain directly from you as well as from other sources in accordance with applicable legislation. 

When you apply for a job offer via our platform, we will ask you to create a candidate profile. This allows you to centralize all of your applications for Kering S.A or its subsidiaries’ offers in a single point, to integrate the supporting documents required for the application and keep your information up to date, or to allow us to easily interact with you.

You can also link your social media account information. If you choose to do so, your public account information will be made available to us and may form an integral part of your application to our job offer.

We process your personal information for the following purposes: Administering, managing and maintaining your candidate profile once you have requested us to create it. This could include data cleansing and deduplication.

To assess and better understand our recruitment campaigns  

In order to analyze, develop and improve our recruitment campaigns, we may process information about you, for example to understand the characteristics of the candidates who apply to our job offers and interact with our recruitment teams or partners.

We may use your information or information related to our recruitment campaigns in order to generate statistics or studies with the aim of obtaining information that allows us to improve our recruitment strategies. This information can range from information related to the job offer you are applying to, to information directly concerning you, such as your characteristics or your skills. We can generate these analyses internally or through, for example, our external partners in charge of the campaign.

To send you service communications or other work opportunities  

Service communications may be sent upon your request, and/or may be important for your safety and the security of your personal information. The information communicated may be necessary for the correct performance of our contract with you or be mandatory to comply with some of our legal obligations. 

Service communications can include, but are not limited to: emailing you to verify your identity when you sign up to our services; emailing you for password and/or username reset; notifying you that a particular service has been, or will be, suspended for maintenance or terminated; notifying you of an upgrade, a rectification or an incident affecting our services that may involve your personal information; or notifying you of an update to our Privacy Policy or Terms of Use.  

With your prior consent, you may receive information and updates about work opportunities. Such communication can be global or local and may include updates on us and work opportunities available to you.

Please be aware that we will never contact you to ask for personal information such as a password.

As part of a business transfer.

We may process your personal information in relation to any actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding in compliance with applicable laws and regulations. 

The purposes for which we process your personal information is the following:

To optimize and manage our website and other means of communication 

We may take certain measures involving the use of your personal information to manage, optimize and improve our means of digital or physical communication, such as our website.

The use of your personal information allows us to perform our contractual obligations or improve our services in accordance with our legitimate interest. Of course, when we use cookies or other tracking devices, we will comply with applicable laws and require consent when it is compulsory.  

We may use some of your personal information to administer, optimize and improve our platform, our content and our other digital offerings to ensure the most user-friendly online navigation experience possible. We may use such personal information to fix operational problems such as pages crashing and software bugs. Please be aware that to do this, we may use cookies or other online tracking technologies.  

We process your personal information for the following purposes:

To respond to public and governmental authorities' requests and potential or actual litigation.

We may process your personal information where it is (i) required as a matter of applicable law or regulation, (ii) necessary to exercise, establish or defend our legal rights, or (iii) necessary to protect your interests or those of any other person. Your personal information may be communicated to third parties (see Section “Who do we share your personal information with?”).

We process your personal information for the following purposes:

4.     WHAT PERSONAL INFORMATION DO WE COLLECT? 

When you interact with us or our approved partners, you may provide us with numerous categories of personal information. Personal data collected relates to contact information, gender, marital status, education and legal work authorization. In some instances, and in accordance with applicable legislation, sensitive data can also be collected. 

This information is necessary to the recruitment process.

If your application is selected, we will ask you for the information and supporting documents necessary to complete the mandatory formalities. This information is required for the conclusion of the employment contract for the selected candidates. In addition, the communication of certain categories of information and supporting documents (civil status, domicile, social security registration number, regularity of stay, etc.) is of a regulatory nature for the selected applications. Consequently, not providing this information will make it impossible to conclude the employment contract.

We mainly collect and process the following personal information:

·       Information you provide us by completing forms or surveys on our e-recruitment website, our dedicated recruitment website, or our website

·       If you choose to link your social media account, your public information will be made available to us and may form an integral part of your application to our job offer

·       If you contact us, we may keep a report of this correspondence and we may record our communication for quality and the purpose of training or to monitor of our recruitment process

·       Details about your visits to our website – including your browsing data, your path, your browsing language, your localization data or other communication information – and the resources you have access to

For further information, please read detailed information about what information we may collect during our recruitment process.

The type of information we may collect is provided in the list below. However, collection of this information is not systematic: we only process the information necessary to fulfill each purpose.

1. Your identifiers and candidate profile information 

This set of personal information enables us to identify you, manage your candidate profile and your job application, and, if necessary, to contact you.

The set could include your first name, last name, pseudonym, signature, email address, postal address, date of birth, login name, phone number, unique personal identifier, online identifier, social media accounts (and related information collected through social log-in), gender, country of residence. We will take steps to minimize the information collected to what is necessary in relation to the purposes for which it is processed. 

2. Information about your employment history and qualifications

We will process all the information provided via our platform during your application, as well as the information available on your CV such as qualifications, references, professional experience. If you choose to link your social media account, your public information will be made available to us and may form an integral part of your application to our job offer.

3. Data about your application

Once you are pre-selected we may have a discussion with you (in person or remotely) to check your suitability for the position and your fit with our teams. Within this context, we may collect interview data.

With your prior consent this interview data can be obtained via audio and video recordings of our interviews, exchanges and discussion.

Also, after first informing you, we may need to contact your previous employers and other references to verify the information you have provided us or to obtain additional information on your skills. By communicating personal information of references, you confirm that you have informed these persons beforehand about the processing of their personal information by us in order to assess your application as part of our recruitment process.

As part of the recruitment process, you may be required to undertake “skills tests” in order to evaluate your aptitude for a particular position, or we may run a “personality test” in order to understand your expectations and your general state of mind. Our methods and techniques for assisting in recruiting or evaluating job applicants are strictly relevant to the open position and will be systematically brought to your attention, in writing if necessary. The results obtained will be confidential and may be communicated to you on request.

4. Information shared spontaneously by you during the application process

As part of the recruitment process, you may share information with us spontaneously. We will always respect the data minimization principle and only collect relevant data to the open position you applied to. The results obtained will be confidential and may be communicated to you on request.

E.     Information necessary for your onboarding

If you are selected following the recruitment process, we may ask you to provide certain information and supporting documents (marital status, domicile, social security number, resident permit, etc.) in order to onboard you and to comply with our contractual and legal obligations with public organizations or health insurance partners.

In addition, we may communicate with you on the personal email address you provided when you created your candidate profile, to share relevant information with you that ensures your successful integration in the entity as part of the onboarding process.

6. Technical, electronic and localization information

Personal information shared by your device such as your IP address, device type, unique device identification numbers (device identifier), browser type, time zone settings, broad geographic location (e.g. country or city-level location); online activity (such as your Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements) and other technical personal information or personal information shared by the service provider.

5.     WHEN DO WE COLLECT YOUR PERSONAL INFORMATION? 

During our sourcing activities, we collect information publicly available online to identify potential candidates for professional opportunities that we think may be of interest. We may contact potential candidates from time to time regarding such opportunities.

When you interact with us, either online or in person, you may also share your personal information with us, when: 

1. You create a candidate profile or you apply to one of our job offers, online
2. You apply via our recruitment partners
3. You interact with us during job interviews, physically or remotely, or through our websites or our social media pages
4. You use your device to browse across different websites

6.     HOW DO WE COLLECT YOUR PERSONAL INFORMATION? 

We mainly obtain information directly from you and process them by automated means when you interact with us. When you interact with us, either online or in person, we collect your personal information through: 

1. Our internal job platform or any of the platforms that we use to disclose our job offers
2. Electronic message (e-mail) or any other means used to exchange with you
3. Third-party sources such as social media or other partners for application screening 

We collect your personal information through any means you may use to interact with us, whether via our recruitment platform, via phone, email, chat, text message or any means you may use to apply to our job offers.

In addition, we may obtain personal information from services provided by other companies to update or supplement your personal information, for example when you link your social media profile with your candidate profile. These companies may have their own privacy and cookies policies, so the personal data processed by them may be subject to their policies and not ours. 

Locally, some of our brands may use specific tools that use data analytics and algorithms to enhance their recruitment process and reduce time to hire effectively.

7.     WHO ARE OUR THIRD-PARTY SOURCES? 

We mainly obtain information directly from you. From time to time, we may also obtain information on you from third parties.

We will only gather such information when the third parties have obtained your consent or are otherwise legally allowed to share such information. In certain limited circumstances, some third parties may be required to disclose your personal information to us. 

Our third-party source categories could include: 

1. Our recruitment partners (recruitment agency, temporary employment companies, headhunters, etc.)
2. Job boards or other CV-library platforms
3. Social media in accordance with their own privacy policies, should you decide to share your social media account with us 
4. Enforcement or judicial authorities or any other public authority
5. Government entities 

8.     SHOULD YOU ALWAYS SHARE YOUR PERSONAL INFORMATION WITH US? 

You may not always be required to provide us with the personal information that we are asking you for. To ensure this statement is applicable, any personal information that is mandatory is clearly identified. 

You always have the possibility of not sharing information with us. However please note that, in certain instances, we may not be able to proceed with your application without your personal information.

We may ask you to provide us with personal information to meet certain legal requirements. In such cases, we will notify you in due time and advise you as to whether your personal information is mandatory or not (as well as the possible consequences if you do not provide your personal information). 

9.     HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION FOR?  

Our general approach is to keep your personal information for no longer than is necessary for the purposes for which it is processed:

·       If your application is successful, we will include your personal information in your employee file and keep it in accordance with our Employee Privacy Policy

·       If your application is not successful, with your prior consent, we will keep your data for a period of two years (2 years) from the last time you logged in to your candidate home account. This enables us to contact you for relevant positions that come up within this timeframe

10.           HOW DO WE PROTECT YOUR PERSONAL INFORMATION? 

We are committed to keeping your personal information safe.  

To do so, we design our services with your safety in mind. Within our Group, we have dedicated teams managing and ensuring the security and privacy of your personal information. We have adopted specific technical and organizational security measures to protect personal information against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access.  

For example, whenever personal information is passed between your device and our servers, we ensure that it is encrypted using Secure Sockets Layer (“SSL”) and/or other security methods. We implement Hypertext Transfer Protocol over Secure Socket Layer (“HTTPS”) in order to protect your connection to our website. All your personal information is stored on secured servers. 

We have also established a specialized personal information security management system. For example, we strictly control the scope of authorization of our employees who have access to the personal information that we collect and process. We regularly review our information collection, storage and processing practices, which includes physical security measures, to prevent any unauthorized access and use. 

We conduct security and privacy protection training courses and tests on a regular basis to enhance our employees’ awareness of the importance of protecting personal information. We take commercially reasonable steps to make sure that our business partners and third-party service providers are able to protect your personal information. Our employees and those of our business partners and third-party service providers who have access to your personal information are subject to enforceable contractual obligations of confidentiality and specific contractual privacy provisions. 

In the event of a security incident resulting in any breach of personal information, as qualified by law, we have an emergency response plan in place to prevent the expansion of such security incidents. In addition, we will report any such personal information breach to the relevant supervisory authority as required by applicable law and inform you via an appropriate channel when required by applicable law.  

Please also note that in order to keep your personal information secure, we may have to reset your password from time to time.  

However, you should be aware that no online service can be entirely secure, and that you play a key role in keeping your personal information safe. To ensure the safest protection of your personal information outside the limits of our control, your devices should be protected (e.g., with updated antivirus software) and your Internet service providers should take appropriate measures for the security of personal information transmission over the network (e.g., with firewalls and anti-spam filtering).

If you have any concerns that your personal information has been put at risk, for example if there’s a possibility that someone could know your password, please contact us as soon as possible, using the contact details provided in Section “How can you contact us?”.

11.           WHERE DO WE STORE YOUR PERSONAL INFORMATION? 

We operate globally and may transfer your personal information to other companies within the Group or to approved partners in locations around the world. For this purpose, we may have to share your personal information outside the country where you have first shared it with us. When we do so, it will always be for the purposes described in this Privacy Policy and where we are satisfied with the levels of protection and security implemented in compliance with applicable privacy legislation. This sharing of your personal information is necessary to enable us to perform the contracts we have with you or take steps at your request, prior to entering into a contract.

In most cases, the personal information we collect from you will be stored in servers located in the European Union. However, this may vary depending on the country in which the information is collected or on the applicable legislation. For more information about the location where your personal information is stored, you can contact us using the dedicated email address provided in Schedule 1 (List of Kering entities acting as controller) or see Section,  “How can you contact us?”.

Personal information we collect from you in the People’s Republic of China will be received by Kering S.A, with its address at 40 rue de Sèvres, Paris 75007, contact phone number: +33 (0)1 45 64 61 00.

We want to ensure that your personal information is always safely used and available to you, wherever you want to access it and whatever reason you wish to use it for.  

When we share, use or transfer personal information, in particular from the European Union, we use standard contractual clauses approved by the European Commission, or put in place other measures under applicable privacy legislation, to ensure that such transfer provides adequate safeguards. You can contact us using the dedicated email address provided in Schedule 1 (List of Kering entities acting as controller)  or see Section  “How can you contact us?” for more information about these safeguards including how to obtain copies of this information.  

As an example, when applying via our website, you will be using a platform provided by one of our partners (i.e., Workday). Even though our partner hosts your personal information within the European Union, it must provide, from time to time, remote access to teams located in the United States of America for maintenance and troubleshooting services, which implements a transfer to the United States of America. Given this country is not recognized as ensuring an adequate level of data protection by the European Commission, we have performed a transfer impact assessment and have implemented appropriate safeguards (i.e., standard contractual clauses based on the model published by the European Commission). You can obtain a copy of these clauses by contacting us using the dedicated email address provided in Schedule 1 (List of Kering entities acting as controller).

12.           WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH? 

We may share and disclose your personal information with approved partners acting on our behalf, or approved partners acting also on their own behalf. The latter may be able to determine “why” and “how” your personal information is processed. 

We may also receive personal information about you from third-party sources.

We will only share your personal information with partners that demonstrate sufficient guarantees regarding the implementation of appropriate technical and organizational measures to respect your rights and keep your personal information safe.

A.             Our service providers

To process your personal information, we rely on approved partners. Approved partners can be acting on our behalf or on their own behalf, depending on the case at hand.

Where they are processing your personal data on our behalf, all approved partners are bound by an obligation to implement appropriate security measures to protect personal information in their possession and bound by a strict confidentiality agreement and specific contractual provisions on “how” and “when” they are allowed to collect and use your personal information. Your personal information may be accessible to the following authorized personnel on a need-to-know basis:  

B.             Kering and other affiliates of our Group

If the position you apply to is not offered by our parent company, Kering S.A., the latter and its affiliates are our main approved partners. They will have access to your personal information but will never use it in contradiction to this Privacy Policy. Kering and its affiliates enable us to:  receive support during our recruitment campaign, manage your candidate profile, assess, and better understand our recruitment campaign, send you non-marketing communications, and optimize and manage our website and other means of communication.

. 

C.             IT service providers

These partners enable us to: 

• Provide you with the services you have requested (e.g., by managing our job platform) and manage your candidate profile with us (e.g., by making sure it is available at any time when you interact with us) 
• Send you service communications (e.g., by emailing you to verify your identity when you sign up) 
• Assess and better understand our business (e.g., by providing personal information visualization tools)
• Optimize and manage our website and other means of communication (e.g., by ensuring that our website is always available based on your browsing habits) 

D.             Recruitment partners

As part of our discussion with the service providers in charge of the management of our recruitment operations, we may share information with recruiting firms, temporary employment agencies or other service providers who may carry out processing operations related to potential candidates on our behalf.

E.              Social networks and job boards

These partners enable us to identify profiles of people potentially interested in our job offers; discuss directly with these people; or receive applications through the application modules available on these platforms.

Please be aware that these partners could also determine “why” and “how” your personal information is used. They have their own privacy and cookies policies, so remember that the personal information you give them will be subject to their rules and not ours.

F.              Public labor organizations, social security, mutual health insurance

If you are hired, in order to finalize the recruitment, our HR department will have to transmit some of the information collected to public bodies (e.g., unemployment insurance, health insurance, retirement) and private organization (e.g., mutual health insurance) to notify them of your hiring.

G.             Audit, law firms and similar corporate professional service providers 

These partners enable us to better understand and conduct our business (they include accountants, lawyers and auditors who may need to use your personal information).

H.      Data analysis providers

Data analysis providers may enable us to provide you with relevant information, updates and marketing content (e.g., by analyzing your answers to a survey, providing insights and helping us to analyze trends and improve our products and services).  

I.               Actual or potential buyers as part of a business transfer

We may disclose your personal information to an actual or a potential buyer (and its agents and advisers) in relation to any actual or proposed divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding in compliance with applicable laws and regulations. Where this is required, we will take steps to minimize any data that is shared.  

J.              Law enforcement body, regulatory body, government agency, court, lawyers to comply with laws and defend our rights and interests

We may disclose your personal information to any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is: (i) required as a matter of applicable law or regulation, (ii) necessary to exercise, establish or defend our legal rights, or (iii) necessary to protect your interests or those of any other person, and on the legal basis set out in this Privacy Policy. Where this is required, we will take steps to minimize any data that is shared.  

K.             To anyone at your request, for our legitimate interest or for compliance with laws and regulations

We may disclose your personal information to any other person: with your consent; where we have an overriding legitimate interest (on balance with your interests) to do so; or where we have a legal or regulatory obligation to do so. 

13.           WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?  

Subject to the privacy legislation applicable to your particular case, you may be entitled to one or more of the following rights and to exercise them on your own or via a legal representative acting on your behalf. We are committed to protecting your rights and allowing you to exercise them. You will never be discriminated against when you exercise your right in good faith under any applicable privacy law.  

If you need any further information regarding your rights, how to exercise them, or if you have any complaints or questions regarding our privacy practices, please contact our privacy team and Data Protection Officer using the dedicated email address provided in Schedule 1 (List of Kering entities acting as controller) or by completing the form available here.

A.             Right of access, rectification and erasure 

Under certain circumstances you may have the right to request access to and obtain a copy of any of your personal information that we may hold. Such right of access also includes the right to receive information in particular about the purposes of the processing, the categories of personal information concerned, the categories of recipients who your information may be disclosed to, and the contemplated period for the retention of your information. 

You may also request correction of any inaccurate personal information relating to you and to request the deletion of your personal information. You can see and update most of this personal information yourself online, by using the dedicated email address specified in Schedule 1 (List of Kering entities acting as controller) or by completing the form available here.

Specifically, subject to your privacy legislation applicable to your particular case, your right of access may include:  

• The right to request whether and how your personal information is processed and whether it has been shared with a third party in the preceding 12 months, in particular if you are a resident of Aruba 
• The right to obtain confirmation that we process personal information about you, to request information about the public and private entities who we have shared your personal information with, and to request information about the possibility of denying consent and the consequences of such denial, in particular if you are a resident of Brazil 
• If we cannot satisfy your request for correction, the right to request that a statement of correction be attached to your information noting that a correction has been sought but not made, in particular if you are a resident of New Zealand 
• The right to be informed of any disclosure of inaccurate personal information about you, in particular if you are a resident of Qatar 

B.             Right to withdraw consent 

Where processing of your personal information is based on your consent, you have the right to withdraw it at any time. Please note that the withdrawal of your consent will not affect the lawfulness of processing based on your consent as carried out before such withdrawal. 

C.             Right to personal information portability 

Under certain conditions, you may have the right to receive personal information you have provided to us within a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible. 

D.             Right to restriction of processing 

Subject to privacy legislation applicable to you, you may have the right to restrict our processing of your personal information, in particular where:  

• You contest the accuracy of the personal information (until we have taken sufficient steps to correct or verify its accuracy)   
• The processing is unlawful, but you do not want us to erase the personal information 
• We no longer need your personal information for the purposes of the processing, but you require such personal information to establish, exercise or defend legal claims
• You have objected to processing that has been justified on legitimate interest grounds, pending verification as to whether we have compelling legitimate grounds to continue processing 

Where personal information is subject to restriction in this way, we will only process it with your consent or to establish, exercise or defend legal claims, in accordance with local legislation. 

Specifically, subject to your applicable privacy legislation, your right to restriction of processing may include:  

• The right to request the anonymization, blocking or deletion of any unnecessary or excessive personal information or personal information processed unlawfully, in particular if you are a resident of Brazil 
• The right to request us to stop transferring your personal information to a third party, in particular if you are a resident of Vietnam   

E.              Right to object to processing 

Where we rely on legitimate interest to process personal information, you may have the right to object to that processing. In this case, we must stop using your personal information for that purpose unless we can either demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms or where we need to process the personal information in order to establish, exercise or defend legal claims. Where we rely on legitimate interest as a justification for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis. 

F.              Deceased person rights to privacy 

To exercise rights on behalf of a deceased individual, you may be required to provide us with proof that you are an immediate family member or executor of the deceased person. Subject to applicable privacy laws, we may not be able to support your request. Please be informed that under certain laws (for example in France), you can define directives relating to the storage, erasure and communication of your personal information after your death. 

I.               Right to lodge a complaint 

You also have the right to lodge a complaint with your local supervisory authority if you consider that the processing of your personal information infringes applicable law.  

If you are a resident of a Member State of the European Economic Area, you may refer to the list of data protection authorities in the European Economic Area available here.  

Under applicable legislation, you may have the right to bring complaints relating to the processing of your personal information before civil courts, in particular if you are a resident of Chile. 

J.              Modalities of response to your requests, additional information or assistance  

If you need any further information regarding your rights or how to exercise any of your rights, or if you have any complaints or questions regarding our privacy practices, please contact our privacy team and Data Protection Officer using the dedicated email address provided in Schedule 1 (List of Kering entities acting as controller) or by completing the form available here (or see Section , “How can you contact us?”). 

To help protect your privacy and maintain security, we will take steps, and may require you to provide certain information, to verify your identity before granting you access to your personal information or complying with your request.  

Where permissible under applicable law, we reserve the right to charge a fee, for instance if your request is manifestly unfounded or excessive, to cover the administrative costs incurred by your request. We will endeavor to respond to your request as soon as possible and in any case within the applicable timeframe. 

In certain countries and states (for example, if you are a Californian resident), if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury stating that you are the person whose personal information is the subject of the request.   

If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (i) we may require you to provide the authorized agent written permission to do so, and (ii) for access and deletion requests, we may require you to verify your own identity directly with us. 

14.           WHAT ARE YOUR OBLIGATIONS REGARDING YOUR PERSONAL INFORMATION?

Not matter how careful and committed we are, there would be no satisfying privacy without your individual involvement. Privacy therefore implies both rights and obligations, and, as part of your obligations, we expect you to take reasonable steps to help us protect and manage your privacy adequately.

For example, in order for us to ensure we retain accurate, complete and up-to-date personal information about you, we request that you keep us informed, without undue delay, in the event your personal information becomes incorrect, incomplete and/or outdated.

We also expect you to take particular care to protect, secure and avoid illegitimate access to, use of and/or disclosure of your personal information. This includes for example: (i) complying with any applicable security rules provided to you; (ii) avoiding discussing any matter involving personal information in inappropriate environments; and (iii) informing and obtaining the consent of third parties prior to sharing any personal information related to them with us.

Failure to comply with the principles and rules of this Privacy Policy (including any other policies referred to therein, as the case may be) may have serious adverse consequences on you, us and/or third parties.

15.           CAN THE PRIVACY POLICY CHANGE?

We may occasionally make changes to this Privacy Policy, for example to comply with new requirements imposed by applicable laws or technical requirements. We will post the updated Privacy Policy on our website. We therefore encourage you to review this page every so often. 

We may also notify you in case of material changes and, where required by applicable law, we will seek your consent to those changes.  

If we wish to process your personal information for a new purpose not described in this Privacy Policy, where necessary we will inform you and where required we will seek your consent.  

16.           HOW CAN YOU CONTACT US?

If you have any questions regarding our privacy practices or how we handle your personal information, please contact our privacy team and Data Protection Officer by using the dedicated email address provided in Schedule 1 (List of Kering entities acting as controller) or by using the form available here.

***

SCHEDULE 1 - List of Kering entities acting as controller

·       Autumnpaper Limited, (Alexander McQueen) 5th Floor Rear Suite, Oakfield House, 35 Perrymount Road, Haywards Heath, West Sussex, RH16 3BW, United Kingdom

Privacy email address: privacy@alexandermcqueen.com

·       Balenciaga, 40, rue de Sèvres, 75007 Paris, France

Privacy email address: privacy@balenciaga.com

• BV ITALIA SR, Località Conti Maltraverso, 36054 Montebello Vicentino, Italy

Privacy email address: privacy@bottegaveneta.com

• Boucheron S.A.S., 26 Place Vendôme, 75001 Paris, France

Privacy email address: privacy@boucheron.com

• Brioni Italia s.r.l., Piazza San Bernardo 101, 00187 Rome, Italy

Privacy email address: privacy@brioni.com

·       Guccio Gucci S.p.A., Via Tornabuoni 73/R, Florence, Italy

Privacy email address: privacy@gucci.com

·       Kering, 40, rue de Sèvres 75007 Paris, France

Privacy email address: privacy@kering.com

·       Kering Eyewear S.p.A., Padoue, Via Altichiero n. 180, Italy

Privacy email address: keringeyewear.privacy@kering.com

·       Pomellato S.p.A., Via Neera 37, 20141 Milan, Italy

Privacy email address: privacy@pomellato.com

·       Qeelin Limited, Room 1108, Harcourt House, 39 Gloucester Road, Wanchai, Hong Kong

Privacy email address: privacy@qeelin.com

·       Richard Ginori s.r.l., Viale Giulio Cesare n.50, 50019 Sesto Fiorentino, Italy

·       Privacy email address: infoprivacy@richardginori1735.comYVES SAINT LAURENT, 37-39 Rue de Bellechasse 75007 PARIS, France

Privacy email address: privacy@ysl.com

·       Design Management S.r.l., Via Pisana 336, 50018 Casellina Scandicci, Florence, Italy

Privacy email address: privacy@themall.it

SCHEDULE 2 – SPECIFIC INFORMATION FOR CALIFORNIAN RESIDENTS

A.     DISCLOSURES FOR CALIFORNIA RESIDENTS

If you are a California resident, the personal information collected from you includes information within the below categories. These categories represent the categories of personal information that we have collected over the past 12 month. The categories listed below are defined by California state law. Inclusion of a category in the list below indicates only that, depending on the phase of the recruitment campaign, the information linked to the job offer proposed or any other information you feel necessary to share with us, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for each candidate.

We may also collect, receive, or otherwise obtain and process sensitive personal information about you. If you are a California resident, the sensitive personal information collected from you includes information within the below categories of data. These categories represent the categories of sensitive personal information that we have collected over the past 12 months and which we have shared as per Section 11 above. The categories listed are defined by California state law. Inclusion of a category in the list below indicates only that, depending on your relationship with us, your role, and the benefits we offer you, we may collect some information within that category. It does not necessarily mean that we collect all information listed in a particular category for each candidate. To the extent we use any of your sensitive personal information for any purposes beyond what is necessary to the employment relationship or to offer you benefits, you may have the right to limit the processing of your personal information as described in Section 12 above.

B.     WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?

Beginning January 1, 2023, you will have the right to make certain requests regarding your personal information. These include the right to request to:

       i.         access your personal information, including the categories of personal information we have collected about you; the categories of sources from which your information is collected; the categories of third parties to whom we disclose your personal information

     ii.         delete your personal information;

    iii.         receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and

    iv.         lodge a complaint with your local data protection authority.

We encourage you to contact us to update or correct your information if it changes or if the personal information, we hold about you is inaccurate.

We are committed to protecting your rights and allowing you to exercise them. You will never be discriminated against when you exercise your right in good faith under California state law. 

To exercise certain rights, we will make sure to verify your identity. If your request is submitted electronically, we will ask for information to confirm your identity.

If you would like to authorize someone to make a request on your behalf, please ensure we have that information on file, or you must provide us with a written, signed permission to submit privacy right requests on your behalf, or provide a letter from your attorney. Your agent or attorney must provide this authorization at the time of request. Note that we may require you to verify your identity with us directly before we provide any requested information to your agent.

We will contact you if we need additional information from you in order to honor your requests. If you would like to discuss or exercise such rights, please contact us at the details provided in this Privacy Policy.

While you also have the right to opt out of the sale of any of your personal information under California law, we do not sell your personal information. 

Last updated on September 2023.