(January 2022)

1. General information

For the purpose of this Privacy Policy, “Christian Louboutin” means CL Shanghai Limited, a company registered in Room L2-19, Floor 2, Tower D, Shanghai IFC Shopping Mall, No. 8, Shi Ji Avenue, Pudong, Shanghai, PRC China. ( “we”/ “us”/ “Christian Louboutin”). You may reach us via privacy.asia@christianlouboutin.com This Privacy Policy is applicable between you and Christian Louboutin, which regulates the collection, storage, use, processing, provision, disclosure, deletion and cross-border transfer outside of Mainland China etc., of your personal information by Christian Louboutin as detailed in article 4 of this Privacy Policy. Unless specifically defined herein, any definition beginning with a capital letter and contained in the Privacy Policy shall have the same meaning as in the Terms of Use ("ToU") available through the following link

Christian Louboutin undertakes to collect and process your personal information in strict compliance with the Personal Information Protection Law ( “PIPL”) and other applicable legal provisions of the People's Republic of China. Where appropriate, Christian Louboutin shall make the declarations to the personal information protection supervisory authorities.

If you do not accept the terms of the Privacy Policy, we may be not able to provide you with the basic services as prescribed below.

2. Your PersonalInformation

For the purpose of this Privacy Policy, Personal Information means all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding the information processed anonymously.

We may collect your personal information directly and indirectly from you. We directly collect your personal information when you have provided us with your consent, unless we can collect your personal information without consent as prescribed by relevant laws, such as for the necessity to conclude or perform a contract in which you are a party, or for the necessity to perform statutory obligations etc.

Personal information we collect indirectly about you are mainly de-identified sales data from our partner TMALL, which are integrated automatically into our Clienteling system. You can refer to privacy policy of TMALL

When we collect your personal information, necessary information is preceded by an asterisk “*”, as it is essential for us to provide you with services or products. [For example, we collect your home address (post code, city, country) for the invoicing of your purchase.].

Additionally, we may collect personal information from you for supplementary services. [For example, we collect your title, country, purchase history etc., to send you commercial prospecting message suited to your preference]. However, when you decide not to provide with such personal information, you can still enjoy our basic services.Details concerning collection and use of your personal information shall refers to Article 4 of this Privacy Policy. The website is encrypted according to SSL (Secure Socket Layer) protocol and is reinforced by a set of various existing encryption processes in order to provide the most effective protection possible.

Moreover, certain personal information that we collect about you may be recognised as Sensitive Personal Information as defined as personal information that is likely to result in harms to personal dignity or damages personal or property safety, once disclosed or illegally used. We only collect sensitive personal information for a specific purpose and have implemented strict protective measures to ensure the safety of your sensitive personal information. For instance, we collect your Billing information in order to make the payment for your order.

3. Minor under the age of 14

In accordance with the ToU, based on the fact that minors under 14 are not authorised to use the website and Christian Louboutin does not provide any service or product to them, therefore we do not intentionally process any personal information of minors under 14. If you are the parent or legal guardian of a minor under 14 who has registered on the website and are aware that personal information of minors under 14 are accidently collected and processed by Christian Louboutin, please contact us at one of the addresses mentioned in article 13 of this Privacy Policy, we shall promptly have the minor's registration cancelled and all their personal information deleted from the Christian Louboutin systems.

4. Use of your personal information

Collection of personal information:

How does Christian Louboutin collect your personal information?


Category of personal information:

What personal information is processed by Christian Louboutin?

Purposes of processing:

How does Christian Louboutin use your personal information?

Legal basis for processing:

What legal basis does Christian Louboutin use to explain the processing of your personal information?

Basic Services

In-store purchasing

Christian Louboutin collects your personal information when you make a purchase in one of our Stores.

When making a purchase in one of our stores, the following personal information is processed:

  • *Title

  • *Surname

  • *First name

  • *Email address

  • *Postal address

  • Nationality

  • Date of birth

  • Preferred means of communication

  • All other information shared with the Christian Louboutin teams during a store visit.

To accomplish your purchase or order.


To comply with applicable laws regarding cash transactions.

  1. Performance of a contract:

The necessity to conclude or perform a contract in which you are a party.

Customer relationships and commercial relationships (after-sales service, etc.)

Christian Louboutin collects your personal information when you request customer service from us online or in person.



In customer relationships and commercial relationships, the following personal information is processed:

  • *Title

  • *Surname

  • *First name

  • *Email address

  • *Postal address

  • Nationality

  • Date of birth

  • Preferred means of communication

  • All information shared with the Christian Louboutin teams during a store visit or in the body of your request for customer service.

To process your requests, answer your questions, manage any complaints, provide any information requested.


To manage your order.


To facilitate any other communications you have with Christian Louboutin.

Performance of a contract:

The necessity to conclude or perform a contract in which you are a party

Protection against fraud and anti-counterfeiting strategy:

Christian Louboutin collects your personal information when you make a purchase in one of our stores as part of its anti-fraud strategy*.

As part of the anti-fraud strategy, the following personal information is processed:

  • *Surname

  • *First name

  • *Purchasing history

  • *Means of contact (email, telephone number, etc.)

  • *Means of payment (with the last four numbers of bank cards where applicable)

  • *Billing address

  • *Delivery address


As part of the anti-counterfeiting strategy, the following personal information is processed:

  • *Surname

  • *First name

  • *Purchasing history

Means of contact (email, telephone number, etc.)

Christian Louboutin consults, analyses and uses your personal information as part of:


  • the anti-fraud strategy, making particular use of comparative methods and data fusion, etc.;


  • the strategy to combat counterfeiting and any sale of authentic Christian Louboutin products in a fraudulent manner.


To preserve the Christian Louboutin brand and products and to protect customers from fraud and the sale of fake Christian Louboutin products.

Consent:
You consent to the processing shall be legal basis for our processing.


Supplementary Services

Browsing the Website

Christian Louboutin uses performance cookies to collect your personal information when you browse the Website.


For more information about how Christian Louboutin uses cookies, please see article 8 of this Privacy Policy.


When browsing the Website, the following information is processed:

  • IP Address

  • Data relating to your browser

  • Data relating to your device

  • Data relating to your use of the Website

  • Last website visited

  • Data relating to connection (time, date, time spent on the Website, etc.)

  • Pages visited

  • Source of the visit to the Website

  • Products searched

  • Location (city, province/state, country)

  • Unique username attributed to each visitor and the expiry date of this username

To facilitate and improve your browsing by registering and improving our understanding of your needs, expectations, preferences (language, products selected, etc.), your behaviour (pages visited, timing of visits, etc.)


To adapt our communications, our offers and Website content.


Consent:

You consent to the installation of cookies when You browse the Website.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.

Creating a customer account on the Website

Christian Louboutin collects your personal information when you create an account on the Website, including through the use of cookies.

When creating a customer account on the Website, the following personal information is processed:

  • Title

  • *Surname

  • *First name

  • *Email address

  • Country

To provide you with the service you requested concerning creation and maintenance of an account.

Consent:

You consent to the processing shall be legal basis for our processing.

Personalised Marketing

Christian Louboutin sends you commercial prospecting messages suited to your preferences about news, exclusive deals, new offers and products from Christian Louboutin.

To send you personalized prospecting messages, Christian Louboutin collect the following data:

  • Email address

  • Phone number

  • Browsing data

To send you commercial prospecting messages suited to your preferences about news, exclusive deals, new offers and products from Christian Louboutin and execute location-based marketing campaigns.

Consent:

You consent to the processing shall be legal basis for our processing.

Newsletter subscription

Christian Louboutin collects your personal information when you subscribe to receive our newsletter and other marketing communications.

When subscribing to the newsletter and other marketing communications, the following personal information is processed:

  • Email address

To keep you informed of new collections and products, latest trends, news, and other marketing and commercial prospecting communications regarding Christian Louboutin.

Consent:

You consent to the processing shall be legal basis for our processing.


Statistics and analysis

Christian Louboutin collects certain statistical information on a style by style basis and when you make a purchase in-store.

In statistics and analysis, the following personal information is processed:

  • Surname

  • First name

  • Purchasing history

To analyse your preferences and the performance of our products, measure the effectiveness of our campaigns and/or our events online and offline, to preserve the image of the house and to improve our campaigns.


To improve our services and maintain visibility and good sales management.


To compile and maintain business statistics and figures, such as sell-through rates.

Consent:

You consent to the processing shall be legal basis for our processing.


Additionally, Christian Louboutin processes personal information collected by any means in the context of a request from a law enforcement or judicial body in order to comply with the legal obligations imposed on us. Please be assured, if we provide any personal information stored in China to any foreign law enforcement or judicial body, we will obtain approvals from competent authorities in China.

5. Duration of your personal information retention

In principle, Christian Louboutin will store your personal information only for the time necessary to achieve the purpose of processing stipulated above.

In the event of prolonged inactivity on your part, for a period of five (5) years, your user account will be deactivated. At the end of this period, Christian Louboutin may contact you to find out whether or not you wish to (i) continue to receive Newsletters and other publications from Christian Louboutin; (ii) keep your account.

Also, Christian Louboutin reserves the right to retain your personal information for a longer period in the following circumstances:

  1. in cases of suspected illegal activity on the Website;

  2. for probative purposes in the context of an obligation (particularly accounting or legal obligations) during statutory limitation periods; and

  3. in response to any requests from the authorities responsible for the protection of personal information.

Christian Louboutin may also keep, for its records, copies of communications with you and any response to questions and/or comments sent by our Customer Service department. Unless otherwise legally required, these data are kept for a maximum data retention period of 5 years. These data can then be archived for the duration of the legal prescription in commercial matters.

Beyond the retention period, your personal information will be anonymised and/or destroyed by the Christian Louboutin systems. The same instruction will be given to any third parties with which your personal information has been shared in accordance with article 6 of the Privacy Policy.

6. Provision of your personal information

First, Christian Louboutin provides your personal information to entrusted third parties acting on behalf of Christian Louboutin, particularly service providers involved in the management of our Website and providing IT, hosting, maintenance and support services for our equipment, infrastructures, software, applications and databases; providers of services essential to the execution of sales (payment provider, delivery provider and order follow-up). Furthermore, Christian Louboutin organises joint events with our commercial partners, this may entail sharing your personal information with these partners, only when you have separately consented to this sharing and strictly in the context of such events. Also, if you have consented, we may from time to time use your personal information or share your personal information with other companies in the Christian Louboutin Group to send you marketing materials. Details concerning the personal information sharing shall refers to below:

Recipients' Name and Contact Information

Types of Personal Information

Purposes

Methods

Microsoft Azure by Rampar

  • Title

  • Surname

  • First name

  • Email address


customer relationship,

for advertising purposes

Storage of the personal information

Magento

  • Title

  • Surname

  • First name

  • Email address

  • Browsing data


The personal information are collected via the website. The personal information processing operations are the following

collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, erasure or destruction.

Cegid

  • Title

  • *Surname

  • *First name

  • *Email address

  • Phone number

  • *Postal address

  • Nationality

  • Date of birth

  • All other information shared with the Christian Louboutin teams during a store visit.


customer relationship, commercial relationship and for advertising purposes

The personal information are collected in store. The personal information processing operations are the following

collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, erasure or destruction

Salesforce

  • Title

  • *Surname

  • *First name

  • *Email address

  • *Postal address

  • Phone number

  • Nationality

  • Date of birth

  • All other information shared with the Christian Louboutin teams during a store visit.


customer relationship, commercial relationship and for advertising purposes

  • The personal information processing operations are the following

  • collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, erasure, or destruction


Christian Louboutin undertakes to limit the sharing of your personal information exclusively to aforementioned third parties for which this information is necessary for one of the purposes set out herein. Third parties selected by Christian Louboutin are contractually bound to comply with the confidentiality and security obligations in accordance with the laws and regulations in force.

If, you have consented, we may from time to time use your personal information or share your personal information with other companies in the Christian Louboutin Group to send you marketing materials. This would allow you to take advantage of high quality, tailored services in each of your interactions and contacts with Christian Louboutin; and Christian Louboutin can offer products and services that might interest you. You may opt out of receiving marketing communications at any time by sending contacting privacy.asia@christianlouboutin.com.We will then stop any further marketing related emails from ourselves. Please note that you may continue to receive communications for a short period after changing your preferences while we are updating our systems. If we use your personal information in any direct marketing communications, you have the right to request that we provide you with the source of that personal information. There is no fee for requesting this information. We will provide you with the source of personal information unless it is impracticable or unreasonable to do so. Under no circumstances will Christian Louboutin offer your personal information for sale. Christian Louboutin may share your personal information if we believe that this disclosure is necessary to comply with current legal provisions, particularly in the context of legal proceedings, or to protect the legitimate interests of Christian Louboutin.

In the event of a restructuring and/or reorganisation of Christian Louboutin, or if its assets are acquired by a third party or assigned to a third party in whole or in part, the customer list and your personal information may be included in the transferred assets. In this case, Christian Louboutin will notify you the third party's name and contact information in advance and strive to ensure that the privacy policies and practices of such third parties will provide the same level of protection to your personal information. If such third parties change the processing purposes and methods, they will obtain your consent.

7. Cross-border Transfer of your personal information

If, you have consented to the transfer of your data outside China or otherwise allowed by applicable laws, your personal information is transferred within the Christian Louboutin group, which include companies located outside of the People's Republic of China, to send you marketing materials. Christian Louboutin ensures that the appropriate measures are put in place to preserve the security of your personal information. The list of Christian Louboutin companies with access to your personal information is accessible here.

Furthermore, because Christian Louboutin has a worldwide operation and some of our entrusted third parties or commercial partners may also be located outside the People's Republic of China. Christian Louboutin will transfer your personal information to such service providers or partners based on your consent or otherwise allowed by applicable laws. You may find the basic information of such entrusted third parties or commercial partners below.

Overseas Recipients' Name and Contact Information

Types of personal information

Purposes

Methods

Microsoft Azure by Rampar

  • Title

  • Surname

  • First name

  • Email address


customer relationship and commercial relationship

Storage of the personal information

Magento

  • Title

  • Surname

  • First name

  • Email address

  • Browsing data


The personal information are collected via the website. The personal information processing operations are the following

collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, erasure or destruction.

Cegid

  • Title

  • *Surname

  • *First name

  • *Email address

  • Phone number

  • *Postal address

  • Nationality

  • Date of birth

  • All other information shared with the Christian Louboutin teams during a store visit.


customer relationship, commercial relationship and for advertising purposes

The personal information are collected in store. The personal information processing operations are the following

collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, erasure or destruction

Salesforce

- Title

- *Surname

- *First name

- *Email address

- *Postal address

- Phone number

- Nationality

- Date of birth

  • All other information shared with the Christian Louboutin teams during a store visit.


customer relationship, commercial relationship and for advertising purposes

The personal information processing operations are the following

collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, erasure, or destruction


Christian Louboutin transfers personal information to such entrusted third parties or commercial partners after fully complying with the relevant laws in China, such as entering into cross-border transfer agreements, conducting security assessment, or obtain relevant certifications, so that your personal information will be subject to the same level of protection as under the laws in China.

8. Cookies

To offer you customisable and customised services, Christian Louboutin uses cookies for account registration and sometimes to track your browsing data on the Website.

8.1 What is a cookie?

A cookie is a small block of data, a text file, sent to your browser from a Web server and stored on the hard drive of your computer. This file allows its issuer to identify your computer for the validity period of the cookie, or for a maximum of six (6) months. Cookies do not, therefore, allow you to be identified directly. By browsing the Website, you accept the use of cookies under the terms and for the purposes set out in this Privacy Policy.

8.2 What categories of cookies are used by Christian Louboutin on the Website?

The Website uses cookies that are strictly necessary for browsing and using the functionalities offered, performance cookies for creating Website visit and performance statistics.

  • Technical cookies:

Technical cookies are necessary for the technical functioning of the Website and are therefore permanently activated to allow the successful conclusion of essential operations proposed by the Website. Technical cookies cannot be deactivated. These cookies allow your route through the Website to be tracked, and remembered, your cookie preferences to be collected and saved, your registration for an account to be completed, the functioning of your basket to be managed until the purchasing process and you to be assisted in the event of any security problems.

If you would like to know more about our partners, personal information processors or entrusted processors with access to these cookies, see the list here.

  • Performance cookies:

Performance cookies collect information on how you use the Website and allow us to analyse your browsing and measure the Website's audience. These cookies are exclusively used for statistical purposes and improve the functioning of the Website.

If you would like to know more about our partners, personal information processors or entrusted processors with access to these cookies, see the list here.

8.3 How to manage your cookie preferences on the Website?

We will not register performance cookies on your device without your consent, which can be given and modified at any time without charge by changing your browser settings. You can also change your preferences in terms of cookie management at any time during your connection to the Website by clicking on the following link.

Each browser has its own cookie management system. They are described in the help menu of each browser, and below you will find instructions on how to manage and disable cookies for the main types of web browsers:

For Internet Explorer 8 and later versions:

  1. Go to “Tools” menu, then “Internet Options”

  2. Click on “Privacy”

  3. Select your preferred level of privacy


For Mozilla Firefox:

  1. Go to “Tools” then “Options” menu

  2. Click on the “Privacy” settings

  3. Select your preferred option on the “Cookies” menu


For Opera:

  1. Go to “Files” > “Preferences”

  2. Click on “Privacy”

  3. Select your preferred options


For Android:

  1. Click on the upper right button

  2. Go to “Settings” then “Privacy and security menu”

  3. Select your preferred option


For Safari on iOS:

  1. In the “Settings” app, go to “Safari” menu

  2. Go to “Accept cookies” under “Privacy”

  3. Select your preferred option


For Google Chrome:

  1. Click the Chrome menu on the browser toolbar

  2. Select “Settings” then click “show advanced settings”

  3. In the “Privacy” section, click the “Content settings” button.

  4. In the “Cookies” section, you can change cookies settings


In any event, if you reject our use of non-essential cookies, you may still use the Website, but you may be limited in using some of its features.


9. Links to other websites

The Website may contain links to other websites. Such third-party websites have their own privacy policies over which Christian Louboutin has no control. This Privacy Policy does not cover the use of the collection of your personal information by third party websites. Christian Louboutin may not be liable for any misuse of your personal data by such third parties, which does not comply with the legal obligations in this regard. Christian Louboutin recommends that you review the privacy statements posted on other websites to understand the procedures for collecting and using personal information.

10. Security of Your Personal Information

Christian Louboutin, in its capacity as personal information processor with the ability to determines the purpose and method of the processing of personal information, implements appropriate physical, technical and organisational measures to protect your personal information against loss, destruction, alteration, theft or unauthorised access, disclosure, copying, use or modification. Examples of the measures we currently use to protect personal information include, without limitation:

  • Deploying Website security measures in line with security good practices (such as ISO 2700X or NIST);

  • Developing and implementing a security management program, based on risk methodology, to increase data protection;

  • Implementing access controls;

  • Undertaking regular scanning to detect system vulnerabilities and security issues; and

  • Undertaking regular security audits performed by external parties.

Your personal information is strictly confidential. Christian Louboutin's employees who, as a result of their role, have access to your personal information, are subject to strict confidentiality obligations.

The Christian Louboutin Group has a procedure for handling a proven or suspected breach of the security of your personal information under the conditions and within the legal deadlines.

Christian Louboutin demands the same technical and organisational security measures from all third parties with which we collaborate.

Transactions concluded on the Website are protected by an SSL encryption process. Christian Louboutin reminds you, however, that no data transmission over the Internet is 100% secure and that all information communicated online can potentially be intercepted and used by people other than the intended recipient.

The Internet is not an entirely secure environment, and it is impossible to be certain that communications with other users are fully encrypted, such as email, instant messaging, social media, or other services. We recommend that you use complex passwords when using such tools and be mindful of protecting your information.

11. Modifications

For material modifications, we will also provide you with appropriate notice (such as through text messages, web banners, etc.). Material modifications include:

  • Material changes have taken place in our service model, e.g. changes in the types of personal information and the purposes as well as methods of the processing activities;

  • Material changes have taken place in our ownership structure. For example, changes in owners caused by business adjustment, bankruptcy, merger and acquisition;

  • Material changes have taken place in the recipients of sharing, transferring or public disclosure of personal information;

  • Material changes have taken place in your rights to participate in the processing of personal information and the ways in which you exercise them;

  • Material changes have taken place in our departments responsible for handling personal information security, contact information and complaint channels; and

  • Other changes that may materially affect your rights and interests.

12. Enforcement of your Rights

You can contact Christian Louboutin at any time to access, copy, update, correct, delete your personal information (including de-registering your account), restrict our processing on your personal information, transfer personal information to other personal information processor or withdraw your consent, by writing to our Customer Service department at one of the following addresses, according to your place of residence:

For the Continental Europe area, please contact the address: privacy.europe@christianlouboutin.com

  • For the Asia Pacific area (except Japan), please contact the address:

privacy.asia@christianlouboutin.com

  • For Japan, please contact the address:

privacy.japan@christianlouboutin.com

  • For the Middle East area, please contact the address:

privacy.mei@christianlouboutin.com

  • For the Americas area (Latin America, North America and South America), please contact:

privacy.americas@christianlouboutin.com

privacy.california@christianlouboutin.com

When the processing of your personal information is based on consent, the withdrawal of consent does not affect processing carried out before the withdrawal of consent. Additionally, the close relatives of a deceased may also exercise the right to access, copy, update and delete of the deceased personal information, based on the close relatives' own legitimate rights and interests.

Christian Louboutin will respond to your request within 15 working days. In order to satisfy your request, when Christian Louboutin has reasonable doubts about your identity, Christian Louboutin reserves the right to ask you for any additional and necessary information enabling it to identify you with certainty.

Where necessary, you must ensure that you provide Christian Louboutin with any changes to your information, in particular to allow us to ship your orders to the correct address and to contact you if necessary.

In the event of a dispute regarding the way in which Christian Louboutin collects and processes your personal information, you have the option to i) issue a complaint by following the procedure accessible here, ii) inform the Data Protection Officer by email to dpo.global@christianlouboutin.com or iii) file a complaint with the relevant supervisory authority.