1. Who is responsible for your data?

Clear Fashion is a brand operated by Clothparency SAS, the controller of the personal data processing described in this policy.‍

Clothparency SAS
15 rue de Louvois
51100 Reims – France

For any question regarding your personal data or to exercise your rights, you can contact us at: contact@clear-fashion.com

Throughout this policy, “Clear Fashion”, “we” or “our” refer to Clothparency SAS and the services it operates.

2. Which services does this policy apply to?

This Privacy Policy applies in particular to:

• the clear-fashion.com website;
• the Clear Fashion mobile application;
• contact and demo-request forms;
• sign-ups to our communications and newsletters;
• interactions with our team in connection with the use of our services.

3. What data may we collect?

The data collected depends on how you use our services.

When you use the Clear Fashion app

We may collect:

• your email address;
• your first name, if you choose to provide it;
• any optional information entered in your profile;
• the information needed to create and manage your account;
• information relating to your use of the app and its features;
• the information you send us when you contact our team.

Some app features may be accessible without creating an account.

When you use our website or contact our team

We may collect:

• your first and last name;
• your professional email address;
• your company and job title;
• your phone number if you choose to share it with us;
• the content of your request or of your exchanges with Clear Fashion;
• the information needed to arrange a meeting or a demonstration.

When you sign up for our newsletter

We mainly collect:

• your email address;
• the date of your sign-up;
• the information used to manage your subscription and unsubscription;
• statistical data on the use of our communications, where permitted.

Technical data

When you use our services, certain technical data may also be processed, such as:

• IP address;
• device and browser type;
• technical information relating to the connection;
• technical logs and data required for the security of our services;
• data relating to the use of the website or app, when the corresponding trackers have been authorised.

We seek to limit data collection to what is necessary to provide and improve our services.

4. Why do we use your data?

We process your data for the following purposes.

Providing and managing our services

We use the necessary data to:

• create and manage your Clear Fashion account;
• enable you to use the app’s features;
• ensure the operation and security of our services;
• respond to your requests.

Depending on the case, this processing is based on the performance of our services, on pre-contractual measures taken at your request, or on our legitimate interest in ensuring the proper functioning of our services.

Responding to requests from brands and professionals

When you contact us, request a demonstration or interact with our team, we may use your data to:

• respond to your request;
• arrange a meeting;
• follow up on our exchanges;
• present our solutions to you where they are relevant to your business.

This processing is based on measures taken at your request before a contract may be concluded and/or on our legitimate interest in developing and managing our business relationships.

Sending you our newsletter and communications

Where your consent is required, we use your email address only after obtaining your agreement.

You can unsubscribe at any time using the link provided for this purpose in each communication.

Marketing rules differ depending on whether they concern individuals or professionals; the CNIL notably requires prior consent for B2C electronic marketing, whereas B2B marketing may in certain situations rely on an information-and-opt-out mechanism.

Understanding and improving our services

We may analyse how our services are used in order to:

• identify technical issues;
• measure feature usage;
• improve the user experience;
• improve the performance and security of our services.

Where such analyses require the use of cookies or trackers subject to consent, they are only carried out after your agreement.

Meeting our obligations and protecting our services

Finally, we may process certain data where necessary to:

• comply with a legal obligation;
• prevent or detect fraudulent or abusive use;
• ensure the security of our systems;
• establish, exercise or defend our rights.

5. Who do we share your data with?

Clear Fashion does not sell your personal data.

Your data may be accessible, within the limits of what is necessary, to:

• authorised members of the Clear Fashion team;
• technical providers involved in the hosting, maintenance and operation of our services;
• providers used to manage contacts and customer relations;
• providers enabling the sending of communications and newsletters;
• audience-measurement or analytics providers, where authorised;
• administrative or judicial authorities or other authorised third parties where the law requires us to.

Our providers acting as processors may only process the data entrusted to them in accordance with our instructions and within the scope of the services they provide.

We may also produce and share aggregated or anonymised statistics that no longer allow the individuals concerned to be identified.

6. Data transfers outside the European Economic Area

Some technical providers may be established in, or process data outside of, the European Economic Area.

Where such transfers take place, we ensure they are governed in accordance with applicable regulations, in particular by an adequacy decision of the European Commission or, where necessary, by standard contractual clauses approved by the European Commission together with appropriate additional safeguards.

The CNIL notably recommends checking, for each provider, the hosting and support locations and the legal mechanisms governing any transfers outside the EU.

7. How long do we keep your data?

We only keep your data for as long as necessary for the purposes for which it was collected.

As a general rule:

Data linked to your Clear Fashion account
It is kept for as long as you use your account. If the account is deleted or closed, data that is no longer necessary is deleted or anonymised, except for data that must be temporarily retained to comply with a legal obligation or to defend our rights.

Contact requests and business prospects
Data used to follow up on a prospect may be kept for three years from its collection or from the prospect’s last contact. This period notably corresponds to the CNIL’s guidelines on prospect management.

Newsletter
Your email address is kept for as long as you remain subscribed to the newsletter. You can unsubscribe at any time. The CNIL itself applies this principle to managing its own newsletter.

Data required to comply with a legal obligation or to defend our rights
Certain data may be archived for the period required by regulation or for the applicable limitation periods.

Technical data and trackers
Their retention period depends on their nature and purpose. Information about the trackers used and their duration is set out in our cookie-management tool where applicable.

8. Your rights

In accordance with the General Data Protection Regulation (“GDPR”) and the French Data Protection Act, you have, depending on the legal basis and the nature of the processing concerned:

a right of access to your personal data;
a right to rectify inaccurate or incomplete data;
a right to erasure of your data where the conditions laid down by the regulation are met;
a right to restriction of processing;
a right to object to certain processing based on our legitimate interest;
a right to portability of certain data;
the right to withdraw your consent at any time for processing based on it.

The exercise of these rights depends in particular on the legal basis for the processing concerned.

You may also set guidelines regarding the retention, erasure and communication of your data after your death, in accordance with French law.

To exercise your rights, you can contact us at:

contact@clear-fashion.com

We may ask you for certain additional information where it is necessary to verify your identity and process your request.

If, after contacting us, you believe that your rights are not being respected, you can lodge a complaint with the French data protection authority (CNIL).

9. Cookies and other trackers

Our website may use cookies and similar technologies.

Some trackers are strictly necessary for the website to function and do not require your consent.

Cookies and trackers that are not strictly necessary — in particular those that may be used for audience measurement, personalisation or certain third-party features — are only stored or read after your consent where it is required.

You can:

accept or refuse trackers subject to consent;
change your choice at any time via our cookie-management tool.

Refusing non-essential cookies does not prevent access to the site’s essential features.

10. Security

We implement appropriate technical and organisational measures to protect the personal data we process against, in particular:

unauthorised access;
alteration;
disclosure;
loss;
accidental or unlawful destruction.

Access to data is limited to those who need it in the course of their duties.

As no IT system can guarantee absolute security, we regularly reassess the measures in place according to the risks and the evolution of our services.

11. Changes to this policy

We may amend this Privacy Policy, in particular to take account of:

changes to our services;
the technologies used;
our organisation;
changes in regulation.

The date shown at the top of this page corresponds to the last update of the Policy.

In the event of a significant change affecting how we use your data, we will inform you where required by regulation.

12. Contact us

For any question about this Privacy Policy or the processing of your personal data:

Clothparency SAS – Clear Fashion
15 rue de Louvois
51100 Reims – France

contact@clear-fashion.com