Date: 14/12/2018

At Les Néons we are committed to protecting and respecting your privacy. This notice describes what personal data we collect, how we will use that data and how we keep your data safe.  For additional information on how we use cookies please refer to our Cookie Policy.  For all other information regarding our services, please refer to our Terms & Conditions.  

    
If you have a question that is not answered here, or if you would like more information about how we collect, use and store your personal data, you can contact us at any time by emailing, info@lesneons.com.

     
In this Privacy Policy we will cover:    

1. Who is the data controller? 
2. What personal data do we collect? 
3. How do we use this personal data?
4. What is our legal basis for processing your personal data? 
5. Who will process your data? 
6. Do we transfer your personal data outside of the Middle East? 
7. How long do we keep your personal data? 
8. Your rights 
9. Security measures 
10. Complaints 
11. Changes to this notice 
12. Legislative reference and useful links 

 

1. Who is the data controller?      

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

       
Les Néons website is owned by Lea Gmayel and run under the Lebanese law    
The term "our online services" refers to Les Néons, our mobile and tablet applications, our pages on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+ and any other websites or apps we own or run from time to time. The term "our services" refers to our online services and any of our other products and services offered from time to time. If you use any of our services, we will refer to you using the terms "user", "visitor", "you", "your", "yours" in this policy.   

       
Should you have any queries about our use of your personal data, please email on info@lesneons.com or write to our Privacy Team at Les Néons on info@lesneons.com 

   

2. What personal data do we collect?     

We collect and process only the data that is required to allow us to provide our services to you.  We collect the following data when you browse or shop at www.lesneons.com:  

a) We process the personal data required to complete and despatch your purchase, including your name, billing address, delivery address, payment details, mobile number, telephone number and email address.  We collect your email address in order to send you confirmation of your order; we collect your telephone number so that we can contact you if there are any issues with the order.  

b) We collect your email address when you sign up for email updates.

c) If you register for a Les Néons account, we collect your name, email address, password, country, day and month of birth and additional information regarding your favorite designers and your marketing preferences.    
d) When you contact our Customer Care team, we may collect additional data to help us resolve any queries relating to your order, delivery, payments, marketing, the website or any other queries. 

e) We collect and process data about you’re browsing on www.lesneons.com, including the pages you visit and how you interact with these pages. If you have registered for an account, we collect browsing data about your access to the dedicated areas of the website.  

f) If you are a customer of  www.lesneons.com or if you have given us your consent, we collect and process your personal data for direct marketing activities.    
g) If you provide us with someone else’s data – for example, if you purchase a product to be delivered to a friend or as a gift – we will collect and process the personal data required to enable the transaction such as the name, delivery address and other contact details for your friend.  If you are receiving an item as a gift, we will process your data only to complete the gift request and our contractual obligations.  

h) When you use the App version of our website, we will ask for your consent to collect personal data from you in order to send you brief messages ("push notifications") about products and services that we believe may be of interest to you. With your consent, we will also collect data regarding your use of the App and your IP address, in order to improve our service to you.  You can disable push notification at any time by updating the App settings in your mobile device.  

i) When you call our Customer Care team, your call will be recorded for training and fraud prevention purposes.   

        

3. How do we use the personal data we collect?      

We collect and process your personal data for the following purposes:

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

b) When you visit www.lesneons.com, we will collect the minimum personal data necessary to allow us to provide you with the services of the website, such as placing and holding items in your shopping bag.

c) When you visit www.lesneons.com, we will use some data about your use of the website to help us improve the website and our promotion of the website.  This will include data about how you came to the website; the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.   
  
d) We also collect data about your use of www.lesneons.com by using cookies.  More data about how we use cookies and how you can, if you wish, turn off cookies is included in our Cookie Policy.   

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

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

g) If you have purchased from www.lesneons.com, we will use the personal data we hold about you, including your purchase history, to contact you via email regarding products and services that may be of interest to you.  If you would prefer not to be contacted in this way, you can unsubscribe from emails at any time using the link on the bottom of the email, or update your contact preferences on www.lesneons.com  or by contacting our Customer Care team.  

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

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

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

k) When you call the Customer Care team, your call will be recorded for training and fraud prevention purposes.  

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

     

4. What is our legal basis for processing your personal data?     

Under the Law we must have a valid reason for using your personal data and we may not collect, store or use data about you that is not compatible with that reason. There are four valid reasons for our use of your personal data: 

I. Most of the data we collect from you is necessary to allow us to fulfill our contract with you or to enter into a contract with you e.g. you provide a billing address and email address when your purchase an item from www.lesneons.com so that we can process your payment and send you your order confirmation.    

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

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

Lastly, we may be required to use your data to meet a legal obligation or to protect your interests e.g. we may exchange information with other specialist organizations for the purposes of fraud detection and credit risk reduction and we will retain financial data long term to meet our statutory obligations.   

    
The legal basis for each of the ways in which we use your personal data is as follows:  

Our use of your data

a) When you purchase a product from www.lesneons.com we ask you for the personal data necessary to allow us to fulfill our contract with you including taking payment, any related anti-fraud checks if you choose to pay by credit/debit card, billing, shipping and delivery of the product and possible handling of the return

b) When you visit www.lesneons.com, we will collect the personal data necessary to allow us to provide you with the services of the website, such as placing and holding items in your shopping bag. 

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

d) We also collect data about your use of www.lesneons.com by using cookies.  More information about how we use cookies and how you can, if you wish, turn off cookies is included in our Cookie Policy.

e) When you register on www.lesneons.com, we will collect the data necessary to ensure that we can recognize you on return visits and provide you with the services registration offers, such as creating a wish list or subscribing to emails about your favorite designers.  If you would prefer not to continue receiving these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting our Customer Care team.

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

g) If you have purchased from www.lesneons.com, we will use the personal data we hold about you, including your purchase history, to contact you via email regarding products and services that may be of interest to you.  If you would prefer not to be contacted in this way, you can unsubscribe from emails at any time using the link on the bottom of the email, or update your preferences via www.Lesneons.com or by contacting our Customer Care team.

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

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

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

k) When you call the Customer Care team, your call will be recorded for training and fraud prevention purposes.

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

Our legal basis for processing :

1. The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data it will not be possible to finalize or execute the contract and your requests. This means that while you will continue to be able to browse www.lesneons.com, you will not be able to purchase products and you will not be able to use the services of our website such as the Wish List
2. When you make a purchase at www.lesneons.com, we are required to process your personal data to meet our legal obligations in accordance with the tax provisions and other statutory rules which apply. You are free to decide whether or not to purchase from us, but if you do make a purchase this use of your data will be necessary to meet our legal obligations. 
3. When you make a purchase at www.lesneons.com, we will use some of your personal data to carry out anti-fraud activities: we have a legitimate interest in carrying out this activity to prevent and prosecute any fraudulent activity. Our use of your data is necessary for our legitimate interest in ensuring that the service we provide to you is managed correctly. You have given your consent to our use of cookies via the cookie banner that appears on the website.  You can choose which cookies to accept via our Cookie Policy. Some cookies are necessary for our legitimate interest in ensuring that the service we provide to you is administered correctly e.g. retaining items in your shopping basket.
4. The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data, it will not be possible to finalize or execute the contract and your requests. This means that while you will continue to be able to browse www.lesneons.com, you will not be able to use the services of our website such as the wish list or alerts about deliveries from your favorite designers. You have given your consent and asked us to send you our marketing communications. Our use of your data is necessary for our legitimate interest in ensuring that you receive information about goods and services that may be of interest to you.

 

5. Who will process your data?    

Your personal data will be processed by the internal staff of Les Néons who have been specifically trained and authorized for this processing. 
Your personal data will also be transmitted to third parties that we use to provide our services; these parties have been rigorously assessed and offer a guarantee of compliance with the legislation on the processing of personal data. These parties have been designated as data processors and carry out their activities according to the instructions given by Les Néons and under its control.   The third parties in question belong to the following categories: banking operators, internet providers, companies specializing in IT and telematics services; couriers; companies that carry out marketing activities, including social media organisations; companies specializing in market research and data processing; companies offering contact centre services; companies providing publishing and distribution services.  

Under some circumstances, we may be required to disclose or share your data without your consent, for example, if we are required by the police, the courts or for other legal reasons.  Your data may be transmitted to the police, judicial and administrative authorities, in accordance with the law, for the investigation and prosecution of crimes, the prevention of and protection from threats to public security, to allow Les Néons to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.  We may also transfer your personal data to a buyer or potential buyer in the event that our assets are acquired by another organization.  The purchaser will be required by law to use your personal data only as described in this Privacy Policy.   

 

6. How long do we keep your data?      

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

      

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

When you have purchased goods from www.Lesneons.com , we will retain the billing data until the end of the relevant accounting period, normally seven years from the billing date;
When you make a payment, we will retain your payment details up to the certification of the payment and the completion of the relevant administrative-accounting formalities regarding your right of withdrawal and the terms applied for the disputing of the payment;      

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

When you give us your consent to send you marketing communications, you can withdraw your consent at any time.  We will consider your consent to be current for two years from your last interaction with any email that we send you, with our App or with www.Lesneons.com .      

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

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

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

When you contact our Customer Care team, we will keep the call recording for 6 months. Credit card details are not recorded as part of the call.  

      

7. Your rights    

You have the right to request a copy of the data that we hold about you (and we will provide this to you free of charge once we have confirmed your identity). If you would like a copy of some or all of your personal data, please email or write to us using the contact details in this policy.    

     
If we do hold data about you we will:   

- Give you a description of it   

- Tell you why we are holding it  

- Tell you who it could be shared with   

- Tell you how long we will keep the data 

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

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

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

- Let you have a concise and clear copy of the data   

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

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

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

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

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

     
To exercise any of these rights, you can sign in to your account, contact our Customer Care team by emailing info@lesneons.com or write to our Privacy Team at Les Néons at info@lesneons.com       
To ensure that the data of our users are not subject to breaches or illegitimate use by third parties, we will ask you to confirm your identity before carrying out your request.  

       

8. Security      

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