PRIVACY POLICY

Last update date: March 2023

INTRODUCTION

Sève (“Sève”, or “we” or “our” or “us”) publishes and hosts a digital platform (the “Platform”), accessible online under a software-as-a-service distribution model, for the actors of the fashion industry in order to facilitate the management and realization of fashion design projects for both the stylists and the brands (and/or their authorized partners) (“User” or "you" or "your") by providing:

a digital workplace for stylists enabling to manage their styling projects ;
a digital showroom for brands (and/or their authorized partners) enabling them to share and diffuse their products online and to manage and monitor their inventory as per the stylists’ requests;
intermediation services though which stylists and brands (and/or their authorized partners) can interact, notably by enabling stylists to request, for the purpose of any of their projects, any product proposed by the brands (and/or their authorized partners) through the Platform, and brands (and/or their authorized partners) to answer to the stylist’s request and share of any follow-ups on the sames.

The protection of your privacy and your personal data is a priority for Sève.

This privacy policy (the "Policy") applies to the Users of Sève’s Platform and aims to inform you in a clear and comprehensive manner of the processing of your personal data carried out in accordance in particular with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR") and the French law no. 78-17 of 6 January 1978, in its latest version in force (together the "Applicable Regulations").

This Policy may be updated at any time as a result of, among others, legal, technical or commercial changes. In such cases, Sève will take appropriate measures to inform you of such changes, where they are significant. We recommend that you refer to this Policy regularly to ensure that you are aware of the latest version.

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1. WHO IS THE CONTROLLER FOR THE PROCESSING OF YOUR PERSONAL DATA?

Sève, a French Société par Actions Simplifiée (simplified joint stock company), whose registered office is located at 13 T Rue Auguste Gervais 92130 Issy-les-Moulineaux, registered in the Trade and Companies Register of Nanterre under number B 919804047 acts as a data controller for the processing of your personal data (i.e., it determines the purposes and means of the processing of your personal data) carried out through the Platform for the purposes described in Section 2 of this Policy.

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2. FOR WHAT PURPOSES IS YOUR PERSONAL DATA COLLECTED AND WHAT ARE THE DETAILS OF SUCH PROCESSING?

Sève ensures that it collects and processes personal data that is relevant, adequate, not excessive and strictly necessary for the purposes pursued.

You will find below a table listing the relevant information related to the processing of personal data, where Sève acts as a data controller, and in particular:

The different purposes of the processing operations;
The personal data collected;
The legal basis on which we rely to carry out the processing;
How long we keep your personal data.
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3. WHICH PERSONAL DATA CAN YOU PROVIDE WITHIN FREE TEXT SLOTS?

Sève ensures that it collects and processes only relevant, adequate, not excessive and strictly necessary personal data for the purposes listed in Section 2 of this Policy. In order for Sève to provides this guarantee, please be careful to only provide relevant personal data within the free text slots which are on Sève’s Platform (i.e., factual data, relating to Sève’s services and having a direct link to the object/purpose of the free text slot concerned).

As a User you have the possibility to enter third party personal data into the Platform (e.g., the personal data of the talent, of the photographer, etc.). By entering these personal data into the Platform, you acknowledge that you have collected and processed such data in a lawful manner and that you have correctly informed the data subjects of the transmission of their data to Sève.

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4. IS THE PROVISION OF YOUR PERSONAL DATA MANDATORY?

Whether or not the provision of your personal data is mandatory will be indicated to you at the time of collection of such personal data: fields marked with an asterisk must be completed, the other fields are optional.

Where you do not provide personal data that is identified as mandatory by an asterisk, Sève may not be able to reply to your request and/or to provide you with its services.

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5. DOES SEVE DEPOSIT AND USE COOKIES?

Sèves uses and deposits cookies on its Platform.

Such cookies comply with European data protection authorities requirements and are exempted from consent.

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6. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA?

Sève will only share your personal data in certain circumstances and in accordance with the provisions of the Applicable Regulations. Sève discloses your personal data only to identified and authorized recipients, as described below. All recipients processing your personal data are subject to confidentiality obligations.

Sève discloses your personal data to:

Internal authorised employees who need to process your personal data for the purposes specified in Section 2 of this Policy.

External recipients:

Public authorities and bodies to whom we must disclose some of your personal data to comply with legal obligations, face a litigation or to protect the rights and/or safety of an individual.

Third-party service providers:

Hosting service provider for the Platform;
Service providers monitoring / tracking User’s experience to improve the Platform;
Payment service providers;
IT and other service providers for the development, marketing and distribution of the Platform

In addition, your personal data may be shared with third parties for the following purposes:

In the event of a merger or acquisition of all or part of Sève by a third party or in the event of a sale, assignment or restructuring.
In response to judicial or administrative proceedings of any kind or to law enforcement measures requested by the competent authorities.

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7. DOES SEVE TRANSFER YOUR PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA?

Your personal data may be transferred to countries which do not offer an adequate level of protection and have not been recognized as adequate country by an adequacy decision from the European Commission (list available here) and more precisely, to the following countries:

United States (USA)

When your personal data is transferred to one of these countries, Sève will ensure an adequate level of protection through the following appropriate safeguards and measures:

European standard contractual clauses

You may obtain a copy of [this/these] warrant[y/ies] at any time: to do so, please contact Sève at the email address specified in Section 9 of this Policy.

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8. WHAT ARE YOUR RIGHTS WITH RESPECT TO THE PROCESSING OF YOUR PERSONAL DATA?

In accordance with the Applicable Regulations, you have the following rights with respect to your personal data:

If your personal data has been processed with your consent, you are entitled to withdraw your consent at any time without affecting the consent given prior to the withdrawal (see the table in Section 2 of this Policy to understand which processing are based on your consent).
You have the right to access and obtain a copy of the personal data we hold about you (provided the request is not manifestly unfounded or excessive, particularly because of its repetitive nature).
You may request to rectify your personal data if they are inaccurate, incomplete or not up to date (provided that the request is not manifestly unfounded or excessive, particularly because of its repetitive nature).
You can request that your personal data be erased. However, this is not an absolute right, as we may be obliged to retain your personal data for legal or legitimate reasons. You may exercise your right to deletion in the following cases: if you have validly objected to the processing of your personal data or have withdrawn your consent, if the personal data is not or is no longer necessary for the purposes for which it was originally collected or processed, or if the personal data is unlawfully processed.

You can request a restriction on processing. This right means that the processing of your personal data by us is restricted, so that we may retain the data, but we may not use or otherwise process it. This right applies in specific circumstances, namely (i) if you challenge the accuracy of your personal data: the processing is then restricted for a period of time to allow Sève to verify the accuracy of the data; (ii) in cases where the processing is unlawful and you object to the erasure of your personal data and instead demand the restriction of their use; (iii) in cases where we no longer need the personal data for the purposes mentioned above in section 2, but they are still necessary for the establishment, exercise or defense of legal claims; and (iv) in cases where you have objected to the processing based on the legitimate interests pursued by Sève, you may request that the processing be restricted for the period necessary to determine whether we can comply with your objection.
You have the right to data portability, meaning to receive the personal data that you have provided to us and that we hold about you in a structured, commonly used and machine-readable format. This applies only where the processing is based on your consent or the execution of pre-contractual measures / performance of a contract and is carried out by automated means (see the table in Section 2 of this Policy to understand which processing rely on these legal basis).
If you are a French citizen, you also have the right to give general and specific instructions to decide the fate of your personal data after your death.
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Please note that you may object to the processing of your personal data.

Where we process your personal data on the basis of Sève's legitimate interests (see the table in Section 2 of this Policy for data processing based on Sève's legitimate interests), you may at any time object to the processing of your personal data on grounds relating to your particular situation (unless we have compelling legitimate grounds for processing such data which override your interests, rights and freedoms, or where such data is necessary for the establishment, exercise or defense of legal claims).

You may also, at any time, unsubscribe or oppose the receipt of direct marketing messages from Sève (e.g. our newsletters). All you have to do is either (i) click on the link in the footer of the communications you receive from Sève; or (iii) send a message to the contact details indicated in Section 9 of this Policy.

Finally, you have the right to lodge a complaint before the relevant supervisory authority (in France, the Commission Nationale de l'Informatique et des Libertés: the “CNIL”). However, we invite you to contact Sève at the address below before filing any complaint before any supervisory authority.

To exercise all these rights, you can send a request:

In writing to the following postal address: Sève SAS, 13 T Rue Auguste Gervais, 92130 Issy-Les-Moulineaux, France.
By e-mail to the following address: contact@seve.app

As an User, you can also modify your data yourself at any time by logging to the Platform and modifying your details.

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9. HOW TO CONTACT SEVE FOR ANY INQUIRY REGARDING THIS POLICY?

If you have any questions, complaints or comments about this Policy or our personal data processing practices, please contact us:

In writing to the following postal address: Sève SAS, 13 T Rue Auguste Gervais, 92130 Issy-Les-Moulineaux, France.
By e-mail to the following address: contact@seve.app.

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