1 INTRODUCTION

This is the Privacy Policy of Flombé (hereinafter referred to as “Flombé” , “we” or “our/us” ). The correct handling of personal data is extremely important to us. That is why we take great care in processing and protecting your personal data. This is done in accordance with the provisions of applicable privacy legislation (including the General Data Protection Regulation).

To guarantee your privacy as much as possible, we adhere to the following core values:

Information : We would like to inform you about why and how we use your personal data. This is described in this Privacy Policy.

Limited Collection : We take great care to limit the information we collect and use to only that information necessary to sell our products and/or provide our services (as defined below).

Security : We take appropriate measures to secure your personal data and require the same from the parties that use your data on your behalf. Flombé proactively continuously tests its websites through an automated security scan.

Right of the individuals : We respect your rights under applicable privacy laws (including the right to access, correct or delete your personal data in accordance with such laws).

This Privacy Policy describes how we implement these core values ​​and how we respect and protect your right to privacy. We urge you to read this statement carefully as it sets out the basis on which we will use your personal data when you purchase our products online or in one of our stores or through other Flombé outlets ( "Products" ), when you access to our websites, contact us or otherwise use our services and applications (collectively referred to as "Services" ).

2. PERSONAL DATA WE COLLECT AND USE

The personal data we collect about you when you purchase our Products or use our Services includes the following (collectively referred to herein as “Personal Data” ):

Your contact details. Your name, postal address and other contact details, such as your telephone number and email address, and any other contact details you provide to us (including delivery address when you purchase our Products online).

Your electronic identification data and other information that we automatically collect when using our online Services. When you visit our websites or apps, use (open, click, read, cursor movements, etc.) our newsletter or are confronted with online marketing advertisements from Flombé, we automatically collect data through your browser or device, using cookies and other technologies to track visitors to the website (including web analytics), such as your IP address, MAC address, your surfing behavior, the Products and Services you like and the contents of your abandoned shopping cart.

Your online purchases. To complete your online purchases via the official Flombé webshop or via other official Flombé social media channels, we use your name, gender, email address, telephone number (if you voluntarily provide this to us), delivery method and delivery address and all relevant information about your purchases, such as the amount and date of your purchases, the Product(s) or Service(s) you purchase, the device you use to make your purchases, payment method, payment status, bank account details, (employee) discount ( if available), voucher code used (if available), gift with your purchases (if applicable) and optional additional personal card or engraving information. In order to offer you payment methods from third parties, we may provide your Personal Data in the form of contact and order information to these third parties during the checkout process so that they can assess your eligibility to use their payment methods and apply these payment methods to you. can coordinate. Your transferred Personal Data will be processed in accordance with the third party's privacy statement .

Your Personal Data when subscribing to our newsletter. In order to provide you with the Flombé newsletter with inspiring and commercial content, we use your email address and additional information if you add it to your profile, such as name, date of birth and favorite store. Flombé also sends personalized newsletters based on your personal preferences.

Your communication data. Any data shared by you when you communicate with us via email, online, telephone, social media or any other form, such as questions, requests or complaints.

Your ratings and reviews and feedback. The opinions, experiences, preferences and interests and Product or event reviews that you publish on our websites or share with us online or via social media.

Health data. We may also collect information about your health, for example about your allergies. We will use health information that you voluntarily provide to us and only with your prior authorization or direction, solely for the purposes set forth in this Privacy Policy. You can refuse or withdraw your consent at any time as set out below (see 'Your rights').

3. PURPOSES OF USING PERSONAL DATA

The Personal Data we collect will only be used for the following purposes:

In the context of the performance of our agreement with you: To carry out our obligations arising from any contracts between you and us and to provide you with the Products, Services and information that you request, including managing and processing your requests, questions or complaints. This includes enabling you to purchase our Products, participate in our Flombé program, sweepstakes, competitions or our sales promotion campaigns, respond to your requests to provide customer service, respond to your inquiries, provide essential information about our Products and Services that you request, etc.

In the context of our legitimate commercial interests: We use your Personal Data as described above (both on an aggregated and on an individual basis) for the purpose of advertising our Products and Services, to contact you by email, regular mail, social media or otherwise record you for direct marketing or other commercial purposes. In addition, we use your Personal Data to analyze and improve the quality of our Products and Services, such as providing customer service and after-sales, and to understand you as a customer (customer optimization). This allows us to understand what may interest you, measure and understand the effectiveness of advertising we serve to you and others, and deliver relevant advertising. In addition, based on your use of our Services and Products you have purchased, we may contact you with advertisements or other marketing materials tailored to your personal preferences and experiences.

We may also use your Personal Data for our other legitimate commercial interests, such as operating and expanding our business activities; to develop and improve or customize our Products and Services; to protect and defend our (and others') rights, property or safety; to prevent abuse and fraud relating to the online sale of our products and to check whether our House Rules for the use of our website(s) and app(s) are complied with; to generate aggregated statistics about the users of our Products and Services; to enable our business activities; to implement company policies and procedures; to enable us to conduct business transactions, such as a merger, sale, reorganization, transfer of assets or business operations of Flombé, acquisition, bankruptcy or similar event; or for other legitimate business purposes permitted by applicable law.

Use of information based on your consent: Under certain circumstances we will also request your consent to process your Personal Data. For example, where you have not purchased our Products but would like to receive direct marketing communications (such as newsletters, promotions, product news) via email, other electronic means or telephone. In addition, in limited circumstances, we will process your health information for the purposes set out in this Privacy Policy.

You can withdraw your consent at any time (see Your Rights section below).

To comply with our legal obligations: Any Personal Data we collect may be used to comply with a legal obligation to which we are subject, such as regulatory authorities, tax authorities or investigative authorities.

4. SOCIAL MEDIA

When you participate in various social media forums such as Facebook, Twitter, Pinterest, Instagram, LinkedIn, etc., you should be familiar with and understand the tools of those sites so that you can make choices about how to use the Personal Data in your social can share media profile(s).

Flombé is bound by the privacy practices or policies of these third parties, so we encourage you to review the applicable privacy notices, terms of use and related information about how your Personal Data is used in these social media environments.

Depending on the choices you have made regarding your settings on various social media sites (and/or in combination with your settings on the Flombé pages), certain Personal Data may be shared with Flombé about your online activities and social media profiles (e.g. interests, marital status, gender, username, photo, comments and content you have posted/shared, etc.).

5. SHARING YOUR PERSONAL DATA

We share your Personal Data with the following parties:

External suppliers. We occasionally contact third parties to help us provide our Products and Services to us, including:

- Business partners, suppliers (such as IT service providers) and subcontractors;

- Contact centers, to assist us in the Consumer Service department;

- Advertising and media companies that carry out marketing and media activities for us

- Providers of analytics services and search engines that help us improve and optimize our website and apps, such as Google Analytics.

In providing their services, these third party providers will access, receive, maintain or otherwise process Personal Data on our behalf. Our contracts with these service providers do not allow the use of your Personal Data for their own (marketing) purposes. Consistent with applicable legal requirements, we take commercially reasonable steps to require third-party providers to adequately protect your Personal Data and to process it only in accordance with our instructions.

Business transaction . In addition, Personal Data may be disclosed as part of a merger, sale or transfer of Flombé's assets.

Third parties in case of a legal requirement . We may disclose your Personal Information if we believe it is required by law.

With permission . We may also disclose information about you, including Personal Data, to another third party where you have consented or requested that we do so, for example in the case of a promotional campaign with another sponsor.

6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

In most cases, your Personal Data is processed within the European Union. Please note, however, that Flombé may transfer and process any Personal Data you provide to us to countries other than your country of residence. The laws of these countries may not provide the same level of protection for your Personal Data. Flombé or any third party suppliers we use will therefore ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with any such transfer, more particularly for Personal Data transferred to countries outside the European Economic Area . This means that we have entered into legally necessary contracts with recipients of your data, including standard contractual clauses as approved by the European Commission or other supervisory authorities, where required.

You are entitled to a copy of all documentation demonstrating the appropriate security measures that have been taken by submitting a request via the contact form.

7. SECURITY

We will take reasonable steps to ensure that your Personal Data is appropriately secured using appropriate technical, physical and organizational measures so that it is protected against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or unlawful destruction and loss.

We take steps to limit access to your Personal Data to those individuals who need to access it for any of the purposes listed in this Privacy Policy. In addition, we contractually ensure that an external supplier that processes your Personal Data ensures the confidentiality and integrity of your data in a secure manner.

8. DATA RETENTION

We will retain your Personal Data for as long as necessary to fulfill the purpose for which it was collected and used (for example, for the time necessary to provide you with customer service, respond to inquiries, or resolve technical problems), unless a longer period is necessary for our legal obligations or to defend a legal claim.

9. YOUR RIGHTS

Subject to the conditions set out in applicable law, you have the following rights in relation to our processing of your Personal Data:

Right of access – You have the right to request confirmation if Flombé is processing Personal Data about you, and if so, access to the Personal Data and additional information. Upon request, we can also provide you with a copy of the Personal Data being processed;

Right to rectification – You have the right to request that Flombé correct, amend or supplement your Personal Data if we have incorrect or incomplete data about you. You can also correct, amend or supplement your Personal Data yourself by updating your profile. We also kindly request that you ensure that any changes in personal circumstances (such as changes of address, bank account, etc.) are notified to Flombé so that we can ensure that your Personal Data is up to date. Flombé will take all reasonable steps to ensure that all Personal Data is correct;

Right to withdraw consent – ​​You have the right to withdraw your consent to receive marketing communications at any time by following the instructions in a marketing communication or by completing the form below. If we use your Personal Data based on your consent for reasons other than marketing communications, you can withdraw your consent by completing the form below;

Right to erasure – You have the right to request erasure of any irrelevant Personal Data we hold about you where (i) the data is no longer necessary in relation to the purposes for which it was collected; (ii) you withdraw your consent and there is no other legal basis for processing; (iii) you object to the processing in the case of direct marketing purposes, or - in all other cases - there is no overriding legitimate ground for processing; (iv) we have processed your data unlawfully. If you have such a request and all requirements are met, we will ensure that Flombé deletes the data that we are not legally obliged to keep;

Right to restrict data use – You have the right to restrict our use of your Personal Data where (i) you contest the accuracy of the Personal Data; (ii) the use is unlawful but you do not want us to delete the data; (iii) we no longer need the Personal Data for the relevant purposes, but you need it for the establishment, exercise or defense of legal claims; or (iv) where you object to data use based on our legitimate interests pending verification whether Flombé indeed has compelling interests to continue the relevant data use;

Right to data portability – to the extent that we use your Personal Data for the performance of a contract with you and that Personal Data is processed automatically, you have the right to receive all such Personal Data that you have provided to Flombé in a structured, commonly used and machine-readable format, and also to oblige us to transmit it to another controller when this is technically possible;

Right to object – to the extent we are relying on our legitimate interests to use your Personal Data, you have the right to object to such use and we must stop such processing unless we can demonstrate compelling legitimate grounds for the use violates your interests, rights and freedoms, or where we need to process the data for the establishment, exercise or defense of legal claims. You also have the right to object to profiling activities carried out by Flombé;

Right to lodge a complaint – You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you reside, if you believe that the collection and use of your Personal Data infringes with this Privacy Policy or applicable law.

For more information about your rights, or how you can exercise your rights, please complete this contact form and do the following:

Select the 'privacy request' option under 'Choose subject'; and

select the relevant subcategory; and

Enter all the email addresses that you use and have used for all related Flombé services in the comments field, such as but not limited to the newsletter registration, the webshop account, the Wireless Perfume Diffuser app, etc.

10. CHANGES TO POLICY

This Privacy Policy may be revised from time to time. If it concerns a fundamental change in the nature of the use of your Personal Data or if the change is otherwise relevant to you, we will ensure that this information is provided well in advance before the change actually takes effect.

11. CONTACT US

If you have any questions about this Privacy Policy or our treatment of your Personal Data generally, please complete our contact form and be sure to indicate the type of your request.