Privacy policy
Policy on cookies and other trackers
Legal notices
Public annexes

1. PRIVACY POLICY

1.1 Purpose

AD BEAUTY, which operates the 1944 PARIS brand and the website www.1944.paris, attaches particular importance to the protection of the personal data of its customers, prospective customers, visitors, partners and users.

The purpose of this Privacy Policy is to explain, in a clear and accessible manner:

what personal data may be collected; ;
under what circumstances they are collected; ;
the purposes for which they are used; ;
on what legal grounds is the processing based; ;
to which recipients they may be disclosed; ;
how long they are kept; ;
what security measures are in place; ;
What are the rights of the individuals concerned, and how can they exercise them?.

This policy has been drawn up in particular in accordance with Regulation (EU) 2016/679 of 27 April 2016, known as the «GDPR», and the French law on data processing, files and civil liberties.

1.2 Scope

This policy applies to the processing of personal data carried out in connection with:

navigation on the website; ;
the creation and management of a customer account; ;
the placing, payment and tracking of an order; ;
from the delivery of the products; ;
the management of returns, exchanges, refunds and complaints ; ;
on the use of the contact form; ;
communication with customer services; ;
subscribing to the newsletter; ;
participation in a promotional campaign, a competition or a sales promotion; ;
the submission or management of a customer review; ;
audience measurement, personalisation and online advertising ; ;
fraud prevention and website security.

It applies in particular to visitors, customers, prospective customers, account holders, subscribers to marketing communications and individuals who engage with AD BEAUTY.

1.3 Data controller

The data controller is:

AD BEAUTY
23 Jean Jacques Rousseau Street
75001 Paris – France
Email: serviceclient@1944.paris

1.4 Principles applied

AD BEAUTY is committed to upholding the following principles:

lawfulness, fairness and transparency : data is processed on a specified legal basis and individuals are informed; ;
purpose limitation : the data is used only for specific, explicit and legitimate purposes ;
minimisation : only relevant data is collected; ;
accuracy : the data is kept up to date as far as possible; ;
storage restrictions : the data is not retained indefinitely; ;
integrity and confidentiality : appropriate measures are put in place to prevent unauthorised access, loss or tampering; ;
responsibility : AD BEAUTY documents its practices and regularly checks that they comply with regulations.

1.5 Definitions

Personal data : any information relating to an identified or identifiable natural person.

Treatment : any operation carried out on personal data, including the collection, recording, access, use, transmission, storage or deletion.

Data controller : an organisation that determines the purposes and means of processing.

Subcontractor : an organisation that processes personal data on behalf of the data controller.

Consent : a free, specific, informed and unambiguous expression of will by which a person consents to a specific treatment.

User : any person accessing the website or using any of the services offered.

1.6 Data that may be collected

Identification details

name; ;
first name; ;
title, where requested; ;
date of birth, only where this is necessary for a specific transaction; ;
customer account ID.

Contact details

postal address; ;
billing address; ;
delivery address; ;
email address; ;
telephone number.

Account details for the customer

username; ;
password in encrypted or hashed form; ;
preferences; ;
address books; ;
login history; ;
order history.

AD BEAUTY does not have access to the password in plain text.

Data relating to orders

products ordered; ;
quantities; ;
amount; ;
discounts and promotional codes; ;
selected gifts, samples or benefits; ;
order date and number; ;
order status; ;
delivery details; ;
returns, exchanges and refunds; ;
purchase history.

Payment details

Payments can be processed by specialist service providers such as Stripe, PayPal or Klarna, if the latter is enabled.

AD BEAUTY does not store the full credit card number or the security code. Payment service providers may transmit limited information such as:

payment status; ;
transaction reference; ;
payment method used; ;
the last four digits of the card, if applicable; ;
information required to prevent fraud.

Data relating to customer service

the content of the applications; ;
emails and messages; ;
attachments sent; ;
photographs of a damaged or faulty product; ;
trade history; ;
information relating to a complaint.

Users are advised not to submit sensitive or excessive amounts of data via forms or attachments.

browser type; ;
operating system; ;
type of device; ;
pages viewed; ;
duration of consultation; ;
work carried out on site; ;
advertising identifiers; ;
information contained in cookies and trackers; ;
safety data and technical logs.

Marketing data and preferences

subscribing to or unsubscribing from the newsletter; ;
consents and refusals; ;
communication preferences; ;
interactions with emails; ;
campaign history; ;
marketing segments; ;
information relating to the source of a visit or a conversion.

Customer reviews

Where the website allows users to post a review, the following data may be processed:

first name or display name; ;
mark awarded; ;
comment; ;
product in question; ;
date of the notice; ;
proof of purchase or verified purchase record; ;
email address, not published, used for verification or moderation.

1.7 Source of the data

Data may be collected:

directly from the individual when they create an account, place an order or make contact; ;
automatically whilst browsing, using cookies or trackers; ;
with payment, delivery, notification or marketing service providers; ;
on social media platforms when users interact with the official 1944 PARIS accounts; ;
from a third party when that person buys a present or a gift voucher for someone else.

1.8 Mandatory or optional

Fields marked as compulsory are required in order to provide the requested service. Failure to provide a response may prevent:

creating an account; ;
the confirmation of an order; ;
payment; ;
delivery; ;
the processing of a request; ;
access to an offer or a promotional campaign.

The other details are optional.

1.9 Objectives

Treatment	Purpose
Account creation	Enable access to the customer portal and loyalty scheme
Order Management	Record and process purchases
Payment	Process orders
Delivery	Delivering products
Returns and refunds	Providing after-sales service
Invoicing and accounting	Comply with tax and accounting obligations
Customer service	Responding to enquiries and complaints
Fraud prevention	Detecting suspicious transactions
Website security	Preventing unauthorised access and incidents
Newsletter	Sending marketing communications
Customer loyalty	Managing benefits and rewards
Customer reviews	Collect and publish feedback
Statistics	Measuring audience figures and improving the website
Targeted advertising	Customise and measure campaigns
Competitions	Manage entries and award prizes
Advocacy	Gathering and preserving evidence

1.10 Commercial communications

Users may receive communications relating to 1944 PARIS’s products, offers, new releases and news when:

they have expressly consented to receive them.

Every marketing message includes a way to unsubscribe. You can also request to unsubscribe by contacting serviceclient@1944.paris.

Messages that are strictly necessary for the fulfilment of an order are not marketing communications and may continue to be sent even after you have unsubscribed from marketing communications.

1.11 Tracking indicators in emails

Emails may contain technical indicators that enable measurement, depending on the applicable settings and consents:

deliverability; ;
the opening; ;
clicking on a link; ;
unsubscribing; ;
incorrect addresses; ;
the overall effectiveness of a campaign.

This information may be used to adjust the frequency of communications, improve their relevance and keep the mailing list up to date.

Where the applicable regulations require your consent, such processing will only commence once your consent has been obtained.

You may withdraw your consent, change your preferences or request that you are no longer tracked by pixels at any time by contacting us at the following address: serviceclient@1944.paris.

You can also use the unsubscribe link in our emails, our preferences manager or our contact form.

1.12 Customer account

In particular, the account allows you to:

view your order history; ;
manage addresses; ;
track a delivery; ;
save preferences; ;
to benefit from any potential advantages; ;
to make future purchases easier.

Users are responsible for keeping their login details confidential. They must notify AD BEAUTY if they suspect any unauthorised use of their account.

1.13 Orders, gifts and samples

Where an order allows you to choose a gift, a sample or a bonus, the information required to make this choice is linked to the order.

You may need to select a gift in your basket. If no gift is selected, it will not be included in the parcel, unless otherwise expressly stated.

Data relating to gifts, promotions and benefits is stored alongside order details for the purposes of sales follow-up, customer service and the prevention of abuse.

1.14 Loyalty scheme

Where a loyalty scheme is offered, AD BEAUTY may process :

the number of points; ;
a record of earnings and expenditure; ;
the benefits awarded; ;
eligible purchases; ;
expiry dates.

The specific terms and conditions of the programme must be set out in specific terms and conditions or in the general terms and conditions of sale.

1.15 Gift cards and promotional codes

In connection with a gift card or promotional code, AD BEAUTY may process:

the code; ;
the amount; ;
the balance; ;
the issue date; ;
the expiry date; ;
the identity of the purchaser or beneficiary, where necessary; ;
related uses.

1.16 Reviews and published content

Reviews may be moderated to ensure they comply with the posting rules, in particular to ensure they do not contain any illegal, offensive, misleading or promotional content, or content unrelated to the product.

Users should avoid including personal data in the body of their reviews. AD BEAUTY may hide or remove any excessive data.

1.17 Social media

When a user interacts with 1944 PARIS on a social media platform, that platform may process their data in accordance with its own terms and conditions.

AD BEAUTY may access publicly available information, private messages and statistics provided by the platform. Certain pages or accounts may entail limited joint liability with the network operator in respect of statistical data.

Users are advised to consult the privacy policies of each platform.

1.18 Internal recipients

The data is accessible only to authorised personnel within AD BEAUTY, in particular as required:

customer service; ;
sales administration; ;
logistics; ;
accounting; ;
marketing; ;
IT; ;
management; ;
legal adviser or compliance provider.

Access is granted on the basis of the duties performed.

1.19 Service providers and subcontractors

AD BEAUTY may use external service providers to provide the following:

accommodation; ;
maintenance; ;
site management; ;
payment; ;
delivery; ;
sending emails; ;
cookie management; ;
audience analysis; ;
advertising; ;
customer reviews; ;
safety; ;
assistance and support.

Service providers are contractually obliged to process data in accordance with AD BEAUTY’s instructions and to put in place appropriate safeguards.

1.20 Main service providers likely to be used

Service provider or solution	Function	Data provided for information purposes only
WordPress	Content management	Technical data and administrator accounts
WooCommerce	Shop management	Account, basket, orders, billing
Hosterra	Hosting and backups	Site data and technical logs
Stripe	Payment	Transaction data and fraud prevention
PayPal	Payment	PayPal account and transaction details
Brevo	Emails and marketing	Email address, campaigns, technical events
CusRev	Customer reviews	Product review
CookieYes	Consent to the use of cookies	Choice and proof of consent
Matomo	Audience measurement	Browsing data and identifiers, depending on settings
Google Analytics 4	Audience measurement	Browsing data and identifiers, depending on settings
Google Ads	Advertising and measurement	Browsing data and conversion
Meta Pixel	Advertising and measurement	Browsing and conversion events
TikTok Pixel	Advertising and measurement	Browsing and conversion events
Pinterest Tag	Advertising and measurement	Browsing and conversion events
Google reCAPTCHA	Protection against abuse	Technical and performance data
Colissimo	Delivery	Name, address, telephone number, email address
Chronopost	Delivery	Name, address, telephone number, email address

This list must be updated to reflect the tools that are actually enabled.

1.21 Transfers outside the European Economic Area

Some service providers may process data in countries located outside the European Economic Area.

When an international data transfer takes place, AD BEAUTY ensures that it is based on a mechanism provided for under the GDPR, in particular:

a decision on suitability; ;
standard contract terms; ;
binding company rules; ;
an exemption provided for by the regulations in a specific case.

Additional measures may be implemented where necessary.

1.22 Retention periods

The timeframes below are for guidance only and must be confirmed in line with the company’s actual practices.

Category	Duration or indicative criterion
Active customer account	During the business relationship
Inactive account	Deletion or anonymisation after a defined period of inactivity as set by AD BEAUTY
Orders and contracts	Time required for processing and subsequent statutory archiving
Invoices and accounting documents	Period specified by accounting and tax requirements
Prospects	Time limit from the date of the last active contact
Newsletter	Until you unsubscribe or withdraw your consent
Opt-out list	Time required to comply with the refusal
Customer service	Time required for processing, followed by proportionate archiving
Customer reviews	During publication and, where necessary, subsequent restricted archiving
Fraud data	A timeframe commensurate with the analysis and any potential disputes
Security logs	Time limit tailored to safety requirements
Cookie consent options	The period required to retain evidence and respect the choice
Cookies	Depending on the expiry period specific to each tracker and the Cookie Policy

At the end of the applicable retention periods, the data is deleted, anonymised or placed in interim storage with restricted access.

1.23 Safety

AD BEAUTY implements appropriate technical and organisational measures, including:

HTTPS encryption of data transmission; ;
rights and authorisations management; ;
strong passwords; ;
strong authentication where available; ;
backups; ;
updates to the website, extensions and systems; ;
log and incident monitoring; ;
restrictions on administrator access; ;
confidentiality clauses; ;
incident management procedures; ;
selection and monitoring of service providers.

As no system can guarantee absolute security, AD BEAUTY is committed to responding swiftly in the event of an incident.

1.24 Data breach

In the event of a data breach that could pose a risk to individuals’ rights and freedoms, AD BEAUTY will analyse the incident, take the necessary corrective measures and make the notifications required by the regulations.

Where the risk is high, those affected may be informed individually, unless otherwise provided for by law.

1.25 Miners

The website and products are primarily intended for people who are capable of making a purchase or who are acting with the authorisation of a legal representative.

AD BEAUTY does not seek to knowingly collect personal data from children without the appropriate authorisation. Where such collection comes to its attention, the necessary measures are taken to investigate the matter or delete the data.

1.26 Automated decisions and profiling

Tools can be used to segment audiences, personalise communications, detect fraud or measure the performance of a campaign.

Unless otherwise stated, the purpose of these processing operations is not to produce a decision based solely on automated processing that has legal effects or a similarly significant impact on the individual.

1.27 Rights of individuals

Subject to the conditions laid down in the regulations, every person has the following rights:

Right of access

To obtain confirmation that data is being processed and to receive a copy of the relevant data.

Right to rectification

Have any inaccurate data corrected or complete any incomplete data.

Right to erasure

Request the erasure of data where the legal conditions are met. This right does not apply where retention is necessary to comply with a legal obligation or to defend rights in court.

Right to restriction

Request a temporary suspension of data use in certain situations.

Right to object

To object to processing based on a legitimate interest on grounds relating to their particular situation. The right to object to marketing communications may be exercised at any time without giving any reason.

Right to data portability

To receive certain data in a structured, machine-readable format, or to request that it be transferred to another organisation where the conditions are met.

Withdrawal of consent

To withdraw consent at any time, without affecting the lawfulness of the processing carried out previously.

Guidelines following a death

To set out guidelines regarding the retention, erasure and disclosure of their data following their death, in accordance with French law.

Right to human intervention

Where a decision is based solely on automated processing and produces legal or significant effects, the individual may, in the cases provided for by law, request human intervention and challenge the decision.

1.28 Exercising rights

Applications may be sent to:

By email: serviceclient@1944.paris
By post: AD BEAUTY – Data Protection Department – 23 rue Jean Jacques Rousseau – 75001 Paris – France

The request must enable the identification of the individual and the right being exercised. Proof of identity may be requested only where this is necessary and proportionate to prevent fraudulent disclosure .

AD BEAUTY responds within the timeframes set out in the GDPR. This timeframe may be extended in the event of complex requests or a large number of requests, provided that the individual is informed accordingly.

1.29 Complaints to the CNIL

If a problem remains unresolved, a complaint may be submitted to:

National Commission for Information Technology and Civil Liberties – CNIL
3 Place de Fontenoy
TSA 80715
75334 Paris Cedex 07
Website: www.cnil.fr

However, AD BEAUTY asks people to contact it in advance so that a solution can be found.

1.30 External links

The website may contain links to third-party websites. AD BEAUTY is not responsible for the processing carried out by these websites. Users should consult their privacy policies.

1.31 Update

This policy may be amended to take account of:

a change in the law or regulations; ;
a recommendation from the CNIL; ;
a change of service provider; ;
a new feature; ;
advances in treatment.

The date of the update is shown at the top of the document. In the event of a substantial change, specific information may be issued where necessary.

2. POLICY ON COOKIES AND OTHER TRACKING TECHNOLOGIES

2.1 Purpose

This policy explains the use of cookies and other trackers on the website www.1944.paris.

A cookie is a small file or identifier that is stored on or read from the user’s device when they visit a website, use an application or open an email.

Tracers can, in particular, be used to:

how the shopping basket works; ;
authentication; ;
saving preferences; ;
site security; ;
audience measurement; ;
content personalisation; ;
advertising measurement and targeting.

2.2 Person responsible for the use of tracers

AD BEAUTY is the data controller for the trackers it places or has placed for its own purposes. Certain partners may act as separate or joint data controllers, depending on the services concerned.

2.3 Categories of cookies

Strictly necessary cookies

These cookies are essential for the website to function and do not generally require consent when they are used solely to provide a service that has been specifically requested.

In particular, they can be used for:

keep the contents of the basket; ;
keep a session open; ;
secure the site; ;
remember your cookie preferences; ;
ensure load balancing; ;
enable authentication.

Functional cookies

They help to improve the user experience, for example by saving certain preferences. Depending on their purpose, they may be subject to consent.

Audience measurement cookies

They enable us to compile visitor statistics, understand user journeys and improve the website.

Depending on their configuration, certain audience measurement tools may be exempt from the consent requirement under strict conditions. Otherwise, they must only be activated once consent has been given.

Advertising cookies

They are used for:

measure campaign performance; ;
attribute a conversion; ;
limit the number of times an advert is shown; ;
build an audience; ;
personalise adverts; ;
carry out retargeting.

They are subject to prior consent.

Social media cookies

Social media buttons, pixels or embedded content may enable these platforms to track your browsing activity. They are generally subject to consent.

2.4 Tools that may be used

Tool	Main purpose	Indicative category
CookieYes	Save and manage your choices	Essential
Elementor	How the website works	Essential
WordPress	How the website works	Essential
WooCommerce	Shopping basket and shop	Essential
Google reCAPTCHA	Protection against bots	Security, depending on configuration
Matomo	Audience measurement	Statistics
Google Analytics 4	Audience measurement	Statistics
Google Tag Manager	Audience measurement	Advertising executive
Google Ads	Measurement and advertising	Advertising executive
Meta Pixel	Measurement, audience and retargeting	Advertising executive
TikTok Pixel	Measurement, audience and retargeting	Advertising executive
Pinterest Tag	Measurement, audience and retargeting	Advertising executive
Brevo	Communications monitoring	Functional or marketing, depending on usage
Stripe	Payment	Essential
Cusrev	Checking and displaying notices	Functional

2.5 Consent

On a first visit, a banner allows you to:

to accept trackers subject to consent; ;
to reject them with equal ease; ;
to tailor options according to purpose; ;
to access more detailed information.

Failure to act does not constitute consent.

Non-essential trackers must not be removed until the user has made a choice.

2.6 Withdrawal or amendment of choices

Users can change their settings at any time by using the cookie management link or button on the website, for example :

«Manage my cookies» or «Cookie settings».

Withdrawing consent must be just as simple as giving it.

2.7 Duration of the choice

The user’s choice is retained for a limited period. At the end of this period, consent may be sought again.

The chosen configuration must comply with the current CNIL recommendations and be verified in the consent tool.

2.8 Cookie lifetime

The service life of a tracker must be commensurate with its intended purpose and must not be automatically extended at each service visit where this contravenes the applicable rules.

A detailed list and the durations are set out in the cookie manager.

2.9 Google Analytics 4

When Google Analytics 4 is enabled following consent, it can be used to measure:

the pages viewed; ;
navigation events; ;
traffic sources; ;
the devices; ;
conversions; ;
the website’s performance.

AD BEAUTY must check the relevant settings, including the retention period, Google signals, granular data collection, consent mode and advertising settings.

2.10 Google Ads

Google Ads can be used to track conversions, create audiences and personalise adverts. The relevant tags must only be enabled once consent has been given, where this is required.

2.11 Meta Pixel

The Meta pixel can send events such as the following to Meta:

page view; ;
viewing a product; ;
Add to basket; ;
start of payment; ;
purchase.

This information may be combined with other data held by Meta, depending on the user’s settings and account.

2.12 TikTok Pixel

The TikTok pixel can be used to measure campaigns, create audiences and analyse conversions. It is subject to prior consent where it is not strictly necessary.

2.13 Pinterest Tag

The Pinterest tag can be used to track actions taken after an advert has been viewed or clicked, and to create advertising audiences.

2.14 Emails and web beacons

Emails may contain tracking pixels or links that enable the measurement of deliverability, open rates or click-through rates.

Where these technologies involve accessing or writing information to a device and are not strictly necessary, their use must comply with the rules applicable to trackers and consent.

You may withdraw your consent, change your preferences or request that you are no longer tracked by pixels at any time by contacting us at the following address: serviceclient@1944.paris. You can also use the unsubscribe link included in our emails, where available.

2.15 Management via the browser

Users can also configure their browser to block or delete cookies. However, doing so may impair certain functions, including:

the basket; ;
the connection; ;
saving preferences; ;
the completion of an order.
Shop locator
Website design

2.16 Evidence of consent

AD BEAUTY retains the information necessary to demonstrate the user’s choice, in particular:

the date; ;
the banner version; ;
the categories that have been accepted or rejected; ;
a consent identifier; ;
the applicable version of the policy.

2.17 International transfers involving tracers

Some tracking providers are based in, or process data outside, the European Economic Area. The applicable safeguards are set out in the Privacy Policy and in the policies of the relevant providers.

2.18 Update to the cookie policy

This policy may be updated in the event of changes to the tools, regulations or the CNIL’s recommendations.

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