LOUIS VUITTON MALLETIER - LV APP & IOT PRIVACY POLICY
Last Update March 30th, 2018
The purpose of this Privacy Policy (the "Policy") is to describe how Louis Vuitton Malletier (“LV”, "We", "Our", or "Us") processes personal information about users (hereinafter: “You”) of the Louis Vuitton LV APP application (“LV APP”), of the Louis Vuitton Tambour Connected Watch (the “Connected Watch”) and/or of the LV Echo device for Horizon luggage (the “Connected Luggage”).
1. WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?
1.1 When using LV APP, LV collects personal information about You and in particular:
a) information relating to Your device such as: the OS version, the language setting and/ or Your device Mac address;
b) information in relation to the use of LV APP: time or duration of access, sections of LV APP which are most visited, crash and reboot;
c) Your device GPS location, subject to Your consent when required.
You may decide to create Your LV account (which will be applicable to all interactions You will have with LV) (hereafter, “Your LV account”) directly through LV APP, in which case LV may also collect the following information
d) Login/Id and other contact information: this may include name, e-mail address, country of residence, address, telephone number;
e) Payment information: for instance credit card details, bank account numbers, and/or paypal account details when You need to provide them to receive products or services You have ordered via LV APP (if e-commerce feature is available on the LV APP version You are using).

When You decide to use LV APP while being logged-in to Your LV account, We may directly identify You, and therefore reconcile Your activities on LV APP with Your other interactions with LV (whether in our stores or on our Websites).
LV APP will request access to information stored on Your device (such as photos, or camera, as this may be needed if you use specific functionalities developed from time to time within LV APP which imply access to such information).
1.2 When using Your Connected Watch, LV collects in particular the following personal information (in association with the unique device identifier assigned to Your Connected Watch):

a) browsing behavior in relation to Your use of Your Connected Watch: this may include the type of watch faces You download, what applications or features embedded in the Connected Watch You use, etc.

b) diagnosis information in relation to Your Connected Watch such as its battery level, storage level or crash and reboot events.
If you decide to pair Your Connected Watch with LV APP, We would also collect the information described in Section 1.1 which We may collect in relation to Your use of LV APP.

The Connected Watch operates with Google Android Wear. The information which Google may collect in relation to Your use of the Connected Watch is not shared with Us. You may download third party applications on Google Play Store directly within Your Connected Watch. The type of personal information collected from such third parties’ application and how it is used will be subject to such third parties application own terms of use and privacy policy, not LV’s.

1.3 When using Your Connected Luggage, You must log-in to LV APP and pair Your Connected Luggage on LV APP. As a result, LV collects the following personal information (in addition to information described in Section 1.1 which We may collect in relation to Your use of LV APP):

a) geolocation of the Connected Luggage, but only if (i) You have decided to turn on and place the LV Echo Device inside Your Connected Luggage AND (ii) Your Connected Luggage is located nearby one of the limited “Points of Interest” pre-identified by LV. Such “Points of Interests” are (i) airports covered by our partner’s communication network and (ii) our LV stores worldwide.

b) technical information relating to the LV Echo Device such as its battery level, or signals that the Connected Luggage was opened during the travel (by way of light sensor);

2. HOW DO WE USE YOUR PERSONAL INFORMATION?
2.1 When using LV APP, LV processes Your personal information for the following purposes:

a) to make LV APP, Our products and Your experience better;

b) to process any order and/or purchase on LV APP and respond to Your requests or questions;

c) to send You information You requested, or to communicate with You about Your account or Our relationship, to ensure the security of LV APP and prevent unauthorised access to LV APP;

d) to improve Our understanding of Your interests and concerns;

e) to understand and analyse Your different relations with LV including on our apps, on our Websites or in our stores; especially if You use LV APP in an identified/logged-in mode with Your LV account, as in such case LV will be able to directly identify You and reconcile Your activity on LV APP with other interactions You may have with LV;

f) customize Your experience with Us and tailor our marketing activities to address Your specific needs and interests,

g) to propose marketing offers in relation to Our products (see “Direct Marketing” below);

h) to meet legal obligations;

i) to ensure safety, security and anti-spam purposes.

2.2 When using Your Connected Watch
LV processes Your personal information to:
a) ensure synchronization process is correctly completed and alert You on any technical issue (low battery or storage level)
b) Better understand Your use of the Connected Watch, and therefore to make the Connected Watch and Your experience on the Connected Watch better (by proposing accurate and improved applications and/or content),
c) and under exceptional circumstances to comply with legal obligations.

When pairing Your Connected Watch with LV APP, LV would also process Your personal information for the purposes described in Section 2.1 in relation to Your use of LV APP. In addition, We will be able to directly identify You and therefore reconcile Your use of the Connected Watch with Your other interactions with Us, whether on our apps, our Websites or in our stores. This will allow us to customize Your experience with the Connected Watch and tailor our marketing activities to fit Your needs and interests.
2.3 When using Your Connected Luggage, LV processes Your personal information for the following purposes:
a) to track the location of Your Connected Luggage in “Points of Interest” pre-identified by the LV (airports and LV stores).
b) to alert You if Your luggage has been opened while in transit;
c) to provide You with relevant offers and propositions of services in relation to Your use of the Connected Luggage;
If You choose not to share certain personal information with Us, please note that We may not be able to provide You with all services available through LV APP. For instance, certain sections of LV APP (such as the Connected Luggage section) are not accessible unless You have created a LV account. Or, You will not be able to purchase any product on LV APP unless You provide identification and payment information.
3. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We do not disclose or otherwise share Your personal information We collect, except:

a) with Our parent and affiliated companies within the LV Group of Companies: (i) when You purchase a product via LV APP: Your personal information is processed by the relevant affiliated company in charge of selling You the product (ii) only authorized personnel with a need to know have access to the information, for purposes of internal audit, management, billing or administrative;

b) with service providers and agents who perform services on Our behalf :Your personal information may be shared with vendors who help Us operating the LV APP, the Connected Watch of the Connected Luggage;

c) with a company that We may acquire or which may acquire us or with which may merge;

d) when We are required to do so by law or when it is necessary to comply with applicable law.

4. USE OF PERSONAL INFORMATION IN DIRECT MARKETING
a) Unless You object to it, We may use Your personal information in direct marketing. In this connection, please note that:
(i) the name, contact details, products and other service portfolio information, transaction pattern and behavior, financial background and demographic data of You held by Us from time to time may be used by Us in direct marketing;

(ii) the following classes of services, products and subjects may be marketed:

(a) our events, special offers and promotions on the following products and services: Handbags, travel, small leather goods, accessories, shoes, ready to wear, timepieces, fine jewellery, perfume, Book & Stationary.

(b) reward, loyalty, or privileges programmes and related services and products, if such programmes are implemented in the future;
b) If You do not wish LV to use Your personal information for use in direct marketing as described above, You may exercise Your opt-out right by notifying LV.

5. COOKIES
We may collect certain information through cookies, or other automated means.
5.1 When You are using LV APP:
Some cookies may be functional to collect information which will allow Us to facilitate Your browsing such as languages preferences or saving the content of Your shopping basket but other cookies also collect information on Your behaviour by collecting referring pages accessed, times of visits, by saving Your preferences.
We also use cookies for Web analytics to measure LV APP activity and determine the areas of the app which are the most visited.
Such information will allow Us to enhance LV APP and have a better understanding of the products and services You would prefer.
You may express Your choice regarding cookies used for behavioural targeting advertising through the privacy settings options of Your browser which should include features to prevent from storing information on the terminal or processing information already stored on such terminal, unless You turn on the feature to allow such storage or processing.
At any time You can set up Your device to prevent the use of cookies by following the instructions relating to Your specific operating system.
If You use iOS : https://support.apple.com/en-us/HT201265
If You use Android:
https://support.google.com/chrome/ansWer/95647?co=GENIE.Platform%3DAndroid&hl=en
5.2 When You are using Your Connected Watch: Subject to Your prior consent, Your browsing behaviour is analysed through an analytics tool embedded in the Connect Watch. You may disable analytics at any time through the LV Link feature accessible directly on Your Connected Watch.
6. TRANSFERRING YOUR PERSONAL INFORMATION
Information We collected about You may be transferred to third parties, stored and processed in particular in the United States for hosting and maintenance purposes of LV APP.
When transferring Your personal information to third parties located in the United States, We make sure that Your personal information benefit from an adequate level of protection as a result of the signature of the EU model clauses that We enter into with the recipient or because of recipient has adhered to the Privacy Shield principles.
In addition, We may transfer Your personal information to Our LV affiliates worldwide hereafter for processing Your order when You purchase a product and for LV relationship management by the different LV affiliates with which You may interact. Such transfers will also benefit from an adequate level of protection as a result of the signature of the EU model clauses that We enter into with the recipient.
7. RETENTION PERIOD
Unless otherwise required by law, the LV shall keep Your personal information for no longer than necessary for the purpose of Your commercial relationship with the LV or the term applicable under local applicable law since our last contact, or as required to comply with the LV legal obligations.
6.1 In relation to LV APP, Your personal information will be kept as long as Your LV APP account is used and 5 years after You close it, except for the logs information which will be kept no longer than one year after their collection.
6.2 In relation to the Connected Watch, Your personal information will be stored for no more than 2 years after Your last use of the Connected Watch.
6.3 In relation to the Connected Luggage, Your personal information will be stored for as long as You use the Connected Luggage in relation with LV APP, and for no longer than 5 years after Your last connexion to the Connected Luggage section of LV APP.
8. YOUR RIGHTS
You may request access to the personal information We maintain about You. If You request such access, We will provide You with all the information as required by law on the purposes of the processing, categories of personal information processed, categories of recipients, personal information retention term, Your rights to rectify, delete or restrict the personal information accessed if applicable, etc.
You may also obtain a copy of any personal information that We hold about You in our records in a format compatible and structure to allow You to exercise Your right to personal information portability.
You may also request that We correct, amend, erase, any information which is incomplete, out of date or inaccurate.
You can request the deletion of Your Personal information (i) if Your personal information is no longer necessary for the purpose of the personal information processing, (ii) You have withdrawn Your consent on the personal information processing based exclusively on such consent, (iii) You objected to the personal information processing, (iv) the personal information processing is unlawful, (v) the personal information must be erased to comply with a legal obligation applicable to the LV. The LV will take reasonable steps to inform the other entities of the LV group of such erasure.
You can request the restriction of the processing (i) in the event the accuracy of Your personal information is contested to allow the LV to check such accuracy, (ii) if You wish to restrict Your personal information rather than deleting it despite the fact that the processing is unlawful, (iii) if You wish the LV to keep Your personal information because You need it for Your defence in the context of legal claims (iv) if You have objected to the processing but the LV conducts verification to check whether it has legitimate grounds for such processing which may override Your own rights.
You also have the right to lodge a complaint with the relevant data protection authority.
When Your information processing is based on Your consent, You may withdraw any consent You previously provided Us with at any moment.
You can also indicate Your objection to the processing of Your personal information at any time when used for marketing purpose or profiling to send You targeted advertising or to object to the sharing of Your personal information with third parties or within the LV group.
You can also provide Your instructions regarding the storage, deletion or disclosure of Your personal information after Your death. Such instructions may be general or specific.
To exercise these rights, please contact our LV Services at the email address or phone number identified in the “Contact” Section of the LV APP version You use.
9. SECURITY MEASURES
We will provide an adequate level of protection for the personal information and make sure that appropriate technical and organizational security measures are in place to protect the personal information (including education and training of relevant personnel) against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
10. CHILDREN
LV APP, the Connected Watch and the Connected Luggage are not directed to children. We do not knowingly collect personally identifiable information from children without permission from a parent or guardian, unless permitted by applicable law.
You must be at least eighteen years old to engage in activities and transactions on our sites, media or otherwise. By engaging in activities or transactions with Us, You affirm that You are at least eighteen years old and/or are fully able to enter into and comply with this Privacy Policy and be legally bound thereby.
If We are notified (by contacting Us at "Contact Us") or learn that a minor has submitted personal information to us through our media or otherwise, We will delete such personal information.

11. THIRD PARTY SITES
We may link to third party sites or services We do not control and which are governed by their own privacy policy. This Privacy Policy does not apply to those third party sites. We strongly advise You to check the privacy policies of all third party sites You visit to find out how they are treating Your personal information.
12. CHANGES TO THIS POLICY
From time to time We may change Our privacy practices. Our Policy may change from time to time to reflect changes in Our processing of Your personal information. We will notify You of any material changes as required by law.

13. CONTACT US
If You would like Us to update the information We have about You or Your preferences, or if You have any questions about the protection of Your personal information please contact either our LV Services (a list of toll-free numbers in Your region is available on Our www.[name of the LV].com website) or the contact address mentioned on the LV APP version You are using.
Last Update [to be completed]

Lanterne By Zanellato and Bortotto GM

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