Privacy Policy

The Data Controller is the person who determines the purposes and means of the processing of personal data, i.e., their "why?" and "how?"

CAMINOV (brand "FRINGUANT") acts as a data controller (FIG. 1.) but also as a subcontractor of the partner brand, which administers the sales funnel into which the "plug-in" of our size selection assistance application is integrated, via a body scan (FIG. 2.).

For all personal data processing where CAMINOV (brand "FRINGUANT") acts as data controller (FIG. 1.):

CAMINOV ("FRINGUANT" brand) also acts as a subcontractor, on behalf of the partner brand that manages the sales process, within the framework of which the CAMINOV "plug-in" ("FRINGUANT" brand) is integrated. It is the partner brand that then acts as the data controller, and thus determines the purposes and means of the processing activities in question, in particular the purposes, legal bases and storage periods.

When CAMINOV (brand "FRINGUANT") acts as a subcontractor (FIG 2.), the data controller is the partner brand, which administers the sales funnel within which the CAMINOV "plug-in" ("FRINGUANT" brand) is integrated. For any questions relating to the protection of your personal data and the exercise of your rights, in the context of this processing of personal data, we invite you to contact this partner brand.

The Data Protection Officer (DPO) of CAMINOV (brand "FRINGUANT") is:

The competent supervisory authority for the protection of personal data is:

Personal data means any information relating to a natural person from which that person can be identified, either directly or indirectly.

Directly identifying data are, for example, your first and last name. Other data is not directly identifying but is nevertheless qualified as personal data, insofar as it provides information about you, in particular, when it is cross-referenced with each other, or cross-referenced with identifying data. This is the case, for example, with your postal address, telephone number, geolocation history, etc.

Although not directly identifiable, your precise physical measurements nevertheless constitute personal data.

In most cases, we collect the personal data in question directly from you. This is the case when you carry out your body scan, via the plug-in that we provide, within the sales path of our partner brands, or directly from our website.

However, we may also collect certain information, indirectly, as a data processor, on behalf of partner brands. This includes, for example, data about your interaction with partner brands' sites.

CAMINOV (brand "FRINGUANT") collects certain personal data directly from you, in the following circumstances:

• You are a user of the website of one of our partner brands, and, as part of the purchase of an item from this brand, you have subscribed to the "find my size" option; in this case, we collect, on behalf of our partner, the clothing brand, data relating to your measurements, via our body scanning system (e.g. height in cm, shoulder circumference, hips, etc.), the suggested size (S, M, L, XL, XXL, etc.), your gender, as well as information relating to your browsing (in particular to avoid you having to carry out a body scan again);
• You are a visitor to our https://www.fringuant.com website, and you have entered personal data on this website (e.g. via a contact form), or you have used our body scanning tool from this website;
• You are a point of contact for one of CAMINOV's customers, partners or suppliers, and the latter thus has your contact data (surname, first name, email address, telephone number, as well as your browsing and connection data on the CAMINOV solution (browsing data and connection metadata, etc.).

CAMINOV ("FRINGUANT" brand) also collects certain personal data indirectly from third parties, on behalf of the partner brand, as a subcontractor of the latter:

• You are a user of the website of one of our partner brands, and, in the context of the purchase of an item of this brand, you have subscribed to the "find my size" option, in which case the partner brand, or its service provider platform (the "DMS" platform), may communicate to us, with your consent, information about you, relating to your interaction with its website (e.g. Order ID, cancelled order, modified order, full or partial refund, affected items, use of a promo code, currency used, etc.): This information is collected on behalf of the partner brand.
• You are a person appearing in a photo of you (model, third party) that you have entrusted to the CAMINOV client and that the latter has uploaded to the UPTOO solution, in the context of the use of the virtual studio service or the fashion item description generation service.

The main purposes for which CAMINOV (brand "FRINGUANT") collects and processes personal data concerning you, as a subcontractor of its partner, the clothing brand, are (c.f. FIG. 1):

• allow you, with our partner brands, to obtain from our partner brands the clothing size that best corresponds to your body measurements, via the "find my size" option, and the use of a body scan;
• To allow you not to have to carry out a body scan again, if you have already subscribed to the "find my size" option;
• To allow you to get personalized recommendations on the clothing sizes that best suit your body type.
• To allow Fringuant's partner to obtain additional information on the user's interaction with the purchase content, with a view to producing statistical data.

CAMINOV (brand name "FRINGUANT") may also be required to collect and process personal data as an independent data controller, with a view to the following purposes (see FIG. 2.):

• to develop anonymised statistical data for the attention of partners;
• develop a morphological database (anonymised statistics), which we share with our partners for research purposes on the notion of height and on the different types of morphologies and morphological postures;
• to enable Fringuant to ensure the invoicing of its partners;
• to allow CAMINOV ("FRINGUANT" brand) to exchange with its co-contractors, partners and suppliers;
• to allow visitors to Fringuant's website to access the services of CAMINOV ("FRINGUANT" brand);
• to provide customers of CAMINOV (brand "FRINGUANT") with an online virtual studio service and a service for generating descriptions of fashion items;
• To allow you to apply for a job offer at CAMINOV ("FRINGUANT" brand), or to submit an unsolicited application.

Under the GDPR, any processing of personal data must have a legal basis, i.e. a legal basis that allows it. Depending on the purpose, the processing we carry out on behalf of our partner, the clothing brand, or on our behalf may be based on the following legal bases (see FIG. 1.):

• your consent;
• the necessity with regard to the performance of a contract or pre-contractual measures to which you are a party;
• our legitimate interests or those of our partner;
• the necessity with regard to compliance with a legal obligation to which we are subject.

How long do we keep your data?

Once your personal data has been collected, CAMINOV (FRINGUANT brand) keeps your data for a period of 36 months, following this collection.

The data collected via the trackers, with your consent, is only kept for a period of 6 months.

The contact data that you have entrusted to us via the contact form on the CAMINOV website (brand "FRINGUANT"), or the data relating to an application (CV, cover letter), are kept for a maximum period of two years, following their collection.

We then compile statistics based on this measurement data and user behavioural information, which we share with our partners for analysis purposes. These statistics are completely anonymous.

CAMINOV (brand "FRINGUANT") entrusts the processing of your previously listed personal data to its subcontractors, as part of the performance of their subcontracting missions. This is particularly true of the service providers who develop and maintain the IT tools we use, as well as the hosting of data.

CAMINOV subcontractors ("FRINGUANT" brand) only process the personal data entrusted to them within the strict framework of the performance of their missions, and in accordance with the documented instructions they have received in this regard.

If you are a customer of one of our partners, we may share certain personal data about you with that partner. This is the case, in particular, with the statistical data that we compile based on information on user measurements.

CAMINOV ("FRINGUANT" brand) transmits the data collected as part of the body scan service to the partner brand, as part of the sales funnel into which the CAMINOV "plug-in" ("FRINGUANT" brand) is integrated (precise measurement data obtained through photo scanning). This information allows partner brands to give you personalized advice on their offers, adapted to your clothing size.

Such further processing is the responsibility of the respective partner brands, which will only process this data if they have the appropriate purpose(s) and legal basis(s) to do so.

Thus, for any information concerning their purposes and means (ends, legal bases, storage periods, etc.), as well as your related rights, we invite you to contact the partner brand involved.

You have the right to access the personal data concerning you that is being processed.

To help you with your process, the National Commission for Information Technology and Civil Liberties (CNIL) provides you with a sample letter.

Where the processing of your personal data by us is based on our legitimate interest (see table above), you have the right to object, on your own legitimate interest grounds, relating to your particular situation, to object to such processing, unless we oppose compelling legitimate grounds. To do so, simply contact us at the aforementioned address.

You have the right to request that we delete personal information about you. This is the case, for example, if you have exercised your right to object, based on a legitimate reason specific to your particular situation.

To help you with your process, the National Commission for Information Technology and Civil Liberties (CNIL) provides you with a sample letter.

If you believe that the data we hold is inaccurate, incomplete or out of date, you have the right to have it rectified and/or updated.

To help you with your process, the National Commission for Information Technology and Civil Liberties (CNIL) provides you with a sample letter.

The restriction of data processing is an alternative measure to its pure and simple erasure. If the processing of your personal data is restricted, we can no longer use it without your express consent, with the exception of storing it. However, the exercise or defence of legal claims, the need to protect the rights of another natural or legal person, or for important reasons of public interest of the Union or of a Member State, allow us to disregard this obligation.

You have the right to obtain the restriction of the processing of personal data concerning you in the following situations:

• you contest the accuracy of your personal data for the period of time that allows us to verify the accuracy of your personal data; or
• in the event of unlawful processing by us and you require restriction of its use rather than erasure; or
• we no longer need the personal data for the purposes of the processing, but you still need the personal data for the establishment, exercise or defence of legal claims; or
• in the event of exercising your right to object during the verification period as to whether the legitimate reasons we pursue prevail over yours.