PRIVACY POLICY

Date of entry into force: Updated to 19 September 2025

The company Benda Bili markets high-end ready-to-wear items and lifestyle accessories under the brands "Sézane", "Octobre Éditions", "Petit Sézane", or as part of collaborations, under third-party brands such as "Les Composantes", on its websites www.sezane.com and home, its IOS and Android mobile applications, as well as, through its subsidiaries, in its physical stores (respectively the "Sites" and "Benda Bili"). 

In order to offer its products for sale, support the sale of its products and manage the Sites, Benda Bili collects personal data from customers and users of its Sites (together the "Users").

This Privacy Policy aims to inform the Users of the Sites of the means implemented by Benda Bili to collect, consult, process and store their Data (the "Privacy Policy"), in compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data of the European Parliament and of the Council of 27 April 2016 ("GDPR") and French law no. 78/17 of 6 January 1978, as amended ("Data Protection and Freedoms Act").

1. Definitions and Identification of the Data Controller

The data controller, who collects personal data and implements the processing of this data, is Benda Bili, a simplified joint-stock company with a capital of € 27,386, registered in the Paris Trade and Companies Register under number 534 652 854, whose registered office is located at 3 rue du Bac in Paris (75007), France ("Data Controller").

"Process" or "Processing" means any operation or set of operations applied to the Data, such as collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, limitation, erasure, or destruction. 

"Data" means any information or set of information relating to a User and allowing them to be identified directly (e.g.: last name, first name, email address, postal address, etc.) or indirectly (e.g. order number using pseudonymised data such as a unique identification number or telephone number, etc.) a User. 

2. Data Collection

Benda Bili is required to collect the following categories of Data on its Sites: 

· Account creation data: Data that the User enters when creating their account in a mandatory or optional manner (title, first name, last name, date of birth, email address, telephone number, password to connect to the account, and marketing preferences);

· Customer data: Data that the User provides during a purchase on the Sites in a mandatory or optional manner (title, first name, last name, date of birth, email address, telephone number, password to log into the account, marketing preferences, billing, and delivery addresses);

· Transactional data: Data allowing the processing of orders placed by the User on the Sites, such as their title, first name, last name, email address, telephone number, postal address, and information related to their payment method (excluding order payment data*);

· Customer service data: Data collected by Benda Bili’s customer service during the User’s exchanges with Benda Bili regarding their orders or otherwise, such as title, first name, last name, email address, telephone number, billing and delivery addresses, and documents attesting to the User’s identity such as an identity card or passport;

· Data related to navigation: User data that Benda Bili collects during the Customer’s navigation on the Sites, including the date, time of connection and/or navigation, browser type, browser language, IP address, and location data (country of navigation);

· Data of participants/competition winners: "Participant" and/or "winner" data collected by Benda Bili when the User participates in a competition, notably first name, last name, place of residence, email address, and social media handle and/or when the User wins a competition, the following additional data: postal address and telephone number;

· Candidate data: Data collected when the User applies for a job posting published by Benda Bili via its Sites, such as identity photograph, title, first name, last name, email address, telephone number, date of birth, place of residence, interests, professional experiences, past training, skills, and identity documents (identity card, passport, visa);

· Video surveillance data: Data collected through video surveillance systems set up within the physical Sites, such as User images. 

The payment data of the orders* (title, first name, last name, email address, telephone number, billing address, bank card number, expiry date, authorisation number, and security code) are collected directly by Benda Bili’s payment providers, Adyen and PayPal, under their respective terms, conditions, and privacy policies. Benda Bili does not have access to this Data;

Benda Bili publishes editorial, commercial, or marketing content on certain websites and social networks such as Facebook, Instagram, TikTok, LinkedIn, and which are owned by third parties. The latter may use automated tools to collect certain Data on the users of these tools, notably profiling their online activity. Any collection of Personal Data in this context is carried out directly by these third parties and is subject to their respective privacy policies, which it is the User’s responsibility to read. To the extent permitted by applicable law, Benda Bili is in no way responsible for the collections and practices of such third parties regarding Personal Data.

3. Legal Bases for the Collection of Data

Benda Bili collects the Data based on one or more of the following legal bases:

Consent: When the User gives their consent, Benda Bili may process their Personal Data for the specific purposes to which the User has consented. This database is used, for example, when the User consents to Benda Bili sending them marketing or commercial communications such as notifications, invitations or newsletters by email and/or SMS, or when the User consents to participate in a competition.

Contract: Benda Bili processes the User’s Personal Data necessary for the performance of a contract (such as a purchase contract) when Benda Bili sells products or services and the User purchases them. The execution by Benda Bili involves the collection of certain Data to deliver the items ordered by the User, and to manage and track their orders.

Legitimate interest: Benda Bili has a legitimate interest when it processes the User Data for purposes such as providing customer service, improving the User experience, developing its products and services, preventing fraud, the security of the Sites or the commercial prospect of its existing customers.

Legal obligation: Benda Bili fulfils a legal obligation whenever the processing of the User’s Personal Data is necessary to comply with a legal obligation in the country of operation, for example in the context of consumer law and the application of legal guarantees or to comply with certain accounting and tax obligations.

4. Purposes of the Collection of Data

Data collected on the Sites are subject to Processing for the purposes described in the table below. 

**Nevertheless, some Data may be retained beyond the indicated retention periods if requested in connection with the detection and/or prosecution of criminal offences or the provision of such Data to police, administrative or judicial authorities.

5. Data Processors and Recipients

In certain cases, as described below, the Data collected may be transmitted to third parties, who may carry out Processing on behalf of Benda Bili (Data Processors) and/or their own account (Data Recipients). For information purposes, here is a non-exhaustive list of Data Processors and Recipients (more information on our Data Processors and Recipients can be communicated upon request to the address hello@sezane.com or the address dpo@sezane.com):

Data recipients

o Payment providers: the payment of purchases on the Sites is made via (i) PayPal or (ii) the secure platform of the payment provider of Benda Bili, Adyen:

o PayPal (Europe) S.à.r.l. et Cie is a Luxembourg limited partnership company, registered in the R.C.S of Luxembourg under number B118349, whose registered office is located at 22-24, Boulevard Royal – L-2449 Luxembourg. For any information, the User can consult the following website: https://www.paypal.com.

o Adyen B.V. is a company registered in Amsterdam (Netherlands) under the number 34259528, whose registered office is located at Simon Carmiggeltstraat 6-50, 1011 DJ in Amsterdam, Netherlands. For any information, the User can consult the following website: https://www.adyen.com.

o Benda Bili does not have access to the Payment Data of Users. The User may choose to save this Data in their customer account. This data is not stored with Benda Bili, but with PayPal and/or Adyen. The User may modify or delete this Data at any time by logging into his/her customer account.

· Any police, administrative or judicial authority in the context of requisitions concerning in particular the fight against fraud.

· Customs services and providers in case of delivery abroad.

· Tax refund providers.

· La Poésie, a simplified joint-stock company registered in the Paris trade and companies register under number 889 423 414, as part of its collaboration with Benda Bili around the products of the brand "Les Composants". Thus, the User who has acquired products of the brand "Les Composants" on the Sites expressly accepts that Benda Bili transfers to La Poésie its Account creation data, Customer data, Customer service data, Transactional data and Data related to navigation. All the processing of this Data by La Poésie is exclusively subject to La Poésie’s Privacy Policy. 

Shops and points of sale Sézane, Octobre Éditions et Petit Sézane - these shops and points of sale are wholly owned by the companies affiliated to Benda Bili (Benda Bili R, Benda Bili Limited, Benda Bili Inc.) and may have access to all the Data referred to in article 2 of this Privacy Policy. 

Data processors

Benda Bili’s data processors may have access to the Data collected for: 

· Preparation, shipping and return of orders (7 Senders, Arvato, C Chez Vous, Chronopost, DHL, Fedex, Kuehne+Nagel, Schneider),

· The follow-up of questions, comments and opinions expressed by customers, in coordination with Benda Bili’s Customer Service (Sprinklr), 

· Updating and improving the content of the Sites and navigation to the Sites (Contentsquare, Google, Meta, Segment),

· The maintenance and technical development operations of the Sites and internal applications of Benda Bili, including the entities that execute orders and ensure the hosting of the Sites, the storage of Data, email service providers, and customer tickets, as well as analysis services, tag management, such as Google Analytics and Amazon Web Services,

· Prospecting and communication operations (Batch, Salesforce), 

· Targeting advertising on third-party platforms (e.g. Google, LINE, Pinterest, Snapchat, TikTok, Yahoo Japan),

· Ensure the continuity of the User’s experience in stores and points of sale, including tracking purchases and orders, returns and refunds (Benda Bili R, Benda Bili Limited, Benda Bili Inc.).

6. Transfer of Data outside the European Union

Benda Bili’s subsidiaries - The Data may be transferred to Benda Bili Inc. and Benda Bili Ltd, the UK and US subsidiaries wholly owned by Benda Bili, so that its Users can benefit from the same "customer experience" in Sézane stores, October Editions and/or Petit Sézane located in the UK and the US. These transfers are made within the framework of the standard contractual clauses of the European Commission and the adequacy decision established between the countries of the European Union and the United States ("Data Privacy Framework").

Benda Bili’s service providers - The Data may also be transferred to Benda Bili’s service providers, allowing the latter to provide its services to its Users (in particular carriers, hosts and technical service providers for managing the Websites). These transfers are made within the framework of the standard contractual clauses of the European Commission and the adequacy decision established between the countries of the European Union and the United States ("Data Privacy Framework").

7. Users' rights over their Data

In accordance with articles 14 to 22 of the GDPR, any User may exercise the following rights:

· A right of access to their Data, 

· A right to rectify their Data,

· A right to delete their Data,

· A right to object to the Processing of their Data,

· A right to the limitation of the Processing of their Data,

· A right to the portability of their Data.

If Benda Bili detects a data breach likely to result in a high risk for the rights and freedoms of the Users, it undertakes to inform them as soon as possible and the competent supervisory authority (in particular the CNIL for France).

Any request to unsubscribe can be exercised with the Customer Service at the email address: hello@sezane.com.

The User may exercise all of their rights: 

· By logging into their customer area on the Sites; or

· By contacting Customer Service at the email address email hello@sezane.com or by simple mail – BENDA BILI, Service Customer, 115 rue du Bac – 75007 Paris, France; or

· By contacting Benda Bili’s Data Protection Officer at dpo@sezane.com or by simple mail – BENDA BILI, Data Protection Officer, 115 rue du Bac – 75007 Paris, France. 

Benda Bili may ask the User to attach certain information (copy of an identity card, passport, or other legally recognised identification document) for identification purposes in order to process their request and protect themselves against fraudulent requests from third parties. In the absence of a response or in case of a response deemed unsatisfactory, the User may refer the matter to the supervisory authority of their country of residence (notably, for France, the CNIL: https://www.cnil.fr/).

8. Data Security Measures

As Data Controller, Benda Bili undertakes to take all necessary precautions to preserve the security and confidentiality of the Data and in particular to prevent it from being altered, distorted, or accessed by unauthorised third parties. 

9. Cookies, Tags and Trackers

When browsing the Sites, information relating to the navigation of the User’s terminal (computer, tablet, smartphone, etc.), may be recorded through files called "Cookies". The cookie allows for navigation tracking or an analysis of the User’s behaviour, including:

During their first connection to the Sites and once a year afterwards, the User is informed by the appearance of a banner that cookies may be automatically installed on their browser software during their visits to the Sites, as well as their purposes, the possibility to accept or refuse them and modify the settings by clicking on the "set cookies" link. They can also modify their preferences through the navigation software used and via the My Account section of the Sites:

-Safari: https://support.apple.com/
-Chrome: https://support.google.com
-Firefox: https://support.mozilla.org/fr/
-Edge: https://support.microsoft.com/
-iOS: https://support.apple.com/
-Android: https://support.google.com

Benda Bili uses the services of the company One Trust to collect and manage the consent of the Users of its Sites. 

10. Social Media

The official accounts of Benda Bili "Sézane", "Octobre Éditions" or "Petit Sézane" on social networks, notably on Facebook, Instagram, LinkedIn, Pinterest and TikTok, allow Users to interact with Benda Bili. These exchanges can be seen by any third party. Increased vigilance is therefore required from Users when they provide Personal Data on these networks; and Benda Bili may in no way be held liable for any damages resulting from the publication of these exchanges.

11. Links to Third-Party Sites

The Sites may provide links to websites, applications, and services other than those of Benda Bili that are operated by third parties. Benda Bili is not responsible for the processing of personal data by these third parties, whose personal data protection policies will apply exclusively.

12. Amendment of this Privacy Policy

This Privacy Policy reflects the current practices of Benda Bili and may be modified and updated from time to time by Benda Bili in order to comply with any regulatory, jurisprudential, editorial, commercial or technical changes. When changes to this Privacy Policy are published, Benda Bili modifies the "Effective Date" at the top of this Privacy Policy to indicate when such changes have taken effect.