LVMH Corporate Website Personal Data Protection Policy
Last update: July 2023
LVMH places the highest priority and takes the utmost care to protect your Personal Data.
This Policy describes how LVMH processes (hereinafter “Processes”, “Processed” or “Processing”) your Personal Data and your rights in respect to protection of your Personal Data.
1. What is “personal data”?
Personal Data refers to any information or pieces of information that could identify You either:
- directly (e.g. your name, surname, email, home address, etc.)
- or indirectly (e.g. through pseudonymized data, such as a unique ID number, etc.).
Unique identifiers such as your computer’s IP address may also be considered as Personal Data.
2. Data controller responsible for protection of your Personal Data and Data Protection Officer
2.1. Who is the data controller?
A data controller is the entity that determines the purposes and means of the processing of your Personal Data and is responsible to You for compliance with data protection regulations. (“Data Controller”).
As regards the Website management and institutional communications, as well as management of your Data for recruitment purposes for the LVMH holding company, the Data Controller is:
LVMH Moët Hennessy-Louis Vuitton SE
a European company established 22 avenue Montaigne, 75008 PARIS, France, registered with the Trade and Companies Register of Paris under number 775 670 417
2.2. Who is the Data Protection Officer?
LVMH has appointed a Data Protection officer (hereinafter “DPO”) who is your designated contact person for all questions concerning the processing of your Personal Data.
This person may be reached:
- by using the contact form available at https://www.lvmh.fr/contact/ , selecting the subject “Personal Data”
- by mail at the following address: LVMH Data Protection Officer, 24-32 rue Jean Goujon, 75008 Paris, France.
3. How is your Personal Data processed?
3.1. What Personal Data is processed by LVMH?
The list of Personal Data processed for each of the purposes described above is given in the table in Appendix 1.
Sensitive data declared by a job applicant, such as health or disability data, is only collected and stored if required by law, regulation or court order, and is only used and disclosed to the extent necessary to meet these obligations.
3.2. How is your Personal Data collected?
We collect your Personal Data as follows:
- directly from You when You use our Website and our services (completing contact forms, when You subscribe to our newsletters or sign up to receive corporate documentation, and when you apply for a job offer;
- automatically when You access or use the Website (technical details, IP address, browsing information, etc.).
3.3 Are You required to provide your Data?
The Data required by LVMH to achieve the objectives described below are indicated by an asterisk in our forms. If you do not complete these required fields we will not be able to provide you with the services requested or respond to your request.
Fields not marked with an asterisk are optional and enable us to improve the services we offer.
3.4. On what legal grounds and for what purposes do We process your Personal Data?
In accordance with current personal data protection regulations, We only collect Personal Data when We have a legal basis to do so.
Data is processed in order to:
- Manage your requests or queries sent via the contact form based on the legitimate interests of LVMH;
- Manage your subscription to our different newsletters, based on your consent;
- Manage your applications to LVMH job offers based on precontractual measures and on the establishment of a contractual relationship between LVMH and job or internship applicants;
- Management of the cybersecurity of the Website based on the legitimate interest of LVMH to ensure the security of the Website and of visitors to the Website;
- Prevent fraudulent acts based on the legitimate interest of LVMH to ensure the security of our assets and content;
- Manage and defend the interests of LVMH in the event of a dispute or court action.
3.5. Who has access to your Personal Data?
- Access within LVMH
The detailed list of persons with access to your Personal Data is provided in the table attached in Appendix 1.
In general, your Personal Data is accessible by:
- Within the LVMH Group:
- LVMH Corporate Communication Department and Financial Communications Department for the management of your requests and queries and to send You newsletters;
- LVMH Human Resources Department to manage your applications to job offers at the LVMH holding company;
- LVMH Security Department to manage cybersecurity of the Website;
- LVMH Legal and Anti-Fraud Departments to manage protection against fraudulent actions or legal claims, if any.
- Accessibility by third parties, specifically:
- our subcontractors and service providers acting for technical and logistical reasons (Website hosting, security and maintenance providers, anti-fraud management providers, technical service providers responsible for sending emails and newsletters, anti-spam and anti-bot service providers, recruitment agencies which may provide US with advice on managing our job candidate databases and help Us select profiles within these databases);
- other LVMH Group affiliates for recruitment reasons: with your express consent when you consent to the transfer of your Data to other LVMH affiliates for recruiting purposes for similar job offers; or when you apply via the Website for a job offer at an LVMH brand of affiliate, which then collects and processes your Data as an independent data controller. In this case, your Data will be processed according to this affiliate’s specific data protection policy, which You may obtain by contacting it directly. Likewise, the rights You enjoy pursuant to personal data protection laws must be directly enforced against it;
- any authority, court or other third party when disclosure is required by law, regulations or a judicial decision, or if such disclosure is necessary to protect and defend our rights.
3.6. For how long is your Personal Data stored?
Details regarding the periods for which LVMH stores your Personal Data is found in the table attached in Appendix 1.
Your Data is stored as long as required for the purpose for which it was collected and, in any case, will be destroyed at the end of such period.
3.7. Transfer of your Personal Data outside of the European Economic Area
Your Data is processed in France by LVMH. However, We may rely on certain service providers, which are located abroad or which themselves rely on processors located abroad, including outside of the European Economic Area (EEA) in countries where personal data protection laws differ from those that apply in the EEA.
Any transfer of your Data outside the EEA will be made subject to appropriate safeguards that comply with applicable regulations on the protection of personal data. This applies in particular to job applicant Data that may be sent to LVMH brands or affiliates outside the EEA, for which LVMH has established Binding Corporate Rules (hereinafter “BCR”).
Upon request, We will provide You with a copy of applicable safeguards.
4. What are your rights in relation to your Data?
4.1. Access, rectification and portability
In accordance with current regulations, You have the right to access your Data. You may also request correction of Your Personal Data should they be inaccurate. Depending on the purpose of processing, You also have the right to have incomplete Personal Data completed.
To respond to your request, We may ask You to provide Us with a proof of your identity. We may also need to ask You for additional information or supporting documents. We will make every effort to respond to your request as soon as possible.
You may, to the extent provided for by law, exercise your right to Data portability which allows You to retrieve, in an interoperable format, the Personal Data that You provided to Us.
4.2. How to exercise your right to erasure of your Data and to limitation of the processing of your Data
You may request erasure of your Personal Data in the following cases:
- You believe that the processing is unlawful or You contest the accuracy of the Data We process about You;
- You have withdrawn, your consent to the processing of your Data.
In addition, to the extent provided for by law, You may request limitation of the processing of your Data.
Please note that despite the exercise of your right to erasure or processing limitation, We will store some of Your Personal Data when the law requires Us to do so, or to exercise or defend our rights.
4.3 Right to establish instructions for the management of your Personal Data after your death
In accordance with Article 63 of Law no. 2016-1321 of October 7, 2016 for a Digital Republic, any person may establish directives relating to the retention, erasure and communication of their personal data after their death.
When the processing of your Data is based on your consent (e.g. newsletter subscription), You may retract this consent at any time, without explanation. This right can be exercised by changing your options relating to subscriptions to our newsletters by clicking on the link provided for this purpose in each email We send You.
5. How is your Personal Data secured?
LVMH employs technical and organizational measures to keep your Data secure and confidential that comply with French and EU legal and regulatory requirements.
Under written agreements, LVMH requires its service providers and processors to provide safeguards and implement sufficient security measures to protect the Personal Data they have agreed to process, in accordance with applicable requirements under personal data protection laws.
However, LVMH does not have control over all risks related to the operation of the Internet and draws your attention to the inherent risks of using any website.
More information on cookies, the different types of cookies and the purposes of cookies is found in Appendix 2.
7. Third-party websites
The Website may contain links to third-party websites (such as the websites of LVMH Group affiliates) that We do not control and which are governed by their own confidentiality and personal data protection policies.
The feature that allows you to apply for a job offer using the “Apply with LinkedIn” feature, making it easier to complete your details, is subject to the general terms and conditions of LinkedIn.
8. Do we sell your personal data?
We do not sell your personal data and have not done so in the past 12 months.
However, insofar as our transfers of your personal data to certain parties may be interpreted as a “sale” under California data protection legislation (California Consumer Privacy Act, CCPA), you have the right, if you live in California, to opt out of this sale.
If you live in California you also have the right to refuse disclosure of your data for the purposes of online advertising based on your centers of interest.
9. How can You contact Us if You have queries or complaints?
- by using the contact form available at https://www.lvmh.fr/contact/ and selecting the subject “Personal Data”
- by mail at the following address: LVMH Data Protection Officer, 24-32 rue Jean Goujon, 75008 Paris, France.
If You have a complaint about the way We process your Data, You also have the right to contact the Commission Nationale de l’Informatique et des Libertés (French data protection authority, CNIL), 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07, Tel: 01 53 73 22 22, www.cnil.fr.
|PURPOSE||DATA CATEGORIES||INTERNAL DATA RECIPIENTS||THIRD-PARTY DATA RECIPIENTS||PERIOD OF STORAGE BEFORE ERASURE OF PERSONAL DATA|
|Management of your requests and queries||Identification Data (last name, first name, mailing address, contact details needed to identify You when You interact with Us)||LVMH Corporate Communication Department and Financial Communications Department||Not applicable||Duration required to manage your requests and queries. Your Data will then be either deleted or anonymized, unless we need to keep it to meet our legal obligations for the applicable statutory retention period.|
|Sending You our newsletters||Contact details (last name, first name, email address)||LVMH Corporate Communication Department and Financial Communications Department||Technical service providers responsible for sending emails and newsletters||Duration of your subscription. Your Data will then be destroyed or anonymized.|
|Management of your applications to LVMH job offers||Candidate Information (last name, first name, email address, telephone number, professional experience, photo, skills, education, languages, salary expectations, home address, personal interests, marital situation)||LVMH Human Resources Department
Department that posted the job offer
|Other LVMH affiliates for recruitment purposes
Service providers: recruitment agencies which may provide US with advice on managing our job candidate databases and help Us select profiles within these databases
|Duration of two (2) years from when the Data has been provided or from the last contact with You.
At the end of this two-year period, LVMH may contact You to know whether You want LVMH to keep retaining your Personal Data, for the purpose of informing You of an opportunity that may arise and match your career aspirations and skills.
In any event, your Data will be erased at your request, within a maximum period of one (1) month from your request.
|Management of website security||Technical information on the device you are using to connect to the Website (IP address, device type, browser ID, etc.)||LVMH Security Department||Anti-spam and anti-bot service providers,||Six (6) months, after which the Data is either erased or anonymized.|
|Fraud prevention||Contact data and data related to fraud||LVMH Legal and Anti-Fraud Departments||Anti-fraud management service providers||Duration required to investigate the complaint + five (5) years from the resolution of the complaint.|
|Disputes/complaints||Contact data and data related to disputes/complaints||LVMH Legal and Anti-Fraud Departments||Any authority, court or other third party when disclosure is required by law, regulations or a judicial decision, or if such disclosure is necessary to protect and defend our rights.||During of the claim + five (5) years from the complaint
In the event of a court action: duration of proceedings through full enforcement of the legal decision or settlement agreement.
Appendix 2: Cookies
What are cookies?
By continuing to use the www.lvmh.fr website, as well as all other LVMH websites with .com, .it, .ru, .co, .jp, .cn domain name suffixes, you agree to our cookie settings and confirm that you have understood our cookies policy.
You can change your settings at any time by going to the section “Manage your cookie settings”.
What types of cookies do we use?
These cookies enable you to use the main functionalities of the Website. These cookies facilitate the browsing experience and are necessary for online purchases.
- Third-party cookies
Third-party cookies are used in particular for statistical analysis by collecting information regarding browsing on our Website, enabling us to enhance your user experience and adapt services to your preferences. There are also advertising cookies designed to personalize and/or enhance the content and browsing experience by proposing content that might be of interest to you on other websites.
All the information collected is anonymized.
How long are cookies stored?
Cookies stored on your device are stored for a period which does not exceed thirteen (13) months. When the validity of the storage period expires, personal data collected through cookies is deleted.