FOREWORD

The company KEWJF attaches great importance to protecting the privacy and data of users of its Website https://kylianmbappe.com (hereinafter the “Website”). It thus strives to adopt and comply with a strict confidentiality policy in accordance with the regulations in force, and particularly the EU General Data Protection Regulation (“GDPR”) 2016/679.

The terms “you” and “your” refer to natural persons using the Website.

The purpose of this Personal Data Protection Charter (hereinafter the “Charter”) is to set out which personal data allowing you to be directly or indirectly identified (hereinafter “Personal Data”) are collected via the Website, the uses made of this data and your rights regarding this data.

The Charter may be modified at any time by KEWJF, notably to ensure compliance with all changes in regulations and jurisprudence, and with publishing and/or technical changes. You are therefore advised to refer regularly to the latest version of the Charter accessible before browsing or using the Website.

1. WHAT IS THE IDENTITY OF THE DATA CONTROLLER?

Data are collected by KEWJF, a simplified joint-stock company (SAS) with a capital of 3,000 Euros, with its registered office at 17, rue Henry Monnier, 75009 Paris, France, registered on the Paris Trade and Company Register (RCS) under number 830 095 584 (“KEWJF“).

2. WHAT PERSONAL DATA IS COLLECTED?

• Personal Data that you provide

Personal Data collected by KEWJF that you provide when filling in the contact form, notably:

• First name;
• Surname;
• E-mail address; and
• Date of birth.

• Personal Data that KEWJF collects automatically

KEWJF also processes your browsing data using data collection tools: cookies, IP address, tags and any other appropriate technical means the use of which is given in Article ‎5.

• Personal Data relating to minors

In accordance with the provisions of Article 8 of the European Regulation 2016/679 and with the French Data Protection Act, only minors aged 15 or over may consent to have their Personal Data processed.

If the user is a minor aged under 15, the agreement of a legal representative is required for the collection and processing of Personal Data.

3. WHAT IS THE LEGAL BASIS FOR THE COLLECTION AND PROCESSING OF PERSONAL DATA? AND FOR WHAT PURPOSES?

Your Personal Data are only processed by KEWJF as permitted by application regulations.

Legal basis

In accordance with Article 6.1.a) of the GDPR, your Personal Data are collected and processed with your free, specific, informed and unequivocal consent given by expressly accepting the content of the Charter when using the Website and completing the contact form.

Purposes

To this end, we hereby inform you that data collected on this legal basis are used as follows:

• To respond to requests sent via the online contact form;

• To generate (anonymous) statistics on Website activity to measure satisfaction and service quality in particular, and to improve and optimise the Website; and

• To facilitate use of the Website and personalise your experience according to your interests and needs.

KEWJF only collects data that are adequate, relevant and not excessive in relation to the purposes for which they are processed.

These objectives are specific and legitimate and your data shall in no case be further processed in a way incompatible with those purposes, unless your prior consent is given.

4. WHO ARE THE RECIPIENTS OF PERSONAL DATA?

KEWJF undertakes to never pass on your Personal Data to a third party with the intent of exploiting them for direct marketing purposes, unless you have been expressly informed of this possibility and have given your express prior authorisation.

The Personal Data collected by KEWJF may be passed on to the following people for the purposes give above in Article 3:

• Authorised persons within KEWJF, each employee having limited access only to the data required for the purpose they implement;

• Service providers, agents or contractors mandated by KEWJF and, more specifically, the provider responsible for supplying the Website and analysing customer behaviour, that is to say the company BLOODY MARY, a limited responsibility company (SARL), with its registered office at 22, rue de Tocqueville, 75017 Paris, France, registered on the Paris Trade and Company Register (RCS) under number 424 815 702;

• The Verheyden & Cognard law firm, located at 57 bis boulevard de Rochechouart, 75009 Paris, France;

• The buyer of KEWJF in the event of a merger or acquisition;

• The competent authorities on request, in compliance with the regulations in force.

All persons dealing with KEWJF or under its responsibility and having access to Personal Data are required to maintain the confidentiality and security of Personal Data and to implement the appropriate measures.

5. COOKIES AND OTHER TRACKERS

The Website uses trackers such as cookies and IP address to process statistics and traffic information, to facilitate browsing and to improve the service for greater user comfort.

Trackers make it possible, during each visit to the Website, and according to the purposes set out in Article 3, to study your behaviour while browsing the Website in order to enhance your browser experience and the use of our services.

What are cookies?

A cookie is a text file containing information, which is stored on your device’s hard drive (computer, tablet, mobile phone) when visiting the Website via your browser. It is sent to your browser by the Website server. The cookie file allows its issuer to identify the device on which it is stored during the validity or storage time of the cookie concerned.

How to deactivate cookies

You can prevent cookies from being saved on your device by changing your browser settings.

If a user decides to deactivate cookies, they may still continue to browse the Website. However, KEWJF cannot be held liable for any dysfunction of the site caused by this configuration.

6. HOW LONG IS PERSONAL DATA STORED?

KEWJF only stores Personal Data for the time necessary to achieve the purposes set out, subject to legal archiving requirements, obligations regarding the storage of certain data and/or anonymisation.

Personal data are deleted after a maximum of three years as of your last contact with KEWJF.

Cookies and trackers are stored for thirteen months as of their insertion in your Internet browser.

7. WHAT SECURITY MEASURES ARE IN PLACE?

The Website has an SSL certificate which guarantees that the information and data transiting via the Website are secure.

As Personal Data are confidential, KEWJF restricts their access to company employees and service providers that require such access as part of the processing process.

All individuals with access to Personal Data are bound by a duty of confidentiality and face disciplinary measures and/or other sanctions if they fail to meet these obligations.

In the event KEWJF uses subcontractors, this communication is the subject of a contract in order to ensure the protection of this information.

Data are stored and processed on secure servers located within the European Union and operated by KEWJF subcontractors acting in accordance with the provisions of the GDPR.

If the integrity, confidentiality or security of the User’s Personal Data is compromised, KEWJF undertakes to (i) report the breach to the French Data Protection Authority (CNIL) within 72 hours after acquiring knowledge thereof and (ii) inform the person concerned as soon as possible if the breach carries a high level of risk regarding the rights and freedoms of the person concerned.

8. YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Subject to the restrictions provided for by the regulations in force, you have the following rights regarding the processing of your Personal Data:

1. Right to be informed

The user has the right to be informed in clear and simple terms of the conditions of use of their Personal Data.

1. Right of access

The right of access allows you to obtain from KEWJF confirmation of whether your Personal Data are processed by us or otherwise and the processing conditions, and to receive a copy thereof.

1. Right to rectification

You have the right to obtain from KEWJF, without undue delay, the rectification of inaccurate, incomplete, equivocal or obsolete Personal Data.

1. Right to erasure

You have the right to obtain from KEWJF, without undue delay, the erasure of your Personal Data where one of the following grounds applies:

• Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

• You wish to withdraw consent on which the processing is based, and where there is no other legal ground for the processing;

• You feel and can provide evidence that your personal data have been unlawfully processed;

• Your personal data have to be erased for compliance with a legal obligation.

1. Right to withdrawal of consent

In the case that KEWJF processes your Personal Data based on consent, this may be withdrawn at any time using the means provided to this effect (see procedure set out in item 8‎K of this Charter).

However, and in accordance with applicable laws, withdrawal of your consent shall only apply to future processing and shall not bring into question the lawfulness of any processing carried out prior to this withdrawal.

1. Right to restriction of processing

The applicable regulations stipulate that this right may be invoked in certain cases, in particular where one of the following applies:

• You contest the accuracy of your personal data, for a period enabling the controller to verify the accuracy of the personal data;

• You feel and can provide evidence that the processing of your Personal Data is unlawful and you oppose the erasure of your Personal Data and request the restriction of their use instead; and

• When KEWJF no longer needs your Personal Data but you still require them for the establishment, exercise or defence of legal claims.

1. Right to object to processing

You may oppose the processing of your Personal Data at any time for direct marketing purposes. You may also oppose profiling. In this case, you will no longer receive personalised offers.

1. Right to data portability

You have the right to receive the Personal Data concerning you or to transmit those data to another service provider.

1. Control of Personal Data after death

You have the right to control your Personal Data post mortem through the adoption of general or specific directives. KEWJF undertakes to respect these directives.

In the absence of directives, KEWJF grants heirs the possibility to exercise certain rights, in particular the right of access, if required for the settlement of the deceased’s succession, and the right to object in order to close the user accounts of the deceased and to object to the processing of their Personal Data.

1. Right to lodge a complaint with a supervisory authority

You may lodge a complaint with the national authority responsible for data protection (the Commission Nationale de l’Informatique et des Libertés, CNIL, in France, the contact details for which can be found via the following link: https://www.cnil.fr/fr/vous-souhaitez-contacter-la-cnil).

1. Exercising your rights

For all questions regarding this Charter or to exercise your rights as set out above, please contact KEWJF at the following address, by post (17, rue Henry Monnier, 75009 Paris, France) or by e-mail: [email protected].

Your request must be in writing and must be signed and accompanied by a photocopy of personal ID showing your signature.

KEWJF undertakes to reply without undue delay and, in any case, within one month as of receipt of your request.

Where necessary, this deadline may be extended to two months in view of the complexity and number of requests sent to KEWJF. In this case, you shall be informed of this extension and the grounds therefor.

If your request is sent by e-mail, the information provided shall also be sent by e-mail when possible, unless you expressly request otherwise.

9. ARE PERSONAL DATA SENT TO RECIPIENTS IN THIRD COUNTRIES?

Personal Data are not transferred outside of the European Union.