Privacy Policy

Last updated: 3 August 2026

This Privacy Policy explains how CLECLE, the company publishing the website www.clecleboutique.com, collects, uses and protects the personal data of users, members and Customers of the CLÉCLÉ Maison.

CLECLE pays particular attention to the protection of privacy and processes personal data in accordance with the General Data Protection Regulation ("GDPR") and the French Data Protection Act. The CNIL notes in particular that an online sales website must clearly inform its customers of the use made of their data and provide them with a simple means of exercising their rights.

1. DATA CONTROLLER

The controller of the processing described in this Policy is: CLECLE, a simplified joint-stock company (SAS) with share capital of €5,000. Registered office: 231 rue Saint-Honoré, 75001 Paris, France. SIREN: 994 538 742. RCS: 994 538 742 R.C.S. Paris. E-mail: bonjour@clecle.fr. Telephone: 06 49 50 51 35

For any request relating to your personal data, you may write to: bonjour@clecle.fr, indicating where useful the subject line "Personal data".

2. WHAT DATA MAY WE COLLECT?

Depending on your use of the site and of the CLÉCLÉ services, we may process various categories of data.

Identification and contact data

In particular: surname; first name; e-mail address; telephone number; billing or delivery postal address.

Data linked to My CLÉCLÉ Suite

When you create an account, we may process in particular: your account credentials; your contact details; your saved addresses; your order history; the pieces saved in My Selection; your preferences; your status within the CLÉCLÉ programme; your points balance and history; your privileges; your referral invitations. Your date of birth may also be provided in order to benefit from birthday-related features or gestures where these are offered.

Order-related data

We may process in particular: the products ordered; the size and options chosen; the order amount; the payment methods used; transaction references; the delivery method and address; delivery tracking; information relating to returns, exchanges, refunds or complaints.

Payment data

Payments are processed by the payment providers offered at the time of the order, such as Stripe, PayPal and Klarna, as well as the services associated with the payment methods selected. CLÉCLÉ does not intend to store your full bank card details directly. The CNIL recommends in particular that online retail sites should not store customers' bank details and should use secure payment solutions.

Data relating to the CLÉCLÉ programme

We may process the information required for: the award of points; bonuses; the Salon Guest, Cléclette and Very Important Cléclette statuses; privileges; the handling of returns affecting points; the referral programme; as well as the detection of any abuse or fraud.

Data sent to the CLÉCLÉ Salon

When you use the Salon, we may process the information you choose to send us, in particular: your first name, nickname or display name; your messages; your photographs or other content; the information needed for their moderation and publication. The conditions for publishing and using this content are set out in the Terms and Conditions of Use.

Data linked to The Fitting Room and size selection

Where certain features allow it, you may choose to send us information intended to help you select a size, in particular certain measurements or fit preferences. This information is only used to the extent necessary for the feature concerned. If a virtual try-on feature requiring a photograph to be uploaded is offered, specific information about its processing is presented before the service is used.

Customer service data

When you contact CLÉCLÉ, we may process: your identity; your contact details; the content of your request; your order number; exchanges with our customer service team; as well as the documents or photographs you choose to send.

Data relating to commercial communications

When you subscribe to a newsletter or accept certain communications, we may process in particular: your e-mail address; your preferences; the date of your consent; as well as certain information allowing us to measure the sending, opening of or interaction with our communications, where this is permitted.

Technical and browsing data

Depending on your cookie choices, we may collect in particular: your IP address; information about your browser or device; the pages viewed; interactions with the site; the source of the visit; as well as data enabling the security and operation of the service. For more information, see our Cookie Policy.

3. WHY DO WE USE YOUR DATA?

Every processing of personal data must be based on a legal basis provided for by the GDPR.

Creation and management of My CLÉCLÉ Suite

  • Purposes: account creation; authentication; management of personal information; access to the features of My Suite; management of preferences and associated services.
  • Legal basis: performance of the Terms of Use and of the services requested by the member.

Order management

  • Purposes: validating and preparing orders; payment; delivery; invoicing; tracking; returns; exchanges; refunds; after-sales service.
  • Legal basis: performance of the sales contract and compliance with our legal obligations.

Loyalty programme, statuses and privileges

  • Purposes: calculating points; managing bonuses; progression within the programme; awarding privileges; managing VIC status.
  • Legal basis: operation of the CLÉCLÉ programme in accordance with the Terms of Use.

Referral

  • Purposes: managing invitations; checking eligibility; awarding the referred customer's benefit and the referrer's points; fraud prevention.
  • Legal basis: operation of the referral programme and CLÉCLÉ's legitimate interest in preventing fraudulent use.

CLÉCLÉ Salon

  • Purposes: receiving content; moderation; publication; handling removal requests or reports.
  • Legal basis: provision of the service offered under the Terms of Use. Where an additional use of content requires specific authorisation, this is obtained separately.

Customer service

  • Purposes: answering questions; handling requests; managing complaints; following up orders and services.
  • Legal basis: performance of the contract where a request concerns an order, and CLÉCLÉ's legitimate interest in responding to other requests.

Newsletter and commercial communications

Electronic commercial communications are sent in accordance with the applicable rules. Where the law requires prior consent, they are only sent once that consent has been obtained. In certain situations provided for by the regulations, in particular for communications relating to similar products or services sent to existing customers, marketing may rely on the applicable legal exception, provided that the person is able to object simply.

Security and fraud prevention

  • Purposes: securing the site and accounts; preventing fraudulent access; preventing abuse relating to orders, points or referrals; protecting CLÉCLÉ and its users.
  • Legal basis: CLÉCLÉ's legitimate interest in securing its services and preventing fraud.

Compliance with our legal obligations

Certain data must be processed or retained in order to comply in particular with our accounting, tax, commercial or consumer-rights obligations.

  • Legal basis: legal obligation.

4. IS THE INFORMATION MANDATORY?

The fields identified as mandatory are necessary in order to provide the service concerned. For example, certain identity, delivery and contact data are necessary in order to process an order. If this information is not provided, CLÉCLÉ may be unable to deliver the service requested.

Information presented as optional may be left blank without preventing the use of the site's other features. Creating a CLÉCLÉ Suite remains optional in order to place an order where purchasing without an account is offered.

5. WHO MAY RECEIVE YOUR DATA?

Data is accessible only to the people and service providers who need it in order to carry out their tasks. Depending on the service used, it may in particular be shared with:

  • authorised individuals within CLECLE;
  • technical providers involved in the operation and hosting of the site;
  • payment providers;
  • carriers and logistics providers, in particular Colissimo and Mondial Relay;
  • providers required for the management of customer or marketing communications, in particular Klaviyo, where these services are used;
  • providers involved in after-sales service or alterations where their involvement is necessary;
  • accounting, legal or administrative providers where necessary;
  • as well as the legally authorised authorities where disclosure is required by law.

Providers only receive the data necessary for their involvement. CLÉCLÉ does not sell its customers' personal data to third parties.

6. PAYMENTS

When a payment is made on the site, the data necessary for its processing is transmitted to the payment provider selected. Depending on the method chosen, this may include Stripe, PayPal, Klarna, Apple Pay or Google Pay and their technical partners.

These providers have their own privacy policies and may, for certain operations, act as independent controllers, in particular for security, fraud prevention or the assessment of an instalment payment request. CLÉCLÉ only receives the information necessary to confirm and follow up the transaction.

7. DELIVERY

The information needed to ship an order may be shared with the carrier chosen. This may include: surname; first name; address; e-mail address; telephone number; reference and information necessary for delivery. This information is used solely to arrange and track the shipment under the carrier's own terms.

8. COMMUNICATIONS BY E-MAIL AND WHATSAPP

CLÉCLÉ may use different channels to respond to requests from its Customers or members. When you voluntarily contact CLÉCLÉ by e-mail or via WhatsApp, the data provided in that exchange is used in order to handle your request. The use of services offered by third parties, in particular WhatsApp, may also be subject to their own terms and privacy policies. Commercial communications via these channels are only sent under the conditions permitted by the applicable regulations.

9. HOW LONG DO WE KEEP YOUR DATA?

Data is only kept for as long as necessary for the purpose for which it was collected, then, where necessary, archived for the periods required or permitted by the regulations. The CNIL notes that data must not be kept indefinitely and that a retention period must be defined for each purpose.

Account and customer relationship

The data required for My Suite is kept for as long as the account is used. In the event of prolonged inactivity, data that has become unnecessary is intended to be deleted or archived. By way of reference, the CNIL generally recommends not keeping the data of an inactive customer in an active database beyond three years after the end of the commercial relationship, subject to legal retention obligations.

Orders and invoicing

The information needed for commercial management is kept for the duration of the contractual relationship. Documents covered by accounting obligations, in particular invoices, are kept for 10 years in accordance with the applicable obligations. The CNIL expressly notes this period for invoicing data.

Commercial prospecting

A Customer's data used for prospecting purposes may be kept for the duration of the commercial relationship and then for 3 years from the end of that relationship or from the last relevant purchase. For a person who has never ordered, prospecting data may be kept for 3 years from its collection or from the last contact initiated by that person.

CLÉCLÉ Salon

Content and associated information is kept for its publication period. In the event of a removal request, it is withdrawn from the Salon under the conditions provided for in the Terms of Use, subject to any temporary technical copies or necessary legal obligations.

Loyalty and referral

The information needed to manage points, statuses and privileges is kept for as long as the account and associated rights are active, then for the period necessary to handle any disputes and legal obligations. The rules on the validity of points and of VIC status are set out in the Terms of Use.

Customer service and complaints

Exchanges are kept for the period needed to handle the request and then, where justified, for a period allowing the management or defence of a possible dispute.

Payment data

CLÉCLÉ does not directly store full bank card details. Payment providers apply their own retention periods according to their obligations and services.

10. DATA TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA

Some technical providers or services used by CLÉCLÉ may involve the processing of data from a country located outside the European Economic Area. Where such transfers take place, CLÉCLÉ ensures that they are based on a mechanism provided for by the GDPR, in particular:

  • an applicable adequacy decision;
  • standard contractual clauses adopted by the European Commission;
  • or any other appropriate safeguard provided for by the regulations.

Standard contractual clauses are precisely one of the mechanisms allowing transfers to third countries to be framed.

11. DATA SECURITY

CLÉCLÉ implements technical and organisational measures intended to protect personal data against, in particular:

  • destruction;
  • loss;
  • alteration;
  • disclosure;
  • unauthorised access;
  • or any unlawful use.

Access to data is limited to people who need to know it in the course of their duties. Providers acting on behalf of CLÉCLÉ are selected taking into account, in particular, their commitments regarding security and confidentiality.

12. YOUR RIGHTS

Depending on the nature of the processing and its legal basis, you may have in particular:

  • the right of access to your data;
  • the right to rectification;
  • the right to erasure;
  • the right to restriction of processing;
  • the right to object;
  • the right to portability where the conditions are met;
  • as well as the right to withdraw your consent at any time where processing is based on it.

The CNIL sets out these various rights and the need for organisations to provide a simple means of exercising them. Withdrawing consent does not call into question the lawfulness of processing carried out before that withdrawal.

13. HOW TO EXERCISE YOUR RIGHTS

You may exercise your rights by contacting: CLECLE — Personal data, bonjour@clecle.fr, or by post: CLECLE, 231 rue Saint-Honoré, 75001 Paris, France

Your request must allow CLÉCLÉ to identify you sufficiently in order to respond to it. Proof of identity may be requested only where there is reasonable doubt as to the identity of the person making the request. CLÉCLÉ responds to requests within the timeframes provided for by the GDPR.

14. COMPLAINT TO THE CNIL

If, after contacting CLÉCLÉ, you consider that your rights are not being respected, you may lodge a complaint with the competent supervisory authority. In France: Commission nationale de l'informatique et des libertés — CNIL, 3 Place de Fontenoy, 75007 Paris, France

The CNIL also allows certain complaints to be filed directly online.

15. COOKIES AND TRACKERS

The use of cookies and other trackers is described separately in our: COOKIE POLICY. You may change your choices at any time from: MANAGE MY COOKIES

16. AUTOMATED DECISIONS

Within the framework of its loyalty programme or of My Suite, CLÉCLÉ does not take decisions producing legal effects concerning a user on the sole basis of entirely automated processing. Some payment providers may, however, use automated fraud-prevention or assessment mechanisms, in particular in the context of a deferred or instalment payment. Where this is the case, these operations are governed by the information and policies provided by the provider concerned.

17. CHANGES TO THE PRIVACY POLICY

This Policy may be amended in order to take account in particular of:

  • changes to the CLÉCLÉ services;
  • the addition or removal of a feature;
  • changes in our service providers;
  • or a change in the applicable regulations.

The date of the last update appears at the top of the page. Where changes substantially affect the way data is used, appropriate information is communicated to the people concerned where necessary.