LVMH Corporate Website Personal Data Protection Policy

Last update: June 2024

This Personal Data Protection Policy (hereinafter the “Privacy Policy” or “Policy”) is intended to provide visitors and users (hereinafter “You”) of the www.lvmh.com/fr website, as well as of all other LVMH websites with .com, .it, .jp domain name suffixes (hereinafter collectively the “Website” or the “Site”) with information relating to how LVMH Moët Hennessy-Louis Vuitton SE (hereinafter “LVMH” or “We/Us”) processes your personal data (hereinafter “Personal Data” or “Data”).

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.

The terms of this Privacy Policy may be amended, in particular if a new processing of Personal Data is carried out. Please check this page regularly to ensure that You agree with any changes. You will be notified of any significant modifications, through specific communications channels.

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 activities of 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.com/en/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: to complete a contact form, subscribe to our newsletters, sign up to receive corporate documentation, create an applicant page and 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:

1. Manage your requests or queries sent via the contact form based on the legitimate interests of LVMH;
2. Manage your subscription to our different newsletters, based on your consent;
3. Manage your requests for corporate documentation, based on your consent;
4. Manage your applicant page, based on your consent;
5. Manage your applications to LVMH job offers based on precontractual measures and on the establishment of a contractual relationship between LVMH and job, work placement or internship applicants;
6. 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;
7. Prevent fraudulent acts based on the legitimate interest of LVMH to ensure the security of our assets and content;
8. 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 LVMH:
  - Corporate Communication Department and Financial Communications Department as regards the management of your requests and newsletter subscriptions;
  - Human Resources Department as regards the management of your applicant page and applications to job offers for activities of the LVMH holding company;
  - Security Department as regards the management of Website security;
  - Legal and Anti-Fraud Departments as regards the management of fraud prevention or court action, if necessary.
• Accessibility by third parties, specifically:
  - Service providersintervene for technical and logistical reasons (accommodation service providers, security and maintenance of the Website, anti-fraud management service providers, service providers responsible for sending emails and newsletters, anti-spam and anti-bot service providers, recruitment agencies that can advise Us on the management of our applicant database and help Us select profiles from this database);
  - Other LVMH affiliates for recruitment purposes: with your explicit consent, when you accept that your data can be shared with other other affiliated companies for recruitment purposes in respect of similar roles; or when You respond to a job offer from a LVMH affiliate through the Site, the latter collects and processes your Data as an independent data controller. In this case, your Data will be treated according to the relative privacy policy of the affiliate company in question, of which you will be aware at the time of Your application or which You can obtain by contacting the affiliate company directly. Similarly, the rights You may have under the applicable regulations in regards to the privacy policy must be exercised by the affiliate company:
  - 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 our processing of your Personal Data is no longer needed for the purposes described in this Privacy Policy;
• 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.

6. Cookies

More information on cookies, the different types of cookies and the purposes of cookies is found in Appendix 2.

You can manage your consent regarding the cookie settings at any time while browsing the Website by clicking on the "Cookie settings" link at the bottom of each page of the Site.

7. Third-party websites

The Website may contain links to third-party websites that We do not control (such as the websites of LVMH Group affiliates) and which are governed by their own confidentiality and personal data protection policies.

This Privacy Policy does not apply to third-party websites. Please review the confidentiality and personal data protection policies of the third-party websites that You visit to understand how they process your Data. LVMH shall not be liable for any use of your Data by any third parties.

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.

LVMH may also, as data controller, process the Personal Data of shareholders for the management of the Shareholders’ Club, including the Club e-boutique dedicated to registered shareholders. This processing is subject to the Club’s privacy policy, which is available here.

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?

For any questions concerning this Privacy Policy or for any queries or complaints regarding your Personal Data, You may contact Us:

• by using the contact form available at https://www.lvmh.com/en/contact/, 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.