Privacy Policy

Last revised: December 31, 2019

Back Market (hereafter “we”) is concerned about the protection of your personal data. We are committed to ensuring the best level of protection for your data, in accordance with the EU Regulation 2016/679 of the European Parliament and the Council of April 27, 2016 regarding the protection of natural persons in regard to the processing of Personal Data, the General Regulation on Data Protection (GDPR) along with the California Consumer Privacy Act (CCPA) of 2018.

By navigating our site, you agree to accept our Policy for the Protection of Personal Data. This Policy, coupled with our Terms of Service, formalize the contractual relationship between the “Back Market” platform and its users. The term “Personal Data” hereinafter means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For this reason, the data that we collect may include your strictly personal data, in that it allows you to be identified as a specific person. On the other hand, some data, such as your navigation data (type of navigator, Terminal and operating system, the path followed on the Site, etc.) do not allow us to identify you directly, but are all considered Personal Data since they are attached and/or may be attached to the former.

This Policy for the Protection of Personal Data is intended to present the following terms to you:

• Who collects your data?

• What are the personal data collected?

• What are the rules for collecting the associated data?

• Why are these data collected?

• How are your data protected?

• What are your rights and how do you exercise them?

If you disagree with any of our terms, you have the choice of: no longer navigating on our site, changing your choices by clicking here or exercising your right to request removal of your data.

We invite users of the “Back Market” platform to periodically refer to our Policy, which may be changed to conform to legislative and regulatory changes in the GDPR and the CCPA. For any information on the protection of personal data, you can also find the site of your national Data Protection Authority here : https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/ind ex_en.htm .

Who collects your data?

Back Market, Inc.,a Delaware corporation, having its headquarters office located at 100 Bogart Street, Brooklyn, New York 11206 (hereinafter “BACK MARKET”), has made available a platform, which is accessible from all of the internet sites that it operates (www.backmarket.fr, www.backmarket.com, www.backmarket.it, www.backmarket.de, www.backmarket.be, www.backmarket.es).

In the scope of providing services related to the Platform, BACK MARKET has collected and processed Personal Data regarding users in order to manage the contractual relationship. In this context, BACK MARKET has set up data processing in accordance with the GDPR and the CCPA, the purpose of which is the management of customers (including the management of contractual relationships, orders, delivery, invoices, accounting, and monitoring the contractual relationship), and more generally, the management of operations that will allow it to communicate with users, or make the functions required for navigation on our sites available.

What data are concerned?

The data collected on BACK MARKET platform.

These data are divided into 2 major categories:

• The data received directly from you when you set up your account or during interactions with our customer service department, or changes to your profile

• The data that we automatically collect through your activities on the site

Data received from the user Data automatically collected The mandatory or voluntary nature of the data is reported to you at the time it is collected: title, last name, first name. Some data are automatically collected through your activities on the site: navigation data, history of shipping address, invoicing address, email address, password, date of birth and age of majority (older than 18), bank information number, telephone number, company. BACK MARKET restricts access by persons of less than 18 years of age, who cannot make a purchase without parental authorization. In addition, data on contacts with customer service are also collected. orders, preferences and interests, products viewed, products added to the cart, delivery incidents, claims, conversations with an advisor. We also perform audience measurements: for example, we measure the number of pages viewed, the number of visits to the site, and the activity of visitors on the site and their return rate. Finally, we collect data using cookies. We have dedicated a page to our cookie policy, which allows you to indicate your preferences

Banking data

For payment requirements, banking information is collected and retained by our service provider for Adyen certified PCI-DSS payment. This standard is an international standard, the purpose of which is to ensure the confidentiality and integrity of card holder data, and to protect credit card and transaction data.

Adyen encrypts the data and only retains it for 3 years for technical purposes (for example: for a recurring payment requested by the user at the time of purchase, such as insurance, or the reimbursement of a purchase, or in case of fraudulent behavior). The encrypted payment data are held in secure data centers in Europe.

“Plug-ins” and social media modules

Our site uses “plug-ins” or social media modules. This primarily consists of small “like” buttons on social networks such as Facebook, Twitter, Google+, etc., which you will find on our sites and applications. It lets you “like” and share information from our site and applications with your friends on social networks. When you visit a page on our Back Market sites (web or mobile) that contains plug-ins or social media modules, a connection is made with the social network servers (Facebook, Twitter, etc.) which are then informed that you have accessed the corresponding page on the Back Market site that was visited, even if you do not have a Facebook or Twitter account, and even if you are not connected to your Facebook or Twitter account. For example: If you are connected to the site www.backmarket.com, the social networks that you are connected to may mention your visit in your account, and on the social networks. If you use plug-ins (example: like), your actions may be registered and published on your accounts with social networks based on the parameters of your social network account. If you do not want the social networks to publish your actions coming from plug-ins in your accounts on the social networks, you must disconnect from your social networks before visiting our site.

Facebook Connect

Facebook lets you connect to our sites with your Facebook account and see what your friends have published on the web. When you connect to our sites with your Facebook account, Back Market can access some information that you have given Facebook in order to offer you a personalized social network experience. Authorization to access your profile data and share your activities with Facebook will be requested from you. Information that is additional to that already present in your Facebook account may be requested by Back Market for purposes of management of your orders and our customer relationship. This additional information is not transmitted to Facebook without your express authorization. Access by Back Market to Facebook data and its use, is in fact limited, and Back Market expressly only uses the data that are strictly required to manage the applications that you use. For each application, you are informed about the data used and how they are used, displayed, shared or transferred.

If you connect to www.backmarket.com using your Facebook identifiers and your friends connect to www.backmarket.com, they will know that you have a Back Market account, unless you have chosen not be visible to your friends on other sites. Users who connect to our site via Facebook can only see the information that you have added via Facebook if they have access to this information on Facebook. You can decide which type of information your friends by have access to by setting the parameters for your account in the Applications section of the Facebook site.

What are the relevant rules regarding the collection and retention of data?

Data collection

We collect the information that you have given us when:

• you set up your customer account “My account”

• you enter an order on our sites

• you navigate on our sites and view our products

• you participate in a game or contest

• you contact our Customer Service Department

• you post an opinion

• you contact an advisor

• you create a product availability alert or reorder your equipment

Duration of data retention

Your Personal Data regarding your account, as well as those regarding your navigation and/or your behavior on the site are retained for 3 years from your last activity on the site or electronic communication support with Back Market or for 6 years from your last order unless otherwise provided by the applicable laws and regulations. At the end of this time, your account is considered “inactive” and will automatically be deactivated. It is up to you to create a new account for any order.

On the other hand, audience measurement statistics and your raw data on visits to the site are not retained for more then 13 months.

However, at the end of the above time limits, including as needed counting from your request for deletion, your personal data may be temporarily archived to meet our legal, accounting and tax requirements.

Who has access to your data?

The data collected on the Back Market sites are intended exclusively for the Back Market group.

The personal data may be given to companies - sub-contractors - which Back Market uses in the scope of the processing of services and orders, especially management, execution, processing and payment as defined in this section.

Sellers

The data required for the delivery of your order (company, email address, title, name, first name, delivery address, telephone number) are sent to Sellers for the respective orders. Customer assistance We use service providers to assist our customers as quickly as possible:

• iAdvize instant messaging system on our pre-purchase site, which hosts data for the European Union. These conversations are registered to measure customer satisfaction, to ensure the quality of the assistance given by advisors and to improve the products and services of iAdvize.

• Postsales contacts(call center, assistance forthe resolution of disputes, etc.) by software tools and telephone and email assistance services, located in the United States and/or Puerto Rico and trained by us.

• The package tracking solution Kronos, which allows us to recover information on delivery status.

Marketing

We use Customer Relationship Management (CRM) software, which uses our data bases and all of the data that are stored there, for all of the users of our sites, respecting the communication approvals and preferences indicated on our sites, notably at the time of the creation of an account. We also use service providers to help us communicate outside of our sites, to promote our advertisements (traffic acquisition, customer match) with new or existing customers.

Payment & Fraud

We use Adyen, a partner that specializes in payments and the Fight against Fraud. The data collected are not sent to third parties, and as our business partner, Adyen conforms to strict rules regarding information disclosure, respect for privacy, the right of revocation and the settlement of disputes. We also use Signifyd, our partner in fraud protection that complies with strict rules concerning personal data protection.

Transfer and hosting of your data

The servers containing the data collected by Back Market are hosted in the United States by our partners that complies with strict rules concerning personal data protection. European users are informed that the data concerning you may be sent by Back Market for the purposes of the goals defined in these conditions to companies located in companies outside the European Union. Prior to transfer outside of the European Union, Back Market implements any procedure required to obtain the guarantees necessary for the security of such transfers (specific clauses, anonymization of data). For the European users, transfers outside the European Union may be done, especially within the scope of the following of our activities: Back Market customer service (Moroccan call center, internal communication tools), IT services on the Back Marketsystems, data use related to social networks(see below). For transfers to our service providers, we ensure that they respect the Regulations on the Protection of Personal Data.

For what purposes are your personal data collected?

Management of orders

The information and data concerning you are necessary to the management of your order, that is, each purchase of goods and/or services made by a customer on our Sites under the conditions laid out in the Terms of Service supplemented, when necessary, by specific conditions. This information may also be retained for purposes of evidence regarding adherence to legal and regulatory requirements (payments, guarantees, disputes, etc.).

Personalization of our services

The information and data concerning you allows us to improve and personalize the services that we offer you on our Back Market internet site and mobile application and the information that you send us.

Back Market information and newsletter

In order to keep you informed of news and offers that you can take advantage of, you may receive offers by electronic communication (email, sms, etc.). We measure the opening rates of our communications to better adapt to your needs. If you do not want to receive Back Market offers and information, you can opt out of mailings by notifying it when you set up your account, or at any time by specifying in the “Personal Info/Newsletter” heading of My Account , where you can unsubscribe using the unsubscribe link at the bottom of the emails. Depending on the choices made during the creation or viewing of your account, you are likely to receive offers from Back Market.

You can personalize newsletter mailings and manage the subscriptions to newsletters that you want to receive when you set up your account or by going to the “Newsletter” section of My Account. You will then be able to select the newsletters that interest you from among the various categories of newsletters. The mailing of Back Market offers and information will be adjusted to your selection. You can also change the frequency of mailings or stop the newsletters at any time by going to My Account or from the subscription link in the footer of the emails.

If you do not select, and if you do not object to them when you set up your account, you are likely to receive information on Back Market news and the newsletters that concern similar products to the ones that you have already ordered or viewed on the Back Market site.

Alerts

We can offer you alerts so that you are informed by email of availability of a product, or of news that may interest you.

As appropriate, these alerts will let you:

• be quickly informed of the next availability of the product that interests you. Subscription to alerts is done by clicking on the “Alerts” button in My Account. The alerts that you are interested in subscribing to are listed in My Account. You can manage alerts or end them by going to the “Alerts” section in My Account.

• be informed of the possibility of selling your equipment to one of our reconditioners.

Subscription to the alert is done in the Resell section when you want to resell an item of equipment that is not available at the time of your visit.

Integration of Trustbadge Trusted Shops

Trustbadge Trusted Shops is inserted on this page to display our Trusted Shops mark of confidence and all of the opinions collected or even to offer Trusted Shop products to buyers after an order.

These operations protect our legitimate overriding interests in the optimal marketing of our products, within the context of balancing various interests. Trustbadge and the services connected to it are offered by Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne.

When you view Trustbadge, the web server automatically registers a “log file”, indicating, for example, the name of the file requested, your IP address, the date and time of your viewing, the volume of data transferred and the Internet service supplier at the origin of the request (access data). These access data are not used, they are automatically erased, at the latest eight days after the end of your viewing.

Other data of a personal nature are transmitted - only to Trusted Shops - if, at the end of an order, you have opted to use Trusted Shops products or if you have already registered for this use. In this case, it is a contractual agreement between you and Trusted Shops that applies.

Fight against Fraud

In order to ensure the security of payments and deliveries and to ensure you of optimum quality of service, personal data collected on the site are also processed by Adyen to determine the risk level of fraud associated with each order and, if necessary, to assist in adjusting its implementation procedures. Within the framework of this analysis, Adyen uses its own software solution.

Back Market may, depending on the results of checks carried out on the orders, take safety measures, in particular verification by code received on a telephone (3D secure) or a request for additional information. These measures will suspend the processing of the order and even, if the result of the analysis does not guarantee the security of the order, to cancel it. The occurrence of an incident (unpaid due to fraudulent use of a payment method, delivery fraud, etc.) will prompt registration of the data connected to the order in the Back Market alert file, and which would, during the next orders, lead Back Market to perform additional verifications.

At any time while the risk analysis is being performed by Back Market, you may make comments. In addition, in accordance with the Data Protection Act of January 6, 1978, you have the rights of access, correction, deletion and opposition provided for by the Data Protection Act of January 6, 1978. In accordance with current regulations, your request must be signed and accompanied by photocopied personal ID showing your signature, and stipulate the correct mailing address for receiving an answer. To exercise your rights regarding the fight against fraud, all you need to do is contact:

At Back Market: Electronically to legal@backmarket.com or by mail to Back Market, Service Juridique/Responsable Données Personnelles, 152 Boulevard Macdonald, 75019 Paris, giving your last name, first name, email address and, if possible, your customer reference number.

Insurance services

For insurance services, our insurance partner Gras Savoye processes personal data and, as part of the digital services, your personal data may be transmitted to trusted Third Parties of this partner to perform the digital services(for example: electronic signature, mailing of a registered letter with return receipt, electronic archiving, etc.).

Personalization of ads on the Back Market sites and social networks

The information that you receive from Back Market may be personalized based on the data that Back Market collects on its sites (declaration data and navigation data), or linked to social networks. We invite you to view the policies for the protection of personal data of the social networks to more closely acquaint yourself with the information that is collected by the social networks and which may be transmitted to Back Market.

Due to your use of Back Market services (sites) or your affiliation with a Back Market social network page, Back Market is likely to receive information concerning you, notably your public profile and your interests, communicated on the social networks, or other data that you may authorize Back Market to process by navigating on its sites or by continuing to use the services offered on the platform (see above paragraph concerning the data collected). Back Market ads connected to your profile and to the information that you publish or share (you interests) may be distributed on your social network pages. If you do not want the social networks or third parties from which Back Market collects or uses information based on your profile or you activity on web sites, devices or applications outside of the social networks for distribution or publicity, you must refer to the conditions of the social networks to understand the procures for fixing parameters, unsubscribing or controlling the distribution of ads. You can also refuse by using the application parameters of your mobile device and directly on the social networks.

Cookies and targeted ads

Our site is designed to be especially attentive to the needs and expectations of our customers. It is for this and other reasons that we use cookies or similar tracing technologies to identify and personalize our services and ads, notably to access your account, manage your order cart, memorize your views and personalize the offers we make and the information we send you. Cookies allow you to benefit from our personalized advice and to stay informed about our promotional offers. You can deactivate cookies at any time. To learn more and to understand the procedure for refusing cookies: click here

We use your data to better understand the profiles of our customers and in this way to better target our advertising campaigns.

Your Rights

What are your rights?

Your rights regarding the Data Protection Act

In accordance with the GDPR and/or CCPA where applicable are defined in this section., you have the rights listed below with regard to your personal data. You only have to write us online at legal@backmarket.com or by mailto Back Market, Legal Team, 154 Boulevard Macdonald, 75019 Paris, France, giving your last name, first name, email address and, if possible, your customer reference number. In accordance with current regulations, your request must be signed and accompanied by photocopied personal ID showing your signature, and stipulate the correct mailing address for receiving an answer. A response will be sent within 1 month from the receipt of the request. If necessary, this period may be extended by two months, depending on the complexity and number of requests. The person responsible for processing will notify the concerned party of this extension and the reasons for the postponement within one month from the receipt of the request.

To exercise your rights regarding the fight against fraud, see the clause Fight against Fraud, above:

In accordance with the Regulations on the Protection of Personal Data, you have the following Specific Rights to:

• disclosure or access (Article 15 of the GDPR and Cal. Civ. Code §§ 1798.100(d), 1798.110, 1798.115.),

• rectification (Article 16 of the GDPR),

• deletion/erasure/removal (Article 17 of the GDPR and Cal. Civ. Code § 1798.105),

• restrict Processing (Article 18 of the GDPR and Cal. Civ. Code § 1798.120. ),

• data portability (Article 20 of the GDPR and Cal. Civ. Code §§ 1798.100(d) and 1798.130(a)(2). ),

• opposition to processing and profiling (Article 21 and 22 of the GDPR),

• Opt-Out Right for Personal Information Sales(Cal. Civ. Code §§ 1798.120 and 1798.135(a)-(b).)

• post mortem directives (Data Protection Act No. 78-17 of January 6, 1978)

Access rights

You have the ability to obtain from Back Market the confirmation that the Data concerning you are or are not processed, and, if they are, access to said Data as well as the following information:

• the purposes of the processing;

• the categories of the Data;

• the recipients or categories of recipients to which the Data have been or will be sent;

• when possible, the retention period of the intended data or, if that is not possible, the criteria used to determine this period;

• the existence of the right to request Back Market to correct or remove the Data, or to limit the processing of your Data, or the right to oppose this processing;

• the right to lodge a complaint with the French Data Protection Authority;

• when the data are not collected from you, any information as to their source;

• the existence of any automatic decision making, including profiling, and, in such cases, useful information regarding the underlying logic, as well as the scope and consequences envisioned for you because of this processing.

When the Data are transferred to a third party country or international organization, you have the right to be informed of the appropriate guarantees regarding this transfer.

Back Market provides a copy of the Data that are subject to this process.

Back Market may require payment of reasonable fees based on the administrative costs for any additional copies requested by the Visitor.

When you present your request electronically, the information is provided under commonly used electronic form, unless the visitor requests otherwise.

Your right to obtain a copy of your Data should not impede the rights and liberties of others.

Rights to correction

You have the ability to obtain from Back Market, as soon as possible, the correction of Data concerning you that is incorrect. You also have the ability to have incomplete data completed, including providing an additional declaration.

Right to removal

You have the right to have Back Market remove, as quickly as possible, Data concerning you when one of the following reasons apply:

• the Data are no longer necessary for the purposes for which they were collected or processed in another way by Back Market;

• you have withdrawn your consent for the processing of these Data and there is no legal basis for the processing;

• you are exercising your right to opposition under the conditions listed below and there is no legitimate and imperative reason for the processing;

• the Data are the object of illegal processing;

• the Data must be removed to adhere to a legal obligation;

• the Data were collected on a child. Rights to limitation

You have the right to have Back Market limit the processing of your Data when one of the following reasons apply:

• Back Market verifies the accuracy of the Data after you challenge the accuracy of the Data,

• the processing is illegal and you oppose the removal of the Data and require instead the limiting of their use;

• Back Market no longer needs the Data for processing but they are still required for the establishment, exercise or defense of legal claims;

• You oppose the processing under the conditions listed below and Back Market verifies whether the legitimate reasons given prevail over your alleged reasons.

Data portability rights

You have the ability to receive from Back Market the Data concerning you, in a structured, commonly used and machine readable format if:

• the processing of the Data is based on consent, or on a contract and

• the processing is done with automated processes.

When you exercise your right to portability, you have the right to obtain only the Data that was transmitted directly by Back Market to a processing manager that you will designate when it is technically possible.

Your right to portability of your Data should not impede the rights and liberties of others.

Rights to opposition to processing and to profiling You have the right, at any time and for reasons based on your specific situation, to oppose the processing of Data concerning you founded on the legitimate interests of Back Market. Back Market will then no longer process the Data, unless it can demonstrate that there are legitimate and imperative reasons for processing that prevail over your interests, rights and liberties, or will retain them for the establishment, exercise or defense of legal claims.

When the Data are processed for marketing purposes, you can oppose the processing of these Data at any time.

Post mortem directives

You have the ability to give us directives related to the retention, removal and communication of your Personal Data after your death. Said directives may be also be registered with “a trusted digitally certified third party”. These directives, or type of “digital will” can designate a person responsible for their execution; failing this, your heirs are designated.

In the absence of any directive, your heirs can contact Back Market to:

• access the processing of Data that will permit “the organization and settlement of the deceased’s estate”;

• receive communication of “digital assets” or “data related to family memories, transferable to heirs”;

• close your visitor account on the Site and oppose the processing of your Personal Data. In any case, you can indicate to us, at any time, that in case of your death, you do not wish your Personal Data to be communicated to a third party.

How do you exercise your Specific Rights?

To exercise your Specific Rights with Back Market and/or, when necessary obtain an oral version of this Policy, you may send your request:

• By email to our Data Protection officer legal@backmarket.com,

• When you visit the Site, in the “ My Account “ section, by selecting the desired heading,

• By mail to our Data Protection officer at the following address: Legal Team Back Market 154 Boulevard MacDonald 75019 PARIS FRANCE

A response will be sent within one (1) month from the receipt of your request. If necessary, this period may be extended by Back Market by two months, depending on the complexity and number of requests. In the case of a request for deletion of your Data and/or in case of the exercise of your right to request removal of your Data, we may nevertheless retain them under temporary Archived form for the period necessary to satisfy our legal, accounting and tax obligations and especially to prevent possible illegal behavior after the deletion of your account (reuse of your old account by a third party), in accordance with Article II-3 of this Confidentiality and Privacy Protection Policy.

It should be noted, that, as necessary, the request for deletion of your visitor account from the Site is not interpreted by Back Market as an express request for the exercise of your right of opposition, limitation or deletion for legitimate reasons. You visitor account is then rendered inactive and the Data concerning you will be placed in temporary Archiving under the conditions and time frames indicated above.

You can also choose the types of emails that you wish to receive or not, by visiting the “My Communications” section. You can then unsubscribe, finally or temporarily, from each category or from all of the emails.

An unsubscribe link is displayed on each email that Back Market sends you.

At any time, you can also request not to receive further ads or adapted marketing in the navigation information of your Terminal, by contacting us directly and for free, or via the unsubscribe link included in all marketing material that we are likely to send you by email. If necessary, the ads that you will continue to receive, unless you object, will no longer be adapted to the navigation of your Terminal. You may, at any time, appeal to the competent supervisory authority (in France, the Data Protection Authority); www.cnil.fr )

Your California Privacy Rights

If you are a California resident, this section provides details on your rights under the California Consumer Privacy Act (CCPA).

Back Market , Inc collects and processes your personal information for business purposes as described in the section “For what purposes are your personal data collected?”. Such personal data will be disclosed to third parties, however, we do not sell (as defined in the CCPA) your personal information.

• To exercise your rights of access, correction, removal, limitation of the processing of data portability and opposition to processing and profiling (as detailed in section “ “What are your rights?”), you may: write us online at legal@backmarket.com or

• by mail to Back Market, Legal Team, 154 Boulevard Macdonald, 75019 Paris, France giving your last name, first name, email address and, if possible, your customer reference number.

A response will be sent within 45 days from the receipt of the request. If necessary, this period may be extended by 45 days where necessary.

Non-discrimination

Under no circumstances will Back Market discriminate you for exercising your rights under the CCPA. Back Market will not:

• Deny you the sale of the Products,

• Impose a higher price for the Products,nor

• Provide you a different level or quality of the Products.

How are your data secured?

Back Market protects your personal data by establishing all reasonable technical and organizational measures to ensure the security of the processing of personal data and its confidentiality. In this regard, Back Market takes every suitable precaution regarding the nature of the data and the risks presented by the processing to preserve the security of the data and especially to avoid that they are distorted, damaged or that non authorized third parties have access to them: physical protection of locations, authentication procedures with personalized and secure access via identifiers and confidential passwords, encryption of certain data, etc. We remind you, however, that you are responsible for the data concerning you that you transmit to Back Market and as such, you contribute to the protection of your personal data by adhering to best practices regarding the use of your computer tools.

You are also reminded of the fact that without adequate security measures (for example, secured configuration of your web navigator, updates of anti-virus programs, firewall software, not using software from doubtful sources, etc.) you run the risk that the data and passwords that you use to protect your data may be disclosed to unauthorized third parties.

Contacts and claims

For any request, you can send it:

• By email to our Data Protection officer legal@backmarket.com,

• When you visit the Site, in the “ My Account “ section, by selecting the desired heading,

• By mail to our Data Protection officer at the following address: Legal Team Back Market 152 Boulevard Macdonald 75019 PARIS FRANCE

If you do not receive a response, or if you are not satisfied with the response given, you can file a claim with the competent protection and supervisory authority of the member State of the European Union in which you usually reside.

• For France, the Data Protection Authority: http://www.cnil.fr/

• For Spain AEPD : https://www.aepd.es/

• For Germany Datenschutz: http://www.datenschutz.de

• For Belgium : http://www.privacycommission.be/

• For other countries: http://ec.europa.eu/justice/article-29/structure/data-protectionauthoritie s/index_en.htm

Glossary

“Order”: means each acquisition of goods and/or services made by a customer on the Site under the conditions set out in the Terms of Service supplemented, when necessary, by specific conditions.

“Cookies”: means tracers and/or equivalent technologies, including “Flash” cookie, resulting from footprinting calculation of your Terminal called “fingerprinting “, local web storage, invisible pixels, used in an alternative or cumulative manner to i) facilitate the navigation of the visitor (Navigation Cookies), ii) offer products and services adapted to the interests of the visitor (Advertising Cookies), iii) allow for the development of statistics (Audience Cookies) and iv) allow the visitor to access personalized products and services on the Site or via messages sent by backmarket.fr (Personalization Cookies) and allow for interaction with Social Networks (Social Network Cookies), etc.

“Personal Data” or “Data”: means any information relating to an identified natural person or one who could be identified, directly or indirectly, especially by reference to an identifier, such as a name, an identification number, localization data or an online identifier, or to one or more specific elements belonging to its physical, physiological, genetic, psychic, economic, cultural or social identity. For this reason, the data that we collect may include your strictly personal data, in that it allows you to be identified as a specific person. On the other hand, some data does not allow for you to be identified directly, such as your profession or your navigation data (type of navigator, Terminal and operating system, the path followed on the Site, etc.) but are nevertheless considered Personal Data since they are attached and/or may be attached to the former.

“Third Party Data”: means the Data that we share, when necessary, with third parties.

“Specific Rights”: means the rights granted to the visitor by the Regulations on the Protection of Personal Data and notably the rights to:

• disclosure or access (Article 15 of the GDPR and Cal. Civ. Code §§ 1798.100(d), 1798.110, 1798.115.),

• rectification (Article 16 of the GDPR),

• deletion/erasure/removal (Article 17 of the GDPR and Cal. Civ. Code § 1798.105),

• restrict Processing (Article 18 of the GDPR and Cal. Civ. Code § 1798.120. ),

• data portability (Article 20 of the GDPR and Cal. Civ. Code §§ 1798.100(d) and 1798.130(a)(2).),

• opposition to processing and profiling (Article 21 and 22 of the GDPR),

• Opt-Out Right for Personal Information Sales(Cal. Civ. Code §§ 1798.120 and 1798.135(a)-(b).)

• post mortem directives(Data Protection Act No. 78-17 of January 6, 1978) “Visitor” means any internet user that has given Personal Data on the registration form of the site, accepted the Terms of Service and the Personal Data Policy, or having, after receipt of an email confirmation, validated his Back Market account.

“Partner(s)”: means the various service providers of Back Market, whether for the processing of your Orders, the delivery of products, customer service, the provision of technological services, advertising, Social Networks (as defined below), etc., or even more specifically, our suppliers for the achievement of product sales and/or services on the Site.

“Regulations on the Protection of Personal Data”: means all of the GDPR, the Data Protection Act No. 78-17 of January 6, 1978, as modified, and any new act or decree adopted for its application and the California Consumer Privacy Act (CCPA).

“GDPR”: means the EU General Data Protection Regulation N°2016/679 of April 27, 2016 applicable as of May 25, 2018 or, in lieu of it, any law that may be adopted for the transposition of said Regulation.

“Site(s)”: means the Internet site backmarket.com published by Back Market in their web and mobile version, as well as the corresponding mobile applications.

“Terminal(s)”: means the equipment (computer, tablet, smartphone, telephone, etc.) that you use to visit or display the Site and/or any digital support produced by a third party.