Privacy Policy

Privacy Policy

This policy (the "Policy") describes how TIMEWAY FRANCE SAS ("we") processes your personal data when you interact with Clyda or when you visit or use our website https://clyda.com (the "Site"). It also informs you of your rights regarding personal data protection.

This Policy does not cover cookies and other trackers that may be placed on the Site or on other media, which are subject to a dedicated policy (the "Cookie Policy"), separate from this one and accessible via the following link: https://clyda.com/pages/cookies.

1. Who is responsible for processing your personal data?

TIMEWAY FRANCE SAS, whose registered office is located at 78, rue Championnet, 75018 Paris, registered under number 419 395 595 with the Paris Trade and Companies Register and operating under the brand name Clyda (hereinafter "Clyda", "we" or "our") is the data controller for your personal data.

2. What personal data do we collect and where does it come from?

We primarily process personal data collected directly from you, such as:

(i) your identifying data (including title, last name, first name, postal address, telephone number, email, date of birth) when creating and during the life of your customer account, or when subscribing to our newsletter or our contests ;

(ii) data relating to your orders (including quote number, invoice number, transaction number, purchase details, product returns), type of event, delivery address, billing address and payment data (credit card number, expiry date and visual cryptogram), when you make purchases on our Site;

(iii) data appearing on any proof of identity that may be requested from you, when required by law or to secure data processing by confirming your identity, for example for the following purposes: to exercise your right to VAT refund, to exercise your rights over your personal data (only in case of reasonable doubt about your identity in the latter case);

(iv) data relating to your measurements (such as ring size);

(v) metadata or technical data (connection time, connection date and time, IP address, logs, etc.) resulting notably from the use of cookies and your browsing on our Site, as well as from the use of the Shopify platform that hosts our Site and manages orders and payments ;

(vi) conversation data or reviews resulting from the sale of our products or the use of our services.

3. How do we use them?

We process your personal data for specified, explicit and legitimate purposes. Each time we process your personal data, we do so on the basis of a legal "justification" (or legal basis) for the processing, specific to each purpose. The purposes and legal bases for processing covered by this Policy are described below.

Purposes	Legal basis
1. To allow you to access and use our Site and its services	The processing of your data is necessary for the performance of the contract (General Terms of Use or GTU) relating to your access and use of the Site that we have concluded with you. Our GTU are accessible at the following link: https://clyda.com/pages/cgv
2. Manage the commercial relationship with you: manage your customer account and the purchase of products on our Site (processing your order, managing your payment, delivery, etc.).	The processing of your data is necessary for the conclusion and performance of the General Terms and Conditions of Sale (GTCS) governing your order and purchase and their follow-up until delivery. Our GTCS are accessible at the following link: https://clyda.com/pages/cgv
3. Ensure our after-sales service for products purchased on our Site.	The processing of your data is necessary to fulfill our legal obligations under the legal warranty and our contractual obligations under the after-sales service and lifetime warranty and growth services for certain products.
4. Combat e-commerce fraud as part of the fight against fraud during orders placed on the Site.	We have a legitimate interest in preventing online fraud committed when purchasing our products and services on our Site.
5. Generate audience measurement statistics and monitor navigation within the Site to improve its usability.	In your legitimate interest, as well as in Clyda's legitimate interest, navigation on our Site and the products and services most appreciated by our customers and prospects are analyzed to improve our product and service offerings and the Site's ergonomics.
6. Improve our customer and prospect knowledge to enhance our product and service offerings.	We have a legitimate interest in improving our customer/prospect knowledge, particularly by performing segmentation, in order to improve our product and service offerings to meet their expectations as closely as possible.
7. Respond to your questions and complaints.	In your legitimate interest, as well as in Clyda's legitimate interest, we respond to your requests, questions, and complaints to provide you with a satisfactory customer experience. We are also required to respond to you due to our legal obligations.
8. Conduct satisfaction surveys and collect your feedback.	We have a legitimate interest in conducting these surveys and collecting your feedback to improve our products and services and provide you with a satisfactory customer experience. This feedback may be anonymized and/or aggregated by our service providers to improve their services and the products and services offered by Clyda.
9. Promote Clyda's image and products and services through targeted commercial prospecting and promotional operations (newsletter)	The sending of promotional or advertising messages, including those containing personalized offers and/or our newsletter, is subject to your prior consent.
10. Organization of contests	Your participation in contests is based on the acceptance of the contest rules (legal basis of the contract)

12. Respond to your requests to exercise rights regarding personal data protection.	This processing is necessary to comply with our legal obligations under Regulation (EU) 2016/679 on the protection of personal data and Law No. 78-17 of January 6, 1978, on information technology, files and freedoms, as amended.

14. Respond to a request for a VAT deduction slip in case of a purchase made in France by a non-resident of the European Union	This processing is necessary to comply with our legal obligations towards tax and customs authorities.
15. In case of a merger-acquisition, restructuring or sale of our business.	We may have a legitimate interest in carrying out restructuring operations, with the aim of preserving and developing our commercial activities, which may result in a transfer of all or part of your data. In any event, the transfer of this data can only take place if (i) you are an active customer and (ii) you have consented to the electronic reception of promotional, commercial, or advertising messages or (iii) you have not objected to the reception by post or telephone of promotional, commercial, or advertising messages.
16. Develop the functionalities of our Site: taking into account your preferences, needs and uses as a User of the Site and more generally improve your customer experience on our Site.	We have a legitimate interest in offering you a satisfactory customer experience, allowing us to develop your interest in our products and services.
17. Fulfilling our legal and regulatory obligations, such as our accounting or tax obligations.	We have a legitimate interest in offering you a satisfactory customer experience, allowing us to develop your interest in our products and services. The processing of your data is necessary for compliance with our legal or regulatory obligations.
18. Asserting our rights or defending ourselves in the event of litigation.	The processing of your data is necessary for the purposes of our legitimate interest in establishing, exercising and/or defending our rights and thus ensuring the continuity of our activities.
19. Where applicable, share your data with our service providers to improve the services to which they contribute on the Site.	Unless you object, we have a legitimate interest in sharing your data with service providers offering certain functionalities of our Site to improve your customer experience and allow them to improve their services, while limiting their access to only the data strictly necessary for the proper execution of said operations.

4. With whom do we share them?

We share your personal data with:

the authorized departments of TIMEWAY FRANCE SAS, its parent company THOM GROUP SAS, companies affiliated with THOM GROUP SAS and companies holding a stake in THOM GROUP SAS, the subcontractors of said companies, when the internal organization of the THOM group requires such sharing of your data (for example, for statistical studies, service quality monitoring, etc.);
Clyda employees, employees of the companies listed above who need to know them due to their function and for the performance of their duties (for example, our sales advisors);
our service providers (such as transport/delivery, data hosting, maintenance, payment, after-sales service workshops, etc.) who process your personal data on our behalf and according to our instructions, as processors;
public authorities, when we are required to do so by law or by a decision of a competent authority;
our external advisors (lawyers, auditors, etc.), when necessary for the legitimate interests pursued by Clyda or for our legal obligations;
our independent partner stores, only when necessary for processing specific requests (including after-sales service or product warranty)

In any event, regardless of the processing carried out and the purpose pursued, Clyda does not market the personal data of its customers and prospects, nor the files or databases containing them.

5. Where is your data located?

Your data is generally hosted and processed within the European Economic Area (EEA). As some of our service providers are located outside the European Economic Area (EEA), your personal data may be transferred outside the EEA, to countries considered not to offer a level of protection equivalent to that which you benefit from within the EEA. This transfer is governed by appropriate transfer mechanisms and by all necessary additional measures (particularly security) to provide an adequate level of protection. You can obtain a copy of the transfer mechanisms implemented (excluding their confidential provisions, if any) using the contact details provided in paragraph 8 below.

6. How long do we keep them?

We retain your personal data for as long as necessary to achieve the purposes for which it was collected and described in paragraph 3 above.

Purpose of processing	Retention period

Management of pre-contractual and contractual relationships, customer relationship follow-up and customer knowledge	Your data, as a customer, is retained for the duration of the contractual relationship (including during the period of guarantees attached to the products). For accounting purposes and/or in the event of litigation, your data may be retained for an additional 5 years with restricted access.

Management of commercial relations (including commercial prospecting)	Your data as a customer is retained for the duration of the commercial relationship with Clyda, then for a period of 3 years from the end of the commercial relationship or the last contact with Clyda from you, unless you object or withdraw your consent. Your data as a non-customer prospect may be retained for a period of 3 years from their collection or the last contact with Clyda from you, unless you object or withdraw your consent.


Identity document (VAT slip, request to exercise rights, etc.)	The identity document is kept for the time necessary to verify identity. The identity document is only kept beyond this period to meet a legal obligation or as proof.

Web customer account	The customer account without purchase (web) is deleted after 2 years of uninterrupted inactivity.



Study, survey, customer selection for segmentation purposes	Your data is kept for the time necessary to carry out studies and surveys, and to analyze the results of these studies and surveys, in order to create customer segments.

Management of complaints and requests to exercise rights	Your data is kept for the time necessary to process your complaint and/or your request to exercise rights, followed by a period of 5 years.
Data relating to payment card by credit card	This data is kept for: 13 months for an immediate debit card 15 months for a deferred debit card

However, we may be required to keep some of your personal data for a longer period than those indicated above, particularly if we are bound by a legal obligation or if this data is necessary to justify a right or a contract in the context of an ongoing dispute. Your personal data will then be archived for the applicable legal limitation period, or, in the event of an ongoing dispute, until the final closure of that dispute. Once the retention periods have expired, your personal data is deleted or anonymized (especially for statistical study purposes).

7. What are your rights?

You have the following rights regarding your personal data:

Access. You can ask us to confirm that we are processing your personal data and, if so, to inform you of the characteristics of the processing(s) of your personal data, access it and obtain a copy.
Rectification. You can ask us to rectify or complete your personal data if it is incorrect or incomplete.
Erasure. You can ask us to erase your personal data in the following cases: when it is no longer necessary for the purposes for which it was collected; when you have withdrawn your consent; following the exercise of your right to object; when your personal data has been unlawfully processed; or to comply with a legal obligation. In some cases, we may refuse to grant your request for erasure of your personal data, particularly if its processing is necessary to comply with a legal obligation or to establish, exercise or defend legal rights. You will then be informed of this.
Restriction. You can ask us to restrict the processing of your personal data (i.e., to keep it but not use it) in the following cases: its accuracy is contested; its processing is unlawful but you do not want it to be deleted; the data is no longer necessary for the data controller but is still necessary for the data subject to establish, exercise or defend legal rights; the data subject has objected to the processing and the data controller is examining whether there are legitimate and compelling reasons not to grant the objection. You will then be informed of this.
Portability. You can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format, or you can request that it be transmitted directly to another data controller, but this right can only be exercised if the processing is based on your consent or on the performance of a contract concluded with you and if the processing is carried out by automated means.
Withdrawal of consent. You can withdraw your consent to any processing of your personal data at any time, to the extent that it is based on your consent, without affecting the lawfulness of processing based on your consent and carried out before its withdrawal.
Digital Legacy. You have the right to define directives (general or specific) regarding the fate of the personal data we hold after your death.
Objection to the processing of personal data based on legitimate interest. You can object to any processing of your personal data based on our legitimate interest (cf. paragraph 3 above).
Bloctel. If you receive our commercial offers by email or SMS, you can request to unsubscribe by clicking on a dedicated link at the bottom of each communication (most often found in the legal notices). If you do not wish to be subject to commercial prospecting by telephone, you can register on a telemarketing opposition list on www.bloctel.gouv.fr

You also have the right to lodge a complaint regarding the processing of your personal data with the competent supervisory authority. In France, the competent supervisory authority is the Commission Nationale de l’Informatique et des Libertés or CNIL (www.cnil.fr). However, we invite you to contact us before any referral to the supervisory authority so that we can respond quickly to your request. You will find the contact details in the section below.

8. Contact

For any questions or complaints concerning your data, you can contact our Data Protection Officer at the following e-mail address: support@clyda.com

9. Update of the Personal Data Protection Policy

We reserve the right to modify this Policy, for example, to take into account developments in applicable regulations and/or legislation, technological advancements, and good commercial practices applicable to our activities. We will inform you directly of any change only if it is a substantial change likely to affect your orders and/or your current contracts with Clyda. We invite you to consult our Policy regularly on our Website.

Last updated: April 28 2026