We aim to protect the privacy of all our users (“User”), so please read and approve our privacy policy.
This information note (“Privacy Policy”) issued pursuant to Regulation UE 679/2016 (“GDPR”) aims to provide Users navigating www.follifollie.it (the “Website”) with the information on how their personal data is managed and to allow them to provide their express and aware consent to the processing of their personal data entered in the Website or provided by them in any other way. All personal data sent by the User (name, surname, e-mail address, telephone number, etc.) is acquired, saved and processed exclusively in conformity with GDPR. The Privacy Policy is issued only for this Website and not for any other websites the User may consult via any links.
When accessing and using the Website, the User acknowledges that he has carefully read this Privacy Policy and accepts the purposes and methods of processing described herein. If the User does not accept what stated in this Privacy Policy, he is invited to leave the Website and, in any case, not use any of its contents or services.
Processing of personal data refers to “any operation or set of operations carried out also without the use of electronic instruments, concerning the collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blockage, communication, dissemination, cancellation and destruction of data, even where not recorded in a database”.
DATA CONTROLLER
The personal data provided or collected through the activities done by the Users on the Website will be processed by FF NET s.r.l., with registered office in Via Chiassi 103, 46100, Mantova (MN), Italy (hereinafter, the “Company”), as Data Controller.
CATEGORIES OF PERSONAL DATA CONCERNED
Navigation data: the hardware and software of the Website acquire some personal data which is transmitted implicitly during the use of Internet communication protocols. This information could, if processed and associated to data held by third parties, lead to the identification of the Users. This category of data includes the IP addresses used by the Users when connecting to the website, the time of the request, the method used in submitting the request to the server, the size of the file obtained in reply, the numerical code indicating the state of the reply given by the server (OK, error, etc.) and other parameters concerning the operating system and computer environment of the User. This data is used only for anonymous statistical information concerning the use of the website and to check the correct operation and is cancelled immediately after processing. Data may be used to ascertain responsibility in the case of hypothetical data processing crimes to the detriment of the website: apart from this case, the web contact data is currently not kept for more than seven days. Personal data related to the geographical location may be used to provide Users with information, proposals and other customized contents based on their location. If Users do not want to share information related to their geographical position, they will have to disable location services on their devices.
Data provided voluntarily by the user: the personal data entered into the Website by the User and the data sent by the User by e-mails to the addresses indicated in the Website (including the sender’s e-mail address and any other personal data contained in the e-mail).
Cookies: both proprietary cookies and third-party cookies will be used by the Website for profiling users and for faster navigation of the Website. By using the Website, you accept the use of cookies. See the full cookie information notice.
PURPOSES OF THE PROCESSING
The Company processes the personal data for the following purpose (the “Purpose”):
to create a database of Users interested in the Website and in the services offered by the Website;
to manage the requests of the Users: of technical or commercial nature or of others kind;
to manage the selection procedures and to contact the candidates who submit their applications through the “Work with us” section of the Site;
upon express consent of User, for marketing purposes, for instance to send the newsletter and/or other promotional messages by e-mail;
upon express consent of the User, to collect and use the data for profiling purposes or to analyze preferences aimed at creating personalized content and offers;
to comply with legal obligations (including those of a fiscal nature) and to protect their rights.
LAWFULNESS OF PROCESSING
The Company treats personal data based on the following grounds:
for the performance of a contract to which the User is party or in order to take steps at the request of the User to entering into a contract, pursuant to art. 6, letter b) of the GDPR;
for compliance with a legal obligation to which the Company is subject, pursuant to art. 6, letter c) of the GDPR;
for the purposes of the legitimate interests pursued by the Company, pursuant to art. 6, letter f) of the GDPR;
upon express consent of the User, pursuant to art. 6, letter a) of the GDPR, for marketing and profiling purposes.
METHODS AND PLACE OF DATA PROCESSING
The personal data is processed using automated tools for the time strictly necessary to achieve the Purpose for which it was gathered.
The Company has adopted specific security and technical measures to grant the security of data and to prevent the loss of data, unlawful or improper use and unauthorized access.
The web services of the Website will be processed on the servers of outsourced companies offering hosting services on behalf of the Company, as well as clouds.
In the event of data transfers outside the European Union, these transfers will take place by guaranteeing adequate levels of protection of your personal data, also in accordance with the provisions of articles 45 and 46 of the GDPR.
COMMUNICATION OF DATA TO THIRD PARTIES
The personal data collected and stored in the databases of the Company will be processed by the employees and/or collaborators of the Data Controller (as well as by the employees of the companies that manage all the stores on behalf of the Data Controller) appointed to process such data.
Users personal data may be processed also by third parties the Company may use for certain activities (e.g. to analyze data, to store data, sending newsletter or other commercial and non-commercial communications, providing marketing assistance; market analysis purposes, to delivery of the purchased goods, to manage the platform for credit card payments and other customer services).
The Company provides these subjects only with the personal data necessary to carry out the agreed activities and they have been appointed “Data Processors” by the Data Controller. Third parties who perform these operations have been selected and are considered to have the experience, capacity and reliability to grant a fully compliance with the current provisions on data processing. The User may request the list of Data Processors by writing to privacy@follifollie.it.
Regarding the communication of personal data, the information issued may be disclosed to the following subjects or categories of subjects: (i) public administrations to meet statutory obligations, regulations or Eu laws; (ii) holding companies, associate companies or subsidiaries of the Company; (iii) other companies or individuals contractually bounded to the Company and appointed specifically to process the personal data of Users.
NON-MANDATORY NATURE OF THE PROVISION OF DATA
Some fields requested on the Website (which may be marked by an asterisk or other symbol) may be mandatory to process any requests.
Entering his personal data on the Website, the User ensures that his personal information is corrected and updated. The User acknowledges to be the sole responsible for the data provided, be they personal, photos, comments or other, releasing from liability the Company.
The provision of data that the Company could deal with for marketing and profiling purposes is absolutely optional. Failure to agree to the processing of data for these purposes or its subsequent withdrawal of consent does not prevent the ability to surf the Website and to make purchases through the same.
Even the provision of data for sending spontaneous applications is optional, but any failure to provide it would make it impossible for the Company to evaluate your profile or to schedule interviews.
WITHDRAWAL OF CONSENT
At any time, the User may object to the processing of data for marketing and profiling purposes (including sending newsletters) or profiling by the Company by sending an email to privacy@follifollie.it.
The withdrawal of consent does not affect the lawfulness of the treatment based on consent before the revocation.
CHILDREN
The newsletter service is not directed to children under the age of 16. Furthermore, the service is not offered to children whose age makes the processing of their personal data illegal or requires parental consent for the processing of the same in accordance with other local laws. The Company do not knowingly collect personal information from children under 16 (the “Age Limit”). If you are under the Age Limit, do not use the newsletter service and do not provide any personal information to us. If you are a parent of a child under the Age Limit and become aware that your child has provided personal information to Folli Follie, please contact us at privacy@follifollie.it; we also remind you that it is possible to exercise the rights described in section 12 “Rights of the interested parties” of this Policy.
If the Company becomes aware that it has collected the personal data of a child under the age of 16, it will take reasonable measures to delete the personal data.
DATA RETENTION PERIOD
Personal data is stored by the Company for a limited period of time necessary for the purposes of each treatment indicated above. At the end of this period, the data will be deleted or made anonymous.
Personal data processed for the fulfillment of contractual commitments, including pre-contractual activity, is stored by the Company for 10 years from the performance of the contractual service or, in the event of non-conclusion of the contract, for the time necessary to respond to the requests of the User.
Personal data processed for accounting management and for invoicing is stored by the Company for the time necessary to fulfill the fiscal obligations and for keeping accounting records.
The e-mail address collected for subscription to the newsletter is stored by the Company until the User’s withdrawal of consent.
The Personal Data supplied through the “Work with us” section is kept for the time required to evaluate the application sent but, in any case, not longer than 18 months from the date in which the said application was sent.
RIGHTS OF THE DATA SUBJECT
The parties to which the personal data refers can exercise the rights provided by the legislation on the protection of personal data (according to the provisions of articles 15 to 22 of the GDPR), including the right:
to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and to know the origin, the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom personal data have been or will be disclosed also in third countries, the time of conservation;
to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her;
to obtain Data controller to erase personal data without undue delay in the cases of art. 17 GDPR;
to obtain from the Data Controller restriction of processing if the accuracy of the personal data is contested or the processing is unlawful or in other conditions listed in art. 18 GDPR;
to receive the personal data concerning him or her, which he or she has provided to the Data Controller, in a structured, commonly used format under art. 20 GDPR;
to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her.
Above mention requests should be sent: by e-mail, to: privacy@follifollie.it, or by post to FF Net s.r.l. Via Chiassi 103, 46100, Mantua (MN), Italy.
Requests relating to the exercise of rights will be processed without undue delay and, in any case, within one month of the request; only in cases of particular complexity and in the number of requests can this term be extended by a further two months.
FINAL CONSIDERATIONS
This privacy policy may be subject to updates. Version of April 6, 2020.