1. Who collect your Personal Data
Subject who collect and process the Personal Data, as data controller (hereinafter “Data Controller” or “Controller”) is PC Srl S.r.l., with registered offices in Italy, via Borgogna 3, Milano, telephone +39 02 83428152, email email@example.com .
In order to fulfill technical issues connected to the Site Data Controller has appointed some data processors (hereinafter collectively “Processors”) that process data on our behalf. These subjects were appointed because of their technical skills related to purposes and modalities of the processing, guarantees offered in relation to security measures adopted and in compliance to applicable data protection laws. These subjects are under our control and you could request a full list writing an email to firstname.lastname@example.org.
Data Controller appointed also the following data processor that could process the Personal Data on its behalf (hereinafter collectively “Data Processor”):
- FARFETCH UK Limited with addresses 211 Old St, London EC1V 9NR
Data Processor may disclose your Personal Data to any of our affiliates, or to our agents or contractors who assist us in providing the services we offer through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time.
Data Processor subcontracted the operation of certain aspects of the Site to Black & White, a trading division of Farfetch UK Limited (company number 06400760, VAT number GB 204 0769 35) (Farfetch). Services provided or procured by Farfetch include, but are not limited to, payment processing, customer service, hosting and delivery logistics. Our agents and contractors will only use your information to the extent necessary to perform their functions.”
2. Why we collect your Personal Data
The information systems and software procedures relied upon to operate the Site acquire, as part of their standard functioning, personal data as part of the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected in order to relate it to identified data subjects, however it might allow user identification per se after being processed and matched with data held by third parties.
The Personal Data includes: IP addresses and/or the domain names of the computers used by any user connecting with this website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), other parameters related to the user's operating system and computer environment, data related to browsing behavior of the user on the Site, information about pages that have been visited or searched, in order to select and return specific advertisements to the user of the Site, for example, using cookies, in respect of which you will find complete information here.
In the processing of Personal Data that may directly or indirectly identify your person, we try to respect a principle of strict necessity. For this reason, we configured the Site in such a way that the use of Personal Data is reduce to a minimum and to limit the processing of Personal Data that could identify the data subject only when needed or at the request of the authorities and the police (as, for example, for traffic data and the time you spend on the Site or your IP address) or for the assessment of responsibility in case of hypothetical crimes against the Site.
Some Personal Data are strictly necessary to operate the Site, others are used only to obtain anonymous statistical information about the Site and to check its correct functioning and are deleted immediately after processing. From time to time you will be informed about obligation or optional nature of the communication of Personal Data and possible consequences.
3. How we will use your Personal Data
Your Personal Data will be processed using automated tools for the time necessary to fulfill the purposes for which such data was collected and in compliance with the principle of necessity and proportionality, avoiding to process the Personal Data where operations could be realized through the use of anonymous data or through other means.
Specific security measures are applied to prevent the loss of the Personal Data, illegal or improper utilization and unauthorized access, but please do not forget that it is essential for the safety of your data that your device is equipped with tools such as constantly antivirus updated and that your internet provider provides a connection ensuring a secure data transmission through firewalls, spam filters, and similar measures.
Your Personal Data may be transferred to, and stored at a destination outside of the European Economic Area including the US. The US and other non-EEA countries do not have similar data protection laws to the EEA, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from Europe. Data Controller will take all reasonable steps to ensure that your privacy rights continue to be protected consistent with our obligations under local law. By submitting information via the Site, you agree to this storing, processing and/or transfer.
4. Who will use your Personal Data
Controller will process your personal data for the technical administration of the website. Your data will be processed by employees and collaborators of Controller appointed as persons in charge of the processing and data processors. Regarding the processing of data performed through the website, Controller has appointed as data processor the company that performs the technical management and maintenance of the website.
Other information regarding the sphere of communication and dissemination of your personal data shall be provided to you in specific areas of the website.
5. Your rights
You may at any time obtain cancellation, conversion into anonymous form, copy, update, adjustment or integration, block of data processed in infringement of the law and oppose the processing as envisaged by Article 7 of Legislative Decree n.196/2003, which is shown in full below.
You will have the right to object in any case to any processing of your Personal Data for purposes of commercial information and marketing, and to oppose for legitimate reasons of the processing of your data for other purposes.
In order to exercise your rights, you may contact the address below or send an e-mail to email@example.com
We wish to inform you comprehensively and transparently about the processing that our company could carry on your personal data provided and/or collected during various contacts that you could have with us, by visiting our website www.paulacademartori.com (hereinafter the “Site”) and/or other websites related to us during the time, during the visit in our stores, by downloading and using our Apps, participating in prize contests, Wi-Fi systems in stores, social networks (hereinafter collectively, “Personal Data”).
Your privacy is extremely important for us and we kindly invite you to read the following information notice. By submitting your Personal Data you may enjoy the advantages and benefits reserved exclusively to our registered clients (subject to availability in your Country/Region), and we offer to those who love our products, that visit our online store or our stores in the world or that use our App or other online services.
1. Who collect the Personal Data
Subjects who collect and process the Personal Data, as Data Controller (hereinafter “Data Controllers” or “Controllers”) are:
- OTB S.p.A., with registered offices in Italy, Breganze (Vi), Via dell'Industria 2, 36042, telephone +390445306555, email firstname.lastname@example.org, for marketing and profiling purposes;
- PC Srl S.r.l., with registered offices in Italy, via Borgogna 3, Milano, telephone +39 02 83428152, email email@example.com, for marketing and profiling purposes and, in case of purchase through the Site, also for administrative and accounting purposes.
Data Controllers appointed also the following data processors that could process the Personal Data on their behalf (hereinafter collectively “Data Processors”):
FARFETCH with addresses 211 Old St, London EC1V 9NR.
2. Why we collect the Personal Data
Personal Data will be processed for the following purposes:
- a. administrative and accounting purposes: execution of sales contract, accounting and fulfillment of legal obligations, after-sales services. The legal basis for this data processing is: execution of a contract of which you are a part. The Data collected for this purpose will be kept for the entire duration of the contractual relationship and for 10 years after the termination of the same.
- b. subject to your consent, for marketing purposes: dispatch of advertising material or direct sales material, market research, commercial communication even customized with automated systems (e-mail, other communication systems via communication networks such as, by way of example but not limited to: SMS, MMS, Whatsapp, WeChat, etc.) and traditional (paper mail) contact methods, and offering of personalized sales services at Data Controllers stores worldwide. The legal basis for this data processing is: your consent. The Data collected for this purpose will be retained until the withdrawal of your consent.
- c. subject to your consent, for profiling purposes, that is analysis of your consumer choices consistent in automated processing of the Personal Data included data relating to purchases details in stores and websites of Data Controllers worldwide. This processing is finalized to predict your purchase preferences and to create clients profiles. The legal basis for this data processing is: your consent. The Data collected for this purpose will be retained until the withdrawal of your consent.
For the purposes of letter a., Data Controllers could collect and process the following Personal Data:
- personal information: first name, middle name, surname, name and surname in the local alphabet, occupation, nationality;
- during your visit in stores we will ask you, address of residence, city of residence, province of residence/state of residence, Country/Region of residence, zip code, email address, phone number, mobile number, during a visit on online store we could collect shipping and invoicing address, method of delivery and payment, name of the holder of the credit card and expiration, requests made to customer service, building/apartment, preferred language, preferred contact method, additional addresses, secondary email, secondary phones, contact method(s) that the customer does not want to be used.
In addition to the Personal Data listed above, for the purposes of letters b. and c., Data Controllers could collect and process also the following Personal Data related to your profile and preferences:
- data collected during your visit in stores included use of Wi-Fi system: birthday, alleged age group, date of birth, in certain Country/Region Wechat ID, gender, method and date of registration, preferences on store and sales assistant, language, categories of preferred products, mode of use of services, preferences about the services marked in stores, redemption campaign, attendance events, products brought into the dressing room but not purchased, preferred language, other brands purchased by customer, individual customer style, type of interaction with the customer, collection preferences, customized clientelling, notes, detail of individual contact initiatives of stores/dealers,
- data concerning purchases made online and in stores: detail of the products purchased, size, price, discount, units, color, fit, model, collection, level of expenditure calculated, abandoned shopping cart, tax / VAT code or VAT exemption, passport number, Global Blue membership number, transaction address, notes related to the discount on a personal basis, purchase channel, purchase frequency, purchase preference (discount / full price), preferred season labels (first / second half);
- data regarding participation in prize contests;
- data collected during navigation or during online store purchases or the use of Apps: data related to browsing behavior and/or use held on Data Controllers websites by using, for example, cookies or information about pages that have been visited or searched or related to wishlist.
3. What happened if you do not provide the Personal Data
Some Personal Data that we will point out during the registration procedure or purchase are required in order to execute the purchase and to pursue the administrative and accounting purposes (letter a. of the Paragraph 2).
Providing and processing of Personal Data for profiling and marketing purposes (letters b. and c. of paragraph 2) is optional and therefore their inclusion in our Customer Relationship Management (CRM) systems that allow the processing of the Personal Data for marketing and profiling purposes will take place only with your consent.
You may at any time revoke your consent to the profiling and/or marketing purposes (letters b. and c. of Paragraph 2) contacting individually Data Controllers to the addresses above mentioned. Failing to provide the Personal Data and/or withhold your consent preclude the pursuit of profiling and marketing purposes but will not have any effect on your ability to finalize your purchases.
4. How we will process the Personal Data
The Personal Data provided and/or collected by Data Controllers will be processed and stored by automated tools and, in some cases, they will be processed and stored on paper. In particular, Personal Data processed for profiling and marketing purposes will be stored in the CRM systems that allow the processing of Personal Data for marketing and profiling purposes of Data Controllers and/or Data Processors whose server is located in United States of America. You acknowledge that the Personal Data is being transferred abroad, also outside European Union, and may become accessible to governments under a lawful order made in that country/region.
The Personal Data collected for administrative and accounting purposes (paragraph 2, letter a.) shall be stored for the time necessary to perform the contract, or the provision of legal warranties in accordance with the terms of the retention required by the applicable law. The Personal Data collected for marketing and profiling purposes (paragraph 2, letters b. and/or c.) will be stored until the client asks to revoke the registration or the consent to the processing of the Personal Data.
On expiry of the retention terms indicated above, the Personal Data will be automatically erased or made permanently and irreversibly anonymous.
5. Who will process the Personal Data
The Personal Data will be processed by:
- employees and associates of the Data Controllers designated as persons in charge of the processing;
- employees and associates of the Data Processors designated by Data Controllers including (i) subjects that manage the traditional or online stores and that may view, edit and update the Personal Data entered into the CRM systems by which the Data Controllers process for marketing and profiling purposes (ii) subjects that manage storing of the Personal Data on behalf of the Data Controllers in accordance to local agreements and laws;
- third party members in or outside the EU, Data Processors, used by the Data Controllers in particular for acquisition services and data entry of Personal Data, shipping, distribution of promotional material, after sales support, market research, management and maintenance of the CRM systems by which the Data Controllers process for marketing and profiling purposes and others Data Controllers IT systems.
6. Your rights
According to Chapter III of Regulation (EU) 2016/679 and other local applicable data protection laws (see details below related to your Country), you can at any time request information on personal data collected, used, disclosed or processed by the Data Controllers (right of access), as well as request for integration, rectification or erasure and object to their processing. Furthermore, starting from 25th of May 2018 (when Regulation (EU) 2016/679 shall apply), you will be able to exercise also the following rights: restriction of processing, data portability and lodge a complaint with a supervisory authority.
In particular, you have the right to object and withdraw your consent, in whole or in part, to the collection, use, disclosure or processing of your personal data for purposes of dispatch of advertising material, direct selling or for the fulfillment of market surveys or commercial communication both automated (e-mail, other systems of distance communication as, by way of example: SMS, MMS, Whatsapp, WeChat, etc.) and traditional (paper mail).
If you prefer that the processing of your personal data is carried out solely by means of traditional contact methods, you may object to the processing of your personal data by means of automated contact methods.
The Data Protection Officer of Controllers is available at the email address firstname.lastname@example.org