Privacy Policy | The LifeSpace

PREAMBLE

This privacy policy (hereinafter: the "Privacy Policy") is intended to tell you what information we collect when you visit this website or other websites of our brand (hereinafter: the "Websites ”) whether or not you have a user account, and describe how we use this information. Where applicable, this Privacy Policy also describes how we treat any information you may provide to us or that we collect, when you visit our locations of operations, or in the context of any other contact we may have. This Privacy Policy is supplemental to any other information provided to you in the other circumstances described above.

These documents provide you with important information about the following:

1. Processing of your personal data

2. Personal Data We Collect

3. How we use your personal data

4. How we share your personal data

5. Children's Privacy

6. Storage, access and transfer of your personal data

7. Security and confidentiality of your personal data

8. Your rights in relation to your personal data – management of your choices

9. California Privacy Law

10. Retention of personal data

11. Our policy on cookies and similar processes

12. Links, Ads, Sponsors and Advertising

13. Controller - data protection officer - and how to contact us

14. Updating this policy – notice

CONSENT

By using this Website, its services or otherwise interacting with us, our Outlets, Stores and/or Websites, you acknowledge having read and understood this Privacy Policy and consent to our collection, use, store, transmit and disclose the personal data we collect through the Websites, Stores and/or Points of Sale in accordance with this Privacy Policy. Unless you already have a user account, we may ask you to expressly consent (for example by ticking a box) if we believe this is appropriate to safeguard your rights or if required by law. If you do not consent to this Privacy Policy, please do not visit this Website, create a user account and do not use or submit your personal data to this Website in any way, or do not expressly consent if this option is offered to you in accordance with applicable laws.

1. PROCESSING OF YOUR PERSONAL DATA

The term "Personal Data" within the meaning of this Privacy Policy means any information allowing us to identify you (or a third person whose data you communicate to us) directly or indirectly, including any data relating to purchases of goods or services. ; or that you choose to communicate to us or share with us, or with third parties, when you use the Website or visit one of our Points of Sale. We will process your personal data in accordance with the European General Data Protection Regulation 2016/679 “Reg. (EU) 2016/679” as well as in accordance with the laws applicable in the country in which your personal data is collected. We reserve the right to carry out additional data processing when required by law or when required in the context of a criminal case, investigation or procedure.

2. PERSONAL DATA WE COLLECT

2.1 Source of personal data

We only collect your personal data when you provide it to us voluntarily, such as:

Websites distributing our products: when you place an order through the Website(s) as a "visitor"; when you create or modify a user account; when you create a wish list; when you enter a contest, sweepstakes or promotion; when you search the Website(s); when you contact us and leave us a comment or question; when you sign up to receive the newsletter and updates on our latest products and services, our Store openings, our events or our promotions; or when you request to receive an order or shipment confirmation or other notification;

Our Boutiques and Outlets: when you fill out the possible request for a customer card, chat informally with our Boutiques or Outlets employees, interact with us or purchase merchandise;

Events: when you participate in our events, surveys or market research, contests, and other promotions, including online, for example, through mini-sites that we operate on third-party social networks such as Facebook;

Our customer service: when you request assistance, special service or after-sales service;

Emails, text messages and other electronic messages: any communication between you and us.

If you provide us with personal data of third parties (for example: members of your family, other of our customers or our potential customers), you must ensure that these third parties are informed and have authorized the use of personal data. about them as described in this Privacy Policy.

2.2 Type of personal data

We may collect and use different types of personal data, depending on the specific purpose and as described below:

personal information, such as first name, last name, gender, age/date of birth, country of origin, as well as any other personal information to the fullest extent permitted by law;
contact details, such as address, email, landline and mobile telephone number, fax number (if applicable) as well as any other contact details to the fullest extent permitted by law;
bank details, such as means of payment (credit card, debit card) if applicable, passport number when required for tax reasons or under applicable legal provisions on money laundering;
information regarding purchases made, such as date, products or services, place of purchase, item number, amount, total purchases, VAT number, complaints, returns, refunds and any other information to the fullest extent permitted by the law ;
habits and profiles, such as data relating to your purchases (purchase history, Store where the transaction took place, type, quantity and price of the products you have purchased), information relating to activity and offers related to customer relationship management (date, categories of actions performed or to be performed and result of these), purchasing habits and preferences (wish list, preferred product categories, colors, style, other brands purchased, countries most visited, how you know our brand, sizes, notes about your shopping habits or special requests you have made - for example: materials used), other information (information relating to your profession, education, hobbies and activities), to the fullest extent permitted by law; And
information relating to your family situation such as marital status, date of marriage, number of children, information relating to children and other family members, to the fullest extent permitted by law.

3. HOW WE USE YOUR PERSONAL DATA

Your personal data may be used for the following purposes, depending on the circumstances in which you interact with us.

3.1 For purchases made online or in our stores (in a Boutique or Point of Sale or on the online seller's website as identified in the general conditions relating to this site)

Your personal data, whether communicated by you or collected when you make a purchase, whether you are a visitor or have a user account, namely, your personal information, your contact details, data relating to your purchase, your tax data, your bank details, information relating to the sale as well as any other information strictly necessary for the delivery of the products, will be used for:

manage and process your purchase of our products, sales and after-sales services, for example, administrative activities, accounting, returns, guarantees, if applicable tax refunds, fraud prevention, communication with you, including by email, about any problems with order processing and any subsequent order inquiries;
to comply with obligations imposed by law, regulation or European laws (including anti-money laundering laws) and to establish or defend our rights in legal proceedings.

It is necessary that you provide us with your personal data for the purposes described above; in case of refusal, you will not be able to proceed with a purchase.

Unless otherwise provided by law, your personal data may be processed for the purposes listed above without having to request your consent, as long as this information is necessary to comply with contractual and legal obligations.

3.2 For specific reasons for which the data was provided voluntarily

Your personal data, whether communicated by you or collected when you request a specific service (for example, creation of a user account on our Websites, subsequent complaint of a delivery, request for information), for example personal information, your contact details, the data strictly necessary to follow up on your request, will be used to:

provide you with the requested service (for example, to create your user account, manage authentication on the website, manage your accounts, assist you, manage your complaints, manage your wish lists, respond to your questions or requests for contact that you have submitted to us, including through the after-sales service);
manage your subscription to the newsletter if you do not have a user account.

It is necessary that you provide us with your personal data for the purposes described above; in case of refusal, we will not be able to follow up on your request.

3.3 For Customer Relationship Management (hereinafter: “CRM”) purposes if you open a user account

Your personal data that you communicate to us by completing a form or that is collected when you visit one of our Boutiques, one of our Points of sale or on one of our Websites and interact with us , for example, your personal information, your contact details, data relating to your habits and your profile, your family situation, will be listed in our centralized CRM database for:

to offer you promotions, discounts and other personalized services, to send you newsletters and other advertising communications regarding our products and services, invitations to events relating to our brand (organized by us or by our distributors ), surveys and market research, invitations to participate in contests, sweepstakes and promotions as well as other offers for people with a user account or contacts of our brand ("marketing" ). We may use traditional means of communication (postal mail or telephone) and/or digital and automated means of communication (email, SMS, MMS, telephone and other digital means such as social networks) and we may send you these communications based on your profile, if you have consented to profiling (see article 3.3 below);
analyze your contacts with us, your areas of interest, your shopping preferences and habits and create individualized or aggregated profiles based on this information, to determine how to provide you with better service, including to provide you with a shopping experience personalized in all our Stores and Points of Sale in Italy and abroad (“profiling”). We may use your personal data to create groups and conduct market and statistical analysis to identify products and/or services that are of interest to our brand customers and to improve our services (including websites). We will combine your personal data collected through the Website with the information we may have obtained from your interactions with our sales staff in our Boutiques and/or our Points of sale. The processing of your personal data for profiling is carried out in accordance with the guarantees and measures provided for by applicable law.

The communication of your personal data for inclusion in the CRM system is optional and free (depending on your choice to participate) and only if you provide your personal data for both the marketing and profiling purposes described under figures 3.3 .a) and b), or for one of the two. You can unsubscribe or choose not to participate at any time (see article 8 below). If you refuse to provide your personal data for one or both of the CRM purposes described above, this will not in any way prevent you from using our services or making purchases, but we will not able to inform you about possible marketing initiatives or the holding of events as described above and we will also not be able to determine your centers of interest and offer you a personalized shopping experience.

4. HOW WE SHARE YOUR PERSONAL DATA

We share your personal data collected with our subsidiaries, distributors and franchisees, including those established in other countries, as well as with other companies that perform services on our behalf (as described below), whether either at our direction or that of a third party. We will only provide these companies and organizations with the personal data necessary to deliver the services and we will prohibit them from using your personal data for any other purpose.

4.1 Sharing with subcontractors

When you purchase our products or use our online sales service, your personal data may be shared by the seller of this Website with certain third parties who provide services to the seller, including those who prepare orders, send products, process credit and debit card payments and perform anti-fraud checks.

Your personal data may be shared with third parties to monitor and analyze Website activity, provide technical and organizational services for the above purposes, maintain our customer database, provide marketing assistance and manage emails, market research, surveys, contests, sweepstakes and promotions. These third parties may access, store and process your personal data to provide these services on our behalf and which may take place in Italy, your country or abroad. Our service providers are not permitted to use your personal data for any purpose other than to provide the services contracted between us and the service provider.

Our subsidiaries that operate our brand locally in Italy and in other countries or online and our business partners (franchisees, distributors) that operate Points of Sale or online sales on their websites will process your personal data for the purposes of CRM and on our instructions as a subcontractor.

4.2 Sharing with other third parties

Your personal data may need to be shared with companies providing payment services and anti-fraud controls and acting independently as data controllers, for the purpose of providing these online sales services.

In the event of an asset transfer or other similar transaction (for example, merger or acquisition, reorganization or liquidation), customer data will most likely be one of the transferred assets and we may share it with any of our legal successors, to the fullest extent permitted by law and in accordance with our legitimate interests. Unless otherwise agreed, your personal data will remain subject to any pre-existing privacy policies.

We may also disclose your personal data to third parties (i) pursuant to EU or Member State law (ii) in connection with legal proceedings; (iii) in response to a request from a public authority based on a legitimate basis; or (iv) to protect our rights, privacy, safety or property, or the public.

Additionally, to the fullest extent permitted by law, we may also disclose your personal data to third party sites to complain about your use of the Website and, where we believe it is necessary to investigate, prevent or take action with respect to illegal activity, suspected fraud or when we have reason to believe, in our sole discretion, that your use of the Website is inconsistent with the Website Terms of Use.

The full list of subcontractors engaged and third parties to whom your personal data is communicated can be obtained from the contact point below (article 13).

5. PROTECTION OF CHILDREN'S PRIVACY

This Website is a site intended for the general public; however, our services are intended for people who are at least 18 years old. We do not knowingly request or collect, use or disclose personal data submitted to us by persons under the age of 18, whether online or in our Boutiques and/or Points of Sale. If it becomes known to us that we have collected personal data from a child, we will delete it immediately.

If you are not 18 years old, please do not create a user account or make an online purchase and ask an adult (for example your parents or your legal representative) to carry out the necessary procedures.

6. STORAGE, ACCESSIBILITY AND TRANSFER OF PERSONAL DATA

Personal data collected through the Websites is mainly processed through electronic means, including web analytics services hosted by the servers of service providers selected by us both within the European Union and outside the European Union. In our Boutiques and Points of Sale, personal data may also be processed in paper form. In both cases, the personal data will only be used for CRM purposes in our centralized and secure database in Italy and will be managed by our Customer Service Manager and our marketing team in Italy and abroad.

Personal data will be accessed only to the extent necessary and under a tiered method of control, only by authorized employees of our Boutiques, Outlets and online vendors (e.g. employees of electronics departments and IT, marketing, sales, administration and security). These employees are subject to confidentiality obligations and are expressly appointed as the person in charge of processing, in accordance with the relevant legal provisions. In particular, if you consent to the processing of your personal data for CRM purposes, your personal data may be read, modified and updated by our employees and the employees of the Boutiques, Points of sale and/or online (in particular the sales and marketing staff). Employees are based in Italy or abroad, are trained and subject to confidentiality commitments. We may indeed use them to collect, use and disclose your personal data according to our instructions.

If we need to transfer your personal data abroad in order to achieve one of the purposes described in this Privacy Policy, including in countries where the data protection legislation differs from that in force in your country , we will take all necessary measures to ensure that these communications comply with European data protection standards, or any other standard of the country where we collect the data, so that the security and confidentiality of your personal data are ensured.

7. SECURITY AND PRIVACY OF YOUR PERSONAL DATA

We have put in place appropriate measures to guarantee the security of your personal data and to avoid any accidental loss as well as any improper access, use, destruction and disclosure of your personal data. For example, when you send us information about your order, we use Secure Socket Layer (SSL) technology, an encryption tool that ensures the security of information when you transmit it over the Internet. We also use firewalls, password systems, and other technologies and safeguards to ensure the proper functioning of this Website. Although we have implemented all the security measures described above, we would like to point out that 100% security is not possible. Therefore, when you transmit personal data, you do so at your own risk and, to the fullest extent permitted by law, we accept no liability for the disclosure of your personal data due to any error, omission or act unauthorized third party during or after the transmission of personal data. We recommend that you (i) periodically update your security software to ensure the protection of data you transmit over the Internet (for example, your anti-virus software) and that you verify that your electronic communications service provider has adopted appropriate security measures for the transmission of personal data via the Internet (for example, firewalls and anti-spam filters); (ii) keep confidential and not disclose to anyone, your username and password to access your user account; and (iii) change your password periodically.

In the implausible hypothesis in which we would be led to believe that the security of your personal data in our possession or in our sphere of control has or has been compromised, we will inform you of this in accordance with the legal requirements and according to the methods provided for by the law (by providing us with your email address, you consent to receive any notification in electronic form, by email).

8. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA – MANAGEMENT OF YOUR CHOICES

8.1 Your rights

You can, at any time and free of charge, access your personal data, receive your personal data in a structured, commonly used and machine-readable format, and transmit them to another controller (data portability), have them corrected, update, modify or remove your personal data (subject to exceptions). You can request that your personal data be updated by contacting us at one of the addresses listed below. Requests to delete your personal data are subject to compliance with the legal obligations regarding the retention of documents that are incumbent on us.

If you believe there is a problem with the way we process your personal data, you can lodge a complaint with your national data protection authority and/or any other competent data protection authority in the European Union or in the European Economic Area.

In order to exercise the above rights, you can send your request by sending an email to info@edvige-natali.be or by post to the address mentioned below (article 13). When you contact us, be sure to provide us with your name, email address, mailing address and/or telephone number(s) to ensure that we process your request correctly.

8.2 Accuracy – Updating your personal data

To enable us to better serve you, we encourage you to regularly review and update your personal data. If you have a user account, you can access and modify your personal data through your account settings on the Website; in other cases, you can contact us (see article 13 below) to assist you in updating your personal data.

8.3 Managing your choices in relation to marketing and profiling

If you wish to no longer participate in one of the CRM, marketing and/or profiling programs, or modify your preferences, you can simply send us your request or send it (see article 13), or modify your choices in your account. 'user. The same procedure applies if you wish to withdraw your consent to profiling.

9. CALIFORNIA PRIVACY LAW

According to California Civil Code Section 1798.83, California residents have the right to request from a business with which they have an established business relationship, certain information as to the type of personal data that is shared with third-party businesses for marketing purposes. as well as the identity of the third parties with whom the company shared this type of information during the previous calendar year. If you are a California resident and would like a copy of information that has been provided to third parties, please send us a written request. A response will be sent within thirty days.

10. CONSERVATION OF PERSONAL DATA

Personal data may be kept for the duration of the business relationship and as long as necessary for the purposes described in this Privacy Policy (for example, if you subscribe to the newsletter, for the duration of your subscription; if you have a user account, until you close said account). At the end of this period, your personal data will only be kept to comply with our legal and regulatory obligations (for example, ten years for accounting purposes; for the duration necessary from a tax point of view, etc.), or for us allow the preservation of evidence of our respective rights and obligations.

Your personal data processed in accordance with the CRM purposes (Article 3.3) will be retained until you close your user account or withdraw your consent to the processing of your personal data for this purpose. Personal data relating to the details of your purchases and processed for profiling and marketing purposes will be kept for a limited period in accordance with the maximum period authorized by law; at the end of this period, the personal data will be erased or anonymized permanently.

11. OUR COOKIES POLICY AND SIMILAR PROCESSES

Please see the “Cookies and Advertising Management” section of the edvige-natali/cookie-policy Website for more information about cookies and how to disable and enable them.

12. LINKS, ADVERTISERS, SPONSORS AND ADVERTISING

This Website may contain links to various Websites owned or controlled by us, as well as links to third-party websites. If you choose to submit your personal data to one of the linked websites, such information will be subject to the privacy policy as well as the security rules of the website in question – including Websites operated and managed by one of our authorized distributors, except for personal data collected by our distributors for CRM purposes and where our Privacy Policy is posted - and will not be subject to this Privacy Policy. It is your responsibility to read these other privacy policies, as we are not responsible for and have no control over the personal data submitted to them, collected, used, disclosed or otherwise processed by them. third-party websites.

13. RESPONSIBLE FOR PROCESSING, DELEGATE FOR DATA PROTECTION – AND HOW TO CONTACT US

For the purposes of this Privacy Policy and the processing of personal data described therein, "we", "our" and "Company" means AT FIVE S.r.l. with registered office at 875, chaussée de Marche BE5100 Wierde. As the holding company and ultimate owner of various brands through its subsidiaries, the Company is the controller (as defined by Reg. (EU) 2016/679) of all personal data collected in the Stores, Points of sales and/or through the Websites, in Italy and abroad for the CRM purposes described in articles 3.2 and 3.3 above. The Company has appointed a Data Protection Officer to whom questions can be addressed and who can receive complaints regarding the processing of personal data for CRM purposes. The Data Protection Officer can be contacted at the following address: 875, chaussée de Marche BE5100 Wierde e-mail: info@edvige-natali.be.

The person responsible for processing personal data collected in the Boutiques, Points of Sale and/or on the Website for the sales purposes described in Article 3.1. is the Boutique, Point of Sale or online store where you made your purchase and/or which collected your personal data. The local seller may be required to process your personal data in accordance with the rules applicable in the country in which it is headquartered. However, unless otherwise provided, the local seller undertakes to process your personal data in accordance with the principles set out in this Privacy Policy.

14. UPDATE OF THIS PRIVACY POLICY – NOTICE

We reserve the right, at our sole discretion, to change, modify, add or remove portions of this Privacy Policy at any time, by posting a revised Privacy Policy on this page of the Website and updating the date appearing in the “Last modified” notice below. It is your responsibility to review this Privacy Policy from time to time and take note of any changes we have made to it. In some cases, we may provide you with additional notices of material changes to this Privacy Policy by posting a notice on the home page of this Website or, for those with a user account, by sending them an email notification or adding a statement to their account. By accepting the modified version of the Privacy Policy by clicking on the "I accept" button in the email or on your user account page (which will be made available to users when required by law) , or making a purchase on the Website or at any Boutique or Outlet after the revision of this Privacy Policy, or otherwise submitting your personal data on the Website after the revised version of the Privacy Policy has been posted, you accept the new content of the Privacy Policy. Following the changes to the Privacy Policy and to the extent required by law, the processing of your personal data will not be carried out without your explicit consent.

For any previous version of this Privacy Policy, please send a request to the email address info@edvige-natali.be

LAST MODIFICATION

This privacy policy comes into effect on May 25, 2018.