WHO COLLECT YOUR PERSONAL DATA
Subject who collect and process the Personal Data, as data controllers (hereinafter “Data Controllers” or “Controllers”) are:
– AAA/UNBRANDED Ltd. company with registered offices in 20-22 Wenlock Road, N1 7GU, London, for administrative and accounting purposes, contact: email@example.com
– for marketing and profiling purposes, contact: firstname.lastname@example.org
In order to fulfill technical issues connected to the Site, we (Data Controllers) have 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: email@example.com
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 are 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.
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.
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.
WHO WILL USE YOUR PERSONAL DATA
Controllers will process your personal data for the technical administration of the website. Your data will be processed by employees and collaborators of Controllers appointed as persons in charge of the processing and data processors.
Other information regarding the sphere of communication and dissemination of your personal data shall be provided to you in specific areas of the website.
You may at any time obtain cancellation, conversion into anonymous form, copy, update, adjustment or integration, block of data processed.
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 firstname.lastname@example.org
1. A data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form.
2. A data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of the processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification data concerning data controller, data processors and the representative designated as per Section 5(2);
e) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
A data subject shall have the right to obtain:
a) updating, rectification or, where interested therein, integration of the data;
b) erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. A data subject shall have the right to object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
b) to the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.
INFORMATION ON PRIVACY
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.aaaunbranded.com (hereinafter the “Site”).
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), 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.
WHO COLLECT THE PERSONAL DATA
Subjects who collect and process the Personal Data, as data controller (hereinafter “Data Controllers” or “Controllers”) is:
– AAA/UNBRANDED Ltd. Corporation with registered offices in 20-22 Wenlock Road, N1 7GU, London, please contact our Customer Care, for administrative and accounting purposes of the online sales only.
Data controllers appointed also the following data processors that could process the Personal Data on their behalf (hereinafter collectively “Data processors”): AAA/UNBRANDED Ltd. Corporation with addresses and email above indicated.
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. 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. 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 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 concerning purchases made online: 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.
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.
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 Kingdom. 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.
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.
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.
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 the Regulation EU 2016/679 will 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 is available at the email address email@example.com