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FURLA.COM PRIVACY NOTICE

This notice explains how Furla S.p.A., a company incorporated under Italian law, with registered office at Via Bellaria 3/5, 40068 San Lazzaro di Savena (“Furla”), processes the data it collects from users of the “Furla.com” website (the “Website”), in accordance with applicable privacy laws (“Privacy Laws”).

a)     types of data collection

Furla collects data from users of the Website in two principal ways. First, it collects personal data provided when users register on the Website, such as name, address, telephone number, and e-mail address, which is retained in the registered user’s Website Account. Second, Furla collects data automatically when a user (registered or not) visits the Website, by using tracking technologies such as “cookies” (for information on data collection through cookies, please see our Cookies Policy. The automatically collected data generally is not identifiable to the user, and as such is not protected by data privacy laws. The personal data collected from you when you register or otherwise provide personally identifying information through the Website is so protected, and your rights under basic privacy laws are set forth in paragraph f) below.

b)     data controller

Furla will process personal data of users registered to the Website, as autonomous data controller, for marketing and profiling purposes (please see paragraph c points iii and iv below). The e-commerce services (online sales) offered through furla.com are managed by Furla in cooperation with Digital River, Furla’s resale agent, which jointly acts with Furla as data controller of data regarding online purchases. Specifically: (i) Digital River oversees the management of all purchase steps on the Website, including payment and user registration; (ii) Furla oversees shipping, delivery, management of returns and after-sale support. The data you provide to purchase online, such as your credit card details, will be processed exclusively by Digital River. Digital River’s privacy policy is available here.

c)     purposes and methods of processing

Furla processes the personal data collected from users when they register and during their browsing and use of the Website for the following purposes:

  1. to fulfil Furla’s legal obligations, and other obligations arising from instructions received from authorities;
  2. to fulfil, together with Digital River, obligations strictly connected to the use of, and instrumental to enable use of, the Website (for example registration on the Website), as well as to manage the contractual relationship, and for purposes of registered users’ purchase of products and accessories online, and any subsequent after-sale assistance;
  3. to carry out marketing, through promotions relating to Furla, Furla’s group local affiliates, Furla’s partners, and Furla’s products and services, whether by electronic means, by email and post, or by telephone, SMS text messaging or Social Media, or by sending newsletters (for example, to be updated on Furla’s new products and to find out about events, contests, demonstrations, loyalty programmes etc. organised by Furla). Such communications will relate to products and services of the fashion, luxury goods and the like. If you prefer to receive marketing communications by traditional means only (i.e., by post or non-automated telephone calls), please write to privacy@furla.com. In addition, Furla will process the personal data you provide through your registration on the Website; your order data; your purchase data (which includes location, date and time of purchase, delivery data, product and payment data); your data concerning your hobbies, job, interests; and data about your online browsing history, for market research, statistical analyses or other research to improve its products, and customer satisfaction analysis; and
  4. to analyse consumer habits on Furla’s retail channels (e-store and brick and mortar stores), for example, in relation to purchased products, viewed products, stores where purchases were made, etc., in order to send commercial communications that are in line with the users’ interests.

The data may be processed either electronically or in hard copy form, both within and outside the European Union (where Furla is located), but regardless of its form, the data will be protected by appropriate safety systems, which are periodically updated and maintained in accordance with applicable Privacy Laws.

Furla uses reasonable organizational, technical and administrative measures to help protect against the loss, misuse and alteration of the personal information under our control. However, no data transmission over the Internet or data storage system can be guaranteed to be 100 percent secure, so please do not send us information you consider confidential via e-mail. It is your personal responsibility to secure your own copies of your passwords and related access codes for our online resources.

The data will be kept for a period not exceeding that necessary for the purposes for which they were collected, after which they will be destroyed or rendered unusable.

Cookies

Furla.com website uses cookies. For more information please consult our Cookies Policy.

d)     Mandatory vs. optional data and consequences of not providing data

In order to register and purchase products through the Website, you must provide the data to complete the Registration Form. If you fail to provide such data, you will be unable to purchase products online or use any additional services that Furla offers to registered users.

As a user of the Website, you are deemed to consent to the use and disclosure of your personal data for the purposes set out under points c) (i) and (ii) above. Providing data for the purposes set out under points c) (iii) (marketing purpose) and (iv) (profiling purpose) is optional. Refusal to provide the data for these purposes will not have any negative consequences for you.

e)     entities and categories of entities to which personal data may be disclosed or which may become aware of the data as data processors or persons in charge of processing; scope of dissemination of the data

The data collected from you through the Website will be processed by Furla staff designated for that purpose, as well as by Furla (including Furla S.p.A. affiliated companies) and Digital River data processors, in order to carry out the activities for which the data was collected (for example to execute online purchase orders). The data may be processed by third parties carrying out activities connected with or instrumental to Furla’s activities, as independent controllers or data processors (the “Processors”) appointed by Furla. Such third parties may, for example, be providers of electronic communications services, banks, financial intermediaries, credit institutions, other financing entities, centralised information system operators (web platform operators, hosting service operators, anti-fraud or risk centres, etc.), insurance companies, consultants and self-employed professionals assisting Furla in credit collection and dispute management, companies that perform packaging, shipping and/or delivery or direct mailing services, research entities and companies, associations, or non-profit foundations. A complete and updated list of persons appointed as Processors is available at Furla’s registered office, and you may request a copy by writing to privacy@furla.com.

If you consent to the processing of your personal data for the purposes above, your personal data collected through the Website will be automatically accessible to Furla sales staff based at Furla’s points of sale worldwide.

Given the global nature of this programme, some of the affiliated companies and partners of Furla who act as Processors on behalf of Furla and in this capacity receive access to your data are established in countries outside the European Union (“EU”) and the European Economic Area and, therefore, may not provide for a data protection level as established in the EU. However, your data will be protected by adequate safety systems (e.g., Processors outside the EU have signed the model clauses approved by the EU Commission), which are continuously updated and maintained for data security protection purposes.

Furla does not share Website users’ personal data with unaffiliated third parties for those parties’ own marketing purposes.

f)        data subject rights

You have rights regarding your personal data, including the rights to do the following:

  1. to receive details of the source of the data, the purposes and methods of the processing, the logic applied to the processing, or if the latter is carried out with the help of electronic means; of the identity of data controller and data processors, the entities or categories of entity to which the data may be communicated and which may become aware of the data;
  2. to update, correct, supplement, or delete the data, to block or render anonymous data that have been processed unlawfully, including data whose retention is unnecessary for the purpose for which such data have been collected or subsequently processed; to certify that the operations requested have been completed, as also related to their contents, to the entities to which the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected; and
  3. to object, on legitimate grounds, to the processing of data, despite the data being relevant to the purposes for which they were collected or to object, also partially (e.g. only in relation to certain communication means), to the data being processed in order to send advertising materials or for direct sales, or market research, or commercial information, profiling purposes, or to receive communications by traditional means only.

To exercise any of these rights, please send to Furla, at the address provided above, a registered letter with return receipt, or email privacy@furla.com.