PRIVACY NOTICE FOR CLIENTS PURCHASING PRODUCTS AT THE LOCAL STORE OR THROUGH THE LOCAL ONLINE CHANNELS
Last Updated: October 8th, 2019
a) When are personal data collected?
Your personal data may be collected if you purchase Furla products or services, as a registered client, at a point of sales located in Canada (the “Furla Local Point of Sales”) or through the Furla website or any social media regarding Furla and available in Canada (the “Furla Local Online Channels”). Furthermore we inform you that, if you visit Furla websites, the parent company of Furla Group, Furla S.p.A., may also process your personal data regarding your online browsing history collected during your visits at the website (whether you are registered client or not), by using tracking technologies such as “cookies” (for information on data collection through cookies, please see Furla here).
In addition, personal information provided in your emails, correspondence, texts or other communications with Furla Affiliate may be collected, maintained and utilized in accordance with this Policy.
If you register as a My Furla Client, your personal data will be collected and processed in accordance with Furla’s global Privacy Notice available here here.
b) who controls your personal data?
Furla Affiliate will process your personal data, as a data controller, to manage your purchase of Furla products, including for the provision of any related service such as shipping, delivery, management of returns and after-sale support.
c) Which personal data do we collect and for which purposes and under which legal basis do we process the personal data collected?
The purposes for which we use and disclose your personal data will depend on the circumstances in which we collect it. Whenever practical we endeavor to inform you why we are collecting your personal data, how we intend to use that data and to whom we intend to disclose it at the time we collect your personal data.
We may use or disclose your personal data for the purposes for which we collected it (and related purposes which would be reasonably expected by you), for other purposes to which you have consented, and as otherwise permitted or required by Privacy Laws.
In general, we collect, use and disclose your personal data so that we can do business together and for purposes connected with our business operations.
Some of the specific purposes for which Furla Affiliate may process your personal data are as follows:
Personal data categories
name, date of birth (only for registered clients), postal code, address, telephone number, e-mail address, purchase data (e.g., purchased products, location, date and time of purchase, delivery data) as well as your IP address, operating system, browser type
d) What other parties may gain access to your information?
- To Furla SpA and the affiliates of of Furla Group;
- To contractors, service providers, and other third parties we use to support our business;
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Furla Affiliate’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information is among the assets transferred;
- To fulfill the purpose for which you provide it;
- To any other party disclosed by us when you provide the information, or to whom we are permitted or required to provide information by law.
- As further set forth in (h) below.
e) How your personal data are processed and protected?
Your personal data may be processed, either electronically or in hard copy form. Furla Affiliate will take reasonable steps to help ensure that your information is kept secure, only used for the purposes set forth in this privacy notice (and not for any other purposes) and are able to be accessed or corrected upon your request.
Furla Affiliate uses reasonable organizational, technical and administrative measures to help protect against the loss, misuse and alteration of the personal information under its control. Personal data may be accessed by persons within Furla Affiliate, or our third party service providers, who require such access to carry out the purposes described in this privacy notice, or such other purposes as may be permitted or required by the applicable law. Personal data we collect is managed by Furla Canada Inc., located in Montreal, Canada.
However, no data transmission over the Internet or data storage system can be guaranteed to be 100 percent secure. 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.
Please notify us as soon as practicable if you become aware of any unauthorised access to, modification or disclosure of your personal data from any Furla source.
f) How your personal data are processed and protected?
Your personal data collected to comply with a legal obligation and to perform the contract will be kept for a period not exceeding that necessary for such purposes and, in any case, not exceeding the limitation period for exercising an action in contract, after which they will be destroyed or rendered unusable or made anonymous.
g) Are personal data required or optional and which are possible consequences of failure to provide such data?
You must provide your data for the purposes set out above (under point c) (1) legal duties and (2) contractual purposes. If you do not wish Furla Affiliate to process your data for these purposes, Furla Affiliate will respect this. However, in this event, you will be unable to purchase products through any Furla Local Online Channels and receive related sale services.
Otherwise you are always able to purchase products as a generic customer (not registered client) at Furla’s points of sale.
h) How do we share the personal data collected?
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
In case you purchase products or receive services as a registered client (“My Furla Client”) and you also consent to the processing of your personal data for marketing or profiling purposes, your personal data will be inserted in the Furla’s CRM database which will be accessible to those Furla local affiliates or partners joining the My Furla Program that act as data processors on behalf of Furla S.p.A. (please refer to Furla’s global Privacy Notice available here for more details).
Depending on the service, Furla Affiliate may also share your personal data to specialized companies which Furla Affiliate entrusts, as data processors, with duties of technical and organizational nature that are necessary to manage relationships with clients. These include companies that provide customer care, payment, shipping or storage services for the purchase of the products or documentation regarding client relationships and companies that evaluate service quality and customer satisfaction. The data you provide to purchase online, such as your credit card details, will be processed exclusively by external providers acting as data processors. A list of these companies can be requested by emailing: firstname.lastname@example.org
The entities with whom we may share your data, as described in this privacy notice, may be located in countries other than the country where you reside, including without limitation in the United States, Japan, Australia, New Zealand and the European Union, including without limitation Ireland. These entities may be subject to laws that differ from the laws which apply in your country. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. By providing us with personal data, you understand and expressly agree that we may transfer it outside of Canada or your jurisdiction of residence. If you do not agree to the transfer of your personal data outside of Canada, do not provide us with personal data. We take reasonable steps to ensure that any recipient of your personal data complies with any privacy laws that apply in your country.
i) Your privacy rights
You have the right to obtain confirmation of the existence or non-existence of personal data relating to you and to request from Furla Affiliate access to and correction/rectification or erasure of personal data or restriction of processing concerning you or to object to processing as well as the right to data portability.
To exercise these rights, you may contact Furla Canada by sending a request to the following email address: email@example.com. If you request access to, or the correction of, your personal data, we will respond to your request within a reasonable period after the request is made. To protect against fraudulent requests for access to your personal data, we ask you for information to allow us to confirm that the person making the request is you or is authorized to access your personal data before granting access. For example, we may require you to verify your identity before you access your personal data. Access to your personal data will be provided in accordance with any applicable laws and is subject to any exemptions which might apply under those laws.
j) CHILDREN UNDER THE AGE OF 13.
This site is not intended for children under 13 years of age. No one under age 13 may provide any personal information through our site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use this site or any of its features. If we learn we have collected or received personal information from a child under the age of 13 without parental consent, we will delete that information. If you believe that we might have any information from or about your child under 13 years of age, please contact us at firstname.lastname@example.org.
k) Changes to this policy.
l) How to Contact Us.
If you have any questions or concerns about this Privacy Notice or the practices described herein, you may contact Furla’s privacy compliance specialist, based in Milan, Via San Raffaele n. 5 at: email@example.com