FURLA PRIVACY NOTICE

 

 

 

This privacy 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 (BO) Italy (“Furla”), processes your data, in accordance with European Regulation 2016/679 (“GDPR”) and the data protection law applicable in your country, territory or location (together with the GDPR, the “Privacy Laws”).

We believe that protecting your personal data is a fundamental value of our business activities and we want to provide you with all the information so that you are able to control the use of your personal data and consent, where appropriate, to the relative processing by Furla, in an explicit and informed manner.

a)    When are personal data collected?

Your personal data may be collected in the following occasions:

  1. if you wish to join the Furla loyalty program (“My Furla Program”) and become a registered client (“My Furla Client”);
  2. if you purchase Furla products or services, as a My Furla Client, at one of the points of sales adhering to the My Furla Program worldwide (please see below the list of participating countries) or if you visit or make a purchase on one of the Furla websites, or also through the Furla app or any other Online Channel or social media related to Furla (the “Online Channels”); or
  3. in the occasion of any promotional initiatives sponsored by Furla (e.g., games or prize competitions).

b)    Who controls your personal data?

Furla S.p.A. with registered office at Via Bellaria 3/5, 40068 San Lazzaro di Savena (BO), Italy will process your personal data, as a data controller, to manage:

  1. your subscription to the My Furla Program to register you as a My Furla Client and to ensure the security of your profile after registration (“My Furla Client Registration”);
  2. any service and/or initiative reserved to My Furla Clients worldwide (e.g., participation in games or prize competitions), including sending communications to keep you informed of these services and initiatives (“Services and Initiatives Reserved to My Furla Clients”);
  3. client interaction with our social pages (Instagram, Facebook, Twitter, YouTube, etc.) (“Social Interactions”);
  4. Marketing” and “Profiling” activities.

 

Regarding the processing of your personal data for your purchase of Furla products, including for the provision of any related service such as shipping, gift messages/gift wrapping, in-store delivery, management of returns, customer assistance and after-sale support (collectively, “Sales Services”), your data will be processed by autonomous data controllers, identified as follows:

Furla S.p.A.

•  for the purchase at one of the Furla point of sales located in Italy or

•  for the purchase through one of the Online Channels available in the EU countries.

Each Furla local affiliate (please see below the list of those local affiliates adhering to the My Furla Program)

 

The privacy notices of the subsidiaries of Furla Group that carry out sales activities at the local level are available here:

Furla Japan 

Furla USA

Furla Australia 

Furla New Zealand 

Furla Canada

For those Furla local affiliates in EU and Switzerland can be requested in-store at the time of purchase.

•  for the purchase at one of the Furla’s affiliate point of sales adhering to the My Furla Program, not located in Italy, or

•  for the purchase through one of the Online Channels available in the non-EU countries.

Each Furla local partners (please see below the list of those local partners adhering to the My Furla Program)

 

The privacy notices of each Furla local partner can be requested in-store at the time of purchase.

•  for the purchase at one of the point of sales of the local partners s adhering to the My Furla Program.

 

c)    The personal data that we collect, its purposes, and the legal bases for processing?

Furla may process your personal data – that you voluntarily provided - for the following purposes, on the following legal basis:

Personal data’s categories

Purposes

Legal basis

name, date of birth, tax code, address, telephone number, e-mail address, data concerning hobbies, job, interests, purchase data (e.g., purchased products, location, date and time of purchase, delivery data), viewed products

(1) to fulfil Furla’s legal obligations, such as,  obligations in relation to product liability and warranties and other obligations arising from inquiries or instructions received from authorities, for example, in the event of fraud or legal disputes (“Legal Obligations”)

 

compliance with a legal obligation to which Furla is subject (art. 6, para.1 let. c) GDPR)

 

name, gender (optional and only for registered clients), date of birth, address, telephone number, e-mail address

 

 

 

(2) to register you as a My Furla Client which allows you to benefit worldwide from exclusive offers and services reserved to registered clients (you will receive a confirmation email after registration) and to ensure the security of your profile after registration (“My Furla Client Registration”)

performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (art. 6, para.1 let. b) GDPR)

name, date of birth (only for registered clients), tax code, address, telephone number, e-mail address, purchase data (e.g., purchased products, location, date and time of purchase, delivery data)

(3) to fulfil obligations strictly connected to the purchase of a product and any related service, such as: shipping, gift message/gift wrapping, in-store delivery, return management, and after-sale assistance (“Sales Services”)

performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (art. 6, para.1 let. b) GDPR)

name, address, telephone number, e-mail address

(4) to ensure your access to exclusive services and initiatives reserved to My Furla Clients around the world (e.g., games or prize competitions), including sending communications to keep you informed of these services and initiatives (“Services and Initiatives Reserved to My Furla Clients”);

performance of a contract to which the data subject is a party or execution of pre-contractual measures adopted at the request of the data subject (art. 6, para. 1, let. b) GDPR)

name, date of birth, gender (only for registered clients), address, telephone number, e-mail address, browsing data, and products viewed in Online Channels

(5)Marketing Activities”:

5a. to conduct market research, statistical analyses, or other research with the objective of improving our products and services and to evaluate the level of client satisfaction

5b. to carry out promotional campaigns and to send offers and marketing communications relative to Furla entities (Furla SPA and  its subsidiaries) and Furla products and services, through the channels that you indicated: post, email, telephone, SMS or social media, also by using automated means (for example, you may wish to receive newsletters to be updated on new Furla products and services 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 send a notice to privacy@furla.com

 

5c. to send you emails or SMS designed to help you improve your purchasing experience on our Online Channels, based on your needs, or to remind you to complete a pending purchase.

5d. to send you, including if you are not interested in enrolling in the My Furla Program, our newsletter via email and communications designed to help you improve your purchasing experience on our Online Channels, based on your needs, or to remind you to complete a pending purchase

 

your consent to the processing for these specific purposes (art. 6, para.1 let. a) GDPR)

name, date of birth, gender (only for registered clients), address, data concerning hobbies, job, interests, purchase data (e.g., purchased products, location, date and time of purchase, delivery data), viewed products

(6) to analyse your consumer habits in Furla retail channels (in-store or within the Online Channels), for example, in relation to purchased products, viewed products, stores where purchases were made, in order to provide personalized offers that are in line with your interests (“Profiling”)

 

your consent to the processing for these specific purposes (art. 6, para.1 let. a) GDPR)

Furla may also process your personal data regarding your online browsing history collected during your visits on our web pages or during Social Interactions (whether you are registered client or not), by using tracking technologies such as “cookies” (for information on data collection through cookies, please see our Cookies Policy).

c)    1. Data collected by third parties

In this section, we inform you regarding the data that was not collected directly from the data subject, that you may send as part of your requested purchase of one of our products or services (such as, for example, the gift message/gift wrapping service).

In compliance with art. 14 of the GDPR for data not obtained directly from the data subject (such as is currently done for personal data of the recipient of a gift package and/or congratulatory message that you may send us to use the service), the notice for the latter is understood to be provided by you; in this regard, you commit to send your family member, friend, or other data subject that receives the service a copy of this notice or a link to access the online version and, in any case, to make the other data subject aware of the essential contents of this notice.

d)    How your personal data are processed and protected?  

Your personal data may be processed, either electronically or in hard copy form. Furla will take reasonable steps to ensure that your information are 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 uses reasonable organizational, technical and administrative measures to help protect against the loss, misuse and alteration of the personal information under its 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.

e)    How long do we keep your personal data?

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 10 years after the termination of the contract (e.g., following your withdrawal from the registration as My Furla Client), after which they will be destroyed or rendered unusable or made anonymous.

Your personal data collected for marketing and profiling purposes may be kept for a period of 7 years (as authorized by the Italian Data Protection Authority), after which they will be destroyed or rendered unusable or made anonymous.

f)     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 under point c) (1) (Legal Obligations), (2) (My Furla Client Registration), and (3) (Sales Services) and (4) (Services and Initiatives Reserved to My Furla Clients). If you do not wish Furla to process your data for these purposes, Furla will respect this. However, in this event, you will be unable to register as a My Furla Client and enjoy the exclusive services and initiatives that Furla offers to its registered clients.

Providing data for the purposes set out under point c) (5) (Marketing Activities) and (6) (Profiling purpose) is instead optional. Not providing your data for these purposes will not have any negative consequences for you. If you consent to Furla processing your personal data for these purposes you can revoke your consent at any time by sending an email to: privacy@furla.com.

g)    How do we share the personal data collected, how do our global services work and to which entities your personal data can be shared extra EEA?

Furla will not disseminate your personal data.

If you register as a My Furla Client and consent to the processing of your personal data for marketing or profiling purposes, your personal data (provided as part of the registration process or during a purchase - e.g., name, date of birth (only for registered clients), address, telephone number, e-mail address, data concerning hobbies, job, interests, purchase data - purchased products, location, date and time of purchase, delivery data - viewed products) will be entered in the Furla’s CRM database which will be accessible to the Furla local affiliates and Furla’s partners that adhere to the My Furla Program, who act as data controllers for the processing of data on behalf of the data owner, Furla.

This way, Furla will share your data within the companies of the Furla network, both in and outside your country of residence and both in and outside the EEA where Furla is located, since the My Furla Program is managed and provides clients with Furla benefits worldwide. In particular, your data will be automatically accessible to all Furla sales staff based at the local points of sale (e.g. if you visit a Furla store in another country, your personal information will be accessed in that store).

Companies within the Furla network include the parent company, subsidiaries of Furla and partners, such as affiliated stores or franchisees. You can find a list of these companies below but please make sure to review this list from time to time to see new joiners.

Where your personal data are sent to countries other than your country of residence or in countries outside the EEA as part of the My Furla Program, your data will be protected by adequate safety systems, which are constantly updated and maintained in accordance with applicable Privacy Laws (for example specific data processing agreements are in place and the non-EU Processors have signed the model clauses approved by the EU Commission). You can request a copy of the EU Standard Contractual Clauses by emailing: privacy@furla.com

Depending on the service, Furla may also share your personal data (provided through your registration or during a purchase - e.g., name, date of birth (only for registered clients), address, telephone number, e-mail address, data concerning hobbies, job, interests, purchase data - purchased products, location, date and time of purchase, delivery data - viewed products) to specialized companies which Furla 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, or carry out, on behalf of Furla, marketing and profiling activities, including on a local basis, including re-targeting activities.

The data you provide to purchase online, such as your credit card details, will be processed exclusively by external providers acting as Furla data processors.

Your personal data will not be transferred outside the EEA. In case it is necessary to transfer your data outside EEA, we will adopt appropriate measures to ensure that your personal data will be adequately protected. A list of these companies is available at Furla’s head office and can be requested by emailing: privacy@furla.com

h)    Existence of automated decision-making, including profiling

Furla may process your personal data through automated decision-making tools. Please consider the following table in order to understand the logic involved, the significance and the envisaged consequences of such processing:

Logic involved and description of the processing

-      logic involved: viewed products, purchase data  and frequency are considered to create clusters of clients (explorer, fan, classic, connoisseur and elite). Depending on the cluster, clients will be addressed profiled marketing communications promoting Furla’s products which are sold at certain prices;

-      information processed: name, date of birth, address, data concerning hobbies, job, interests, purchase data (e.g., purchased products, location, date and time of purchase, delivery data), viewed products;

-      source of the information: upon collection of your consent to be profiled, Furla processes the data you provide when you register, use Online Channels, and purchase products as a registered client;

-      how the information provided impact the decision: the profiling is based solely on the data you provide, therefore the outcome depends totally on it;

-      measures to mitigate possible risks: a specific DPIA on the profiling activity has been conducted to ensure its impartiality, effectiveness and absence of harmful consequences and you can request a copy of the main summary by sending a request to the following email address: privacy@furla.com

Processing significance and envisaged consequences of such processing

Visits on the Online Channel and purchase habits as a registered client will define the types of products that Furla will promote to you.

 

Therefore, if you see or purchase products that are:

-    cheaper than the ones usually viewed or purchased (or if your views or purchases are more frequent), you will be addressed promotional communications regarding the former items;

-    more expensive than the ones usually viewed or purchased (or if your views or purchases are less frequent), you will be addressed promotional communications regarding the former items

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 access to and 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.  

Regarding the processing of personal data for marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing (art. 21, para. 2 GDPR).

Regarding the processing of personal data for profiling purposes, you have the right to obtain human intervention on the part of Furla, to express your point of view and to contest the decision (art. 22, para. 3 GDPR).

Your address may be used for sending promotional communications relating Furla products or services similar to those you already benefit from. You will be able at all times, either initially or in subsequent communications, to object to the use of your address for such purpose, as well as to object to such processing by emailing: privacy@furla.com.

You have the right to lodge a complaint with the Italian Data Protection Authority and/or other competent supervisory authority where you consider that the processing of your personal data infringes the Privacy Laws.

To exercise these rights, you may contact Furla by sending a request to the following email address: privacy@furla.com.

With regard to all issues related to processing of your personal data and to the exercise of your rights under the GDPR, you may contact the data protection officer, EUCS Srls Unipersonale, Piazzale Mazzini 64, 35137 Padova, Italy, Dr. Eric Falzone, email: dpo@furla.com.

j)      Sharing of data scheme (for Japanese customers)

  1. If you consent to the processing of your personal data for marketing and profiling purposes, your personal data will be added in Furla’s database. Furla will share your data with companies within the Furla group and Furla’s partners, by making your data automatically accessible to all Furla sales staff based at the points of sale worldwide. Companies within the Furla group includes parent companies, and subsidiaries of Furla. Furla’s partners means affiliated stores or franchisees within the Furla network. You can find a list of companies within the Furla group and Furla’s partners here/below.
  2. Furla will share the personal data you provide through your registration (e.g., name, surname, address, city, post code/zip code, telephone number, email address, date of birth, occupation, etc.); your purchase data (which includes location, date and time of purchase, delivery data, product and payment data); data on your visits to our website (e.g. viewed products); and your data concerning your hobbies, job, and interests.
  3. Depending on the service, Furla may share your data provided above (see previous point) with companies within the Furla group, Furla’s partners and to specialised companies which Furla entrusts, as data processors, with duties of technical and organisational nature that are necessary to manage relationships with clients. These include companies that provide storage services for documentation regarding client relationships and companies that evaluate service quality and customer satisfaction, or carry out, on behalf of Furla, marketing and profiling activities, including on a local basis. A list of these is available at Furla’s head office and can be requested by emailing: privacy@furla.com.
  4. Furla may process and share the data that you provide through the app for the purposes illustrated in points c).2 (registration as My Furla Client, to increase the quality of the customer experience whenever you visit a Furla store anywhere in the world); c).5 (marketing activities); and c).6 (profiling purposes: to send commercial communications that are in line with users’ interests).
  5. Furla S.p.A. is the data controller and the entity in charge of management of the personal data.

k)    Data sharing scheme (for Australian customers)

If you reside in Australia, you have a legal right under the Privacy Act 1988 (Cth) to request access to your personal data which is held by us. You also have a right to seek correction (including correction of any errors) of your personal data. If you would like to request access to, or correction of, your personal data, please contact us using our contact details in Section (i) above.  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.  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.

If you believe that we have breached this privacy notice or have otherwise interfered with your privacy, you may write to us with your complaint using the contact details in Section (i) above.  We take all privacy complaints seriously and will endeavour to resolve any issues in a timely and fair manner. If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner.

l)   Data sharing scheme (for Canadian customers)

If you reside in Canada, you have a right to request access to your personal data which is held by Furla and the right to request its modification (including the correction of any errors). If you would like to request access to, or correction of, your personal data, please contact Furla’s privacy compliance specialist, based in Milan, Via San Raffaele n. 5 at the following e-mail address: privacy@furla.com.  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 may ask you for additional information to confirm that the person making the request is you or is authorized to access your personal data. 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 applicable laws, and is subject to any exemptions which might apply under those laws.   

We reserve the right to transfer all personal data we have about you in the event of mergers or acquisitions with third parties.

Some or all of the personal data we collect may be sent to or stored on servers located outside of Canada, in particular, in the European Union. Data protection laws in EU or other non- EU countries may differ from those in Canada. 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 your data outside of Canada or your jurisdiction of residence. If you do not agree to this transfer, we ask that you do not provide us with personal data.

We reserve the right to modify this Privacy Notice at any time. By accessing or using Furla’s website or providing us with your personal data after such changes, the user consents to this Privacy Notice, as amended. Please periodically review this Privacy Notice so that you are continuously updated on the personal data we collect, how we use it, and with whom we share it. 

 

FURLA LOCAL AFFILIATES ADHERING TO THE MY FURLA PROGRAM

FURLA S.P.A.

Via Bellaria 3/5 40068 San Lazzaro di Savena, Bologna IT

KENT SA FURLA

Space num 41 Maasmechelen Village Zatellan 100, Maasmechelen Belgium

FURLA UK LTD

Regent Street 221, W1B 4NU, London UK

FURLA ESPANA SL

Paseo de Gracia, 59 08007 Barcellona, España

FURLA IRELAND ACCESSORIES LTD

6th floor South Bank House, Barrow street, Dublin, Ireland

FURLA GERMANY GMBH

Theatinerstr. 30 80333 Munchen, Germany

FURLA FRANCE SAS

7/9 Rue La Boétie 75008 Paris, France

FURLA AUSTRIA GMBH

Designer Outlet Strasse 1 Parndorf A-7111 Austria

FURLA HOLLAND B.V.

Stadsweide 438, Unit 320, 6041TP Roermond - The Netherlands

FURLA PORTUGAL, LDA

Edifício Premium | R. Miguel Serrano, nº 9 - 6º - Miraflores - 1495-173 Algés    

FURLA POLSKA SP. Z.O.O.

Ul. Floriańska 2 - 03-707 Warszawa, Poland

FURLA PRAGUE S.R.O.

Jindřišská 937/16, New Town, 110 00 Praga 1

FURLA JAPAN CO., LTD

Jingumae Tower Building 10F, 1-5-8, Jingumae, Shibuya-ku, Tokyo 150-0001, Japan

FURLA (U.S.A.), INC.

432 Park Avenue South 14th Floor New York, NY 10016

FURLA SWITZERLAND SA

Beroldingen 26 CH- 6850 Mendrisio

FURLA AUSTRALIA PTY LTD

Level 10, 379

Collins Street, Melbourne Vic 3000, Australia

FURLA CANADA INC.

1635 Sherbrooke Street West, #210 Montréal, Québec H3H 1E2

FURLA LOCAL PARTNERS ADHERING TO THE MY FURLA PROGRAM

THE RIVER SRL

ITALY – MONZA – Via Italia, 37

RO-RO SRL

ITALY - PADOVA - Via Santa Lucia, 16

ITALY – VENEZIA – San Marco, 4833/4834

ITALY – TREVISO – C.so del Popolo, 67

FALCOMER S.R.L.

ITALY - PORDENONE - C.so Vittorio Emanuele, 42/C

MARK G.C. SRL

ITALY - ROMA - Galleria A. Sordi

VIOLA PIACENTINI & C. SAS

ITALY - ROMA - P.zza Buenos Aires, 11/12

ASAR S.A.S. DI VANESSA STELLA & C.

ITALY - ROMA - Viale Libia, 203 - 205

LIFE STYLE SRL

ITALY - SAN GIMIGNANO – P.zza della Cisterna, 16

LOOK BOUTIQUE DI LYUBCHENKO OLGA

ITALY - SAN MARINO – Via Basilicius, 6

BABA' SRL

ITALY – TAORMINA – C.so Umberto I, 48

ETRUSCA SRL SOCIO UNICO

ITALY - TORINO - P.zza CLN, 255

CALZABELLA SRL

ITALY - VERONA - Via Mazzini, 55

WORLD REFERENCE SAS

ITALY – RIMINI – Piazza Tre Martiri, 18

ITALY – RAVENNA – Corso Matteotti, 37