1. Data Controller
2. Processed data
Depending on the purposes of the processing, the Data Controller may collect and process different categories of the personal data of data subjects (collectively the ““Data” o “Personal Data"). Data includes:
- personal details such as name, surname, date of birth, home address, country of residence, nationality and gender (“Identification Data”);
- contact details such as email address and telephone number (“Contact Data”);
- data on purchases such as products purchased, place, date, time and store of purchase, purchase history, delivery details, payment and invoicing methods, as well as any personal data contained in communications between the data subject and the Data Controller concerning products purchased or of interest to the customer (“Purchase Data”);
- browsing data such as IP address, information on the browser used by the data subject, pages visited, date, time and duration of each visit, other parameters related to the data subject’s operating system and computer environment, as well as any other information on the data subject’s activity in Distance Selling Channels (as defined below) for example: products viewed, frequency of viewing, purchasing habits and how the data subject interacts with our website, etc. which will be collected via cookies and/or scripts, and also via buttons or widgets1 (“Browsing Data”)2 ;
- profiling data such as the information collected: (i) following an analysis of the personal data of data subjects regarding, for example, their interests and preferences, as indicated directly by the data subject; and/or (ii) an analysis of other personal data on the data subject such as, for example, Personal Data, Browsing Data and Purchase Data both in aggregate and individual form (“Profiling Data”).
3. Methods of acquiring personal data
The Data Controller may collect the Personal Data of data subjects in paper form or in electronic form, e.g. via tablets through the following channels:
- the website (the“Website”) following: (i) ) registration of the data subject on the e-commerce; (ii) registration for the newsletter; (iii) the completion of a purchase in “guest” mode; and/or (iv)their browsing activity;
- the distance sales channels adopted by the Data Controller that enable the data subject to purchase Furla products at any time for example, instant messaging applications, etc. (“Distance Selling Channels;and
- our stores and/or franchisees (“Stores") and/or Affiliates including through specific apps provided to sales assistants.
4. Purpose of processing
Furla wishes to process the Personal Data of data subjects for different purposes. Each purpose involves the processing of different categories of personal data and is legitimised on a different legal basis. In particular:
- fulfilment of legal obligations: fulfilment of obligations relating to product liability or warranty, together with obligations of a taxation, contributory and consumer obligations;
- purchase of products and related services 3: the fulfilment of obligations strictly related to the purchase of a product and any related service such as, for example, the creation of an account on the Website, the management and monitoring of a wishlist and orders, home or in-store delivery of goods, the “book an appointment” service, virtual shopping (through various channels, such as instant communication apps), warranty and assistance in the event of loss of payment receipts, returns and repairs management, customer support (including support for order completion and payment for online purchases), reminders of products in the online shopping cart, and after-sales support;
- profiling:analysis of the behaviour of data subjects on Distance Selling Channels, on the Website and at Stores and Affiliates, the processing of information and its comparison against KPIs on the preferences and purchasing habits of data subjects, the viewing by sale assistants of purchase history, preferences and, in general, the results of processing by our IT systems of information collected on the data subject in order to: (i) offer the data subject personalised offers and products that are always suited to their needs and interests; (ii) ensure a unique and customised shopping experience and customer care; and (iii) offer the option to participate in events that Furla believes may be of interest to them; data subjects may always change their preferences for contact channels by writing to firstname.lastname@example.org
- marketing: the implementation of commercial, advertising, promotional and general marketing initiatives such as, for example, the sending of the newsletter with information on products, offers and discounts offered by Furla; the sending of relational communications (also) via instant messaging, social media, text message and telephone communication, including the sending of greeting messages to the data subject (e.g. on the data subject's birthday and anniversary at Furla) and invitations to special events organised by Furla; data subjects may always change their preferences for contact channels by writing to email@example.com or through the unsubscribe function included in the marketing communication;
- profiled marketing: the sending of specific marketing communications that reflect the interests and preferences of each data subject following profiling - for example the sending of communications aimed at raising awareness of the world of Furla and fostering interest in the brand; clienteling activities (such as the sending of personalised offers for products suited to the data subject’s needs), guaranteeing a unique and personalised shopping and customer care experience and offering the chance to participate in events aimed exclusively at individual data subjects, or that Furla considers to be of interest to them; data subjects may always change their preferences for contact channels by writing to firstname.lastname@example.org or through the unsubscribe function included in the profiled marketing communication;
- legal defence:the safeguarding of legal defence requirements in relation to any disputes that may arise with the data subject following the execution of the contract or use of the Distance Selling Channels, and in general the requirement to protect Furla, including through enforcement of its terms of online payments and fraud prevention.
5. Legal basis of the processing and period of retention
The following chart sets out the processed Data, the legal basis and the retention period for each of the purposes of processing described above.
6. Methods of processing
Mandatory or optional nature of Data provision
The provision of certain Data is necessary to make a purchase of products and/or use services related them. Failure to provide such Data will result in it being impossible to proceed with the execution of contracts and the fruition of relevant services. The provision of Data for the purposes indicated in letters c), d) and e) of Article 4 above (marketing, profiling and profiled marketing) is optional. In such cases, failure to provide Data will not have any negative consequences and will not in any way preclude the purchase of Furla branded products or the fruition of the related services. Consent given may be revoked at any time by contacting Furla at email@example.com . Processing carried out prior to the revocation of your consent will remain valid.
Personal Data may also be processed by automated means for the purposes indicated in letters c), d) and e) of Article 4 above (marketing, profiling and profiled marketing). Using profiling tools, the Data Controller is able to cross-reference and re-process Personal Data in order to create groups of customers grouped together on the basis of: (i) purchasing attitudes and behaviour (e.g. spending and frequency of purchases); and (ii) interests and types of products and services purchased and/or viewed. The inclusion of the data subject in a certain group enables Furla to offer her/him if consent has been given, where required by the applicable Privacy Laws types of products and services that are in line with the data subject’s purchasing preferences (for example products that he/she usually views or purchases) and the characteristics of the group to which he/she belongs. In compliance with the GDPR, a specific impact assessment has been conducted on the automated processing described herein, in order to confirm the lack of significant risks to the rights and freedoms of data subjects and to ensure that processing takes place impartially, effectively, and without harmful consequences for the data subject. You can always request a copy of the impact assessment summary by contacting Furla at firstname.lastname@example.org.
In any event, Furla may perform internal market analysis activities, in aggregate form, aimed at obtaining information on the performance of its business, that of its Affiliates and Stores and, in general, aimed at managing and planning its business. To this end, Furla will adopt appropriate technical and organisational measures to guarantee a level of security adequate to the risk (such as, for example, the pseudonymisation and/or anonymisation of Personal Data collected on the data subject as well as Data deriving from profiling activities). Therefore, since this form of analysis concerns information that can no longer be traced back to any data subject, it will not involve the processing of personal data.
7. Place of processing and Data sharing
The Personal Data of the data subject will be entered into the Furla CRM database, processed in accordance with the purposes described above and stored for the period necessary to achieve them. The servers on which the data present in the CRM is stored are located in Ireland in a Microsoft Azure environment. Through CRM, Furla will share Personal Data with Affiliates and/or Stores that are integrated in our CRM system and which are appointed as processors or will process data as controllers, depending on the relationship with Furla. Such Affiliates and/or Stores may be located within and outside your country of residence and within and outside the EEA, as Furla offers customers the option to receive offers in line with their interests and needs in all countries where Furla operates. In particular, Personal Data can be accessed by personnel of Affiliates and/or sales assistants at the Stores in accordance with the access segregation policy adopted by Data Controller (for example, if you visit a Furla store in a country other than your country of residence, the Data will also be accessible at that store). Where Personal Data is sent to states other than your country of residence or to states outside the EEA, the Personal Data shall be protected by appropriate security systems which are continually updated and maintained in accordance with applicable Privacy Laws (for example, specific data processing agreements are in place and non-EEA data processors have signed the European Commission's Standard Contractual Clauses). A list of the entities with which Personal Data is shared can be found at the following link www.furla.com/privacy. You can always request a copy of the Standard Contractual Clauses of the European Commission or other applicable data transfer safeguards by sending an email to email@example.com or by consulting the European Commission website.
8. Rights of data subjects
To exercise these rights, you can contact Furla by sending a request to the following email address: firstname.lastname@example.org. Furla will provide information on action taken on a request to the data subject without undue delay and in any event within one month of receipt of the request.
For any matter related to the processing of Personal Data and/or the exercise of rights, the Data Protection Officer of Furla S.p.A. Dr. Eufemia Marvulli can be contacted at the following contact details: Via San Raffaele, 5 - 20121 Milan; email: email@example.com.
|FURLA S.P.A.||Via Bellaria 3/5 40068 San Lazzaro di Savena, Bologna IT|
|KENT SA FURLA||Zetellaan(E) 100, 3630 Maasmechelen, Belgium|
|FURLA UK LTD||Regent Street 221, W1B 4NJ, London UK|
|FURLA ESPANA SL||Paseo de Gracia, 59 08007 Barcellona|
|FURLA IRELAND ACCESSORIES LTD||6th floor, South Bank House, Barrow Street, Dublin 4, Ireland|
|FURLA GERMANY GMBH||Theatinerstrasse. 30 80333 - Munchen|
|FURLA FRANCE SAS||414 rue Saint-Honoré 75008 Paris|
|FURLA AUSTRIA GMBH||Designer Outlet Strasse 1 Parndorf A-7111 Austria|
|FURLA HOLLAND B.V.||Stadsweide 438, Unit 320, 6041TP Roermond, The Netherlands|
|FURLA POLSKA Sp. Z.o.o.||Presso Blackstone ul. Floriańska 2 - 03-707 Warszawa, Poland|
|FURLA SWITZERLAND SA||c/o Fidinam SA, succursale di Mendrisio Via Franco Zorzi 18|
|FURLA PRAGUE S.R.O.||Jindřišská 937/16, Praha 1 - Nové Město, CZ|
|FURLA PORTUGAL, LDA||Rua Rodrigo da Fonseca, n.º 82, 1.º direito, 1250-193 Lisboa|
|FURLA SAN MARINO S.R.L.||Strada degli Angariani n. 41 47891 san Marino|
|FURLA (USA) INC..||530 7th Avenue, Floor M1 New York, NY 10018o|
|FURLA CANADA INC.||1635 Sherbrooke Street West, #210 Montréal, Québec H3H 1E2|
|FURLA JAPAN CO. LTD||Jingumae Tower Bldg., 5-8, Jingumae 1-Chom, Shibuya -ku, Tokio, Japan|
|FURLA AUSTRALIA PTY LTD||Level 10, 379 Collins Street Melbourne Vic 3000|
|FURLA NEW ZEALAND LIMITED||Level 9, 45 Queen Street Auckland, NZ 1010|
|FURLA SINGAPORE PTE. LTD.||80 Raffles Place, #32-01 UOB Plaza, 048624 Singapore|
|THE RIVER||Via Italia, 37/3 – 20900 Monza|
|ASAR||Viale Libia, 203/205 – 00199 Roma|
|LOOK BOUTIQUE DI LYUBCHENKO OLGA||Contrada della Pieve – 47890 San Marino|
|TOMANI SRLS||Corso Vittorio Emanuele, 44 – 33170 Pordenone|
|LIFESTYLE||P.za della Cisterna, 16 – 53037 San Gimignano|
|RO-RO||San Marco, (S. Salvador) 4833 – 30124 Venezia|
|CALZABELLA||Via Mazzini, 55 / Vic. 3 Marchetti,16 - 37100 Verona|