FURLA PRIVACY POLICY

Furla Rus LLC (hereinafter - the Seller) is a legal entity registered in accordance with the legislation of the Russian Federation, with its location at the address: Russian Federation, 121099, Moscow, Smolenskaya Square, 3, ET / POM / KAB 8 / I / 19, OGRN 1115027002782, TIN 5027172101.

The seller is a subsidiary of Furla SpA, a legal entity established in accordance with Italian law on February 17, 1983 and registered with the Bologna Chamber of Commerce and Industry under number: BO-278122, located to the address: Italy, Bologna, San Lazzaro di Savena (BO), Via Bellaria, 3-5 (hereinafter - “Furla”) in the Russian Federation.

The Seller processes the personal data of the buyers, that is, the persons who made the purchase of Furla goods in one of the Seller’s own retail stores or by placing an order in the Seller’s online store located at: https://furla.com/ru (hereinafter referred to as the “Web-site” »), As well as potential buyers who are interested in Furla products and who have visited one of the Seller’s own retail stores or the Web-site (hereinafter the“ Buyer ”).

Processing of personal data is carried out by the Seller in accordance with the Council of Europe Convention No.108 “On the Protection of Individuals with Automatic Processing of Personal Data” and Federal Law No. 152-FZ of July 21, 2006 “On Personal Data” (“Legislation on the Protection of Personal Data” ), on the territory of the Russian Federation and exclusively in relation to the Russian market, in the following order:

a) Purpose and methods of processing

The Seller may process the data that the Buyer provides by filling out the Buyer's registration form in the online store electronically and / or the Buyer's Questionnaire in the form of a document on paper and / or by filling in personal data in the personal data collection information system (hereinafter - “ ISPSD ”), and the processing of which he gives consent, for the following purposes:

i. registering the Buyer on the Web-site in a personal account in order to make a purchase in the Seller’s online store on the Web-site or registering the Buyer in a personal account on the Web-site without making a purchase to participate in the loyalty program; in both cases, registration in the personal account on the Web-site allows customers to take advantage of the offers and services available exclusively to registered customers, and also allows to store the data entered during registration in the personal account of the Buyer, which will simplify ordering on the Web-site when making future purchases;

ii. promotion of goods, services on the market, conducting marketing events through advertising related to products under the Furla trademark and services provided by the Seller, the Seller’s partners, through direct contacts with potential consumers using communications (taking into account the selected contact options);

iii. analysis of consumer preferences in the framework of the retail channels used by the Seller (own retail network and online store on the Web-site), for example, in terms of purchased products, viewing goods, stores in which purchases were made, in order to send commercial messages that correspond to the interests of Buyers .

In addition, the Seller processes the personal data of the Buyer who made a purchase in the online store on the Web-site without registration. In this case, the processing of the Buyer's personal data is carried out for the purpose of fulfilling the purchase and sale agreement (acceptance of payment for goods and related services, organization of delivery of goods to the place indicated by the Buyer). In this case, the Buyer does not register in the personal account on the Web-site, the personal data provided by the Buyer is processed by the Seller on the basis of clause 5, part 1 of Article 6 of the Personal Data Law and is stored by the Seller no more than 365 days from the moment of placing the order.

The Buyer's personal data can be processed using automation tools or without using them by the seller performing any action (operation) or a set of actions (operations), including collection, recording, systematization, accumulation, storage, clarification (updating, changing), retrieval, use, transfer (provision, access), depersonalization, blocking, deletion, destruction of Personal Data.

Buyers' personal data will be stored exclusively on the territory of the Russian Federation for a period not exceeding the necessary period to achieve the goals for which they were collected, after which the personal data will be destroyed or brought into a state in which it cannot be used (anonymized). In particular, the Buyer agrees that the processing of his Personal Data is allowed at least for the entire period of his participation in the Loyalty Program or for the period necessary to fulfill the Seller’s obligations to the Buyer in each case when the Buyer places an order in the online store “Furla” (http://www.furla.com/en/ru/eshop).

b) Mandatory data and consequences of non-reporting

In any case, the Buyer has the right not to provide any of his personal data to the Seller, the provision of personal data occurs solely at the buyer's will. However, the failure to provide personal data for the purposes specified in paragraph a) (i) will not allow the Buyer to register as a Furla client and use the additional services that the Seller offers registered customers = including, but not limited to, the opportunity to attend events organized by the Seller, preliminary displays of collections etc.).

The provision of the Buyer's data for the other purposes specified in paragraphs a) (ii) and (iii) is not mandatory, the collection of such data is carried out exclusively with the consent of the Buyer. Failure to provide Buyer data for these purposes does not entail any negative consequences for the Buyer.

c) Organizations and types of organizations to which Personal Data may be disclosed (third parties entrusted with the processing of personal data) and the amount of data disclosed; cross-border transfer outside Russia

Depending on the service provided, the Seller has the right to exchange Buyer data with the local partners of the Seller and specialized local companies, which, on behalf of the Seller, are persons who process personal data, perform technical and organizational duties necessary for interaction with customers. These include companies that provide services for storing documents related to customer relationships, and companies that evaluate the quality of service and customer satisfaction or carry out advertising and determination of customer preferences on behalf of the Seller. In addition, the transfer of the processing of Buyers' Personal Data to the local companies listed below, processing personal data on behalf of the Seller, may be necessary for the Seller to fulfill its obligations to the Buyer, in particular, for the assembly and delivery of Goods purchased by the Buyer through the Furla Online Store at the address indicated by the Buyer.

Their list is given below:

• LLC Kuehne + Nagel; Address: 123001, Moscow, Trekhprudny per. d.9, p. 1

• Oneway Studio (IP Neverov Aleksey Aleksandrovich); Address: Arkhangelsk, Karl Liebknecht St., 19, of. 404;

• LLC “DHL Global Mail”; Address: 127051, Moscow, B. Sukharevsky per., 21, p. 2;

• Boxberry RU LLC; Address: 620100, Sverdlovsk Region, Yekaterinburg, Siberian Highway, Building 12 Building B1, Entrance 8

• FSUE Russian Post; Address: 131000, Moscow city, Warsaw highway, 37.

• Easy Way LLC; address: 109428, Moscow, Vyazovsky 1-y passage, bld. 4, p. 19

• LLC "STRIZH"; Address: 127322, Moscow, Ogorodny passage, 20, apt. 1

• Armadillo Business Parcel JSC; Address: 129226, Moscow, st. Dokukina, 16, building 1;

• CJSC Pochtomat; address: 125156, Moscow, Leningradsky pr-t, d.37A, building 14, building 1 address;

• LLC “Network of automated points of delivery”; Address: 109316, Moscow, Volgogradsky Prospekt, 42, building 23;

• LLC "Contact Center GRAN"; Address: 105120, Moscow, Kostomarovsky per., d. 11, p. 1.

• For the provision of advertising services (information and marketing campaigns), data is transmitted:

• Mindbox LLC; 125124, Moscow, st. Pravdy, d. 26, ET / POM 12 / XXX

A list of third parties is also available at the seller’s head office and may be requested by sending an e-mail to CC_Russia@furla.com.

For the avoidance of doubt, the Buyer's registration in the personal account on the Web-site, namely, entering data into the registration form and clicking the "Register" button, means that the Buyer has read this Policy, agrees with it and expresses its consent to the processing of his personal data, which he indicated in registration form.

If the Buyer agrees to the processing of his Personal Data for the above purposes, the Buyer's Personal Data entered into the Seller’s database will automatically be available to employees of the Seller’s outlets in the Russian Federation, as they ensure that the Seller conducts its business.

For the avoidance of doubt, none of the affiliated companies and none of the Seller’s partners that process data on behalf of and in the interests of the Seller, and as such have access to the Buyers ’Personal Data, are not established outside the Russian Federation, and the Seller will not be cross-border transfer Personal data of buyers outside of Russia.

The seller carries out cross-border transfer of personal data of the Buyers if these Buyers give their consent in any way that can confirm the fact of its receipt, in order to conduct marketing events, analyze consumer preferences in the main company - Joint-Stock Company “Furla S.p.A”, located at: Italy, Bologna, San Lazzaro diSavena (BO), Via Bellaria, 3-5 (hereinafter referred to as “Furla S.p.A”), as well as in subsidiaries of “Furla S.p.A” to countries providing adequate protection of the rights of subjects Personal data, including in the following countries:

Austria

Spain

Serbia

Australia

Canada

Slovakia

Azerbaijan

Cyprus

Slovenia

Albania

Kingdom of Morocco

Hong Kong Special Administrative Region

Belgium

Latvia

Tunis Republic

Bulgaria

Luxembourg

Turkey

Bosnia and Herzegovina

Malta

Ukraine

United Kingdom

Malaysia

Finland

Hungary

Netherlands

France

Germany

Poland

Croatia

Greece

Portugal

Czech Republic

State of Israel

Republic of Korea

Sweden

Denmark

Republic of Chile

Switzerland

Italy

Romania

d) Rights of data subjects

The Buyer has read and understands the contents of this Privacy Policy of Buyers' personal data and gives prior consent to the processing of his Personal Data in accordance with the terms of the Policy by posting the appropriate mark (s) in the registration form in your personal account on the website http: //www.furla. com / ru / ru either by affixing a personal signature to the Buyer’s Questionnaire in paper form or by filling in the information about yourself in the ISPDD.

The Buyer hereby confirms the understanding that he has the right to withdraw his consent at any time, without additional payment and without any adverse consequences in person, or by sending a written request to the seller's mailing address. Information on the procedure for revoking the Buyer's consent to the processing of personal data can be clarified by e-mail CC_Russia@furla.com.

The Buyer has the right (by personal appeal or by sending a written request) to access his personal data and receive information regarding the processing of his personal data, including the timing, goals and legal grounds for processing, information about the Seller and persons having access to personal data of the Buyer, or persons entrusted with the processing of personal data of the Buyer.

The buyer is recommended to periodically visit this section of the website of the Furla online store for the purpose of familiarizing themselves with the changes.

For the avoidance of doubt, this Policy applies solely to the personal data of Buyers who fill out the buyer’s questionnaire or provide data when filling in the ISPD in Furla stores, as well as Buyers who place orders through the Furla Online Store, and do not apply to special projects, unless otherwise specified.

Postal address: Russian Federation, 121099, Moscow, Smolenskaya pl., 3, office Furla

Phone: +7 (495) 641 40 76