PRIVACY NOTICE –
LAST UPDATE JULY 30th, 2019
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”), and Furla (U.S.A.), Inc. (“Furla US”), who operates this website, found at www.Furla.com (the “Website”) on behalf of Furla, will collect and process your data. Furla US is considered a “Furla local affiliate” as such term is used in this policy.
a) When personal data are collected?
Collection by Furla:
Your personal data may be collected by Furla on the following occasions:
- if you join the Furla loyalty program (“My Furla Program”) and become a registered client (“My Furla Client”);
- if you purchase Furla products, as a My Furla Client, at one of the Furla points of sales adhering to the My Furla Program worldwide (please see below the list of adhering countries); and
- if you interact with any Furla promotional initiatives (such as game or prize competitions) on the Website.
Furla may also collect personal data about you from advertising networks or data aggregators from time to time. If you ever click on a link to one of our advertisements on other websites or social media pages, we may also receive your information.
Collection by Furla US:
Furla US will collect your personal data when you make a purchase on the Website, and when you otherwise interact with the Website or with Furla US through the Website.
Collection by Third Parties:
When this Policy Does not Apply:
This policy does not apply to information collected by any third party (except such collection done on Furla or Furla US’s behalf or when providing services to Furla or Furla US in connection with the Website), including through any application or content (including advertising) that may link to or be accessible from or on the Website.
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:
- your subscription to the My Furla Program to register you as a My Furla Client;
- any service related to any Furla promotional initiatives worldwide (such as game or prize competitions);
- customer’s interaction with our social pages (Instagram, Facebook, Twitter, YouTube, etc.);
- to manage your e-mail address for the subscription to Furla's newsletter, to receive updates on Furla's new products and services and to discover events, prize competitions, loyalty programs (etc.) organized by Furla worldwide;
- marketing and profiling activities.
Regarding the processing of your personal data for your purchase of Furla products, as a registered client, including for the provision of any related service such as presenting our products or services, shipping, delivery, management of returns and after-sale support, there will be autonomous data controllers, as follows:
• if you make a purchase at one of the Furla points of sale (i.e., brick and mortar stores) located in Italy; or
• if you make a purchase through any other website owned or operated by Furla to which this policy is posted.
Each Furla local affiliate (please see below the list of those local affiliates adhering to the My Furla Program)
Additional country specific privacy notices of each Furla local affiliate can be found at the following locations:
1. Japan: Furla Privacy Notice
2. United States;
3. Australia: Furla Privacy Notice;
4. Furla local affiliates in EU and Switzerland can be requested in-store at the time of purchase.
• If you make a purchase at one of Furla’s local affiliate’s points of sale (i.e., brick and mortar stores) adhering to the My Furla Program, not located in Italy, or
• If you make a purchase through any other website owned or operated by a Furla local affiliate to which this policy is posted or which is subject to one of the privacy policies linked in the box to the left of this one.
Each Furla local partner (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.
• If you make a purchase at one of the points of sale of local partners adhering to the My Furla Program
c) Which personal data do we collect and for which purposes and under which legal basis do we process the personal data collected?
Furla, or the applicable Furla local affiliate or Furla local partner, depending on the case, may process your personal data for the following purposes:
Personal data’s categories
name, date of birth, mailing 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 or the Furla local affiliate’s or local partner’s legal obligations and other obligations arising from instructions received from authorities
compliance with a legal obligation to which Furla or the Furla local affiliate or the Furla local partner are subject
name, date of birth, mailing address, telephone number, e-mail address
(2) to register you as a My Furla Client which allows you to benefit worldwide from offers and services exclusive to registered clients (you will receive a confirmation email after 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
name, date of birth, mailing 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 your purchase of a product as a registered client and any subsequent after-sale assistance, and the provision of a service such as your participation to Furla’s initiatives (e.g. a contest or sweepstakes), to enforce Furla’s or the Furla local affiliate’s or Furla local partner’s rights arising from any contracts entered into between you and such company, including for billing and collections, if needed
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
name, date of birth, mailing address, telephone number, e-mail address: for My Furla Clients.
e-mail address: for customers/web site visitors who are not registered as My Furla Clients.
(4) to carry out marketing and promotional initiatives and inform you about activities at Furla or its affiliates and about Furla’s products and services, whether by post or email, also by using automated means (for example, you may wish to receive newsletters to be updated on Furla’s new 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 such as fashion, luxury goods and the like. If you prefer to receive marketing communications by traditional means only (e.g. by post).
In addition, Furla may process your data for market research, statistical analyses, or other research to improve its and its affiliates’ and partners’ products and services, and for customer satisfaction analysis.
your consent to the processing for these specific purposes
name, date of birth, mailing address, data concerning hobbies, job, interests, purchase data (e.g., purchased products, location, date and time of purchase, delivery data), viewed products and any other information the Website collects that is defined as personal data or personally identifiable information pursuant to applicable law.
(5) to analyse your consumer habits on Furla’s retail channels (in-store or online), including through Furla local affiliates or Furla local partners (as processors on behalf of Furla), 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
your consent to the processing for these specific purposes
d) How your personal data are processed and protected?
Your personal data may be processed, either electronically or in hard copy form. Furla and each Furla local affiliate will take reasonable steps designed to ensure (i) that your information are kept secure, (ii) only used for the purposes set forth in this privacy notice (and not for any other purposes), and (iii) that your data are able to be accessed or corrected upon your request (as appropriate).
Furla and each Furla local affiliate uses reasonable organizational, technical and administrative measures designed to help protect against the loss, misuse and alteration of the personal information under each entity’s control. However, no data transmission over the Internet or data storage system can be guaranteed to be one-hundred percent secure, so please do not send us information you consider confidential via e-mail or provide it on the Website.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to change your password from time to time. We also highly recommend that you use a password that is dissimilar to and cannot be easily found by unauthorized third parties who may have obtained your login credentials to other sites. Keep in mind that if you use the same password for all websites, if someone obtains your credentials for one site, they may be able to then use those credentials to log into any other site you use.
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.
In order for Furla and the Furla local affiliates to provide you our services, we must have up to date information about you. Please log into your account from time to time to ensure you have provided us all of the most up to date information for you, or we may be unable to send you your purchases.
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 Section c) (1) (legal duties), (2) (registration as My Furla Client), and (3) (contractual purposes). If you do not wish Furla or the Furla local affiliate, as applicable, to process your data for their respective purposes, Furla or the Furla local affiliate, as applicable, will respect this. However, in this event, you will be unable to register as a My Furla Client and use the additional services that we offer to registered clients, register for an account on the Website, purchase products online as a registered client or participate in Furla’s initiatives (e.g., contests and sweepstakes).
Providing data for the purposes set out under Section c) (4) (marketing purpose) and (5) (profiling purpose) is 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 emailing: firstname.lastname@example.org.
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?
Neither Furla nor the Furla local affiliates will disseminate your personal data outside its group of companies, except to its service providers required to provide our services and make the Website available.
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 through your registration or during a purchase - e.g., name, date of birth, mailing 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 inserted into Furla’s customer relationship management (“CRM”) database which will be accessible to those Furla local affiliates and Furla local partners joining the My Furla Program.
This way, Furla will share your data within the Furla company group, 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’s benefits worldwide. In particular, your data will be automatically accessible to all sales staff based at local points of sale in the various countries (e.g. if you visit a Furla store in another country, your personal information will be accessed in that store).
Companies within the Furla company group include parent companies, subsidiaries and affiliates of Furla, including each Furla local affiliate, 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 entities that may have been added.
When your data is sent outside the European Economic Area as part of the My Furla Program, Furla will use commercially reasonable efforts to (i) ensure that its processors use reasonable security measures designed to protect your data in accordance with applicable laws, and (ii) sign model clauses approved the EU Commission for such cross boundary transfers outside the EEA with the processors receiving such data.
Depending on the service, Furla or a Furla local affilaite may also share your personal data (provided through your registration or during a purchase - e.g., name, date of birth, mailing 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) with specialized companies which Furla or the Furla local affiliate entrusts, as data processors, with duties that are necessary to manage relationships with clients or provide our services to you. These include companies that provide customer care, payment, shipping or storage services for the purchase of the products, companies that assist us in relationship management with our customers, and companies that evaluate service quality and customer satisfaction, or carry out, on behalf of Furla, marketing and profiling activities.
The data you provide on the Website when you purchase online, such as your credit card details, will be processed exclusively by external providers acting as Furla or the Furla local affiliate’s data processors. A list of these companies is available at Furla’s head office and can be requested by emailing: email@example.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 sent profiled marketing communications promoting Furla’s products which are sold at certain prices;
- information processed: name, date of birth, mailing 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, and purchase products as a registered client;
- measures to mitigate possible risks: a specific data privacy impact assessment on the profiling activity has been conducted in an attempt to ensure its impartiality, effectiveness and absence of harmful consequences and you can request a copy of the main summary of this assessment by sending a request to the following email address: firstname.lastname@example.org
Processing significance and envisaged consequences of such processing
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, under certain circumstances, to (i) obtain confirmation of the existence or non-existence of personal data relating to you in our files (ii) to request from Furla or the Furla local affiliate access to and rectification or erasure of personal data, or restriction of processing concerning you, (iii) to object to processing, and (iv) to port your data to another controller of your choice. We will use commercially reasonable efforts to honour all such requests.
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). We agree to stop using your data for such purposes after you send us your objection, once we have confirmed your identity, but please keep in mind that certain activities cannot be stopped, and you may receive marketing communications from us for a period of time after we have taken action on your objection.
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 mailing address may be used for sending promotional communications relating to Furla products similar to those you have purchased, or services that you have received from us. 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: email@example.com or clicking on the “unsubscribe” link in any e-mail you receive from us. Keep in mind that it may take a few days to process your unsubscribe request, and you may receive communications from us during that period.
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 Italian or EEA privacy laws.
To exercise your rights as set forth herein, you may contact Furla by sending a request to the following email address: firstname.lastname@example.org.
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: email@example.com.
j) Sharing of data scheme (for Japanese customers)
- 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, subsidiaries and affiliates 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.
- 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.
- 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: firstname.lastname@example.org.
- Furla may process and share the data that you provide through the app for the purposes illustrated in points c).2 (registration as MyFurla Client, to increase the quality of the customer experience whenever you visit a Furla store anywhere in the world); c).4 (marketing purposes); and c).5 (profiling purposes: to send commercial communications that are in line with users’ interests).
- Furla S.p.A. is the data controller and the entity in charge of management of the personal data.
k) Sharing of data 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) further information for UNITED STATES clients purchasing products on the website
This section explains further how Furla (U.S.A.), Inc., a company incorporated under the law of the State of New York, with an office at 432 Park Avenue South, 14th Floor, NY 10016 ("Furla US"), processes your data. In particular:
- DNT. Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser's DNT option in your browser's preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or user names, and some other features of a website may become unavailable or not function properly. Please keep in mind that our Website may not respond to DNT settings.
- Your California Privacy Rights.
- California Civil Code Section § 1798.83 permits users of this Website that are California residents to request certain information regarding Furla’s and Furla US’ disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write us at: Furla (U.S.A.), Inc., 432 Park Avenue South, 14th Floor, New York, New York 10016. Under Section 1798.83.
- Neither Furla nor Furla US currently share any personal information with outside third parties for their direct marketing purposes (although Furla does use personal data for its own benefit and for the benefit of its various local affiliates or local partners), but this may change, so please come back to this policy from time to time to review and confirm whether we have changed our practices.
- Third Parties’ Data Collection. We use the services of various third parties to help us track and understand how users use our Website, how they move around the World Wide Web, how they interact with us online, and to better understand our market and how consumers see our brand and buy our products, including for profiling.
- Children under the age of 13: The Website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use this Website 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 a child under 13 years of age, please contact us at firstname.lastname@example.org.
FURLA LOCAL AFFILIATES ADHERING TO THE MY FURLA PROGRAM
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 POLSKA SP. Z.O.O.
Ul. Sienna 82 00-815 Warsaw - Poland
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 PRAGUE S.R.O.
Jindřišská 937/16, New Town, 110 00 Prague 1
FURLA AUSTRALIA PTY LTD
Level 10, 379 Collins Street, Melbourne Vic 3000
FURLA LOCAL PARTNER ADHERING TO THE MY FURLA PROGRAM
C.P.C. SAS DI CARLOTTA PIANCASTELLI CARTWRIGHT
ITALY - MILANO MARITTIMA – Viale Gramsci, 43/b
THE RIVER SRL
ITALY – MONZA – Via Italia, 37
ITALY - PADOVA - Via Santa Lucia, 16
ITALY – VENEZIA – San Marco, 4833/4834
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
SOCIETA' ELLE S.N.C.
ITALY - ROMA - P.zza Balduina, 54
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
ITALY – TAORMINA – C.so Umberto I, 48
ETRUSCA SRL SOCIO UNICO
ITALY - TORINO - P.zza CLN, 255
ITALY - VERONA - Via Mazzini, 55
LINEA CASA CAVALIERE SRL
ITALY – SALERNO – Via Santissimi Martiri Salernitani, 42
WORLD REFERENCE SAS
ITALY – RIMINI – Piazza Tre Martiri, 18