PRIVACY POLICY
Updated to the European General Data Protection Regulation No. 679/2016 (GDPR) and Legislative Decree No. 101/2018
In compliance with the obligations arising from EU legislation (European General Data Protection Regulation No. 679/2016, GDPR) and Legislative Decree No. 101/2018, this website www.fashionpo.com respects and protects the confidentiality of visitors and users, implementing proportionate measures designed not to infringe upon users' rights.
This document also takes into account Recommendation No. 2/2001 adopted by European Data Protection Authorities to identify the minimum requirements for collecting personal data online.
This privacy policy applies exclusively to the online activities of this site and is valid for visitors/users of the site. The information notice is provided only for the website www.fashionpo.com and not for other websites that may be consulted by the user via links.
The purpose of this privacy policy is to provide maximum transparency regarding the information the site collects and how it uses it.
LEGAL BASIS FOR PROCESSING
Data processed on the basis of consent
By using or consulting this site, visitors and users explicitly approve this privacy policy and consent to the processing of their personal data in relation to the methods and purposes described below, including any disclosure to third parties if necessary for the provision of a service.
The provision of data and therefore Consent to the collection and processing of data is optional.
The User may refuse consent and may revoke consent already provided at any time via the link at the bottom of the page.
However, denying consent may make it impossible to provide certain services and the browsing experience on the site could be compromised.
TYPES OF DATA PROCESSED
Browsing the Site for consultation purposes does not require any request for personal data; however, technologies are in use that involve storing some data related to the tools used, which can in some way be traced back to the user.
The personal data we receive from our customers helps us personalize and continually improve the services offered through the site. We use such data in particular to manage orders, deliver products and services, process payments, communicate with users regarding orders, products, and services, update our records, and manage user accounts.
Certain products on the platform may be marketed directly by third-party suppliers participating in the FashionPO Marketplace. In such cases, the data necessary to execute the order may be communicated to the respective supplier in order to manage the sale, issue tax documentation, prepare the goods, and handle any returns, complaints, and post-sale support activities.
We also use this data to improve our online store and the services offered, prevent fraud or misuse of the platform, and enable third parties to carry out technical, logistical, and administrative activities necessary for the execution of requested services.
Browsing data
The computer systems and software procedures used to operate this website acquire, during their normal operation and for the duration of the connection only, certain personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes:
Internet Protocol (IP) address associated with the device used to connect;
type of browser and parameters of the device used to connect to the site;
name of the Internet Service Provider (ISP);
date and time of visit;
referral and exit web pages of the visitor;
number of clicks made within the site, if any, and any preference expressed;
other parameters related to the user's operating system and IT environment.
This data may be used to obtain anonymous statistical information on the use of the site and to check its correct functioning, as well as:
to comply with requirements laid down by national and EU regulations;
to establish liability in the event of hypothetical cybercrimes against the site and for investigations in the event of potential disputes.
Only data collected (both via website and App) for surveillance purposes persists on the servers for a period of 12 months.
Data provided voluntarily by the User
The optional, explicit, and voluntary sending of email messages to the addresses indicated on this Site entails the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the communication.
Specific summary information notices, in which consent for the processing of data is explicitly requested where necessary, will be progressively reported or displayed on the pages of the Site set up for particular services on request (newsletter, registration as a site user).
Data resulting from the installation of the APP
The processing of personal data resulting from the installation and use of the "FASHIONPO" APP (hereinafter "App") is carried out to allow the use of services distributed through this application.
Some of the data collected by the App (e.g. geolocation data) may also be used for profiling purposes to offer products and services based on expressed consents.
Following the download and installation of the App, the model used, as well as the type and version of the operating system used, are automatically detected by the mobile device. This information helps us deliver requested performance, manage the App, analyze its use, protect the App and its content from improper or inappropriate use, and improve the user experience.
Personal data is used to make the App available, maintain and improve it, and communicate with users.
The download of the App is also used as numerical data solely to obtain anonymous statistical information regarding the number of users downloading the App itself.
Regarding data saved by the App in the device's keystore, based on the operating system used, please note the following:
Android: data is saved in shared preferences until the customer performs "Clear Data" in Application Management or uninstalls the App;
iOS: data is saved in the keystore;
Windows Phone: data is saved in the keystore until the customer uninstalls the App.
The website Owner is not involved in such processing; for further information regarding the saving and deletion of data on the device, please refer to the manufacturers of the operating systems used.
PURPOSES OF PROCESSING
a) to provide requested services and manage customer relationships. Providing personal data required for these purposes is not mandatory, but refusal to provide it implies the impossibility of executing what is requested;
b) to enable the management of sales made through the FashionPO Marketplace, the transmission to suppliers of data strictly necessary to execute orders, issue invoices, manage returns, complaints, and obligations connected with the execution of the sales contract;
c) to comply with requirements laid down by national and EU regulations;
d) for security purposes (spam filters, firewalls, virus detection), automatically recorded data may possibly include personal data such as IP addresses, which could be used, in accordance with applicable laws, to block attempts to damage the site itself or cause harm to other users, or otherwise harmful or criminal activities.
Said information is processed based on the legitimate interests of the Data Controller.
Secondary purposes of personal data processing
Personal data collected for the above purposes may also be processed to carry out activities functional to promoting and selling products via the website, the APP, and conducting market research and customer satisfaction surveys: providing data for these purposes is optional, and consent is required for processing such data.
By giving consent for processing for Marketing purposes, the data subject specifically acknowledges these promotional, commercial, and marketing purposes in a broad sense (including consequent management and administrative activities) and expressly authorizes them, once consent has been given according to the established procedures, pursuant to the EU Regulation.
As required by Art. 21 of the EU Regulation, it is specifically and separately informed that where personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing, and if the data subject objects to processing for direct marketing purposes, personal data shall no longer be processed for such purposes.
THIRD-PARTY SERVICE PROVIDERS
FASHIONPO uses other companies and individuals to perform certain activities on our behalf.
In addition to the Data Controller, in some cases, categories of in-house personnel involved in the organization of the site (administrative, sales, marketing, legal personnel, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the data.
These providers only have access to personal data that is necessary to perform their duties. We guarantee that they cannot use the same data for other purposes and are also required to process personal data in accordance with this Privacy Policy and applicable data protection regulations.
Please note that IT systems and software procedures governing app operations (Apple Store, Google Play, or Windows Phone Store) acquire, during their normal operation, certain data traceable to the user whose transmission is implicit in the use of internet communication protocols, smartphones, and devices used.
The Data Controller is not involved in such processing and cannot be held responsible for it.
However, data subjects can consult the privacy information made available on the following sites:
Apple Store:
https://www.apple.com/legal/internet-services/itunes/it/terms.html
Google Play:
https://play.google.com/intl/it_it/about/play-terms/index.html
Windows Phone Store:
https://www.microsoft.com/it-it/privacy/privacystatement
SECURITY MEASURES AND PROCESSING METHODS
Personal data is processed using automated tools for the time strictly necessary to achieve the purposes for which it was collected. Specific security measures are observed to prevent data loss, unlawful or incorrect use, and unauthorized access.
COMMUNICATION AND DISCLOSURE
Collected personal data will not be disseminated, sold, exchanged, or communicated to third parties other than the Controller without the explicit consent of the data subject. Communication to third parties—other than the Controller, internal and external Data Processors, and persons authorized to process data designated and appointed under Art. 13 para. 1 letter e) of the EU Regulation—is provided exclusively for pursuing the purposes outlined in the "Data processed on the basis of consent and Purposes of processing" sections of this notice and strictly within those limits, potentially to: third-party companies providing technical and IT support/supplies (companies creating APPs and enterprise management software, etc.), affiliated companies, or third parties providing FASHIONPO with information processing services or complementary activities to those offered by FASHIONPO to enable contract execution, shipping agents, all committed to the correct and regular pursuit of the described purposes. Within the Marketplace service offered via the FashionPO platform, user personal data may be communicated to third-party suppliers who directly market their products through the site.
Such suppliers will process received data as independent Data Controllers and solely for purposes connected to executing the sale, issuing tax documents, managing shipments, returns, complaints, post-sale assistance, and additional obligations under applicable regulations.
FashionPO communicates exclusively data strictly necessary for order execution and is not responsible for subsequent processing carried out by the supplier as an independent Data Controller.
In any case, processing by third parties must take place fairly and in compliance with current legal provisions.
Subject to explicit consent, communication to third-party companies (belonging to the same group as the Data Controller, or third-party suppliers of products related to the Controller's business: e.g., companies selling clothing products and accessories) is envisaged for marketing purposes (traditional or automated) of the latter.
PLACE OF PROCESSING
Data collected by the site is processed at the Data Controller's premises in accordance with applicable laws, namely Fashion Group Prato S.r.l., with registered office located in (59100) Prato (PO), via dei Confini 20, situated in the European Economic Area and acting in compliance with European standards.
COOKIES
This site, like all websites, uses cookies—small text files that allow saving information on visitor preferences to improve site features, simplify navigation by automating procedures (e.g. Login, site language), and analyze site usage.
In particular, session cookies are essential to distinguish between connected users and are useful to prevent a requested feature from being provided to the wrong user, as well as for security purposes to prevent cyber attacks on the site. Session cookies do not contain personal data and last only for the current session, i.e., until the browser is closed. Consent is not required for them.
Functionality cookies used by the site are strictly necessary for using the site, specifically linked to an express request for functionality by the user (such as Login), for which no consent is required.
FashionPo may also use web beacons (including conversion pixels) or other technologies for purposes similar to those described above and integrate them into web pages, marketing emails, newsletters, and affiliated websites to determine if messages have been opened and links clicked. Web beacons do not place data on User devices, but can monitor website activity together with cookies. Information on cookies above applies similarly to web beacons and related technologies.
By using the site, the visitor explicitly consents to the use of cookies.
DISABLING COOKIES
Cookies are tied to the browser used and can be disabled directly from the browser, thereby refusing/withdrawing consent for cookie usage.
Please note that disabling cookies may prevent the proper use of certain site functions; therefore, it will not be possible to access certain features, pages, and sections of our website, and FASHIONPO declines all liability in this regard.
Instructions for disabling cookies are detailed in the "help" menu of the browser in use, where you can modify cookie preferences by following the links found on these web pages:
For Internet Explorer™: Block-or-allow-cookies;
For Safari™: https://www.apple.com/legal/privacy/en-ww/cookies/;
For Chrome™: https://support.google.com/chrome/answer/95647?hl=it&hlrm=en;
For Firefox™: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop.
THIRD-PARTY COOKIES
This site also acts as an intermediary for third-party cookies, used to provide additional services and features to visitors and to improve the use of the site itself, such as social buttons or videos. This site has no control over third-party cookies, which are entirely managed by third parties. Consequently, information on the use and purposes of these cookies, as well as methods for disabling them, is provided directly by third parties on the pages indicated below.
Specifically, this site uses cookies from the following third parties:
Google Analytics: an analysis tool from Google that, through the use of cookies (performance cookies), collects anonymous browsing data (IPs truncated at the last octet) exclusively aggregated to examine site usage by users, compile reports on site activity, and provide other information, including visitor numbers and pages visited. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. Data sent to Google is stored on Google servers in the United States.
Under a specific agreement with Google, designated as Data Processor, Google undertakes to process data according to instructions given by the Controller (see bottom of notice) via software settings. Based on these settings, advertising and data-sharing options are disabled.
Further information on Google Analytics cookies can be found on the Google Analytics Cookie Usage on Websites page.
Users can selectively disable data collection by Google Analytics by installing this plugin on their browser: https://tools.google.com/dlpage/gaoptout?hl=en.
Youtube: a platform owned by Google for video sharing that uses cookies to collect user and device browsing information. Videos on the site do not deliver cookies upon accessing the page, as the "advanced privacy (no cookies)" option has been set, under which YouTube does not store visitor information unless they voluntarily play the video.
cookie: test_cookie .doubleclick.net is not a permanent cookie, but is used to check whether the user's browser supports cookies.
For further information on data use and processing by Google, please review the information on the designated Google page and the page regarding How Google uses data when you use our partners' sites or apps.
SOCIAL NETWORK PLUGINS
This site also incorporates plugins and/or buttons for social networks to allow easy content sharing on your favorite social networks. These plugins are programmed not to set any cookies upon accessing the page to safeguard user privacy. Cookies may be set, if provided for by social networks, only when the user makes actual and voluntary use of the plugin. Note that if the user browses while logged into the social network, they have already consented to the use of cookies delivered through this site when signing up for the social network.
The collection and use of information obtained via plugins are governed by the respective privacy policies of the social networks, to which please refer.
TRANSFER OF DATA TO EXTRA-EU COUNTRIES
This site does not transmit collected data outside the European Union. All our servers and Processors are located within the Union. Exceptions apply to data processed by Google through Google Analytics and Google Maps, where transfer is authorized based on "Standard Contractual Clauses" and additional measures as per EDPB Recommendation No. 1/2020.
USER RIGHTS
Pursuant to European Regulation 679/2016 (GDPR) and in accordance with the Privacy Decree No. 101/2018, Users may, under the terms and limits set by current regulations, exercise the following rights:
request confirmation of the existence of personal data concerning them (right of access);
obtain information about the logic, methods, and purposes of processing;
request updating, rectification, integration, erasure, anonymization, or blocking of data processed in violation of the law, including data no longer necessary for the purposes for which it was collected;
in cases of consent-based processing, receive—at the sole cost of any medium—their data provided to the controller and held by it, in a structured, commonly used, and machine-readable format;
the right to lodge a complaint with the Data Protection Authority or Judicial Authority;
pursuant to Art. 2-terdecies of Privacy Decree No. 101/2018, all rights (Arts. 15 through 22 of the EU Regulation) relating to personal data concerning deceased persons may be exercised by anyone who has an interest of their own or acts to protect the data subject as their agent, or for family reasons deserving protection;
as well as, more generally, exercise all rights recognized by current legal provisions.
Requests should be addressed to the Data Controller.
Where data is processed based on legitimate interests, data subjects' rights are guaranteed (except portability right, which is not provided by rules), particularly the right to object to processing, which can be exercised by sending a request to the Data Controller. It is possible to object to processing of personal data:
a) for legitimate reasons;
b) (without needing to justify objection) when data is processed for commercial or marketing purposes.
WITHOUT PREJUDICE TO LIMITATIONS ON DATA SUBJECT RIGHTS UNDER ARTS. 2-undecies AND 2-duodecies LEGISLATIVE DECREE No. 101/2018
APPEAL
If the User believes that the above rights regarding personal data protection have been violated, the data subject may lodge a complaint with the Data Protection Authority pursuant to Art. 77 of the Regulation and Art. 141 of the Privacy Decree or bring legal proceedings before the Judicial Authority pursuant to Arts. 78 and 79 of the EU Regulation and Arts. 152 et seq. of the Privacy Decree.
DATA CONTROLLER
The Data Controller under current laws is Fashion Group Prato s.r.l., located at Via dei Confini 20, 59100 Prato, contactable via the CONTACTS section.
DATA PROCESSOR
To know the appointed internal and external Data Processors, the Data Controller refers to the corporate privacy policy.
For any communication, you can contact the Controller via email: web@fashionpo.com.
Google is appointed Data Processor, processing data on behalf of the controller (Google Analytics).
