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INFORMATION FOR USERS REGARDING REGISTRATION ON THE WEBSITE
pursuant to article 13 and 14 of the EU General Regulations no. 679/16 on the protection of personal data and Law Decree No. 101/2018


Pursuant to articles 13 and 14 of the EU General Regulations No. 679/16 regarding the protection of personal data and in compliance with Law Decree No. 101/2018, the company Fashion Group Prato S.r.l., hereinafter FASHIONPO, with registered offices at via del Carmine 11, Prato (PO), in its capacity as data controller, informs users wishing to register on the website www.fashionpo.com, as Data Subjects, the purposes and methods used to process the personal data collected, the scope of communication and dissemination, as well as the way in which data are used.


1) Data for processing

- Personal data stated on the registration form (name, surname, email address, telephone number etc) provided and collected from the data subject and voluntarily transmitted during registration on the FASHIONPO website.

- Computer Data, such as the user’s IP address.

 

2) Purpose of data processing

- Personal data are processed with the purpose of creating a personal account, further to a request by the data subject itself, to be used for the various services offered by the Data Controller via the website and to access the online portal.

The data can also be used for the purpose of so-called “soft spam”.

- Data such as email address and phone number, if permitted by the data subject, are also used for the delivery of commercial and promotional communications and informational messages related to the activities and services of the Data Controller, through automated means (such as email and text message) and traditional media (such as telephone contact with or without operator) , in full observance of the principles of lawfulness and fairness and the provisions of law.

- Email address and telephone number, if permitted, may be communicated to third-party companies (belonging to the same group as the Data Controller, or third-party companies for the supply of products related to the activity of the owner: e.g., company selling clothing and accessories) for marketing purposes (traditional or automatic) of the latter.

In any case, processing will take place in full compliance with the principle of fairness and legality and applicable laws.

- The computer data acquired, such as your IP address, will be processed to allow access to the services offered by the site owner via the company website and reserved to registered users, or, for example but not limited to access to the reserved area, the collection and management of orders submitted by users through the website , payment for the products, the delivery of the purchased products.


3) Processing methods

Processed personal data are sent to the Controller’s server or to servers managed by third parties. Data are stored in electronic and hard copy files with full insurance of the minimum security measures provided for by law. The Data Controller must take all necessary safety precautions to minimize the risk of destruction, loss, unauthorized access, or access which is not allowed or not compatible with the purpose of collection of personal data.


4) Communication and dissemination

The personal data collected will not be disclosed, sold, traded or communicated with any third party other than the Data Controller, without the express consent of the data subject. Communication to third parties, other than the Controller, by internal or external processors, and by identified and appointed processors ex art. 13 para. 1 letter e) of the EU Regulations is permitted for the sole pursuit of the purposes as set out in point 2 of this information sheet and in all cases within said limits, to: subjects and third-party companies supplying technical and computer assistance (e.g. companies that make the APPs and the company management system, etc.), affiliated companies or other third parties that provide information processing services to FASHIONPO or activities complementary to those offered by FASHIONPO , to allow the execution of the contract, shippers, all engaged in proper and regular pursuit of the purposes described.

In any case, processing by third parties will be made fairly and in compliance with current laws.

Subsequent to express agreement, communication will be made to third-party companies (belonging to the same group as the Data Controller, or third-party companies for the supply of products related to the activity of the owner: e.g., company selling clothing and accessories) for marketing purposes (traditional or automatic) of the latter.

 

5) Nature of provision

The provision of data is optional, but necessary because any refusal to do so will make it impossible for the Data Controller to create a personal account to use the services offered by the site owner via the corporate website reserved to registered users.

With regard to the provision of data for marketing purposes, the same is optional and the refusal is not affected and will not affect the main processing function, but it will make it impossible for the holder to comply with accessory requests. The same applies to the granting of consent to the communication of personal data to third parties for marketing purposes of the latter.


6) Mandatory and optional nature of consent

In all the cases illustrated above in points 2 and 3 (for hypotheses of communication to third parties) the company FASHIONPO has no obligation to acquire specific consent for data processing. Also, all processing as above pursues the primary purposes for which article 6, para. 1, letters b), c) e) and f) of the EU Regulations excludes the need to acquire specific consent.

 Providing personal data to FASHIONPO and giving both consent for data processing for marketing purposes and separate consent for communication to third parties for processing for marketing purposes for the aims and with the methods shown above is entirely optional and discretionary (and can be revoked without formality also after providing consent) and not providing said data, as specified in point 5 above, will have no other consequence than the impossibility for FASHIONPO and for any third party to proceed with the mentioned marketing processing.

If marketing consent is denied, there will be no interference and/or consequence to one’s own personal account.

In all cases, and only in reference to the use of the email provided by the data subject at the time of registration, you are informed that FASHIONPO can send informative and advertising material only if solely relating to similar products and/or services to the ones for which the data subject originally provided marketing consent.

In this case, the data subject retains the right to oppose processing at any time (notifying his opt-out to the email address info@fashionpo.com. ) if they should receive any. In all cases, the data subject, when receiving any emails sent by FASHIONPO for said purposes, will be duly informed of the possibility of opposing processing at any time, in a simple manner, free of charge. Such opposition will have no consequence on the affiliation, or on other federal or other types of relationship.

Please note that individual consents are deemed freely provided by checking the "I consent" boxes present under the registration form.

 

7) Retention times

Data will be retained for the times set out in the reference laws, pursuant to article 13, paragraph 2, letter a) of the Regulations.

In particular, the data will be kept for the time necessary to fulfil the purpose of managing the account created by the data subject to access the services offered by the Data Controller via the corporate website. In any case the data will be kept until the request to delete the account, or if this is deleted by the owner.

With regard to processing for the purposes of sending commercial communications and promotional services of the Data Controller and to send informational messages relating to its activities, if agreed, the data will be stored no later than two years from the first contact, subject to the objection to processing by the party concerned. The opposition to processing can be advanced by the data subject, independently of the method used to send same (traditional or automatic), in particular, for phone numbers found on the lists it is necessary to oppose processing by registration on the Public Opt-out register, while for email, deletion is provided through referral to the appropriate link. In any case, deletion can be requested by sending a fax to 0574/621397 or by sending an e-mail to the address info@fashionpo.com.

In reference to personal data subject to processing for Marketing purposes or to processing for profiling purposes, said data will be retained in observance of the principle of proportionality and until the purposes of said handling have been pursued or until - if prior to the former - consent by the data subject is not specifically revoked.

In all cases, civil law, accounting, fiscal data will be retained for a term of ten years, as provided for by law.

 

8) Consent of minors

In compliance with art. 8, paragraph 1 of the EU Regulations and pursuant to art.2-quinquies of the Privacy Decree No. 101/2018, minors over 14 years of age may express their consent to the processing of their data also for marketing purposes. The consent of minors under the age of 14 is permitted on condition that it is provided by those exercising parental authority.

In compliance with art. 2-quinquies of the Privacy Decree, FASHIONPO, when preparing the registration and acquisition of consent forms, uses a particularly clear and simple language, concise and exhaustive, easily accessible and comprehensible in order to make the consent given by the minor valid related to the direct offer also to possible Users (over the age of 14).

 

9) Exercising the data subject’s rights

Pursuant to articles 13, paragraph 2, letters (b) and (d), 15, 18, 19 and 21 of the Regulations, and pursuant to the Privacy Decree No. 101/2018 interested users are informed that they have the right to ask the company FASHIONPO, as the Data Controller, to access their personal data, to correct or delete them or to limit processing that concerns them or to oppose processing, in the foreseen cases; they have the right, as individuals, to file a complaint to the Data Protection Authority, following the procedures and indications published on the Authority’s official website at www.garanteprivacy.it.  Any corrections, deletions or limitations to processing carried out on the subject data’s request - unless it proves impossible or implies a disproportionate effort - will be communicated by FASHIONPO to each of the recipients to whom personal data has been sent. The company FASHIONPO can communicate said recipients to the interested party if the latter should request it. Exercising rights is not subject to any restriction of kind and is free of charge. The address for exercising rights is: info@fashionpo.com

 

10) User's rights

Pursuant to the European Regulations 679/2016 (GDPR) and Privacy Decree No. 101/2018, users may exercise the following rights, according to the methods and limitations established by current law:

- request confirmation of the existence of the personal data concerning him/her (right of access);

- receive information regarding the logics, methods and purposes of the data processing;

- request the updating, correction, integration, erasure, transformation into anonymous form, blocking of the data processed in violation of the law, thereby including those no longer necessary to pursue the purposes for which they were collected;

- in cases of processing based on consent, receiving, only at the cost of any medium, the data provided to the data controller, in a structured, legible format from a computer and in a format commonly used by an electronic device;

-the right to lodge a complaint with the Data Protection Authority or the judicial authority;

- Pursuant to Article 2-terdecies of the Privacy Decree No. 101/2018, all rights (from Article 15 to article 22 of the EU Regulations) concerning the personal data related to deceased individuals may be exercised by those who have a direct personal interest or act to protect the concerned party, in the role of proxy agent, or acting for family reasons worthy of protection.

- as well as, in more general terms, exercise all the right granted by the regulations in force.

All requests must be submitted to the Data Controller.

If the data are processed based on legitimate interests, the right of the data subject for processing are guaranteed (except the right to portability that is not provided for by law), in particular the right to opposing the processing, which may be exercised by submitting a request to the Data Controller. It is possible to oppose the processing of one’s personal data:

A) for legitimate reasons;

b) (without the need to give reason for said opposition) when the data are processed for commercial or marketing purposes.

WITHOUT PREJUDICE TO THE LIMITATIONS TO THE RIGHTS OF THE INTERESTED PARTIES REFERRED TO IN ARTICLES 2- undecies and 2-duodecies of Law Decree No. 101/2018

 

11) Recourse

If the User deems that the aforementioned rights regarding the protection of personal data were violated, the interested party may lodge a complaint with the Data Protection Authority pursuant to art. 77 of the Regulations and art. 141 of the Privacy Decree or file a claim at the Judicial Authority pursuant to art. 78 and 79 of the EU Regulations and pursuant to art. 152 and following of the Privacy Decree.

 

12) Data Controller and Processors

The Data Controller is the company Fashion Group Prato S.r.l., with registered offices in via del Carmine 11, (59100) Prato (PO).

To learn about the appointed internal and external Processors, the Data Controller refers to the company privacy policy.

For all communications, it is possible to contact the Data Controller at the email address: web@fashionpo.com.