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FURLA PRIVACY NOTICE

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”), processes your data, in accordance with European Regulation 2016/679 (“GDPR”) and the data protection law applicable in your country, territory or location (together with the GDPR, the “Privacy Laws”).

a)    When personal data are collected?

Your personal data may be collected in the following occasions:

  1. if you wish to join the Furla loyalty program (“My Furla Program”) and become a registered client (“My Furla Client”);
  2. if you purchase Furla products or services, as 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) or through one of the Furla website, the Furla app or any other social media regarding Furla (the “Online Channels”); or
  3. in the occasion of any Furla promotional initiatives (such as game or prize competitions).

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:

  1. your subscription to the My Furla Program to register you as a My Furla Client;
  2. any service related to any Furla promotional initiatives worldwide (such as game or prize competitions);
  3. the 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 shipping, delivery, management of returns and after-sale support, there will be autonomous data controllers, as follows:

Furla S.p.A.

  • for the purchase at one of the Furla point of sales located in Italy or
  • for the purchase through one of the Online Channels available in the EU countries.

Each Furla local affiliate (please see below the list of those local affiliates adhering to the My Furla Program)

 

The privacy notices of each Furla local affiliates in Japan is available here, in US here, in Australia here, in New Zealand here and for those Furla local affiliates in EU and Switzerland can be requested in-store at the time of purchase.

  • for the purchase at one of the Furla’s affiliate point of sales adhering to the My Furla Program, not located in Italy, or
  • for the purchase through one of the Online Channels available in the non-EU countries.

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.

  • for the purchase at one of the point of sales of the 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 may process your personal data for the following purposes, on the following legal basis:

Personal data’s categories

Purposes

Legal basis

name, date of birth, tax code, 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 legal obligations and other obligations arising from instructions received from authorities

compliance with a legal obligation to which Furla is subject (art. 6, para.1 let. c) GDPR)

 

name, date of birth, 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 (art. 6, para.1 let. b) GDPR)

name, date of birth, tax code, 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 competition)

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 (art. 6, para.1 let. b) GDPR)

name, date of birth, address, telephone number, e-mail address

(4) to carry out marketing and promotions initiatives relating to Furla entities and Furla’s products and services, whether by post, email, telephone, SMS or social media, 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 of the fashion, luxury goods and the like. If you prefer to receive marketing communications by traditional means only (i.e., by post or non-automated telephone calls), please write to privacy@furla.com.

In addition, Furla may process your data for market research, statistical analyses, or other research to improve its products and services, and for customer satisfaction analysis.

 

your consent to the processing for these specific purposes (art. 6, para.1 let. a) GDPR)

name, date of birth, address, data concerning hobbies, job, interests, purchase data (e.g., purchased products, location, date and time of purchase, delivery data), viewed products

(5) to analyse your consumer habits on Furla’s retail channels (in-store or within the Online Channels), 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 (art. 6, para.1 let. a) GDPR)

Furla may also process your personal data regarding your online browsing history collected during your visits at the website (whether you are registered client or not), by using tracking technologies such as “cookies” (for information on data collection through cookies, please see our Cookies Policy).

d)    How your personal data are processed and protected?  

Your personal data may be processed, either electronically or in hard copy form. Furla will take reasonable steps to ensure that your information are kept secure, only used for the purposes set forth in this privacy notice (and not for any other purposes), and are able to be accessed or corrected upon your request.

Furla uses reasonable organizational, technical and administrative measures to help protect against the loss, misuse and alteration of the personal information under its control. However, no data transmission over the Internet or data storage system can be guaranteed to be 100 percent secure, so please do not send us information you consider confidential via e-mail. It is your personal responsibility to secure your own copies of your passwords and related access codes for our online resources.

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.

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 point c) (1) (legal duties), (2) (registration as My Furla Client), and (3) (contractual purposes). If you do not wish Furla to process your data for these purposes, Furla will respect this. However, in this event, you will be unable to register as a My Furla Client and use the additional services that Furla offers to registered clients, register to the Website, purchase products online or as a registered client or to participate to Furla’s initiatives.

Providing data for the purposes set out under point c) (4) (marketing purpose) and (5) (profiling purpose) is instead 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: privacy@furla.com.

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?

Furla will not disseminate your personal data.

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, 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 in the Furla’s CRM database which will be accessible to those Furla local affiliates or partners joining the My Furla Program that act as data processors on behalf of Furla.

This way, Furla will share your data within the companies of the Furla network, 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 Furla sales staff based at the local points of sale (e.g. if you visit a Furla store in another country, your personal information will be accessed in that store).

Companies within the Furla network includes parent companies, subsidiaries and affiliates of Furla 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 joiners.

Where your personal data are sent to countries other than your country of residence or in countries outside the EEA as part of the My Furla Program, your data will be protected by adequate safety systems, which are constantly updated and maintained in accordance with applicable Privacy Laws (for example specific data processing agreements are in place and the non-EU Processors have signed the model clauses approved by the EU Commission). You can request a copy of the EU Standard Contractual Clauses by emailing: privacy@furla.com

Depending on the service, Furla may also share your personal data (provided through your registration or during a purchase - e.g., name, date of birth, 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) to specialized companies which Furla entrusts, as data processors, with duties of technical and organizational nature that are necessary to manage relationships with clients. These include companies that provide customer care, payment, shipping or storage services for the purchase of the products or 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. The data you provide to purchase online, such as your credit card details, will be processed exclusively by external providers acting as Furla data processors. Your personal data will not be transferred outside the EEA. In case it is necessary to transfer your data outside EEA, we will adopt appropriate measures to ensure that your personal data will be adequately protected. A list of these companies is available at Furla’s head office and can be requested by emailing: privacy@furla.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 addressed profiled marketing communications promoting Furla’s products which are sold at certain prices;

-      information processed: name, date of birth, 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, use Online Channels, and purchase products as a registered client;

-      how the information provided impact the decision: the profiling is based solely on the data you provide, therefore the outcome depends totally on it;

-      measures to mitigate possible risks: a specific DPIA on the profiling activity has been conducted to ensure its impartiality, effectiveness and absence of harmful consequences and you can request a copy of the main summary by sending a request to the following email address: privacy@furla.com

Processing significance and envisaged consequences of such processing

Visits on the Online Channel and 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 to obtain confirmation of the existence or non-existence of personal data relating to you and to request from Furla access to and rectification or erasure of personal data or restriction of processing concerning you or to object to processing as well as the right to data portability.  

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).

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 address may be used for sending promotional communications relating Furla products or services similar to those you already benefit from. 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: privacy@furla.com.

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 the Privacy Laws.

To exercise these rights, you may contact Furla by sending a request to the following email address: privacy@furla.com.

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: dpo@furla.com.

j)      Sharing of data scheme (for Japanese customers)

  1. 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.
  2. 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.
  3. 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: privacy@furla.com.
  4. 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).
  5. Furla S.p.A. is the data controller and the entity in charge of management of the personal data.

 

FURLA LOCAL AFFILIATES ADHERING TO THE MY FURLA PROGRAM

FURLA S.P.A.

Via Bellaria 3/5 40068 San Lazzaro di Savena, Bologna, Italy

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. Floriańska 2 - 03-707 Warszawa, 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, USA

FURLA SWITZERLAND SA

Beroldingen 26 CH- 6850 Mendrisio, Switzerland

FURLA PRAGUE S.R.O.

Jindřišská 937/16, New Town, 110 00 Prague 1, Czech Republic

FURLA AUSTRALIA PTY LTD

Level 10, 379 Collins Street, Melbourne Vic 3000, Australia

FURLA LOCAL PARTNER ADHERING TO THE MY FURLA PROGRAM

THE RIVER SRL

ITALY – MONZA – Via Italia, 37

RO-RO SRL

ITALY - PADOVA - Via Santa Lucia, 16

ITALY – VENEZIA – San Marco, 4833/4834

FALCOMER S.R.L.

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

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

BABA' SRL

ITALY – TAORMINA – C.so Umberto I, 48

ETRUSCA SRL SOCIO UNICO

ITALY - TORINO - P.zza CLN, 255

CALZABELLA SRL

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