WEBSITE PRIVACY POLICY

 

Effective Date: 02 January 2019

 

This Privacy Policy sets out how Fiorelli uses and protects any personal data that you provide to us either in store or when you use this website www.fiorelli.com (“Website”). Fiorelli is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this Privacy Policy. Fiorelli may change this Privacy Policy from time to time by updating this page. Please check back frequently to see any updates or changes to this Privacy Policy.

 

GBG Europe Footwear & Accessories Limited is the controller of your personal data.

 

INDEX

 

            1. HOW IS YOUR PERSONAL DATA COLLECTED

            2. PURPOSES FOR PROCESSING YOUR PERSONAL DATA

            3. MARKETING

            4. SHARING YOUR PERSONAL DATA

            5. INTERNATIONAL TRANSFERS

            6. DATA RETENTION

            7. YOUR RIGHTS

            8. CONTACT US

 

 1.   HOW IS YOUR PERSONAL DATA COLLECTED

 

We may process your personal data when you submit it to us in the following ways:

 

• Communications via our Website. We collect personal data when you provide it to us through communications via our Website. This includes where you have contacted us through the channels listed on the “Contact Us” page on our Website and similar situations in which you have chosen to provide the information to us, including for customer services support.

 

• Goods or services you request. Where you request a good or service from us, we will collect your personal data in order to process your request and otherwise contact you following a purchase.

 

• Automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

 

• In-store. In certain cases, we ask you to provide us with your contact details in store to allow us to send you marketing materials.

 

• CCTV. We operate CCTV cameras in our stores. Where you enter one of our stores and come within the range of our CCTV cameras, we will collect and process your personal data. We will not collect or process your biometric data through our CCTV systems. [EW1] 

 

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, for example providers of technical, payment and delivery services.

 

The type of personal data we may collect includes identity data (including name and title), contact data (including postal address, email address and telephone numbers), financial data (including bank account and payment card details), transaction data (details of products and services you have purchased from us) profile data (including your interests, preferences, feedback and survey responses) and photographs and video images which may later be used to identify you.

 

 2.   PURPOSES FOR PROCESSING YOUR PERSONAL DATA

 

We process any personal data you provide to us to enable us to perform the contract we are about to enter into or have entered into with you, to ensure compliance with local legal and regulatory requirements and for the purposes of our legitimate business interests, including:

 

• to enable us to carry out our obligations arising from any contracts and to provide you with the information, products and services that you request from us;
• to enable us to respond to an enquiry or other request you make when you contact us via our Website or otherwise, including for customer services support;
• to notify you about changes to our service;
• to enable us to issue a notice or corrective action to you in relation to any of our products or services, if required;
• to better understand how you interact with our Website, including its functionality and features, and ensure that content is presented in the most effective manner;
• to enable us to send you direct marketing that you have consented to receive;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about and we feel may interest you, as described in the “Marketing” section below; and
• to monitor and collect video evidence of any crime or wrongdoing in our stores.  

 

 3.   MARKETING

 

We may contact you to provide you with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. We may also contact you to provide you with information about goods and services by way of direct marketing that you have consented to receive during a visit to one of our stores. You may be contacted by us, Global Brands Group affiliated companies, or by one of our selected partners, in each case where you have consented to receive these communications.

 

You may opt out of receiving our marketing communications at any time by contacting us at enquiries@fiorelli.com or by using the unsubscribe link in any of our communications.

 

We will continue to contact you for non-marketing related purposes where we need to issue a field corrective or safety notice, or where we need to send certain information to you under a legal, regulatory, or ethical requirement.

 4.   SHARING YOUR PERSONAL DATA

 

We may share your personal data with:

 

• other companies within the Global Brands Group;
• our selected commercial partners and sponsors where you have chosen to participate in surveys, opinion groups or other marketing-related initiatives relating to your use of our goods and services;
• a prospective seller or buyer in the event of a sale or purchase of any Global Brands Group business or asset so that the buyer can continue to provide you with information and services;
• our service providers that we engage to provide services for us. Where we provide your personal data to third party services providers, they are required to keep your personal data confidential and secure, and must only use your personal data as instructed by us;
• our distributors, business partners, or other service providers, including for marketing purposes or where you have chosen to share your personal data through various features and functionality provided via our Website; and
• law enforcement agencies, for the purposes of reporting or evidencing a crime.

 

We may also disclose your personal data where required to respond to authorised requests from government authorities or where required by law.  Where we are required by law, we may also disclose your personal data where it is necessary to enforce or apply this Privacy Policy or other agreements; to investigate or protect the rights, property or safety of Fiorelli and other companies within the Global Brands Group, our products and services and our customers, distributors or business partners; or to prevent or take action regarding illegal activities or fraud, situations involving potential threats to the safety of any person or as evidence in litigation. 

 

 5.   INTERNATIONAL TRANSFERS

 

We may share your personal data within the Global Brands Group. If you are located in the European Economic Area (“EEA”), this will involve transferring your data outside the EEA.

 

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

 

• where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

 

• where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

 

For further information on the specific mechanism used by us when transferring your personal data outside of the EEA, please send your request to enquiries@fiorelli.com. We will process any request in line with any local laws and our policies and procedures.

 6.   DATA RETENTION

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 7.   YOUR RIGHTS

 

You may inform us of any changes in your personal data, and in accordance with our obligations under applicable data protection laws we will update or delete your personal data accordingly.

 

EEA residents: You may have the right to: request (a) access to the personal data we hold about you; (b) request we correct any inaccurate personal data we hold about you; (c) request we delete any personal data we hold about you; (d) restrict the processing of personal data we hold about you; (e) object to the processing of personal data we hold about you; and/or (f) receive any personal data we hold about you in a structured and commonly used machine-readable format or have such personal information transmitted to another company.

 

We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you.

 

To exercise any of your rights in connection with your personal data, please contact enquiries@fiorelli.com. We will process any request in line with any local laws and our policies and procedures. If you are located in the EEA, you have the right to lodge a complaint about how we process your personal data with the supervisory authority in your country.

 8.   CONTACT US

 

If you have any questions about the processing of personal data via this Website, please contact us by email at enquiries@fiorelli.com. If you contact us, we will do our utmost best to address any concerns you may have about our processing of your personal data. 

Cookies

1.         How we use cookies and similar technologies

 

GBG Europe F&A Limited uses cookies and similar technologies including web beacons, embedded scripts and e-tags (together referred to as “cookies”, unless otherwise stated) to provide users an efficient experience in using the website.

 

Cookies are small text files that are sent to your computer when you visit a website. Cookies are widely used by web site owners in order to make their web sites work, like letting you navigate between pages efficiently, storing your preferences and generally improving your experience of a website.

 

A cookie file can contain information such as a user ID that the site uses to track the pages you have visited, but the only personal data a cookie can contain is information you supply yourself. A cookie cannot read data off your hard disk or read cookie files created by other sites. Some parts of our website use cookies to track user traffic patterns. We do this in order to determine the usefulness of our website information to our users and to see how effective our navigational structure is in helping users reach that information. We do not connect this information with data about individual users. nor does it share this information or sell it to any third party.

 

By using our website you accept our use of these cookies. If your browser settings are set up as ‘Do Not Track’, we will not use cookies and tracking technologies.  See section four below for more details on how you can opt-out of cookies.

 

Here are some additional things you should know about our use of cookies:

 

• you may encounter cookies from our third party service providers that we have allowed on our website that assist us with various aspects of our website operations and services.
• you also may encounter cookies from third parties on certain pages of the websites that we do not control and have not authorised. For example, if you view a web page posted as a link from our website, there may be a cookie placed by that web page.

 2.              Cookies used on our website

 

We use cookies for a variety of reasons, including providing you the service you have requested, to enhance the performance of and analyse how our website is used and to enhance your online experience, for example, by remembering your log-in status and viewing preferences from a previous use of our website.

 

Our use of cookies falls into four categories:

 

• Strictly necessary cookies: required for the operation of our website. These include for example, cookies that enable you to log into secure areas of our website, to move around the website and use its features such as use the shopping basket when making a purchase. 
• Performance cookies: also known as “analytical” cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around the sites when they are using them. For example, they allow us to understand which pages are visited most often, and if they get error messages from web pages. All information collected by these cookies is aggregated and therefore anonymous.
• Functionality cookies: these cookies are necessary for our website to operate and allow us to remember what choices you make and provide enhanced, more personal features. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
• Advertising and marketing cookies: these cookies are used to send you advertising and marketing-related material tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.

 

We may change our use of cookies over time, but our use of cookies will generally fall into the above categories. Please visit this page regularly so that you are aware of any changes.

 3.              Google Analytics

 

This website uses Google Analytics to collect information about how users use the website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. In case IP-anonymization is activated on this website, your IP address will be partially used within the European Union or just in the European Economic Area if it is used by other parties. Only in exceptional cases will the full IP address be transferred to a Google server in the United States, and then shortened so it is only partially used there. The IP-anonymization is active on this website.

 

Google will use this information on behalf of the operator of this website for the purpose of analysing your use of the website, compiling reports on website activity for website operators and providing them other services relating to website activity and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser; please note, however, that if you do this you may not be able to use the full website. You can also opt-out from being tracked by Google Analytics in the future by downloading and installing ‘Google Analytics Opt-out Browser Add-on’ for your current web browser: http://tools.google.com/dlpage/gaoptout?hl=de.

 

Alternatively, you can opt-out from being tracked by Google Analytics in the future by clicking on the following link: https://tools.google.com/dlpage/gaoptout.

 4.              Opting out of cookies

 

You have the right to decide whether to accept or reject cookies. If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set. If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; please visit your browser's help menu for further details. Please note that if you choose to reject cookies, doing so may impair some of our website functionality.

 

For more information and how cookies they can be managed and deleted please visit http://www.allaboutcookies.org/ or http://www.networkadvertising.org/choices/.

List of cookies we collect

The table below lists the cookies we collect and what information they store.

COOKIE name	COOKIE Description
CART	The association with your shopping cart.
CATEGORY_INFO	Stores the category info on the page, that allows to display pages more quickly.
COMPARE	The items that you have in the Compare Products list.
CURRENCY	Your preferred currency
CUSTOMER	An encrypted version of your customer id with the store.
CUSTOMER_AUTH	An indicator if you are currently logged into the store.
CUSTOMER_INFO	An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS	Stores the Customer Segment ID
EXTERNAL_NO_CACHE	A flag, which indicates whether caching is disabled or not.
FRONTEND	You sesssion ID on the server.
GUEST-VIEW	Allows guests to edit their orders.
LAST_CATEGORY	The last category you visited.
LAST_PRODUCT	The most recent product you have viewed.
NEWMESSAGE	Indicates whether a new message has been received.
NO_CACHE	Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART	A link to information about your cart and viewing history if you have asked the site.
POLL	The ID of any polls you have recently voted in.
POLLN	Information on what polls you have voted on.
RECENTLYCOMPARED	The items that you have recently compared.
STF	Information on products you have emailed to friends.
STORE	The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE	Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS	The products that you have recently viewed.
WISHLIST	An encrypted list of products added to your Wishlist.
WISHLIST_CNT	The number of items in your Wishlist.