FURLA SH PRIVACY NOTICE

Last updated on 27th July 2020

This notice explains how Furla Retail (Shanghai) Co., Ltd. a company incorporated under the laws of the People’s Republic of China, with its registered office at Room 305, 3/F, No 2000 YiShan Road, Shanghai China 201103 (“Furla SH”), collects, uses, or processes the personal data of clients, in accordance with data protection laws and regulations applicable in the People’s Republic of China (“Privacy Laws”).

a) WHEN AND WHAT TYPE OF DATA IS COLLECTED?

Furla SH may collect data from users that wish to register as a client of Furla SH (“Furla Client”), buy Furla products or receive Furla services: (i) at one of the Furla SH physical location points of sale; (ii) through the Furla SH website, https://www.furla.cn/cn/en/ (the “Website”), or any other social media or other platforms related to Furla SH; (iii) in the occasion of Furla SH promotional initiatives; or (iv) through non-Furla SH e-commerce platforms that are authorized to sell Furla products in the People’s Republic of China through the Internet, such as tmall.com.

Depending on your request or consent, personal data may include: (i) the personal data you provide through your registration (e.g., name, date of birth, address, post code/zip code, occupation, telephone number, e-mail address, etc.); (ii) your purchase data (which includes location, date and time of purchase, delivery data, product and payment data); (iii) your data concerning your hobbies, job, interests; or (iv) data about your online browsing history or activity (whether you are a registered Furla Client or not), by using tracking technologies such as “cookies” (for information on data collection through cookies, please see our Cookies Policy [http://www.furla.cn/cn/en/cookie-cn]) (“Personal Data”).

The Personal Data collected from you when you register as a Furla Client or otherwise provide personally identifying information, for example through the Website, is protected, and your rights under Privacy Laws are set forth in paragraph i) below.

b) WHO CONTROLS YOUR DATA?

Furla SH is the data controller and the entity in charge of management of the Personal Data. Furla SH will take a lead to control and process the Personal Data of users that register as Furla Clients, to manage the Furla Client subscription, and for marketing and profiling purposes (please see paragraph c) below).

The e-commerce services (online sales) are managed by Furla SH in cooperation with Shanghai Xingyun Information Technology Co. Ltd. (“Shanghai Xingyun”), Furla SH’s resale agent, which jointly acts with Furla SH as data controller and processor of data regarding online purchases in accordance with the following specific scope of duties: (i) Shanghai Xingyun oversees the management of all purchase steps, including payment (for which it will be the data controller) and user registration (for which it will be the data processor); and (ii) Furla SH oversees shipping, delivery, management of returns, and after-sale support. The data you provide to purchase online, such as your credit card details,will be processed exclusively by Shanghai Xingyun. Furla Shanghai have signed strict confidentiality agreement with Shanghai Xingyun to request it to process Personal Data according to the instruction of Furla Shanghai, this privacy notice and any other related confidentiality and security measures.

c) HOW DO WE USE THE DATA COLLECTED?

Furla SH may process your Personal Data for the following purposes:

    i. to fulfil Furla SH’s legal obligations, and other obligations arising from instructions received from authorities;

    ii. to register you as a Furla Client, which allows you to benefit from offers and services exclusive to registered clients (you will receive a confirmation email after registration);

    <>iii. to fulfil, together with Shanghai Xingyun if necessary, obligations strictly connected to the use of, and instrumental to enable the use of, relevant websites and e-commerce platforms, as well as to manage the contractual relationship, purchase of products and accessories, and any subsequent after-sale assistance or to participate to Furla SH’s initiatives (e.g. a competition)

    iv. to carry out marketing and promotions initiatives, including those relating to Furla S.p.A., a company incorporated under Italian law, with registered office at Via Bellaria 3/5, 40068 San Lazzaro di Savena (“Furla HQ”), Furla SH, other local affiliates (together with Furla SH and Furla HQ referred to as the “Furla Group”), Furla’s Partners, and Furla’s products and services, whether by electronic means, by email and post, or by telephone, SMS, or social media, or by sending newsletters (for example, to be updated on Furla’s new products and to find out about events, contests, demonstrations, loyalty programmes, etc. organised by Furla), also by using automated means. 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 [online.cn@furla.com]. In addition, Furla SH may process your data for market research, statistical analyses, or other research to improve its products and customer satisfaction analysis

    v. to analyse consumer habits on Furla SH’s retail channels (e-store or brick and mortar stores), for example, in relation to purchased products, viewed products, or stores where purchases were made, in order to provide personalized offers that are in line with the users’ interests.

d) HOW IS YOUR DATA PROTECTED?

Furla SH will take reasonable steps to ensure that your information is kept secure, only used for the purposes set forth in this Furla Privacy Notice (and not for any other purposes) and is able to be accessed or corrected upon your request.

Furla SH uses reasonable organizational, technical, and administrative measures to help protect against the loss, misuse, and alteration of the Personal Data 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) MINORS AND OTHER PERSONS LACKING THE REQUISITE LEGAL CAPACITY

Furla Group is committed to protecting the privacy of minors and other persons lacking the requisite legal capacity. All uses of websites, other Internet-based platforms, promotional initiatives, or services provided by Furla Group are not designed or intended to include personal information of minors, i.e. any natural person under the age of 18 years old. Similarly, this notice and the related consent is not designed or intended to be used in situations involving other persons lacking the requisite legal capacity to understand or enter into consent-based agreements for the provision of information. Furla Group does not collect Personal Data from any person we actually know is a minor or a person lacking the requisite legal capacity. Any person who wishes to register as a Furla Client or otherwise use the related data systems is thereby confirming that he or she is not a minor or is not otherwise lacking the requisite legal capacity, and Furla Group reserves the right to immediately take corrective measures in accordance with applicable Privacy Laws if Furla Group discovers that Personal Data has been collected from a minor or other person lacking the requisite legal capacity.

f) HOW LONG DO WE KEEP YOUR DATA?

Your Personal Data will be kept for a period not exceeding that necessary for the purposes for which they were collected, after which they will be destroyed or rendered unusable.

g) MANDATORY VS. OPTIONAL DATA AND CONSEQUENCES OF NOT PROVIDING DATA

You must provide your data for the purposes set out under point c) (i) (legal duties), (ii) (registration as Furla SH Client), and (iii) (contractual purposes). If you do not wish Furla SH to process your data for these purposes, Furla SH will respect this. However, in this event, you will be unable to register as a Furla Client and use the additional services that Furla SH offers to registered clients, register to the relevant websites, purchase products online, or participate in Furla SH’s initiatives.

Providing data for the purposes set out under point c) (iv) (marketing purposes) or (v) (profiling purposes) is optional. Not providing your data for these purposes will not have any negative consequences for you. If you consent to Furla SH processing your Personal Data for these purposes, you can revoke your consent at any time by emailing: [online.cn@furla.com].

h) HOW DO WE SHARE THE DATA COLLECTED AND HOW DO OUR GLOBAL SERVICES WORK?

    i. If you register as a Furla Client and consent to the processing of your Personal Data for marketing and profiling purposes, your Personal Data will be added to Furla SH’s database.

    ii. Furla SH may share your data provided in h) (i) 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 SH, marketing and profiling activities, including on a local basis. A list of these is available at Furla SH’s head office and can be requested by emailing: [online.cn@furla.com].

    iii. Furla SH may process the data that you provide for the purposes illustrated in points c) i (legal duties), c) ii (registration as a Furla Client); c iii) (contractual purposes); c) iv (marketing purposes); and c) v (profiling purposes: to send personalised offers that are in line with users’ interests). Without specific consent, Furla SH does not share Furla SH Clients’ Personal Data with unaffiliated third parties for those parties’ own marketing purposes. If you visit a Furla Group store in another country, your Personal Data will not be accessed in that store.

i) YOUR PRIVACY RIGHTS

If you wish to exercise your access, correction, cancellation, portability, and objection rights detailed below (under the Privacy Laws), or make complaints and other inquiries, please send a letter to Furla SH or email [online.cn@furla.com] to the attention of the CRM Customer Service Officer,. Under the Privacy Laws you have the right:

    i. to obtain confirmation as to whether or not Personal Data concerning you exist, regardless of their being already recorded, and communication of such data in intelligible form;

    ii. to receive details of the source of the data, the purposes and methods of the processing, the logic applied to the processing, or if the latter is carried out with the help of electronic means, of the identity of data controller and data processors, the entities or categories of entity to which the data may be communicated and which may become aware of the data;

    iii. to update, correct, supplement, or delete the data, to block or render anonymous data that have been processed unlawfully, including data whose retention is unnecessary for the purpose for which such data have been collected or subsequently processed; to have a certification that the operations requested have been completed, as also related to their contents, to the entities to which the data were communicated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected; and to receive the Personal Data concerning you and copy or transmit it to another data controller (right to data portability);

    iv. to object, on legitimate grounds, to the processing of data, despite the data being relevant to the purposes for which they were collected or to object, also partially (e.g., only in relation to certain communication means), to the data being processed in order to send advertising materials or for direct sales, or market research, or commercial information, profiling purposes, or to receive communications by traditional means only;

    v. to revoke your consent to the collection, use or process of data at any time, free of charge, and without any disadvantages (other than not receiving the services Furla SH provided to you).

You have the right to file a complaint with the competent supervisory data protection authority or Furla SH where you consider that the processing or other handling of your Personal Data infringes the Privacy Laws.