PRIVACY AND COOKIE POLICY

United States

Privacy Policy

The United States section of www.renecaovilla.com (the "Site") is operated by FiloBlu USA, Corp. (“FiloBlu”), a Delaware corporation, having an address at 350 Fifth Avenue, 41st Floor, New York, NY 10118, a subsidiary of FiloBlu S.p.A., an Italian corporation having an address at Via Caltana 116, 30030 Santa Maria di Sala (VE), Italy. The Site is owned by RENE CAOVILLA SpA having an address at Via Nazionale 24, 30032 Fiesso D’Artico (VE), Italy (referred to herein as "Rene Caovilla"). All references herein to "We," "Our" or "Us" are references to FiloBlu. The following Privacy Policy applies to all of the services offered by Us in connection with the Site. For convenience, the words "user," "You" and "Your" as used in this Privacy Policy refer to users of the Site.

We recognize that Your privacy and the protection of Your Personal Information is important to You, and therefore, We have adopted this Privacy Policy. This Privacy Policy describes Our privacy practices and how We treat the Personal Information collected from You when You use the Site, including any Personal Information You provide when You conduct business with Us on or through the Site.

Personal Information and Aggregate Information of users of the Site may be processed, shared with and/or used by, in accordance herewith, Rene Caovilla and Our respective affiliates, subsidiaries, parents, agents, representatives and/or employees (collectively referred to herein as “Our Affiliates”), including Our Affiliates located in the European Union (“EU”). In light of the foregoing, any processing of data will be conducted in compliance with US law as well as the laws of the EU and other applicable countries.


Rene Caovilla products are available for sale in Rene Caovilla brand stores, many department and specialty stores, as well as on other websites. Personal Information collected through these other channels is not provided to Us. This Privacy Policy does not address the privacy practices of other retailers and/or websites which sell the Rene Caovilla products. When purchasing products from websites other than this Site, We strongly suggest reviewing the privacy policies provided on such websites. We are not responsible for the data collection practices of other retailers or websites.

WHAT KIND OF INFORMATION DO WE OBTAIN AND MANAGE?


The information that We may collect from You (and/or manage) when You use the Site includes, but is not limited to:

  • "Personal Information" that (i) You provide to Us and (ii) personally identifies You, such as name, email address, mailing address, phone number, billing, credit card and banking information; and
  • "Aggregate Information" such as the types of products purchased, the Site pages you access most frequently or search terms you enter.

We use customer information in an effort to improve Your shopping experience and to communicate with You about the Rene Caovilla products, services, promotions and contests. We may also use this information to make offers to You, to help Us target specific products and services to You, and to help Us develop and improve the Site by tailoring it to Your interests.

Except as otherwise provided in this Privacy Policy, all information provided by You is stored on FiloBlu and Rene Caovilla’s data servers provided by several partners during the time You subscribe to the Site and/or purchase Rene Caovilla products. We use commercially reasonable efforts to ensure that such information is secure and to protect against the loss, misuse, and alteration of the information under Our direct control. Notwithstanding the foregoing, We cannot guarantee that Our security measures will prevent illegal or otherwise unauthorized access to Our computers or data servers. For the avoidance of doubt, We will not retain Your credit card or other banking information without Your separate, prior written authorization.

HOW DO WE OBTAIN THE PERSONAL INFORMATION?

We may obtain, collect, retain, store or otherwise maintain Your Personal Information from the following sources:

  • Information that You provide to Us when You (i) initiate contact with Us through this Site and/or through Our Customer Service line, (ii) voluntarily register with the Site, (iii) subscribe to Our electronic newsletter, (iv) respond to a survey published by Us or purchase goods from Us;
  • Your payment for Rene Caovilla Products;
  • Your entries for sweepstakes and other promotions provided or sponsored by Us or Rene Caovilla;
  • Your responses to communications from Us. From time to time, We may communicate with You through email, postal mail or other forms of electronic communications regarding Your purchases of goods from Us and the Site. If You respond to these communications, Your responses may contain Personal Information; and
  • Third parties to whom You have provided Your Personal Information and have consented to those third parties’ sale, rental or transfer of such Personal Information.

You can decline to provide Your Personal Information to Us by not engaging in the activities described above. If You decline to submit Personal Information, We may not be able to or may choose not to provide to You some or all of the features available on the Site.

The Aggregate Information that We also collect is non-personally identifiable server-log information relating to users of the Site. This information may include information such as, but not limited to (i) Your account activity, including storage usage, number of log-ins, data displayed or selected, including user interface elements, links, etc.; and (ii) Your web requests, Internet Protocol address, browser type, browser language, the date and time of Your requests, the pages accessed, date and time of access, one or more cookies that may uniquely identify Your browser and referrer Uniform Resource Locator (“URL”). None of this information enables Us to personally identify or contact You. Aggregate Information is used in a collective manner, and no single person can be identified by that compiled information. The Site collects Aggregate Information, as may be permitted by applicable law.

How We Collect Personal Information From Third Parties:

We may collect or purchase information from third parties regarding persons who provided such information to those third parties. Information provided by the third party may include, but is not limited to, individual names, email and postal addresses, telephone numbers, birth dates, genders, and any other information provided by the third party. When obtaining such information from third parties, We use commercially reasonable efforts to ensure that (i) the third party possesses the right to transfer the information to Us and (ii) We have received the right to communicate with the persons who provided the information.

HOW DO WE USE YOUR INFORMATION?

We only use Personal Information for the purposes and in the manner described in this Privacy Policy. Specifically, We only use Your Personal Information for:

  • Doing business with You, including processing Your orders and payments and communicating with You regarding Your purchases of Rene Caovilla products from Us;
  • Communicating with You regarding sweepstakes and other contests and promotions offered or sponsored by Us or Rene Caovilla that you have entered;
  • Sending You electronic newsletters and promotional emails if You have agreed to receive such emails during registration or by completing Our email sign up form (mobile marketing communications may be sent to You if You have submitted Your mobile telephone on this Site);
  • Processing, formatting and displaying customized content on the Site for You to enhance Your shopping experience;
  • Auditing, research and analysis in order to maintain, protect and improve the Site and the goods offered or provided by Us;
  • Responding to communications initiated by You;
  • Ensuring the technical functioning of the Site, including creating and maintaining back-ups or other archival copies of Personal Information and other related data; and/or
  • Internal purposes, such as fraud and theft prevention, accident reporting, development and administration of the Site, data analytics, and compliance with Our legal obligations, policies and procedures.

We restrict access to Personal Information to those employees, contractors and agents of FiloBlu and/or Rene Caovilla (including their respective affiliates and subsidiaries) who need to access Personal Information for the purposes specified above. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations.

Except as otherwise set forth herein, We do not share Your Personal Information with third parties without Your consent, except when We believe that it is reasonably necessary to do so in order to comply with a subpoena or other judicial order or process, as otherwise required by law or in order to enforce Our Terms of Use. In such circumstances, Your Personal Information may also be disclosed to Our attorneys.

If We desire to use Your Personal Information for any purpose other than those described in this Privacy Policy, We will request Your consent prior to such use and offer You an effective way to opt out of the use of Personal Information for those other purposes. If You opt out or otherwise decline to submit Personal Information in response to such a request, We may not be able to provide to You some or all of the features available on the Site.

[HOW IS INFORMATION COLLECTED BY AUTOMATED MEANS?][

We use "cookies" and "web beacons" as automatic systems of data collection to receive certain information every time You interact with Us.

Cookies
Like many companies, We use "cookies" on this Site. Cookies are bits of text that are placed on Your computer's hard drive when You visit certain websites, that, among other things, uniquely identify Your browser and allow the website to “remember” Your computer and Your activities on the website. Cookies allow Us to enhance Your online experience by saving Your preferences while You are visiting a particular site. We use cookies, for example, to preserve the contents of Your virtual shopping bag between visits. We also use cookies to measure activity on the Site and determine which areas and features of the Site are the most popular. Cookies allow Us to see how and when You use the Site, but they cannot be used to track personal information such as email address or phone number. These cookies cannot damage a user's files and cannot read information from a user's hard drive.


Most browsers will tell You how to stop accepting new cookies, how to be notified when You receive a new cookie and how to disable existing cookies. Without cookies, however, You may not be able to take full advantage of all of the features of the Site. For example, if You turn off cookies or refuse them, You will not be able to make purchases on the Site.


Web Beacons

Certain pages on this Site contain "web beacons" (also known as Internet tags, pixel tags and clear GIFs). Web beacons are used for internal purposes, such as to obtain the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, and the type of browser used to view the page. We also retain service providers who use web beacons to assess the effectiveness of Our email communications and learn what pages Our visitors viewed.

HOW DO WE COLLECT INFORMATION FROM SOCIAL MEDIA?

In the event that You access the Site or content on or through third party social media sites, services, plug-ins, or applications You may allow Us and/or Rene Caovilla (including its affiliates) to access certain information from Your social media account (e.g., name, e-mail address, profile photo, gender, birthday, location, Your list of friends and their contact information, people You follow and/or who follow You, the posts or the 'likes' You make). Other non-personally identifiable information (e.g., content viewed and information about advertisements within the content you have been shown or may have clicked on, etc.) may be provided to Us and/or Rene Caovilla (including its affiliates) from Your interaction with the Site or content. If You access the Site through a third party social media site that has access to Your Personal Information, You expressly consent to the use of Your Personal Information by Us in accordance with this Privacy Policy.

If You post information or content on a blog, in online forums or communities on the Site, or when You interact with the Site through social media sites, plug-ins or other applications, this information could become public on the Internet and We cannot prevent further use of this information. Please review third party social media sites' privacy policies and terms of use for more information.

WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?

We do not sell or otherwise disclose Personal Information or any other information about Our customers, except as described herein. We may share the Personal Information You provide to Us and the Aggregate Information collected by Us with companies that are related to or affiliated with Us, including, but not limited to Rene Caovilla and our respective affiliates, licensees and joint venture partners, for the purposes described in this Privacy Policy. Both FiloBlu and/or Rene Caovilla (including its affiliates) may also share Your Personal Information with our respective service providers who perform services on our behalf based on our instructions, as well as reputable third party organizations for marketing and promotional purposes. These service providers are not authorized by Us to use or disclose any information transferred to them except as necessary to perform services on our behalf or comply with legal requirements. A complete list of the businesses or third party processors that may be recipients of Your Personal Information may be requested by email request to Customer Care at customercare@caovilla.com, or privacy@caovilla.com.


We also may disclose information about You (i) if You have consented to the sale, rental or sharing of Your Personal Information,

(ii) if We are required to do so by law or legal process (such as a court order), (iii) in response to a request by law enforcement authorities, or (iv) when We believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

In the event there is a change in Our corporate structure, including but not limited to a merger, consolidation, sale, liquidation, transfer of all or a portion of Our business or assets, We reserve the right to transfer or assign all Personal Information and other information We have collected on and through the Site. Following such a transfer, You may contact the entity to whom We transferred Your Personal Information with any inquiries concerning the processing of that information.

When You sign up for any service offered by a third party, Personal Information necessary for the third party to provide its services may be shared with the third party and Your privacy will be maintained in accordance with the third party’s privacy policy.

HOW WE PROTECT YOUR PERSONAL INFORMATION?

We maintain commercially reasonable and appropriate administrative, technical and physical safeguards to protect the Personal Information that You provide on this Site against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use and other unlawful forms of processing. We use Secure Sockets Layer ("SSL") technology to protect the transmission over the Internet of Your credit card data. You can check the security of Your connection by looking at the URL line of Your browser. When accessing a secure site, the first characters of the site address change from "http" to "https." If You are using a web browser or firewall that does not permit communications through secure sites, You will not be able to make purchases on the Site. If You cannot access the secure server for any reason, please print Our shopping page and place Your order by phone at calling Customer Service at (+39) 041 8380024.

No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under Our control to intercept or access transmissions or private communications unlawfully. While We strive to protect Your Personal Information, neither We nor any of Our service providers can ensure or warrant the security of any information You transmit to Us over the Internet. Any such transmission is done at Your own risk.

HOW DO WE TREAT LINKS TO OTHER SITES?


This Privacy Policy only pertains to the Site. This Site may contain links to other websites and portals for Your convenience and information. Such links may be to advertisers, content providers or other companies who may use the Rene Caovilla logo and/or style as a result of a co-branding or other agreement; however, these sites may be operated by companies that are not affiliated with Us or Rene Caovilla. Linked sites may have their own privacy policies. We strongly suggest You review the privacy policy and terms of use of the websites and portals that You visit through links placed on the Site as well as those for websites that provide links to the Site. We are not responsible for the content of any third party websites, the use of such sites, or the privacy practices of those sites. We do not control the content that appears on these sites or take any responsibility for their content, nor should it be implied that We endorse or otherwise recommend such sites or the products or services offered thereon. You should contact these websites directly if You have any questions about their use of Your Personal Information. We are not responsible for any use of Your Personal Information or any other type of information when You use such third party sites and/or services.

HOW DO YOU OPT OUT OR UPDATE INFORMATION STORED WITH US?

We offer You certain choices about how We communicate with You and what information We collect from You. You may withdraw any consent You previously provided to Us or object at any time on legitimate grounds and free of charge to the processing of Your Personal Information, providing that such withdrawal or objection is made in writing, and We will apply Your preferences going forward. We will endeavor to comply with Your requests as soon as reasonably practicable. However, We may need to retain certain information for record keeping purposes, and there may also be residual information that will remain within Our databases and other records, which will not be removed or changed. Moreover, We will use Your deleted information for the purposes of detecting and avoiding fraud and will share such information with third parties only when We believe that it is reasonably necessary to do so in order to comply with a subpoena or other judicial order or process, as otherwise required by law or in order to enforce Our Terms of Use.

We make good faith efforts to provide You with access to Your Personal Information. Where applicable, We ask individual users to identify themselves and the information requested to be accessed, corrected or removed, in writing, before processing such requests. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical efforts, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required. In any case, where We provide information access and correction, We provide this service free of charge, unless doing so would require a disproportionate effort.

You can choose not to receive marketing communications from Us by clicking on the unsubscribe link in Our marketing emails, or contacting Us as follows: Please include Your name, address, email address and request in an email to Customer Care at customercare@caovilla.com. In addition, You may use the same contact information if You would like to update any Personal Information that You have previously provided to Us.

HOW WILL YOU KNOW IF WE UPDATE OUR PRIVACY POLICY?

We may, at Our sole discretion, revise this Privacy Policy at any time in a manner consistent with applicable laws and regulations without prior notice to You. We will indicate at the top of the Privacy Policy when it was updated. We recommend that You periodically review this Privacy Policy to remain informed about how We use Your Personal Information.


WHAT RIGHTS DO CALIFORNIA CONSUMERS HAVE?

In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 400 R Street, STE 1080, Sacramento, CA 95814; or by telephone at (916) 445-1254 or (800) 952-5210; or by email to dca@dca.ca.gov. For more information about protecting Your privacy, You may wish to visit: www.ftc.gov.

If You are a resident of California, You may make a written request to customercare@caovilla.com,or privacy@caovilla.com to ask Us (i) to refrain from sharing Your Personal Information with certain of Our affiliates and other third parties for marketing purposes; and/or (ii) how We have shared Your Personal information with select third parties for their direct marketing purposes. In response to Your written request, We will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses.

Do Not Track Signals

The Site does not recognize Do Not Track signals. Some third parties may collect aggregate information about the users’ online activities over time and across websites while using the Site. While this information generally does not include personally identifiable information, certain processing activities that combine aggregate information with other information in possession of such third parties could result in the identification of users.

ARE CHILDREN/MINORS ALLOWED TO USE THE WEBSITE?

Consistent with the Federal Children's Online Privacy Protection Act of 1998 (COPPA), We will never knowingly request personally identifiable information from anyone under the age of 13 without verifiable parental consent. If We become aware that a customer is under the age of 13 and has registered without prior verifiable parental consent, We will remove his or her personally identifiable registration information from Our files. If You are under the age of 18, You may use this Site only with the involvement of a parent or guardian.

WHERE IS THE INFORMATION COLLECTED STORED?

Your connection to the Site will be through and to servers located in the [United States and/or Italy and/or Belgium. You acknowledge that the Personal Information You provide to Us is collected and stored in the United States and/or EU and, therefore, You consent to the transfer of information to, use and storage of the information in the United States and/or EU, regardless of Your country of domicile. Orders placed through the Site will be fully processed in and shipped from the United States and/or Italy and all information You provide will be processed and securely maintained in Our web servers and internal systems located within the United States and/or EU. IN ADDITION, IF YOU ARE LOCATED OUTSIDE THE UNITED STATES, YOU SHOULD NOTE THAT YOUR INFORMATION WILL BE TRANSFERRED TO THE UNITED STATES, THE LAWS OF WHICH MAY BE DEEMED BY OTHER COUNTRIES TO HAVE INADEQUATE DATA PROTECTION. This Privacy Policy and Our legal obligations are subject to the laws of the State of New York and the United States, regardless of the location of any user. Any claims or complaints must be filed in the United States in the State of New York.

All Personal Information that is securely maintained in Our web servers within Italy is subject to Italian legislation (Reg. EU 679/2016), hereinafter called Personal Data Protection Code or “Code” for short, which expressly states the purposes and methods of processing personal data which are submitted to the Site. The Data Controller is Rene Caovilla and FiloBlu. According to the law, You can at any time obtain (i) proof about whether or not Your Personal Information is present in the system, (ii) information about Your Personal Information’s contents and origin, (iii) verification, integration or updating and rectification of Your Personal Information, (iv) removal or change to anonymous form of Your Personal Information.

HOW DO WE ADDRESS COMPLAINTS?

We regularly review Our compliance with this Privacy Policy. Please direct any questions or concerns regarding this Privacy Policy or Our treatment of Personal Information to Customer Care at customercare@caovilla.com, or privacy@caovilla.com. When We receive formal written complaints at this email address, Our policy is to contact the complaining user regarding the user’s concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Information that cannot be resolved between Us and an individual.

LIMITATIONS ON LIABILITY

IN NO EVENT SHALL WE OR ANY OF OUR AFFILIATED ENTITIES OR SUPPLIERS BE LIABLE FOR ANY INDIRECT, SPECIAL, PUNITIVE, INCIDENTAL, EXEMPLARY OR CONSEQUENTIAL DAMAGES, EVEN IF THESE ENTITIES HAVE BEEN PREVIOUSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, WHETHER IN AN ACTION UNDER CONTRACT, TORT, NEGLIGENCE OR ANY OTHER THEORY, ARISING OUT OF OR IN CONNECTION WITH THE USE, INABILITY TO USE OR PERFORMANCE OF THE INFORMATION, SERVICES, PRODUCTS AND MATERIALS AVAILABLE FROM THE WEBSITE. THESE LIMITATIONS SHALL APPLY NOTWITHSTANDING ANY FAILURE OF ESSENTIAL PURPOSE OR THE EXISTENCE OF ANY LIMITED REMEDY.

NOTHING IN THE FOREGOING DISCLAIMER OF LIABILITY LANGUAGE SHALL SERVE TO DENY ANY CONSUMER, THAT IS A RESIDENT OF NEW JERSEY, (I) THE RIGHT TO BRING A PRODUCT LIABILITY CLAIM UNDER THE NEW JERSEY PRODUCT LIABILITY ACT, N.J.S.A. 2A:58C-1, (II) THE ABILITY TO SEEK PUNITIVE DAMAGES OR (III) THE ABILITY TO SEEK CONSEQUENTIAL DAMAGES IN INSTANCES OF INJURY TO THE PERSON IN THE CASE OF CONSUMER GOODS. CERTAIN STATES LAWS SIMILARLY DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTIES OR THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES. IF THESE LAWS APPLY TO YOU, SOME OR ALL OF THE ABOVE DISCLAIMERS, EXCLUSIONS, OR LIMITATIONS MAY NOT APPLY TO YOU, AND YOU MIGHT HAVE ADDITIONAL RIGHTS.

SEVERABILITY

If any provision of this Privacy Policy is found to be illegal, void, or unenforceable, that provision will be deemed severed from the balance of the agreement and will not affect the validity and enforceability of the remaining provisions, which will continue in full force and effect.

ACKNOWLEDGEMENT

By completing forms provided by Us and providing Personal Information through the Site, through any means, and by using the Site and services contained therein, You hereby represent and warrant that:

  • You have read, understand and agree to Our Privacy Policy;
  • You are an actual person of at least 18 years of age, You have the right to provide the information that You submit to Us, and the information You submit is accurate, complete and truthful; and
  • If You do not agree to the terms of this Privacy Policy, then do not provide Your information to Us through any means. In such case, We are relieved of any of Our obligations to You as set forth in this Privacy Policy.

If You have any questions regarding this Privacy Policy, please contact Our Customer Care at customercare@caovilla.com.



Effective Date: 03.04.2020

 

Canada

PRIVACY POLICY

RENÉ CAOVILLA SPA

Please read this privacy policy carefully.  It describes the way of processing user’s personal data that access on www.renecaovilla.com (the “Site”), regardless of whether they are only visitors or users that, subject to registration, use the respective services, including registration of their personal account, the on-line purchase of products, and the additional services made available by René Caovilla S.p.A. through the Site ("Users"). René Caovilla recognises the importance of offering Users of the Site services that are underpinned by a concern to protect their data to enable each User to control their privacy throughout all the processing stages of their data.

 

This privacy policy applies exclusively to the processing of personal data carried out through the Site; any third party internet sites that can be consulted by the User via links are subject to a privacy policy issued by the operators of those respective third-party sites. It is recommended that Users inspect these documents before browsing on third-party sites.

 

Sales transacted through the online shop that is part of the Site (hereinafter “E-Store”) and all the activities related to them (for example, handling of orders, sales, product delivery, payments handling, administering returns and warranties, post-sales activity) are carried out by FiloBlu S.p.a. on its own name, in accord to  René Caovilla S.p.A., to assure Users an integrated service and to improve their buying experience.

 

1. DATA CONTROLLER

 

The independent controller of  personal data of Users who visit and browse the Site (browsing and profiling data), as well as of those Users that register and use available service on the Site, with the exception made for online purchases (personal records, further data aimed to marketing and profiling activity, where authorized by the User), is René Caovilla S.p.A. (referred to hereinafter as “Caovilla"), with registered offices at Via Nazionale, 24, 30032 Fiesso d’Artico (Venice), Italy, Tax Code/VAT registration number IT00166690271, telephone: +39-049-9801300, email: privacy@caovilla.com.

 

As for the processing of  personal data connected and correlating to the purchases made through the E-Store (including pre- and post-sales assistance), the joint data controller of the processing, together with Caovilla, is FiloBlu S.p.a., with registered office at Via Caltana 116/C., Santa Maria di Sala (Venice), Italy, VAT registration number IT04274870288 (hereinafter, also referred to as “FiloBlu”).

 

2. TYPE OF DATA

 

Browsing data

 

For Users to consult public pages of the Site they are not requested to provide personal data.   However, any possible contact with Caovilla and/or FiloBlu, any optional, explicit, and spontaneous dispatch of messages, of electronic or traditional mail, to their addresses shall entail the subsequent acquisition of the address, including e-mail ones, of the sender or of the respective telephone number, needed to reply to requests, as well as of any other personal data included in the respective communications.  Said data shall be used for the sole purpose of giving effect to the request of the User and can be notified to third parties only in the case where this is necessary for that purpose.  The data will be held for the time strictly necessary to provide the User with the requested service and shall not be disclosed.

 

In addition, the information systems and the computer programs used for operating the Site gather certain personal data the transmission of which is implicit in the use of internet communication protocols (for example, IP addresses or dominion names of the computers used by the Users connecting  to the Site, URI -Uniform Resource Identifier- addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained on replying, the numerical code for the status of the reply given by the server - successful, error etc., and other parameters relating to the User’s operating system and computer environment). Though the information is not gathered to be matched with the identified data subjects it could, by its nature, through processing and matching with data held by third parties, enable Users to be identified.

 

This information is used solely to obtain statistical information - unmatched with an identifying data item of the User - on the use of the Site and to check on its proper operation and it  is immediately cancelled after being processed.

 

Data provided when registering and when using the services

 

Registering on the Site and using the respective services are optional.  Though registering on the Site, it makes browsing and purchasing simpler for Users, any online purchases may be made even without registering.

 

When Users register at the Site by creating a Personal Account or they use other services available at the Site, the processing of personal data will be directed at the operations, or the complex of operations (purely by way of example: gathering, registering, consulting, organising, keeping, processing, communicating, modifying, selecting, and using), that mostly regard the data provided by Users when they register and/or when they use the services:

 

a)      USERS’ IDENTIFYING AND CONTACTING DATA, obtained when Users register their account, including:

 

● certain data  essential for registering their account (for example: username, password, name, surname, telephone and/or email contacts);

 

●  certain data  entirely optional and useful solely to manage the account (for example: date of birth, gender, address where resident);

 

b)      DATA CONCERNING USER’S PROFILE, provided at the choice of the User for creating and handling their profile, including their nickname and any additional information about their occupation, their preferences, and interests;

 

c)       DATA REGARDING ONLINE PURCHASES, provided generally by the User and essential to close the contract and to finalize the orders (for example: personal records, address where resident, data invoicing, delivery, payment data, information regarding any interaction with FiloBlu regarding pre- and post-sales services, returns, complaints, warranties);

 

d)      if Users opt for login using social applications (for example: Facebook Connect, Google+, Twitter), SOME DATA MADE PUBLIC BY USERS IN THEIR PROFILE ON THE RESPECTIVE SOCIAL NETWORK (for example: name, surname, gender, town and email address, language, photograph). Processing shall be limited to data type requested for traditional way of registering on the Site and to manage Users’ accounts.  The use of this type of access shall not entail Caovilla in any way notifying data to any social networks;

 

e)      DATA REGARDING USERS’ HABITS AND PREFERENCES (for example: history purchases, wish lists, type of products purchased, consumer preferences, interests, preferred outfits);

 

f)       any DATA ABOUT THIRD PARTIES (FOR EXAMPLE: RECIPIENTS OF PRODUCTS SENT AS PRESENTS) that, though they do not use Site functions, their data may in any case be obtained by Caovilla or FiloBlu in that said third parties are input, by the Users, as recipients of deliveries.

 

Data updating

 

Users must ensure that  personal data  provided to Caovilla and to FiloBlu are correct and, in the event of data changes, they must update the data by emailing Caovilla (and/or to FiloBlu in case of data given during online purchases) or, in case of  registered Users, by using allowed options in their personal area.

 

Data regarding minors

 

Caovilla and FiloBlu do not accept registrations or orders by minors (persons under the age of 18 years old), nor do they knowingly gather or use their personal data.  Minors are instructed not to register or not to make online purchases and to ask an adult to carry out the necessary procedures.

 

3. THE PURPOSES OF PROCESSING PERSONAL DATA

 

Personal data is gathered and it is processed for the purposes and in the ways listed below:

 

    (1)            FOR PROVIDING SERVICES requested by Users (for example: managing the processes of registering and accessing the Site, operating Users’ accounts, assisting Users, and handling any complaints, handling wish lists, and processing data for the performance of individual services requested by Users). In relation to these purposes Caovilla may process personal data without the  Users consent in accordance to article 6, point b) of European regulation 2016/679;

 

    (2)            for fulfilling any OBBLIGATIONS IN LAW AND/OR IN REGULATIONS (for example: invoicing, keeping accounts, duties to report safety accidents).  In relation to these purposes the data may be processed by the joint data controllers without the consent of Users in accordance with article 6, point a) of European regulation EU 2016/679;

 

    (3)            for HANDLING ONLINE ORDERS (for example: performing online operations necessary for managing orders; checking that the information given for the transaction is complete, valid, correct and not fraudulent; processing the order and delivering products; providing pre- and after- sales service, including returns and repairs or giving effect to the legal warranties, contacting Users, including via e-mail, for any problem related to handling the order or to subsequent requests relating to the order).  In relation to these purposes the data shall be processed by the joint data controllers without the consent of Users in accordance to article 6, point b) of European regulation EU 2016/679;

 

    (4)            for DEFENDING OUR RIGHTS both in court proceedings and out of court.  In relation to these purposes Caovilla and FiloBlu can process the personal data without the consent of Users in accordance to article 6,  point f) of European regulation EU 2016/679;

 

    (5)            to conduct internal STATISTICAL ANALYSES, subject to the data being anonymised, to improve quality  services.  In relation to these purposes the joint data controllers may use the information freely in that it is anonymous and in aggregated form;

 

    (6)            subject to the consent of Users, for MARKETING PURPOSES,through dispatching, by e-mail, traditional (paper) mail, telephone, fax and/or SMS/MMS, and push notifications, newsletters and sales communications regarding the products and services of Caovilla, and also to conduct by telephone or via e-mail STATISTICAL ANALYSES, MARKET POLLS AND MARKET RESEARCH, including online, regarding the products and services offered by Caovilla.  If Users have also consented to  profiling activity described earlier, Caovilla may use the result of the analysis carried out in this way to send notifications that Caovilla judges to be of interest to the Users, and to inform Users about its products and/or services that may be of interest to them;

 

    (7)            subject to the consent of Users, for PROFILING PURPOSES, and specifically about the analysis by Caovilla of Users’ purchasing choices, preferences, interests, and habits as recorded while they were using the services. The data may be used by Caovilla also by creating individual and/or aggregated profiles to conduct market and statistical analyses directed at identifying products and/or services of interest to its customers.

 

4. USERS’ NATURE OF DATA PROVISION  – MANDATORY OR OPTIONAL

 

Regarding  data processing purposes listed in points (1) to (5), the provision of data marked as mandatory during registration phase (or in other circumstances where Users are requested to provide data) is necessary in order to use the services and any refusal makes it materially impossible to use the services.  For these data processing purposes, the consent of Users doesn’t need to be obtained.

 

The provision of data other than mandatory data  ̶  for example data about Users’ profiles  ̶  is entirely optional and free, and any refusal does not in any way prevent Users from using the services.  Where this happens, however, Users may be unable to fully use a number of functions on the Site that require, for technical purposes,  provision of certain information (for example:  suggestions for outfits that may be of interest to the User).

 

The provision of data that may assist the data processing purposes in points (6) and (7) is not mandatory and any refusal does not in any way prevent Users from using the services. However, where this happens Caovilla may not be able, for example, to transmit to Users targeted promotional material about products that may be of interest to the User.  In any case, it is understood that the processing of data for these purposes may only take place where there is the expressed consent of Users.

 

5. COOKIE

Pursuant to Provision no. 229 http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/3118884 issued by the Personal Data Protection Authority on May 8, 2014, www.renecaovilla.com provides the following information on cookies and on their functions, as well as instructions on how to disable them.

 

What are cookies?

Cookies are small text files that the sites visited by the user send and record on his/her PC or on any other device, even mobile, to be sent back to the original sites on the next visit.

Cookies are used for various purposes, for instance, to remember the user’s actions and preferences (such as, for instance, login data, selected language, font size, other display settings, etc.) so that they must not re-entered when the user returns to the same site or surfs from one of its pages to another; or to perform computer authentications, to monitor sessions and store information on the activities of user who access a site, and it can also contain a unique ID code that allows keeping track of the user’s surfing within the site for statistic or advertising purposes.

Cookies can be sent by www.renecaovilla.com or also by different sites (the so-called “third party” cookies). Some operations cannot be carried out without using cookies that in some cases are technically necessary for the site to work.

 

Types of cookies found on the site www.renecaovilla.com and relevant functions

There are various types of cookies, according to their characteristics and functions:

-          Technical cookies, which are used for the sole purpose of sending a communication on an electronic communication network, or in the measure strictly necessary to provide a service explicitly requested by the user. In other words, these cookies are indispensable to make www.renecaovilla.com work, or necessary to perform activities that you have requested. This type of cookie can be found in our site;

-          Navigation or session cookies, used to allow you to login in the reserved area of www.renecaovilla.com or to make a purchase on our site. This type of cookie can be found in our site;

-          Analytics cookies, used to collect information, in an aggregate form, on the number  of users of www.renecaovilla.com and of the displayed pages (for instance, Google AdWords, Google Analytics and Mailchimp). Please, refer to the relevant policies that can change from time to time and that we recommend consulting every now and then, where you will find more detailed information:

 http://www.google.com/policies/technologies/ads/;

https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage;

http://mailchimp.com/legal/privacy/).

This type of cookie can be found in our site;

-          Function cookies, which allow you to surf www.renecaovilla.com at your best, according to already selected criteria and options (such as, for instance, your preferred language) so that you won’t have to select such option or the products you have chosen at every access, and they can be stored in the virtual trolley until your next visit to our site. This type of cookie can be found in our site;

-          cookies of third parties, used by partners of www.renecaovilla.com, in order to display advertising banners of www.renecaovilla.com when you are on other sites, showing you the latest products that you have looked at on www.renecaovilla.com. While you browse on www.renecaovilla.com, these cookies are used also to show you products that you might like or similar to those you have previously browsed, based on your previous navigation chronology. The use of these cookies does not imply personal data treatment, but it can enable your computer or other devices to connect and track down saved data: these cookies connect to the browser installed on your computer or on other devices used while browsing on www.renecaovilla.com;

-          profiling cookies, used to create user profiles in order to send advertising messages consistent with the preferences shown by the user during his/her navigation. Our site contains third party cookies that access user data only at aggregate level. Please, find here below the links to the privacy policies and relevant consent forms of such third parties, which can change from time to time and that we recommend consulting every now and then, where you will find more detailed information:

-          http://www.google.com/intl/en/policies/technologies/ads/; http://www.google.com/intl/en/policies/privacy/.

http://www.google.com/intl/it/policies/technologies/ads/; http://www.google.com/intl/it/policies/privacy/ .

http://legal.yandex.com/privacy/

https://www.adroll.com/about/privacy

http://www.criteo.com/privacy/

https://twitter.com/privacy?lang=it

https://support.twitter.com/articles/20170514-twitters-use-of-cookies-and-similar-technologies#

https://www.youtube.com/static?template=privacy_guidelines

https://www.linkedin.com/legal/privacy-policy;

https://www.linkedin.com/legal/cookie_policy

https://www.facebook.com/help/cookies/?ref=sitefooter

All the above-described types of cookies can stay in your computer or mobile device for different times, according to their function.

The cookies stored in your computer or mobile device cannot be used to recall any of the data stored in your hard disk, transmit viruses, identify and use your e-mail address, or for purposes other than those described above.

 

How to modify cookie settings

You can set and manage your cookie preferences at any time, by selecting which cookies you want to authorize, block or cancel, totally or partially, through the settings of your browser (or the navigation program that you use).

Find here below the path to follow to manage the cookies from the following browsers:

Internet Explorerhttp://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies 
Safarihttp://support.apple.com/kb/PH19255   
Chromehttps://support.google.com/chrome/answer/95647?hl=it-IT&hlrm=fr&hlrm=en  
Firefoxhttp://support.mozilla.org/it-IT/kb/enable-and-disable-cookies-website-preferences

For more information and details on the various types of cookies, their functions and characteristics, visit the free access sites, independent from www.renecaovilla.com - www.AllAboutCookies.org and www.youronlinechoices.com.

To disable analytics cookies and prevent Google Analytics from collecting data on your navigation you can download the browser additional Component for disabling Google Analytics: tools.google.com/dlpage/gaoptout.

We will store your cookie preferences thanks to a dedicated technical cookie with the characteristics specified in the previous table. 

We inform you that blocking or cancel, totally or partially:

- technical cookies, could make it impossible to use our site, see its contents and use the relevant services; 

- function cookies, could make some services or site functions unavailable or working incorrectly, forcing you to modify or manually enter some information or preferences every time you visit the site.

- of other cookies (analytics and profiling), will not affect the site efficiency.

 

6. DISCLOSURE AND DATA RELEASE

 

So that the activities related to the E-Store function properly, the personal data indicated above may be accessed by employee staff, as well as by non-employee personnel appointed by the joint data controllers, that need to process data to carry out their duties (for example, digital function, administration, and customer service).  In addition, the personal data can be made available to third party companies that, on behalf of the joint data controllers, perform specific services in the capacity of Data Processors (for example, suppliers of logistical and forwarding services, data services) or notified to third parties (a list of them is available on request following the procedures under article 10) that process the data independently and in accordance with the law solely in order to give effect to the purchase contract (for example, payment intermediaries or banks that perform remote electronic payment services by means of credit/debit cards).

 

Regarding the other processing activities Caovilla may make available data to its employees and non-employee workers;  data may also be available to third party companies that, on behalf of the joint data controllers, perform specific services in the capacity of Data Processors (for example, suppliers of logistical and data services, handling of marketing and analysis activities – FiloBlu, for example, which operates the Site and holds on its servers the transaction data relating to online purchases).

 

The data may be notified to police forces or to the judicial authorities in accordance with the law and subject to a formal request from them.

 

The personal data shall not be released or transferred to third parties so that they can use them for their own purposes.  The Parties agree that in the event of extraordinary corporate operations (for example, the assignment or renting of a business, mergers, etc.), the data may be assigned or transferred to the third party buyers/leaseholders or title holders.

 

7. TRANSFER OF DATA ABROAD

 

As a rule, personal data shall not be transferred abroad.  If, to run the Site in a better and more efficient way, the data were to be transferred abroad, Caovilla (and FiloBlu) undertake to guarantee proper levels of protection and safeguard including  a contractual nature in accordance with the applicable rules, including making standard contract clauses.

 

8. SECURITY

 

Caovilla, and FiloBlu in so far as it has competence, acknowledge the importance of protecting personal data of customers (for example, their identifying data and their financial data, including their credit card numbers) and of the Users of the Site.  For this reason, Caovilla and FiloBlu adopt policies and security measures of a technical and organisational nature to protect, having regard of the rules in force, the personal data of the Users and the information systems used in managing the site.  In particular, Caovilla and FiloBlu have implemented measures to protect personal data against accidental or intentional tampering, loss, destruction, dissemination, or unauthorized access to data gathered online.

 

However, though Caovilla and FiloBlu continue to implement and improve security measures in line with the development of technology and of industry standards, for the very nature of the Internet these measures cannot restrict or totally exclude the risk of unauthorised access or the dissemination of data.  Accordingly, Users are advised to periodically update their software for protecting data transmission over networks (for example, antivirus software) and to check that their provider of electronic communication services has adopted suitable means for the security of data transmission over networks (for example, firewalls and anti spamming filters). Users are also reminded that access to their personal account, containing their personal data, is only possible by means of a username and password.  To help us to better protect that data we accordingly recommend that Users do not disclose or make available that information to third parties.

 

About payments made for online purchases via the E-Store, the Site uses systems to guarantee the utmost security thanks to the use of the most advanced technological and codifying systems (SSL).

 

9.  DATA HOLDING

 

Personal data shall be held for the time needed to achieve the purposes described above. In particular, the data shall be held for the entire duration of the relationship (for example, creation of the account), as well as for the time necessary for fulfilling legal obligations (for example, keeping accounts for 10 years, holding data for invoicing purposes and for fulfilling tax obligations, where the data regards online purchases) or, in  case of data related to marketing purposes, until consent is withdrawn or customer asked  for deleting (for example, unsubscribing from newsletters).

 

Where consent is given for profiling, the data shall be held for the maximum time determined for profiling and customized marketing by the “Garante per la protezione dei dati personali”  (Italian Data Protection Authority).

 

Apart from such cases, personal data shall be held only to fulfil the legal and regulatory obligations on Caovilla and FiloBlu, or for evidential purposes connected to conducting a legal defence.

 

10. RIGHTS OF THE DATA SUBJECT

 

Under articles 15-22 of European regulation EU 2016/679 Users have the right at any time to obtain from Caovilla and FiloBlu :

  • confirmation as to the existence of their data, access to their content and to obtain a copy (right to access)
  •  updating, modifying and /or correct personal data (right of correction);

 

  • Asked for deleting or limiting data treatment on the hypothesis expected from Regulations, here enclosed, where data have been treated with law violation or whether it is not required a conservation in relation to purposes for those data that have been gathered or otherwise treated (deleting right and limitation right);

 

  • Cancel the agreement, where given, in any moment and without any preconception for legitimacy treatment based on given approval before its revocation. (annulation agreement right);

 

  •  As far as it concerns from the Regulations (UE) 2016/679, receiving copy of provided data in a structural format of common and legible use from an automatic device and ask for these data to  get transmitted to another data controller whether archivable ( portability data right);

 

  • Withdraw in any moment to data treatment for direct marketing purposes including profiling in the measure that this is connected to that direct marketing and on the hypothesis where the treatment is based on a legitim interest (right to withdraw);

 

Users likewise have the right to apply to the” Garante per la protezione dei dati personali” (Italian Data Protection Authority) www.garanteprivacy.it to uphold their rights. To exercise those rights Users may send their application by email to:  privacy@caovilla.com or contact Caovilla (and FiloBlu, if the application concerns the processing of data for handling online purchases) at their respective registered offices (see point 1).

 

If Users have consented to the use of their data by Caovilla so that they receive advertising, promotion material and information and want their data no longer to be used to receive advertising (or be used to receive advertising only through certain channels, for example by post of email) all they need to do is notify this request to Caovilla in the manner indicated below, or by changing their account accordingly. Users can also follow the same procedure if they intend to withdraw their consent, if given, to the use of their data for profiling.  To exercise these rights Users can apply to the addresses shown in point 1.

 

11. AMENDMENTS

 

Caovilla and FiloBlu may amend or update this privacy policy, inter alia to comply with new duties imposed by laws in force or for technical needs.  The amendments and the updates will be notified to Users and shall be operative from the time of their publication on the Site. (Where, under the applicable rules, the amendments require Users’ consent, Users will be allowed to freely express their choice).  Accordingly, Users are invited to consult this page regularly to check on the most recently updated version of the privacy policy on the Site.

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