Everyone has the right to protection of his/her Personal Data. We respect users' right to be informed regarding the collection of, and other operations involving their Personal Data. In using data that may directly or indirectly identify you personally, we will apply a principle of strict necessity. For this reason, we have designed the Website in such a way that the use of your Personal Data will be kept to a minimum and will not exceed the purposes for which your Personal Data was collected and/or processed; we do not process your Personal Data when we can provide you with services through the use of anonymous or traffic data (such as marketing research made for improving our services, browsing data processed to provide you with customized contents or offers adapted to your preferred language, your location, etc.) or by other means which allow us to identify you, apart from when it is strictly necessary or upon request by competent public authorities or the police (for example, in case of traffic data or your IP address).
For the purposes of the Data Protection Legislation (as defined below) companies of the PUIG Group that may need to have access to and process the Personal Data collected on the Website for one of the purposes listed below shall be considered as separated and independent controller of your Personal Data. In this context, the following companies (hereinafter, jointly referred as to the “Companies”) may be classified as controller of your Personal Data with respect to the following data processing activities:
· Marketing purposes (as defined below)(including general Online Customer and Information/Complaint Services regarding the Website): PUIG FRANCE S.A.S - a French company with registered office at 65-67 Avenue des Champs Elysées 75008, Paris (France), holder of Tax Identification Number (SIRET) nº 682030507 and intra-European number VAT: FR14 682030507, recorded with the Commercial Registry of Paris (hereinafter referred to as “PUIG FRANCE”);
· Online Sales (as defined below): Online Shop - United States of America (including Customer Services regarding the Online sale conducted): NINA RICCI, SARL – a French company with its principal business address at 39 Avenue Montaigne, 75008, Paris (France) which is registered at the register of trade and companies of Paris under number 582 133 211, with a company capital of 5058000 euros, with Tax Identification number (SIRET) 582 133 211 00042and Intra-European VAT n°: FR05582133211 (hereinafter referred to as “Fashion NINA RICCI”).
For the accuracy of your provided Personal Data in our files, please communicate any changes to our Customer Service. Therefore, we can ensure that the information contained in our files is, always, up-to-date and accurate. We reserve the right to suspend or interrupt the provision of the requested services should you provide inaccurate Personal Data, without prejudice to any action by law.
· Email: firstname.lastname@example.org
Any and all Personal Data sent to the Companies through the Website and/or the course of the purchase of products will be collected and/or processed by the Companies pursuant to the laws applicable to the state/country of residence of the customer including, as it pertains to residents of the European Union, EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation or GDPR) without prejudice however to any applicable local mandatory laws benefitting to consumers, in accordance with EU Regulation 593/2008 (“ROME I”) of 17 June 2018, or any other conflict of laws rules applicable (together, “Data Protection Legislation”).
The Companies may collect and process your Personal Data for a variety of different purposes. The reasons for collecting Personal Data will be expressly listed below. This information will be presented to Users from time to time on the website, before a consent is given and Personal Data is disclosed to the Companies, to provide full transparency regarding the use of data for Commercial Purposes or for Marketing Purposes. The responsible controller is specified per each particular purpose.
· Online Sales: Your Personal Data may be processed to provide the e-commerce services you subscribed to or reserved for registered users (as long as it is applicable and you provide the appropriate consent, if required separately), notably to fulfill placed orders for products, to contact you in case of any order issues or where we need to provide your Personal Data to our service providers to fulfill your order (herein the “Commercial Purposes"). This data processing is based on the fulfillment of our contractual obligations with the client in relation to the order.
Your Personal Data may also be processed (when permitted by applicable regulations) to send to users, also through newsletters, commercial information and updates related to your purchased products, including product information, offers, exclusive sales, promotional campaigns, events and similar initiatives organized by the Companies, if such data processing by law exceptionally does not require your separate consent and thus can be based on the legitimate interests as long as you don’t raise an objection towards us.
We may have access to third-parties Personal Data which was directly disclosed by its Users, for example when a User bought a product to be sent to a friend, when the User wishes to recommend to a friend a service of the Website or the sale of a particular product.
The specific Company, which is acting as a seller (Fashion NINA RICCI), shall be considered as the controller of your Personal Data collected and processed on the Website for Commercial Purposes, as it will determine the purposes and means of processing Personal Data for such Commercial Purposes such data.
· Marketing Purposes (Website and individual Online-Shops): Whenever we request, and you expressly dive us your consent, your Personal Data may also be processed for marketing purposes, notablyto send to users also though newsletters, commercial information and updates on our products, offers, exclusive sales, sampling and promotional campaigns and on events and similar initiatives organized by PUIG FRANCE and/or any companies of the PUIG Group, or to facilitate your navigation on the Website (herein the “marketing Purposes”). This data processinf is based on consent.
Your Personal Data is mostly processed by electronic means and, in some circumstances, by paper-based means, such as when the processing of your Personal Data is required for preventing fraud on the Website. Your Personal Data shall be stored in a way which allows us to identify you for the period necessary for the purposes which the data was collected for and subsequently processed and, in any case, in accordance with Data Protection Legislation. Your Personal Data shall not be disclosed to third-parties other than us for purposes which are not permitted by law or without your consent.
For the Marketing Purposes, we may process your Personal Data as well as browsing data ("Traffic data") resulting from the use of the Website and of our services by any User, in order to provide Users with customized contents and offers on our services or to deliver any newsletter they subscribed to, subject to their discretionary right to withdraw their subscription to such newsletter or to oppose or object to the receiving of any advertising or marketing content which we think is of interest to a specific User. For Marketing Purposes, Personal Data and Traffic data is mostly processed by electronic means and shall be stored for us in any case, in accordance with Data Protection Legislation and available to our Processors. The information obtained includes the internet protocol (IP) address of the device you are using, the navigation program you use, your operating system, the date and time of access, the Internet address of the website whereby you accessed our websites and also information on how you use our websites.
The basis for processing your personal data according to the above-mentioned purpose is founded on your consent. For further information on the use, as well as the configuration of your preferences on cookies (and/or similar technologies), please see our Cookies Policy.
You can always withdraw your consent regarding the data processing for Marketing Purposes by informing us using the contact information provided in below clause 9.
PUIG FRANCE shall be considered as the controller of your Personal Data collected and processed on the Website for Marketing Purposes, as it determines the purposes and means of processing Personal Data.
· Recipient: · The Companies and certain entities appointed by the Companies that will also process Personal Data relating to the Website’s Users and the Online Sales (hereinafter the "Processors").
The above-mentioned Processors have been chosen because of their experience in processing Personal Data and they provide sufficient guarantees regarding compliance with Data Protection Legislation (including the technical security measures governing the processing to be carried out). In processing the Personal Data for Commercial Purposes, the Processors shall act only under the instructions from the Companies. We regularly check that our Processors comply with our instructions and that they continue to provide sufficient guarantees regarding their full compliance with Data Protection Legislation on Personal Data processing.
The Processors of your Personal Data for Commercial Purposes are:
· Customer service, for purposes related to the shipping, delivery and return of products purchased on the Website and customer service to users of the Website;
· Computer services, for purposes related to hosting Companies servers;
· Payment platforms, for purposes related to the payment method and its execution;
· Logistic services, for purposes related to shipping and delivery and return of the products purchased on the Website.
· Marketing services, for the analysis of use of our Website, sending communications, managing advertising content, etc.
Aside from the Processors appointed for Personal Data processing, your Personal Data will be made available also to third-parties, independent controllers, for purposes related to supplying services requested by Users (for example, for purchase transactions) or for purposes of third parties. For more information on the matter, see section 5 (To Whom Your Personal Data Will Be Disclosed).
Moreover, your Personal Data may be disclosed to the police or to judicial authorities, according to applicable laws and upon a formal request by such entities, for example in the event we need to prevent fraud on the Site (anti-fraud services).
Granting your Personal Data to us (in particular, your personal details, your e-mail address, your address, your Credit/Debit Card numbers and bank code and your telephone number) is necessary for processing your order for the purchase of products on the Website, supplying other services provided on the Website upon your request, or when your Personal Data is needed to fulfil obligations required by law or regulations. The refusal to provide us with some of your Personal Data necessary for performing the above purposes may consequently prevent us from processing your order for the purchase of products sold on the Website, sending you requested Newsletters or fulfilling obligations required by law and other regulations etc. Therefore, failing to provide Personal Data may constitute, in some cases, a legitimate and justified reason for not processing your order for the purchase of products sold on the Website or not providing the Website’s services.
Disclosure of further Personal Data to us other than that required for fulfilling legal or contractual obligations and to be properly browse our services with necessary traffic data is, on the contrary, optional and does not have any effect on the use of the Website and of its services or on the purchase of products on the Website. We will inform you at every step whether disclosing your Personal Data to us is compulsory or optional by marking with an appropriate symbol (*) the information that is compulsory, or data needed for the purchase of products on the Website.
Personal Data will be disclosed to third-party companies that provide, on behalf of the Companies, specific information technology-, marketing and other services as data Processors or to other recipients (for example, for purchase transactions) of Personal Data collected by us that process your Personal Data only for the Commercial Purposes as independent data controller and, in any case, according to applicable laws and regulations.
Your Personal Data may also be shared between the Companies, the Companies distributors, and Nina Ricci’s licensees with registered offices in EU countries or non-EU countries for their own Marketing Purposes.
Notwithstanding the foregoing, Personal Data will not be disclosed to any other third-parties or disseminated or transferred without informing our Users of such disclosure / dissemination /transfer, and, in any case, in accordance with the applicable laws.
For the best possible protection of your Personal Data outside the limits of our control and management of the same, it is advisable that your computer be provided with software devices that protect network data transmission/receipt (such as updated antivirus systems) and that your Internet service provider take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
The Personal Data we collect from you is currently held within the European Union (‘EU’), except personal data which is collected via Cookies on the Website of the Companies. However, it is possible that in the future such Personal Data may be transferred, stored and/or processed outside the EU.
By submitting your Personal Data, you agree to this transfer, storing and/or processing. Please note that some cookie providers and data recipients may be in the United States or other countries which may have a lower level of data protection. For further information, click on "Cookie Settings” in the Cookie Banner. However, we will take reasonable steps to ensure that your Personal Data is given equivalent protection in accordance with the Data Protection Legislation, by implementing adequate contractual conditions in our agreements with business partners dealing with transfer of Personal Data to ensure that Personal Data are processed according to our instructions, and in such a way to maintain their integrity and security.
Each time your consent is required, the Companies will inform you in advance and will give you the option to either provide or refuse your consent for the use of your Personal Data, including your e-mail address, for the above purposes, by ticking the appropriate boxes.
We wish to inform you that we may process your Personal Data also without your consent in certain circumstances, such as when such processing is necessary for performing a legal obligation to which we are subject or when such processing is necessary for performing obligations undertaken in contracts with the users.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
Category A. Identifiers
Examples : A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Category B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Category C. Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category D. Commercial information.
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Category E. Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category F. Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Category G. Geolocation data
Examples: Physical location or movements.
Category H. Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Category I. Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Category J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Category K. Inferences drawn from other personal information.
Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
· Publicly available information from government records.
· De-identified or aggregated consumer information.
· Information excluded from the CCPA's scope, like:
o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
· Directly from our customers or their agents. For example, from information that our customers provide in order to facilitate the purchase of our products.
· Indirectly from our clients or their agents. For example, through information we collect from our customers in the course of providing products to them.
Both directly and indirectly from activity on our website (www.ninaricci.com).
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
· To fulfill or meet the reason for which the information is provided. For example, if you provide us with your address, we will use this information to ship products to you.
· To provide you with information, products or services that you request from us.
· To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
· To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
· To improve our website and present its contents to you.
· For testing, research, analysis and product development.
· As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
· As described to you when collecting your personal information or as otherwise set forth in the CCPA.
· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: California Protected Class information
Category D: Commercial Information
We disclose your personal information for a business purpose to the following categories of third parties:
· Our affiliates.
· Service providers.
· Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal information
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months, or longer if the period requested starts no earlier than January 1, 2022 provided that our fulfilment of such request is possible and is not unduly burdensome. Once we receive and confirm your verifiable consumer request, we will disclose to you:
· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· The specific pieces of personal information we collected about you (also called a data portability request).
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
o sales, identifying the personal information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion & Correction Request Rights
You have the right to request that we delete or correct any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will correct or delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We may deny your correction request if we determine that the information that you are seeking to correct is accurate, we cannot verify your identity, or your request is manifestly unfounded or excessive.
Exercising Access, Data Portability, Correction and Deletion Rights
To exercise the access, data portability correction, and deletion rights described above, please submit a verifiable consumer request to us by email at email@example.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
When handling requests to correct, we may require you to provide documentation that rebuts the information that we have on file. In determining whether such documentation is necessary, we will have regard to:
(A) The nature of the personal information at issue (e.g., whether it is objective, subjective, unstructured, sensitive, etc.).
(B) The nature of the documentation upon which we consider the personal information to be accurate (e.g., whether the documentation is from a trusted source, whether the documentation is verifiable, etc.)
(C) The purpose for which we collect, maintain, or use the personal information. For example, if the personal information is essential to the functioning of our business, we may require more documentation.
(D) The impact on you. For example, if the personal information has a negative impact on you, we may require less documentation.
We may delete the contested personal information as an alternative to correcting the information if the deletion of the personal information does not negatively impact you or where you consent to the deletion.
When responding to a request to correct, we will inform you whether we have complied with your question to correct, and if we have not, we will provide the basis for such action.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
· Deny you goods or services.
· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Sensitive Personal Information
California residents are permitted to request that businesses do not use their Sensitive Personal Information for purposes other than those directly related to the provision of services, or other limited purposes as set out by Californian law. Sensitive Personal Information includes social security numbers, financial account information, precise geolocation data, account login details and credit/debit card numbers. It is our policy to only use this information for the purposes of providing services to you. We currently store the following sensitive information: financial account information, account login details and credit card numbers. We do not process this information for purposes of inferring characteristics from those of whom we store Sensitive Personal Information.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
For residents of Colorado, Connecticut and Virginia
If you are a Colorado, Connecticut, or Virginia resident, you have the right to request access to, or correction or deletion of, your personal information; or to opt out of the processing of your personal information for targeted advertising purposes or the sale of your personal information. Certain advertising practices that we engage in, such as providing you with email alerts, event registrations and other notices concerning our products or services, or events or news that may be of interest to you, may be deemed targeted advertising or a “sale” under some state laws.
You can exercise these rights by submitting a request to firstname.lastname@example.org. Before processing your request, we will take reasonable steps to verify your identity, which will include verifying that the email address from which you submit the request matches the email address we maintain on file for you.
For residents of Utah
· request access to your personal information;
· request the deletion of personal information you have provided to us;
· opt-out of the processing of your sensitive information; or
· opt out of the processing of your personal information for targeted advertising purposes or the sale of your personal information.
Certain advertising practices we engage in may be deemed targeted advertising.
You can exercise these rights by submitting a request to email@example.com. Before processing your request, we will take reasonable steps to verify your identity, which will include verifying that the email address from which you submit the request matches the email address we maintain on file for you.
Last update: July 2023
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