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Newsletter Privacy Policy 

 

 

 

 

 

Regulation (EU) 679/2016 General Data Protection Regulation

 

a. Who processes your personal data:
XOEAN LLC., with registered office in (), email customerprivacy@xoean.com (hereinafter, “XOEAN”), is the company that, in its capacity as Data Controller, collects and processes your personal data, pursuant to Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”).

b. Why we process your personal data:
The data that you provide us with by filling out this electronic form is necessary to allow you to sub-scribe to the XOEAN Newsletter and update you by sending you promotional material (via email) on XOEAN branded products, services (e.g. purchase methods, home delivery, etc.), initiatives and events (e.g. next openings of XOEAN stores), as well as to carry out market researches (to better know your interests and to improve our offer).
If you indicate your country/region to us, we will send you communications regarding events and initiatives related thereto.
The legal basis for the processing of your data will be your consent according to Article 6, paragraph 1, letter a) of the Regulation.

c. Your consent:
In order to be able to keep you updated on our products, services, initiatives and events, to send you promotional material, including customised material based on your country/region, or to carry out market researches, we need your explicit consent (pursuant to Article 6, paragraph 1, letter a) of the Regulation). Should you not provide us with your consent, we will not be able to proceed with your subscription to our Newsletter. You may freely revoke your consent (see letter h) of the policy) without prejudice to the lawfulness of the data processing prior to revocation, by simply following the link enclosed in all our Newsletters or by writing to customerprivacy@xoean.com.

d. What data is required:
Please provide us with all the data required as “compulsory” (*), since it is necessary for your subscription to our Newsletter; in the case of missing or incomplete compilation, the subscription cannot be completed. If you decide not to indicate your country/region (an “optional” data), this will simply mean we are unable to send you communications on events and initiatives related to your country/region.

e. How we process your data:
Your data will be processed electronically pursuant to the applicable laws, in accordance with the prescriptions under the provisions in force - as subsequently amended and/or supplemented - issued by the Authority for Personal Data Protection (which include Guidelines for promotional activities and against spam issued on 4 July 2013) and, in any case, in a manner that guarantees their protection and confidentiality and prevents unauthorized disclosure, use, alteration or deletion thereof.

f. Duration of your personal data’s storage:
Your data will be processed for the duration of your subscription to our Newsletter service or - in any case - until you revoke your consent (which you may request at any time, also by following the link enclosed in all our Newsletters); subsequently, the data will be deleted or anonymized.

g. Who processes your personal data:
Your personal data will not be disclosed. In order to allow you to receive our Newsletter and to be contacted by XOEAN, your data may be made known (within their respective roles) to people author-ised to process it in the CRM, Digital and E-Commerce Department of XOEAN, as well as to our commercial partners and the companies that provide us with services[1] useful for the management of our website or that carry out marketing activities on our behalf.

h. Your data is transferred outside the European Union:
In order to permit us to correctly manage our Website and the Newsletter service requested by you, your personal data may be subject to transfer to non-European Union countries/regions that host XOEAN stores, the list of which is published on our website In order to permit us to correctly manage our Website and the Newsletter service requested by you, your personal data may be subject to transfer (i) to non-European Union countries/regions that host XOEAN stores, the list of which is published on our website www.xoean.com, or where our sale service providers are established, as well as (ii) to our commercial partners which can be located outside European Union.
The applicable provisions establish that your specific consent is not necessary to transfer data to third countries/regions since the transfer is carried out based on the adoption of adequate guarantees pur-suant to Articles 46 and 47 of the Regulation, such as the adoption of standard contract clauses ap-proved by the European Commission as applied to the relations with the retail companies that man-age the Fendi stores worldwide and with our service providers.

i. Your rights:
By means of notice to be sent to the internal Officer of the CRM Department, email customerprivacy@xoean.com XOEAN, ()

you may, at any time, exercise your rights[2] under Articles 15 to 22 of the Regulation, which include the right to know what data we are processing, the procedures we are following and the purposes we are using them for, as well as the right to change the data you have provided us with or to delete it, to request us to limit the use of your data, to request us to receive or to transfer your data to another data controller, without prejudice to your right to change or to revoke your consents.
Moreover, you may always oppose that your data be processed, in particular, for marketing purposes.

j. Who you may file a complaint with:
We hereby remind you that, if you think that the processing of your personal data infringes the regulatory provisions, you may file a complaint with the Authority for personal data protection (), or with the Authority for personal data protection with jurisdiction in the country/region you reside habitually, work in or in the place where the alleged infringement took place.

k. The Data Protection Officer:
The Data Protection Officer appointed by XOEAN LLC. may be contacted at the following email address dpo@xoean.com.

 

Footnotes

[1]Your data will be made known to the following recipients, in their capacity as External Processing Officers:

(i) to companies empowered to process, manage and send newsletters and promotional material;
(ii) to companies that organize and manage market researches on our behalf;
(iii) to companies empowered to manage our website and the related IT archives;
(iv) Fendi’s commercial partners

The names of all the External Processing Officers may be requested via email to be sent to customerprivacy@xoean.com

[2]Articles 15 to 22 of the Regulation provide for specific rights, which include:

  • the right to obtain confirmation of whether or not your personal data are being processed;

  • the right to be granted access to your personal data and the information indicated by Article 15 of the Regulation;

  • the right to correct your inaccurate personal data without undue delay or to supplement your incomplete personal data;

  • the right to delete your personal data without undue delay;

  • the right to be granted restrictions on the processing of your personal data;

  • the right to be informed of any corrections or deletion or restrictions concerning the processing carried out in relation to your personal data;

  • the right to receive your personal data on an automatic device in a structured, ordinary and legible format;

  • the right to oppose, at any time, for reasons related to a particular situation, the processing of your personal data.

You have the right to revoke, at any time without prejudice, the consents provided for any processing and to oppose our analysis-related activities.
Moreover, pursuant to Article 21 of the Regulation, you shall be entitled, at any time, to oppose, for reasons related to your particular situation, the processing of your personal data carried out to pursue the legitimate interest of the Data Controller pursuant to Article 6, paragraph 1, sub-para. f) of the Regulation.

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