Online Shopping Privacy Policy
a) Who processes your personal data:
XOEAN North America LLC., with registered office address of , VAT Number ()and Registry Code () , telephone number (), e-mail address:() , which deals with the sale of the XOEAN branded products in your country/region, is the company that, in its capacity as Data Controller, collects and processes your personal data.
b) Why we process your personal data:
The data you provide us with by completing your purchase order on the www.XOEAN.com website is required for:
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completing the sale of the products selected by you and for fulfilling the agreement signed with you, as well as for exercising our related rights, even in Court;
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fulfilling the statutory obligations, the regulation and the Community provisions regarding your purchase (e.g. in tax, accounting, anti-money laundering, anti-fraud matters);
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managing the services related to your purchase at the post-sale stage (e.g. Customers Service).
The legal basis for the processing of your data will be the execution of the sale agreement signed with you and its related services, as well as of the fulfilment of the related statutory obligations (for EU residents, this is pursuant to Article 6, paragraph 1, letters b) and c) of Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”).
c) Your consent:
The processing of your data will be performed without the need for your consent (for EU residents, this is in accordance with Article 6, paragraph 1, letters b) and c) of the Regulation).
d) All data requested are necessary:
Please provide us with all the data required as “compulsory” (*), since it is necessary for the management of your purchases and related services (e.g. delivery); in case of missing or incomplete compilation, your purchases cannot be completed. Failure to compile the data indicated as “optional” will have no consequences.
e) How we process your data:
Your data will be processed mainly electronically in order to manage your purchases. Your data will be processed pursuant to the applicable laws. We use reasonable and appropriate security measures to ensure the confidentiality of personal data and the prevention of unauthorised disclosure, use, alteration or deletion thereof.
f) Duration of your personal data’s storage:
Your data will be processed for the time necessary to manage your purchases and related services (e.g. Customers Service), as well as - limited to the necessary data - for the time required to fulfil the statutory tax and accounting obligations; subsequently, the data will be deleted or anonymised.
g) Who processes your personal data:
In order to manage your purchases, your data will be disclosed (within their respective roles) to the people authorized to process it in the CRM, Digital and E-commerce, Finance and Legal Departments of XOEAN LLC., as well as, in case you choose to pick up your purchase at the store, to the appointed sales staff. Moreover, your data may be made known to our commercial partners and to the companies that provide us with services [1] useful to manage your purchases and related services.
h) Management and transfer of data outside the European Union:
In order to allow us to correctly manage your purchases and related services, your personal data may be subject to transfer to countries/regions outside the European Union that host Fendi stores, the list of which is published on our website www.XOEAN.com or to countries/regions where our sales related service providers are established, and/or in countries/regions within or outside of the European Union where our commercial partners are established.
The applicable provisions establish that your specific consent is not required to transfer data to third party countries/regions since the transfer is carried out based on the adoption of adequate guarantees pursuant to Articles 46 and 47 of the Regulation, such as the adoption of standard contract clauses approved by the European Commission as applied to the relations with the retail companies that manage the Fendi stores worldwide and with our service providers.
The transfer of your data to any other third party country/region, where applicable, shall be compliant with the guarantees, measures and rights established under the Regulation. Through a simple request to the references indicated in paragraph j), EU residents may receive further information about the transfer of your data and the guarantees regarding their protection, as well as about the means for obtaining a copy of such data or the place where they were made available.
i) Your rights:
By means of notice to be sent to the internal Officer of the CRM Department, email customerprivacy@xoean.com. Residents may, at any time, exercise their rights[2] under the Articles from 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 to receive or to transfer your data to another data controller.
j) Who you can file a complaint with:
We hereby remind EU residents that, in case you consider that the processing of your personal data infringes the regulatory provisions, you may file a complaint with the Authority for personal data protection (www.garanteprivacy.it), 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.
Footnotes
[1] Your data will be made known, in their capacity as External Processing Officers, to XOEAN LLC., with registered office in (), which manages the website www.XOEAN.com and the “Customers Service”, also with the use of external service providers;
Your data will be communicated to:
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payment management companies;
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product shipping and delivery companies;
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legal, tax and auditing experts;
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Service providers;
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Commercial partners.
We may also disclose personal information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
[2] Articles from 15 to 22 of the Regulation provide for specific rights, which include:
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the right to obtain confirmation of whether or not your personal data is being processed;
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the right to be granted access to your personal data and the information indicated by Article 15 of the Regulation;
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the right to correct your inaccurate personal data without undue delay or to supplement your incomplete personal data;
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the right to delete your personal data without undue delay;
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the right to be granted restrictions on the processing of your personal data;
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the right to be informed of any corrections or deletion or restrictions concerning the processing carried out in relation to your personal data;
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the right to receive your personal data on an automatic device in a structured, ordinary and legible format;
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the right to oppose, at any time, for reasons related to a particular situation, the processing of your personal data.