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XOEÂN & Me

Privacy Notice

SYNTHETIC PRIVACY NOTICE XOEAN & ME 

 

 

 

 

 

 

 

 

 

By registering with XOEAN & Me, XOEAN LLC., as Data Controller, will process the data you provide us by filling in the present electronic form (e.g. title, name, surname, e-mail, age range, country/region of residence, nationality), to create your personal area within the XOEAN web site, allow you to join our loyalty program and access the services and facilities reserved to the registered members and manage your purchases faster.

Furthermore, if you wish to provide your consent, XOEAN LLC. may use your data, including those related to your purchases (e.g., boutique where the sale took place, number, type and price of purchased products), those eventually communicated to XOEAN by third parties authorized resellers and/or provided by you when visiting XOEAN stores (e.g. age, favorite products, colours and materials, style, hobbies, most visited countries/regions, size), in order to:

  • learn more about your purchase habits and your preferences, so as to customize our offer of products and services in the Fendi world and offer you a tailored treatment at each XOEAN store;

  • contact you, also by sending customized communications (e.g. newsletter, mail, e-mail, calls via operator, text messages, instant messaging such as WhatsApp, WeChat and Social networks in general, posts, messages or communication on initiatives on social networks, etc.) and keep you updated on XOEAN brand products, services (e.g. new purchasing methods, home delivery, etc.), initiatives and events), or to have you participate in market surveys.

Should you not wish to provide your consent you can still subscribe to XOEAN & Me and take advantage of the related services offered by us. Your consent can be freely withdrawn.

In general, personal data will be retained for no longer than is necessary for the purposes for which the data were collected. Your data necessary for managing your purchases and the related services will be processed for the time necessary to reach such purposes and, subsequently, to comply with the related legal requirements (e.g. tax and accounting requirements), after which the data will be deleted or anonymized.

For customer loyalty, your data will be processed for the entire duration of your registration to our loyalty program.

Processing of data collected for the purposes of contacting you, also by sending customized communications on our products, services and events and to participate in market surveys and to know your preferences will be based on the consents you will provide us with, which can be in any case withdrawn at any given time. With limited reference to data collected for purposes of learning about your habits and preferences, data will be retained for a maximum period of 7 years. At the time when consent will be revoked or, as the case may be, when the term above mentioned expires, data will be deleted or anonymized.

Please note that by sending an e-mail to customerprivacy@xoean.com you will always be able to withdraw from your registration with XOEAN & Me. Pursuant to applicable law, you may have a right to access your personal data, update and delete them, withdraw or modify the consent you provided us with, and receive or ask for the transmission of your data to another data controller. Furthermore you will always be able to object at any time to the processing of your personal data for marketing purposes and/or for analysis of your preference purposes; or, if different, with the supervisory authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

If you would like more detailed information, please read the full text that follows in the XOEAN & Me Extended Privacy Policy.

a) Who processes your personal data:

XOEAN LLC., with registered office in telephone number (), e-mail address: customerprivacy@xoean.com ("XOEAN"), is the company which, as Data Controller, collects and processes your personal data.

b) How we collect and why we process your data:

We process the data you are providing to us:

- by filling in the XOEAN & ME electronic form and

- the data relating to your purchases or data provided by you when visiting XOEAN stores (e.g. favourite products, colours and materials, style, hobbies, most visited countries/regions, size), and

- those eventually communicated to XOEAN by third parties authorized resellers will be processed, as the case, in order:

  1. to allow you to access to all the services and facilities reserved by XOEAN to the registered members of its loyalty program, even though the creation of your personal online account, such as: to manage your purchases faster, to take advantage, depending on the initiatives/campaigns undertaken from time to time by XOEAN, of benefits and free services (e.g. personal shopping, tailoring, home delivery, gadget and/or discounts on your birthday and/or based on your purchase threshold), check your purchase history, create your Wish Lists and view on your online profile – if you wish – also your purchase history at XOEAN stores and the Wish Lists created for you at the stores;

  2. to analyze your interests, preferences and purchase habits, also on the basis of the data provided by you when visiting and purchasing at XOEAN stores and on XOEAN web site, in order to allow XOEAN to customize its offer of products and services and allow you to receive a tailored treatment at each XOEAN store;

  3. to keep you updated by sending you promotional material, also customized (e.g. by mail, e-mail,  calls via operators, text message, instant messaging, such as WhatsApp, WeChat and Social networks in general), posts, messages or communications on initiatives on social networks, etc.) on XOEAN brand products (e.g. clothing, leather goods, accessories, home, etc.), services of XOEAN world (e.g. purchasing methods, home delivery, etc.), initiatives and events organized by XOEAN or to which XOEAN adheres (e.g. new opening of XOEAN stores), as well as to have you participate in market surveys (in order to learn more about your interests and to improve our offer);

  4. to send you our Newsletter on XOEAN brand products.

The legal basis [1] for the processing of your data will be, depending on the case, the performance of the contract or your consent, if provided. For EU residents, this is in accordance with Article 6, paragraph 1, letters a) and b) of Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”).

c) Your consent:

In order to learn more about your interests and purchase preferences (so as to improve our offer of services and products), keep you updated on our products, services, initiatives and events, send you promotional material, even customized, or have you participate in market surveys (purposes no. 2, 3 and 4 paragraph b) we need your explicit consent. Should you not wish to provide your consent you can still subscribe to XOEAN & Me and take advantage of the facilities offered to the registered members (purpose no.1 paragraph b). Your consent can be freely withdrawn (as set forth in lett. j) of this Privacy Notice) at any time simply by accessing your personal area in XOEAN & Me or even by sending an e-mail to customerprivacy@xoean.com; the withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.  

Please note that, in case of withdrawal of your consent for sending updates, promotional communications or market surveys (purposes no. 3 and 4 paragraph b), you will no longer be the recipient of any type of communication. If you wish, you may withdraw your consent only to the receipt of communications via electronic means (e.g. newsletter, e-mail, sms, instant messaging), continuing to receive commercial communications only by mail or calls via operators, if provided and vice versa.

d) Which data are processed and which ones are mandatory

For the purposes indicated above, XOEAN shall process the following categories of personal data:

  • Personal details (title, name, surname, date of birth and nationality);

  • Contact details (Country/Region of residence, e-mail address, mobile telephone number);

  • Data related to the delivery of goods (address, telephone number, gift box);

  • Data related to the purchases you made (boutique where you made the purchase, number, type and price of products purchased);

  • Additional personal data useful to carry out marketing and analysis activities (age, favorite product categories, favorite color, style, other brands purchased, hobbies, most visited countries/regions, as the client knows Fendi, size, measures, marital status, number of children, anniversary, notes related to purchase preferences or special needs expressed by the client – e.g. favorites materials), if you have a Personal Sales Assistant, XOEAN events to which you participated.   

We ask you to provide all the data requested as “mandatory” (e.g.  name, surname, e-mail address, date of birth, address) as needed for your registration and creation of your profile in XOEAN & Me; in case of missing or incomplete compilation of such data, your registration will not be completed. Failure to provide the data marked as “optional” (that are the additional personal data useful to carry out the marketing and analysis activities listed above), will simply not allow us to use your data for the purposes no. 2 e 3 paragraph b) for which you have provided your consent; any refusal will have no consequences on your possibility of proceeding with the purchase of our products, but it will not be possible for us to inform you about our products and services, our initiatives and events or analyze your preference and interests.

e) How do we process your data:

Your data will be processed with and without the aid of electronic tools and stored on servers located in Italy.  In particular, if you provide us with your consent to use your data for the purposes no. 2 and 3 paragraph b) above, your data will be organized and processed using automated methods based on your preferences, enabling us to  know your interests and propensities to purchase (e.g. by checking which products you purchased), adjust our products and services offer and update you on our products (e.g. new collections), services (e.g. purchase methods, home delivery, etc.), initiatives and events (e.g. invitations to events organized by XOEAN or to which XOEAN adheres), send promotional material that can also meet your tastes and interests (e.g. if you have purchased women's footwear in the past, we could send you our new women's catalogue, or send you promotions related to matching products or the same style), or contact you to participate in market surveys (e.g. through interviews, telephone contact, e-mail, etc.).

We specify that none of our analysis activities of your data and preferences will be based solely on automated processing but will always involve the intervention and evaluation of our persons in charge of the processing.

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. In the event that we are required by law to inform you of a breach to your personal data we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

f) Data entry into our CRM (Customer Relationship Management) system:

The insertion of your data into XOEAN CRM system – for the purposes no. 2), 3) and 4) of paragraph b) above -  is optional and will only take place if you provide us with your consent to the processing of your data. The insertion of your data into our CRM system, will entail the possibility of reading, inserting and amending them by employees and staff (at the offices and stores) of XOEAN, XOEAN LLC. and other retail companies of XOEAN brand products in America and abroad (each for its respective field of competence) specifically authorized to data processing, pursuant to art. 29 of the Regulation.

g) How long do we store your data:

In general, personal data will be retained for no longer than is necessary for the purposes for which the data were collected. For the purposes No. 1, 2 and 3 paragraph b) your data will be processed, as the case may be, for the entire duration of your registration to our loyalty program and on the basis of the consents you will provide us with, which can be withdrawn at any given time (as set forth in lett. j) of this Privacy Notice). With limited reference to data collected for purposes No. 2 paragraph b) data will be processed for a maximum period of 7 years (pursuant to the Data Protection Authority’s decision dated 22 December 2015). At the time when consent will be revoked or, as the case may be, when the term above mentioned expires, data will be deleted or anonymized.

h) By whom your data are processed:

To manage your registration with XOEAN & Me and, if you give your consent, to pursue the further purposes no. 2, 3 and 4 paragraph b), your data will come to knowledge (limited to the respective field of competence) of the persons in charge of the processing at XOEAN CRM Department and of the companies acting as external Data Processors which provide us with services useful for the management of our website, of the purchases or that carry out marketing activities on our behalf[2],  as well as to our commercial partners..

i) Your data are transferred to Extra EU country/region:

To allow us to provide you with a tailored service also in the event of purchases made at XOEAN stores abroad, your personal data may be transferred to the extra-EU countries/regions where XOEAN stores are located, and/or in countries/regions within or outside of the European Union where our commercial partners are established..

The transfer of your data will take place in full compliance with the safeguards, measures and rights provided by the privacy legislation [3]. By simple request to be made to the contacts indicated in paragraph j), EU residents will receive more information on the transfer of your data and on the safeguards provided for their protection.

j) Your rights:

By sending an email to XOEAN CRM Department, e-mail customerprivacy@xoean.com, XOEAN LLC.,

, EU residents may exercise at any time their rights [4] provided for by Articles from 15 to 22 of the Regulation, such as access which data we are processing, with which methods and for what purposes we process them, rectify the data you provided to us or delete them, ask us to restrict the processing of your data, request to receive or ask for the transmission of your data to another data controller, without prejudice to the possibility of changing or withdrawing your consent.

In particular, EU residents have the right to withdraw at any time the consents provided to the processing and to object to the processing of your personal data especially for marketing purposes and/or for the analysis of your preference.

We remind you that, by sending an e-mail to customerprivacy@xoean.com you will be able to withdraw your registration with XOEAN & Me.

k) Who you can contact to lodge a complaint:

We remind EU residents that, should you consider the processing of your data infringes the Regulation, you may in any event lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it), or, if different, the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

l) Data Protection Officer (DPO):

You can contact the Data Protection Officer appointed by XOEAN LLC. at the e-mail address dpo@xoean.com.

Footnotes

[1] The processing of your data:

- for purposes listed under point 1 paragraph b) shall take place without your consent, pursuant to art. 6, paragraph 1, letter b) of the Regulation;

- for purposes listed under points 2, 3, and 4 paragraph b) shall take place based on your consent, pursuant to art. 6, paragraph 1, letter a) of the Regulation.

[2] Your data may become to knowledge, as external Data Processors, of the following recipients:

  1. retail companies which manage XOEAN stores in America and abroad (if you have made purchases in our stores);

  2. companies that are commercial partners of XOEAN;

  3. companies which carry out the analysis of your purchases on our behalf;

  4. companies responsible for managing XOEAN "Customer Service" on our behalf;

  5. companies in charge of processing, managing and sending newsletters and promotional material;

  6. companies that organize and manage market research and surveys on our behalf;

  7. companies entrusted with the management of our website and the related databases;

  8. companies that deal with the management and technical maintenance of the CRM system.

The names of all the external Data Processors can be requested via email to customerprivacy@xoean.com.

[3] Pursuant to the applicable legislation, we do not need your specific consent to transfer your data to third countries/regions since the transfer is made on the basis of appropriate safeguards pursuant to articles 46 and 47 of the Regulation, such as the adoption of the standard data protection contractual clauses adopted by the EU Commission as it happens in the relationships with the retail companies that manage the XOEAN stores in the world.

The transfer of your data to any additional third countries/regions, if necessary, will take place in full compliance with the safeguards, measures and rights as provided for by the Regulation. By simple request to be made to the contacts indicated in paragraph j), you will receive more information on the transfer of your data and on the safeguards provided for their protection as well as on the means to obtain a copy of the data or the place where they were made available.

The data will still be stored on servers in Italy.

[4] The articles from 15 to 22 of the Regulation recognize specific rights including:

  • obtaining confirmation as to whether or not personal data concerning you is being processed;

  • obtaining access to your personal data and to the information set out in Article 15 of the Regulation;

  • obtaining the rectification of the inaccurate personal data that concern you without undue delay or the supplementing of incomplete personal data;

  • obtaining the erasure of the personal data that concern you without undue delay;

  • obtaining the restriction of processing the personal data that concern you;

  • being informed of any rectifications or erasures or restrictions of processing in relation to the personal data that concern you;

  • receiving in a structured, commonly used and machine-readable format the personal data that concern you;

  • objecting at any time, on grounds associated with your specific situation, to the processing of the personal data that concern you.

In particular, you have the right to withdraw at any time the consents provided to the processing and to object to our market analysis activities.

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