PRIVACY POLICY
FABIANA FILIPPI S.p.A., with registered office in Via Bruno Buozzi, 90, 06030 Giano dell'Umbria (PG) - Italy, VAT Reg. No./Tax ID 02676310549 (hereinafter 'Fabiana Filippi') and The Level USA CORP - an affiliate of The Level SRL - with registered office in Piazza Arcole 4, Milan (MI), Italy, VAT No./F.F. 00610091209 (hereinafter, "TLG"), as joint controllers ("Joint Controllers") of the processing of the personal data of users (hereinafter, the "Users") who browse and purchase products and use the services available on the website www.fabianafilippi.com (hereinafter, the "Site"), as indicated in purpose number 1 of this notice, provide below the information, pursuant to Articles 13 and 14 of the European Regulation 2016/679 of 27 April 2016 (hereinafter, the "Regulation").
Please note that this information is also provided by Fabiana Filippi as autonomous data controller for the purposes listed in numbers 2, 3 and 4 of this notice. With respect to these purposes TLG is a Data Controller, by virtue of a specific contract signed between the parties.
This Site and its services are reserved for persons who have reached the age of eighteen years.
Fabiana Filippi has appointed its own Personal Data Protection Officer (DPO), who can be reached at the email address dpo@fabianafilippi.com and at the physical address of the company listed above.
TLG has also appointed its own Personal Data Protection Officer (DPO), who can be reached at the email address dpo@thelevelgroup.com and at the physical address of the company listed above.
1. Purposes and legal bases of the processing of Fabiana Filippi and TLG as Joint Controllers.
The Users' personal data will be processed by the Joint Controllers for the following purposes:
a) to enable navigation and for the provision of services on the Site. The User data collected by the Joint Controllers, for the purposes listed above, include: first name, last name, email address, date of birth, online identifiers. The legal basis for the processing is the need to execute the contract to which the User is a party or to respond to his/her specific requests;
b) for sales and after-sales activities implemented through the e-commerce of the Site. The User data collected by the Joint Controllers for this purpose include: the User's first name, last name, address, email address, telephone number, date of birth, username and password, as well as data relating to sales made and all personal information provided by the User. The User's personal data will also be used to ascertain his or her identity, thus avoiding possible fraud or abuse (including by validating his or her e-mail address) and to contact him or her for return management and after-sales service. The legal basis for the processing is the need to execute the contract to which the User is a party or to respond to his/her specific requests.
c) administrative-accounting purposes. I.e. to carry out activities of an organisational, administrative, financial and accounting nature, such as internal organisational activities and activities functional to the fulfilment of contractual and pre-contractual obligations and reporting between the Joint Controllers. The legal basis for the processing is the fulfilment of legal obligations;
The provision of personal data for the processing purposes indicated above is optional but necessary in order to make purchases in e-commerce and use the services of the Site. Failure to provide them will make it impossible for the User to browse the Site, make purchases and use the related services. The above processing does not require the consent of Users.
2. Further purposes and legal bases of the processing of Fabiana Filippi as autonomous Data Controller: marketing and newsletters (sending of advertising material, direct sales and commercial communication).
With the free and optional consent of the User, his/her personal data (i.e. name, surname, address, telephone number, e-mail address and date of birth) may also be processed by Fabiana Filippi for marketing purposes and for sending the newsletter. Fabiana Filippi may contact the User by post, e-mail, telephone (fixed and/or mobile, with automated call or call communication systems with and/or without the intervention of an operator), SMS, MMS or WhatsApp to propose the purchase of its products and/or services, present offers, promotions and commercial opportunities.
The legal basis for this processing is consent.
In the event of non-consent, the possibility of registering on the Site and making use of the related services shall not be affected in any way.
In the case of consent, the User may revoke it at any time by making a request to Fabiana Filippi in the manner indicated in paragraph 8 below.
The User may also, object to further sending of promotional communications by email in the manner set out in paragraph 8 below or by using the "unsubscribe" link provided in each promotional email.
3. Further purposes for processing by Fabiana Filippi: soft spam.
Fabiana Filippi may carry out marketing by e-mail directed to Users who have made purchases, in order to propose to them products similar to those they have purchased (so-called soft spam). The legal basis for this processing is the legitimate interest of the Controller. The User's consent is therefore not required, but he/she may object at any time in the manner set out in paragraph 8 below or by using the appropriate "unsubscribe" link in each email sent.
4. Further purposes for processing by Fabiana Filippi: profiling.
With the User's free and optional consent, his personal data (i.e. personal and contact details, information on the services and products in which he has expressed an interest, details of purchases made) may also be processed by Fabiana Filippi in order to define his purchasing choices and thus to analyse his consumer preferences and create individual and group profiles, also in order to be able to send him targeted commercial offers consistent with the profile identified and automated e-mails on the basis of his purchasing behaviour.
The legal basis for this processing is consent.
If consent is not given, the possibility of registering on the Site will not be affected in any way.
In the case of consent, the User may revoke it at any time or may object to it by making a request to Fabiana Filippi in the manner indicated in paragraph 8 below.
5. Processing methods and data retention periods
The Joint Data Controllers and Fabiana Filippi, for the processing of which it is the autonomous Data Controller, will process the Users' personal data by means of manual and computerised tools, with logics strictly related to the purposes themselves and, in any case, in such a way as to guarantee the security and confidentiality of the data.
The data collected through Fabiana Filippi's e-commerce is processed together with the data that the customer has provided by making purchases and/or registering their account at the Company's Stores or in its mobile applications. For more information on this processing, the customer can refer to the privacy policy available at their respective Stores.
No fully automated decision-making processes are used that could have legal effects for the Users or significantly affect their person.
The Users' personal data shall be used by the Joint Controllers for the time strictly necessary to fulfil the purposes set out in paragraph 1 above. Once these purposes have been fulfilled, the data will be kept for the time required by law for administrative, accounting and tax purposes and to enforce any rights and interests of the Joint Controllers (10 years).
For the purposes set out in paragraphs 2, 3 and 4 above, Users' personal data will be processed by Fabiana Filippi until consent is revoked or opposition is made, in accordance with the most recent provisions of the Italian Data Protection Authority.
For the purpose mentioned in paragraph 4, in any case, the data will be used for a maximum period of 7 years after their registration.
For the processing of which Fabiana Filippi is autonomous Data Controller, the data will also be kept for the time necessary to protect its rights and interests.
6. Using Live chat
The Joint Controllers inform that Facebook and Google registered Users can authenticate themselves in the Live chat by importing their Facebook and Google profiles. The data that will be disclosed to the Joint Controllers are the following: name, surname, e-mail address and will be used to pre-fill the contact request form via Live chat. By subscribing to this service and clicking on the Facebook or Google button, the User consents to the above-mentioned data being transferred from the Facebook platform and Google to the Joint Controllers.
7. Data recipients
Employees and/or collaborators of TLG and Fabiana Filippi may come to know the personal data of Users. These parties shall process the data of Users exclusively for the purposes stated in this notice and in accordance with the instructions given to them.
Furthermore, Users' personal data may be disclosed to parties who process personal data in their capacity as Data Processors, such as, by way of example, suppliers of IT and logistical services functional to the operation of the Site and/or the Services, suppliers of outsourcing or cloud computing services, professionals and consultants.
Users may request the list of Processors by making a request in the manner indicated in paragraph 8 below.
Furthermore, Users' personal data may be disclosed, to the extent that this is necessary and essential to the performance of contractual obligations, to autonomous third-party data controllers, such as the providers of payment services and logistics services necessary for the delivery of goods sold through the Site. These autonomous controllers will process the User's data exclusively for the purpose of the correct execution of the orders placed by the User.
Users' personal data may be transferred by Fabiana Filippi to its group companies, which have been appointed as Data Processors, also located in countries outside the European Union, adopting appropriate guarantees and the necessary security measures to guarantee an adequate level of data security and the exercise of Users' rights.
Users have the right to obtain information on this transfer at any time by making a request to Fabiana Filippi in the manner indicated in paragraph 8 below.
8. Rights of the Data Subjects
In order to exercise the rights guaranteed by the Regulation with respect to the processing under this notice Users may contact Fabiana Filippi, using the following methods:
By writing to the registered office of Fabiana Filippi S.p.A. - Via Bruno Buozzi, 90, 06030 Giano dell'Umbria (PG), Italy.
By sending an e-mail to Fabiana Filippi 's Data Protection Officer (DPO) , whose contact details are given below: mail dpo@fabianafilippi.com.
With the access request, Users have the right to obtain information on (i) the origin of the personal data; (ii) the purposes and modes of the processing; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) the identification details of the Joint Controllers and Processors; (v) the persons or categories of persons to whom the personal data may be disclosed or who may become aware of them in their capacity as Data Processors or Authorised Persons.
Users also have the right to obtain:
(a) rectification and integration of data;
(b) cancellation (so-called 'oblivion') of any processed data in breach of the law, including any data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
c) certification that the operations referred to in points a) and b) have been brought to the attention of those to whom the data have been disclosed or disseminated, unless this proves impossible or involves a manifestly disproportionate effort compared to the protected right.
Furthermore, Users have the right:
(d) to withdraw their consent at any time, if the processing is based on their consent;
e) to the data portability (the right to receive or communicate personal data concerning them in a structured, commonly used and machine-readable format to another data controller);
(f) to the restriction of processing;
(g) to object:
(i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if they are relevant to the purpose of the collection;
(ii) in whole or in part, to the processing of personal data concerning them for marketing purposes;
(iii) processing for profiling purposes to the extent that such processing is related to marketing.
(h) if they deem that the processing concerning them is in breach of the Regulation, to lodge a complaint with a supervisory authority (in the Member State where they habitually reside, in the Member State where they work or in the Member State where the alleged breach occurred). The Italian supervisory authority is the Garante per la Protezione dei Dati Personali, based in Rome (http://www.garanteprivacy.it/).
Any future changes to this policy will be posted on the Site and, where appropriate, notified to Users by e-mail.
Version 0.2 November 2023