This privacy statement explains how Krocette, a company incorporated under Italian law, with registered office in Circonvallazione Clodia 15 00195 Rome Italy, processes your data in accordance with the European Regulation 2016/679 (“GDPR “) and with the data protection law applicable in your country, territory or locality (together with the GDPR, the”Read on Privacy “).
We believe that the protection of your personal data is a fundamental value of our business activity and we want to provide you with any information so that you are able to control the use of your personal data and to consent, where appropriate, to its processing by Krocette in explicit and informed manner.
a) when is personal data collected?
Your personal data may be collected on the following occasions:
- if you wish to join the Krocette loyalty program (“My Krocette Program“) and become a registered customer (“My Krocette Customer“);
- if you purchase Krocette products or services, as a My Krocette Customer, in one of the points of sale participating in the My Krocette Program worldwide (see the list of participating countries below) or if you visit and / or make a purchase on one of the websites Krocette or also through the Krocette App or any other online channel or social media relating to Krocette (the “Online Channels “);
- on the occasion of any promotional initiatives promoted by Krocette (such as, for example, games or competitions with prizes).
b) who is the data controller of your personal data?
F.G.P.A. Group S.r.l.s. , with registered office in C.ne Clodia 15, 00195 Rome (RM), Italy, will process your personal data, as data controller, to manage:
- your subscription to the My Krocette Program to register you as a My Krocette Customer and to ensure the security of your profile after registration (“My Krocette Customer Registration”);
- any service and / or initiative reserved for My Krocette customers worldwide (for example, participation in games or prize competitions), including, the sending of communications aimed at making you aware of such services and initiatives (“Services and Initiatives reserved for My Krocette Customers “);
- customer interaction with our social pages (Instagram, Facebook, Twitter, YouTube, etc.) (“Social Interaction“);
- the activities “Marketing” “Profiling“
In relation to the processing of your personal data for the purchase of Krocette products, including the provision of any related service such as shipping, “gift message / gift wrapping” service, in-store delivery, returns management, customer service and post-support sale (collectively, i “Sales Services“), your personal data will be processed by independent data controllers, identified as follows:
|krocette||• for the purchase in one of the Krocette points of sale located in Italy • for the purchase through one of the Online Channels available in EU countries|
c) the personal data we collect, the purposes and legal bases of the processing?
Krocette may process your personal data – voluntarily provided by you – for the following purposes, according to the following legal bases:
|Categories of personal data||Purpose||Legal basis|
|name, date of birth, social security number, address, telephone number, e-mail address, data relating to hobbies, work, interests, purchase data (e.g. products purchased, place, date and time of purchase, delivery), displayed products||(1) to fulfill the legal obligations of Krocette such as, for example, obligations in relation to product liability or warranty and other obligations arising from investigations or instructions given by the authorities, for example, in the event of fraud or litigation (“Legal obligations “)||fulfillment of a legal obligation to which Krocette is subject (Article 6, paragraph 1, letter c), GDPR)|
|name, gender (optional and for registered customers only), date of birth, address, telephone number, e-mail address||(2) to register you as a My Krocette Customer which allows you to benefit worldwide from exclusive offers and services reserved for registered customers (you will receive a confirmation email after registration) and to ensure the security of your profile after the registration (“My Krocette Customer Registration”)||execution of a contract of which the interested party is a party or execution of pre-contractual measures adopted at the request of the same (Article 6, paragraph 1, letter b), GDPR)|
|name, date of birth (only for registered customers), social security number, address, telephone number, e-mail address, purchase data (e.g. products purchased, place, date and time of purchase, delivery data||(3) to fulfill the obligations strictly connected to the purchase of a Krocette product and any related service such as: shipping, “gift message / gift wrapping”, delivery to the store, management of returns, customer service and after-sales support (” Sale“)||execution of a contract of which the interested party is a party or execution of pre-contractual measures adopted at the request of the same (Article 6, paragraph 1, letter b), GDPR)|
|name, address, telephone number, e-mail address||(4) to guarantee you access to exclusive services and initiatives reserved for My Krocette customers all over the world (for example, games or prize competitions) including the sending of communications aimed at making you aware of such services and initiatives ( “Services and Initiatives reserved for My Krocette Customers“);||execution of a contract of which the interested party is a party or execution of pre-contractual measures adopted at the request of the same (Article 6, paragraph 1, letter b), GDPR)|
|name, date of birth, gender (only for registered customers), address, telephone number, e-mail address, navigation data and products displayed on the Online Channels||(5) “Marketing Activities”: 5a. to conduct market research, statistical analysis or other research aimed at improving our products and services and for evaluating the degree of customer satisfaction 5b. for the creation of promotional campaigns, and for the sending of offers and commercial communications relating to Krocette subjects and Krocette products and services, through the channels indicated by you: mail, e-mail, telephone, SMS or social media, also using automatic means (for example, you may wish to receive newsletters to be updated on new Krocette products and services and to find out about events, competitions, demonstrations, loyalty programs organized by Krocette) These communications will concern fashion products and services, luxury goods and the like. If you prefer to receive marketing communications only by traditional means (for example, by post or non-automated telephone calls), please notify us at the following address: email@example.com. to send you e-mails or text messages designed to help you improve your shopping experience on our Online Channels, according to your needs, or to remind you to finalize a purchase left pending 5d. to send you, even if you are not interested in subscribing to the My Krocette Program, our e-mail newsletter and communications designed to help you improve your shopping experience on our Online Channels, based on your needs, or to remind you to finalize a pending purchase||your consent to the processing for these specific purposes (Article 6, paragraph 1, letter a), GDPR)|
|name, date of birth, gender (for registered customers only), address, data relating to hobbies, work, interests, purchase data (e.g. products purchased, place, date and time of purchase, delivery data), displayed products||(6) to analyze your consumption habits on the Krocette sales channels (in-store or on the Online Channels), for example, in relation to the products purchased, the products viewed, the stores where purchases were made, in order to offer you personalized offers in line with your interests (“Profiling”)||your consent to the processing for these specific purposes (Article 6, paragraph 1, letter a), GDPR)|
Krocette may also process your personal data relating to your online browsing history collected during your visits to our web pages or during your Social Interactions (regardless of whether you are a registered customer or not), using tracking technologies such as “cookies” (for information on the collection of data through cookies, see our Information on Cookie).
c) 1. Data collected from third parties.
In this section we inform you about the data not collected from the interested party, possibly conferred by you as part of your purchase request for one of our products or services (such as, for example, as part of the “gift message / gift wrapping” service. ).
In compliance with art. 14 of the GDPR in the case of data not obtained directly from the interested party (as is currently the case for the personal data of the recipient of a gift package and / or the message of greetings that he will possibly want to provide to us to use the service), the information to the latter is understood to have been released through him; in this regard, you undertake to transmit a copy of this information or the access link to the online version to your family member, friend or other interested party recipient of the service and, in any case, to make the essential contents of this information available to the third party informative.
d) how are your personal data processed and protected?
Your personal data can be processed electronically or in paper form. Krocette will take appropriate measures to ensure that your information is kept secure, used only for the purposes indicated in this privacy statement (and not for any other purpose) and that it can be consulted or corrected at your request.
Krocette uses appropriate organizational, technical and administrative measures to help protect against the loss, misuse and modification of personal information under its control. However, the security of the data transmission over the Internet or the data storage system cannot be 100% guaranteed, so do not send any information that you consider confidential by email. It is your personal responsibility to protect your copies of your passwords and associated access codes for our online resources.
e) how long do we keep your personal data?
Your personal data collected to fulfill a legal obligation and to execute the contract will be kept for a period not exceeding that necessary for these purposes and, in any case, not exceeding 10 years after the termination of the contract (for example, following the revocation of registration as a My Krocette Customer), after which they will be destroyed or rendered unusable or made anonymous.
Your personal data collected for marketing and profiling purposes may be kept for a period of 7 years (as authorized by the Authority for the Protection of Personal Data), after which they will be destroyed or rendered unusable or made anonymous.
f) is it mandatory or optional to provide personal data and what are the possible consequences of not providing such data?
You must provide your data for the purposes indicated in point c) (1) (legal obligations), (2) (registration as a My Krocette Customer), (3) (Sales Services) and (4) (Reserved Services and Initiatives to My Krocette Customers). If you do not want Krocette to process your data for these purposes, Krocette will respect this choice. However, in this case, it will not be possible to register as a My Krocette Customer and benefit from the exclusive services and initiatives that Krocette offers to its registered customers.
Providing data for the purposes referred to in point c) (5) (marketing purposes) and (6) (profiling purposes) is optional. Not providing your data for these purposes will not have any negative consequences for you. If you agree to Krocette processing your personal data for these purposes, you can withdraw your consent at any time by sending an email to: firstname.lastname@example.org.
g) how do we share the personal data collected, how do our global services work and with which third parties may your personal data be shared?
Krocette will not disclose your personal data.
If you register as a My Krocette Customer and consent to the processing of your personal data for marketing or profiling purposes, your personal data (provided during registration or during a purchase – e.g. name, date of birth (only for customers registered), address, telephone number, email address, data relating to hobbies, work, interests, purchase data, products purchased, place, date and time of purchase, delivery data, products displayed) will be entered in the CRM database of Krocette which will be accessible to the local branches of Krocette and / or to the affiliates who adhere to the My Krocette Program, who act as data processors carried out on behalf of the Krocette data controller.
In this way, Krocette will share your data with the companies in the Krocette network, both within and outside its country of residence and both within and outside the EEA in which Krocette is located, since The My Krocette Program is managed and offers Krocette benefits to customers around the world. In particular, your data will be automatically accessible to all Krocette sales staff, who are employed in local outlets (for example, if you visit a Krocette store in another country, your personal information will also be accessible in that store).
The companies within the Krocette network include the parent company, the subsidiaries and affiliates of Krocette, and partners, such as affiliated or franchised stores. You can find a list of these companies below but be sure to check this list from time to time to see the new members.
Where your personal data is sent to countries other than your country of residence or to countries outside the EEA as part of the My Krocette Program, your data will be protected by adequate security systems, which are constantly updated and maintained in accordance with the applicable Privacy Laws (for example, specific agreements on data processing are in force and non-EU Data Processors have signed the standard clauses approved by the EU Commission). You can request a copy of the EU Standard Contractual Clauses by sending an email to: email@example.com.
Depending on the service, Krocette may also share your personal data (provided through registration or during a purchase – for example, name, date of birth (only for registered customers), address, telephone number, e-mail address, data relating to hobbies, work, interests, purchase data – products purchased, place, date and time of purchase, delivery data – products displayed) with specialized companies to which Krocette entrusts, as data processors, tasks of technical and organizational nature necessary to manage relationships with customers. These include companies that provide assistance, payment, shipping or storage services for the purchase of products or documentation relating to customer relations and companies that evaluate the quality of service and customer satisfaction, or perform, on behalf of Krocette, marketing and profiling activities, also on a local basis, including re-targeting activities.
The data you provide for online purchases, such as your credit card details, will only be processed by external suppliers who act as Krocette’s data processors.
Your personal data will not be transferred outside the EEA. Should it prove necessary to transfer your data outside the EEA, we will take appropriate steps to ensure that your personal data is adequately protected. A list of these companies is available at the Krocette headquarters and can be requested by sending an email to: firstname.lastname@example.org
h) existence of automated decision-making processes, including profiling
Krocette may process your personal data using automatic decision tools. Please consider the following table to understand the logic used, the relevance and the expected consequences of such processing:
|Logic used and description of the treatment||– logic used: the products displayed, the purchase data and the frequency are taken into account to create groups of customers (explorer, fan, classic, connoisseur and elite). Depending on the group, customers will be sent profiled marketing communications promoting Krocette products sold at certain prices; – information processed: name, date of birth, address, data relating to hobbies, work, interests, purchase data (e.g. products purchased, place, date and time of purchase, delivery data), products displayed; – source of information: at the time of obtaining consent to be profiled, Krocette processes the data provided during registration, when using the Online Channels and when purchasing products as registered customers; – how the information provided affects the decision: profiling is based exclusively on the data provided, so the result totally depends on them; – measures to mitigate possible risks: a specific DPIA was conducted on the profiling activity to ensure its impartiality, effectiveness and absence of harmful consequences and can request a copy of the main summary by sending a request to the following email address: email@example.com|
|Relevance of the processing and expected consequences of such processing||Your visits to the Online Channel and your shopping habits as a registered customer will define the types of products that Krocette will promote for you.|
Therefore, if you see or buy products that are: – cheaper than those you usually see or buy (or if your views or purchases are more frequent), you will be directed to promotional communications relating to the above items; who generally sees or buys (or if his views or purchases are less frequent) will be directed to promotional communications relating to the aforementioned items.
i) Your privacy rights
You have the right to obtain confirmation of the existence or not of personal data concerning you and to request Krocette to access and correct or delete personal data or limit the processing that concerns you or to oppose the processing of data and the right to data portability.
With regard to the processing of personal data for marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing purposes, including profiling to the extent that it is connected to such direct marketing (Article 21, paragraph 2, GDPR).
Regarding the processing of personal data for profiling purposes, you have the right to obtain human intervention by Krocette, to express your opinion and to contest the decision (article 22, paragraph 3, of the GDPR).
Your address may be used to send promotional communications relating to Krocette products or services similar to those you already benefit from. At any time, both initially and in subsequent communications, you can oppose the use of your address for this purpose, as well as oppose such processing by sending an email to: firstname.lastname@example.org.
You have the right to lodge a complaint with the Personal Data Protection Authority and / or other competent supervisory authority if you believe that the processing of your personal data violates the Privacy Laws.
To exercise these rights, you can contact Krocette by sending a request to the following e-mail address: email@example.com.