Privacy Policy

Introduction

Following your consultation of this website (the "Site") and use of the services offered through it, data relating to identified or identifiable individuals may be processed. Accordingly, we provide this notice on the processing of personal data pursuant to Article 13 of EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, Italian Legislative Decree 196/2003 as subsequently amended and supplemented, as well as the applicable regulations on the processing of personal data (hereinafter the "Privacy Regulations").

Data controller

The Data Controller for the data you provide is Miroglio Fashion S.r.l., a company incorporated under Italian law subject to the management and coordination of its sole shareholder Miroglio S.p.A., with registered office in Alba (CN) - Italy, Via S. Margherita 23, tax code and VAT number 03232400048 (hereinafter "Miroglio" or the "Controller").

Data protection officer

The Miroglio group has appointed a Data Protection Officer, whose contact details are as follows: Miroglio Group - Data Protection Officer, Via S. Barbara 11, 12051 – Alba (CN), Italy, email: dpo@miroglio.com.

Types of data processed

Miroglio may process various types of personal data (the "Data"), depending on the products, services and features of the Site.

The Data subject to processing may include the following:

  • Personal identification data

    First name and surname, date of birth

  • Contact data

    Email, telephone number, shipping address

  • Data voluntarily provided by the user

    Simply browsing the Site does not require the user to provide any personal data. The optional, explicit and voluntary sending of emails to the addresses indicated on this Site, or of a message through the other forms of contact indicated on this Site, results in the subsequent acquisition of the sender's address, which is necessary to reply to the request, as well as any other personal data included in the message. Such data will be used solely to follow up on the user's request and may be disclosed to third parties only where necessary for that purpose

  • Data relating to purchases made by the customer

    Data relating to the products purchased and the amount spent

  • Data relating to products added to the cart

    Data relating to products added to the "virtual cart" and their price

  • Browsing data

    The computer systems and software procedures used to operate this Site acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users connecting to the Site, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server's response (successful outcome, error, etc.) and other parameters relating to the user's operating system and computer environment.

    This data is used solely to derive anonymous statistical information on the use of the Site and to check that it is functioning correctly, and is deleted immediately after processing. The data may be used to establish liability in the event of hypothetical computer crimes against the Site: except for this possibility, web contact data currently does not persist for more than seven days.

  • Cookies

    For information about the cookies present on the Site, please refer to the Cookie Policy.

Some data may be requested on a mandatory basis, as it is necessary for the provision of the service or product requested. Failure to provide such data may make it impossible to complete registration and therefore to use certain services on the Site.

Legal bases and purposes of processing

Miroglio may process your Data for different purposes, depending on the products, services and features of the Site. The Data will be processed for the purposes and according to the legal bases indicated below:

  • Contacts: the optional, explicit and voluntary sending of an email to the addresses indicated on this Site, or of a message through the other forms of contact indicated on this Site (e.g. "Customer Service"), results in the subsequent acquisition of the sender's address, necessary to reply to the request, as well as any other personal data included in the message. Such data will be used solely to follow up on the user's request and may be disclosed to third parties only where necessary for that purpose. The user's consent is not required for the processing of data for these purposes, since the processing is necessary for the performance of a contract to which the user is a party or for the implementation of pre-contractual measures taken at the user's request, as well as, where applicable, to comply with a legal obligation (legal basis: performance of a contract to which the data subject is a party or of pre-contractual measures taken at the data subject's request, as well as, where applicable, a legal obligation to which the Controller is subject);
  • Online sales: online sale on the Site of the products available and provision of any other services related to such sale (legal basis: performance of a contract to which the data subject is a party);
  • Loyalty Programme membership: fulfilment of the obligations arising from the Loyalty Programme Regulations and the Loyalty Activities Regulations (hereinafter the "Regulations"), aimed at issuing the loyalty card, in physical or electronic form, identifying cardholders and providing the services reserved for cardholders (legal basis: performance of a contract to which the data subject is a party or of pre-contractual measures taken at the data subject's request);
  • Legal and contractual obligations: in accordance with applicable laws and regulations, including for the purpose of preventing and detecting possible abuse, unlawful conduct, offences or fraud (legal basis: legal obligation to which the Controller is subject);
  • Marketing: periodic sending of updates regarding products and events organised by Miroglio, also in accordance with the Regulations, sending of commercial, informational, promotional and/or advertising material by automated means (email, web, SMS, instant messaging, calls without an operator) and/or non-automated means (paper mail and calls with an operator), as well as in relation to market research and initiatives organised by Miroglio (legal basis: data subject's consent);
  • Newsletter: periodic sending of commercial, informational, promotional and/or advertising material by email (legal basis: consent);
  • Customer profiling: analysis of purchases and choices in order to better understand selections and preferences and, as a result, offer, including through automated decision-making and profiling processes, a personalised service in line with the customer's specific needs and characteristics (legal basis: consent);
  • Cart reminder: a service sending, to the email address provided, a reminder relating to the products placed in the "virtual cart", where the purchase process has not been completed (legal basis: consent).

Processing methods

The processing of the Data will take place using manual and electronic tools, according to logics strictly related to the purposes indicated above, in such a way as to guarantee the security and confidentiality of the Data in compliance with the Privacy Regulations.

The Data will be processed exclusively by trained and authorised personnel, adopting technical and organisational measures appropriate to guarantee a level of security commensurate with the risk, as well as to preserve confidentiality, integrity and availability.

From this Site it may be possible to access, through specific links, third-party websites. Should the user access such sites through the relevant links, they are invited to consult the respective privacy notices in order to learn about the methods of personal data processing adopted by such parties, over which the Controller exercises no control.

Some sections of the Site may also offer a "social login" feature, which allows access to the reserved area using the credentials of a social network. By opting for this authentication method, the user declares that they accept the terms of use and the privacy notice of the chosen social network.

Data retention

The Data may be retained for different periods of time depending on the purpose for which they are collected and processed by the Controller and, in any event, in accordance with the Privacy Regulations.

In particular:

  • for the "contacts" purpose, the Data will be retained for the time strictly necessary to provide the user with the requested service, subject to any further retention obligations provided for by law;
  • for the "online sales" purpose, the Data will be retained for a period of time not exceeding that allowed by tax and civil law regulations (therefore, save for exceptions provided for by law, for a period not exceeding 10 years);
  • for the "Loyalty Programme membership" purpose, the Data will be retained for the entire duration of the Loyalty Programme or until the enrolled person has informed us of their intention to cancel their membership of the Loyalty Programme;
  • for the "legal and contractual obligations" purpose, the Data will be retained for a period of time not exceeding that allowed by tax and civil law regulations (therefore, save for exceptions provided for by law, for a period not exceeding 10 years);
  • for the "newsletter" purpose, the Data will be retained until the enrolled person withdraws their consent to processing following their decision to no longer receive such newsletters. Consent may be withdrawn at any time, including through the specific "unsubscribe" procedure at the bottom of each newsletter;
  • for the "marketing" and "customer profiling" purposes, the Data will be retained for the entire duration of the Loyalty Programme or until the enrolled person has informed us of their intention to cancel their membership of the Loyalty Programme. Should the Loyalty Programme have a duration of less than 2 years, the Data will be retained for a maximum period of 2 years from when consent was given or renewed. In any event, should the Controller find that there is no longer an interest in receiving updates on products and events organised by Miroglio, the Data will no longer be retained;
  • for the "cart reminder" purpose, the Data relating to the consent given to receive reminders of products placed in the "virtual cart" will be retained for a period of 6 months from when consent was given, while Data relating to products added to the cart will be retained for a period of time not exceeding 7 days from the date they were added.

Sharing and transfer

The Data may be disclosed or made accessible to companies belonging to the Miroglio group, to duly trained and authorised personnel of the Controller, as well as to appointed third parties qualified as data processors or sub-processors, for carrying out activities strictly connected to the purposes indicated in this Privacy Policy, such as, by way of example: banking services, communication and marketing services, financial services, technical and administrative help desks and logistics activities.

Personal Data will be processed within the European Economic Area (EEA). Should it become necessary, for reasons connected with the provision or improvement of efficiency of services, to transfer the Data outside the EEA, the transfer will take place in compliance with the Privacy Regulations, to countries subject to an adequacy decision of the European Commission or on the basis of the Standard Contractual Clauses (SCCs) approved by the European Commission, possibly supplemented by additional safeguard measures where required.

The Data may also be disclosed to parties to whom disclosure is required by legal obligations, as well as to the competent Authorities (including judicial authorities) in the cases provided for by applicable law.

The updated list of data processors may be requested at any time by contacting the Controller at the addresses indicated in this Notice.

Rights of data subjects

Pursuant to the Privacy Regulations, data subjects have the right at any time to exercise their rights under Articles 15 et seq. of EU Regulation 679/2016, including the right to:

  • obtain information on the purposes and methods of processing;
  • obtain access to the Data;
  • request rectification and updating of inaccurate or incomplete Data;
  • obtain erasure of the Data;
  • object to processing, including for marketing purposes and, where applicable, to automated decision-making processes, including profiling;
  • obtain restriction of processing;
  • withdraw consent given at any time;
  • receive the Data provided in a structured format and, where technically possible, transmit it to another controller (portability).

Data subjects also have the right to lodge a complaint with the Supervisory Authority.

These rights may be exercised by contacting the Controller directly at the email address privacy@miroglio.com or by writing to Miroglio Fashion S.r.l. - Omnichannel Division, Via S. Barbara 11, 12051 – Alba (CN), Italy.

Changes to the policy

The entry into force of new industry regulations, as well as the ongoing review and updating of services for users, may make it necessary to change the methods of processing users' personal data. It is therefore possible that our privacy policy may change over time, and we invite visitors to check this page periodically.