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NOTICE PURSUANT TO ART. 13, EU REG. NO. 679/2016 (“GDPR”)
“Virtual Personal Shopping Experience” Service

The present notice discloses which of your personal data is collected by Haeres Equita S.r.l. (hereinafter referred to as “we” or “us”), for what purposes and how those are processed. Herein-below you will also find information for the exercise of your rights under the GDPR. 

We generally collect your data upon your booking, through the channels we will make you available (without limitation, telephone, WhatsApp, Telegram or other instant messaging, email) an appointment for a “Virtual Personal Shopping Experience” session (hereinafter, the “Service”) and when you exploit such at one of our boutiques of your choice (the list is available at www.borsalino.com), as well as in case of a purchase of our products further to your use of the Service. We inform you that your personal data collected in the events above will be processed in order to allow you to book and use the Service and the purchase, if any, of products, this including the relevant operations required under the applicable administrative and tax obligations as set forth below.   

1. Who processes your data: the data controller 

Haeres Equita S.r.l., a company incorporated under the laws of Italy, seated in Corso Garibaldi 122 -15048- Valenza (AL), Italy – Fiscal Code/VAT ID no. 02471250064 (hereinafter, “Borsalino”). 

2. What data we process - Types of processed data 

Your contact details. We will store the contact information you provide us (for instance, name, surname, address, telephone number, e-mail, country of residence) when you book the Service and use it and/or buy a product as a result of using the same Service. 

Your payment and billing information, as well as any special instructions relating to any purchases you make. We will retain the payment and billing information you provide to us (for instance, your credit card number, your bank details, postcode and address when you purchase a product) for the purposes of managing your purchase and order shipping. Where applicable, we will also process any data you may provide us in relation to particular instructions regarding purchases you may make using the Service (for example, if your purchase was a gift). 

Your image and portrait, while using the Service, only if you decide to leave the relevant function of the video call/instant messaging application active. If you do not intend to show us your face, or, in any case, do not want to show us the environment or the people around you, you can deactivate the displaying at any time. In any case, if you do not want to use any video call/messaging application, you will not be able to use the Service.  

3. Where do we get your data - Data collection methods: 

Directly from you. For instance, when you book or use the Service. 
In case of your failure in providing your data, you will not b able to book the Service, thereby not being allowed to select and purchase products through the same Service. 

Third party data provided directly by you. Any provision (for example for the shipment of a product) of personal and contact information of any third party other than yourself constitutes a processing of personal data with respect to which you shall be intended as an independent controller, thus undertaking all the obligations and liabilities envisaged by the current legislation on personal data. In this sense, you warrant to Borsalino that any data of third parties that you may provide have been collected by you in full compliance with the current legislation on personal data upon a relevant legal basis legitimizing the provision of said personal data of third parties to Borsalino, which will be hold harmless from any dispute, claim, request for compensation for damage that should be lodged against Borsalino from any relevant third party and deriving from the aforementioned provision of data. 

4. Why and for how long we process your data - Purpose and legal basis of data processing; retention period
 
To allow your booking and use of the Service. For instance, we will use your data to manage your booking and make sure you can use the Service at the desired time, day and boutique of your choice. Without your data we will not be able to manage your booking and your use of the Service.  

The legal basis for this processing is the execution of a your contractual/pre-contractual request.  


The retention period of your data is equal to the period necessary to process your request for booking the Service, i.e. up to the actual use of the Service itself, without prejudice to the further storage period for the purposes indicated below, up to 10 years from the date of the last purchase. 


b) To provide you with any products that you may have purchased through the use of the Service. For example, we will use your data to manage any purchase of products you may complete through the use of the Service, confirm such and manage the ancillary services thereof, such as the shipment of purchased products. Without your data we will not be able to process your purchase. 

The legal basis for this processing is the execution of a your contractual/pre-contractual request.  

The retention period of your data is equal to the period necessary to process your purchase, without prejudice to the further storage period for the purposes indicated below, up to 10 years from the date of the last purchase. 

5. Nature of the provision of personal data 

For the purposes a) and b) referred to in the previous paragraph, the provision of data is necessary to allow you to book and exploit the Service, as well as to make purchases using it. 

6. Where your data is processed - data transfer 

The data will be processed and stored by Borsalino at its showroom located in via Sant’Andrea 5 - 20121 – Milan, Italy, and at its own Borsalino’s boutiques located in Italy and France, whose references are listed on a specific page of the site. 

7. Who we share your data with – personal data recipients 

Notwithstanding that, where required by law, we will obtain your prior consent and carry out any relevant formalities, we may share your data with the following third parties (acting as processors as well): 

Our service providers. We may share your data with third parties so that they can provide us with services (for instance couriers, warehouse managers and logistics providers); in this case though we will enter into a data processing agreement pursuant to art. 28 GDPR aimed at protecting your data. These subjects will only process the data necessary for the performance of their functions and solely for the performance thereof on our behalf or to comply with the law. You can ask for the details of these data processors under art. 28 GDPR by contacting us via email at privacy@borsalino.com. 

Should be believe to be required to do so under legal obligations or for our or third parties’ judicial defence. Where permitted or required by law, we may also share data requested by a government agency or other authorized person or organization in order to protect or exercise our or a third party's rights, or to limit or prevent fraud (including fraud credit card or other fraud that we believe could occur during a lottery or promotion or event) and other wrongdoing.  

8. Minors 

The service is destined to a sole public of age and not intended for minors. If you are a parent or guardian and you think your child has provided us with any personal data, you can contact us. 

9. Security measures 

We take the security measures required by law. 
We take security measures to protect your data. The standard security measures we use depend on the type of data we process and meet the requirements of the law and the standards of European government agencies. 

10. Your rights
 
You can contact Borsalino to request access to your personal data, rectification, cancellation or limitation of processing, to oppose the processing and request the portability of your data; you can also revoke the consent at any time (this will not affect the lawfulness of the processing based on the consent provided before the revocation). 

When you exercise your right of access, you have the right to know if your data is being processed, what is the purpose of the processing, what are the categories of data processed, who are the recipients or categories of recipients to whom our data are communicated (and, should they seat in a third country, which guarantees are applied), the retention period of your data (or the criteria for determining the retention period), whether automated processing is in progress (for instance by profiling) and what is the logic of this processing, the origin of the data (in case those are not originally collected by us). 

You have the right to lodge a complaint with the Supervisory Authority for Italy (“Garante per la Protezione dei Dati Personali”) or any other competent authority under GDPR and to ask Borsalino, at any time, for information about the data processors and the subjects authorized by the to process your data. 

You can exercise your rights by contacting Borsalino (at the addresses indicated above or by sending an email to privacy@borsalino.com) 

11. What we do if we update this notice 

We may make changes to our privacy policy. We will also post an updated version on our site with a different date than the one indicated below. Please check the site periodically for updates. 


29 April 2021 – V3 



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