This Privacy Policy ("Privacy Policy") is intended to help you understand what information we collect when you visit this Website, whether or not you are a registered user.
By visiting the Website, using its services or otherwise interacting with us, our stores and/or the Website, you confirm that you have read and understand this Privacy Policy and you agree that we may collect, use, store, share and disclose personal data we collect through the Websites, stores and/or points of sale in accordance with this Privacy Policy. If you are not already registered with us, we may ask you to opt-in (for example, by checking a box) if we believe it is appropriate to protect your rights or if required by applicable law. If you do not agree to the terms of this Privacy Policy, please do not visit this Web page, do not create an account, or otherwise use or transmit or submit personal data to this Web page, and do not agree if this option offered to you in accordance with applicable law.

1. PERSONAL DATA PROCESSING

When we use "Personal Data" in this Privacy Policy, we refer to any information that allows us to identify you (or a third party whose personal data you provide to us), directly or indirectly, including any information related to with the purchase of goods or services; or that you choose to contact or share with us or third parties using the Websites or at points of sale. We will process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 "Regulation (EU) 2016/679" and the law of the country in which the data is to be collected, if applicable. We reserve the right to carry out additional processing as required by law or as part of a criminal or other investigation or proceeding.

2. PERSONAL DATA WE COLLECT

2.1 Source of data
We only collect your personal data if you provide us with this information, for example:
Brand sites that distribute our products: when placing an order through the Website(s) as a "guest"; creating an account or changing your account; by setting up a wish list; participation in contests, lotteries or promotions; Search on the site; contact us with a comment or question; sign up to receive email newsletters and updates about our latest products and services, boutique openings, events or promotions; or request to receive order confirmation, delivery confirmation or other notices;
Our stores: when filling out our customer card, during informal chats, when you visit our boutiques or outlets, communicate with us or buy products;
Events: by participating in our events, surveys and market research, challenges and other promotions, including online, such as mini-sites we run on third-party social networks such as Facebook;
Our customer service: when requesting assistance, special services or after-sales service;
Email, text and other electronic messages: When communicating between you and us.
If you provide us with the personal information of third parties (such as your family members, other customers or our potential customers), you must ensure that those third parties are informed and authorized to use their data as described in this Privacy Policy.
2.2 Types of data
We may collect and use different types of personal data depending on the specific purpose as described below:
personal data such as name, surname, gender, age/date of birth, country of origin and other personal data in accordance with applicable law;
contact details such as address, email address, telephone number, mobile phone number, fax number (if applicable) and other contact details in accordance with applicable law;
payment details such as payment instrument (credit card, debit card) if applicable, passport number if necessary for tax or money laundering reasons;
sales-related information such as date, products or services provided, place of purchase, product codes, amount, sales amount, VAT number, complaints, returns, refunds and other sales-related information in accordance with applicable law;
habits and profiles, such as data about your purchases (purchase history, including the boutique where the sale takes place, the type, quantity and price of the products you purchased), information related to customer relationship management actions and initiatives (date and categories of said actions, as performed or to be performed and the results of said actions), buying habits and preferences (wish list, best product categories, color, style, other brands bought, most visited countries, how you know our brands, sizes, notes in relation to the purchase, your stated habits or special needs - for example, better materials), other information (information about work, education, hobbies and lifestyle) in accordance with applicable law; and
family information such as marital status, anniversary date, number of children, information about children and other family information as permitted by applicable law.

3. HOW WE USE PERSONAL DATA

Personal data may be used for the following purposes, depending on the specific circumstances in which you interact with us.
3.1 For online and in-store sales (by the local boutique / outlet where you make the purchase or by the local website seller as set out in the Terms of Sale of your online purchase)
Your personal data provided by you or collected during any purchase, regardless of whether you are a guest or a registered user, i.e. basic personal data, contact data, data about your purchases, fiscal data, payment details, sales information and any other data strictly necessary for the delivery of products will be used:
manage, administer and process your purchase of our products, sales and after-sales services, such as administration, accounting, returns, warranties, tax refunds, if applicable, fraud prevention, communication with you, including by email, for any -what is the problem related to the processing of the order or subsequent requests regarding the order;
to comply with obligations imposed by laws, regulations or EU law (including anti-money laundering laws), and to institute or defend legal claims.
Providing your personal data for the specified purposes is necessary; failure to do so will prevent the purchase from being completed.
Unless otherwise required to comply with local law, data may be processed for these purposes without obtaining your consent as it is necessary to comply with contractual and legal obligations.
3.2 For the specific purposes for which it was invoked
Your personal data provided by you or collected when you request a specific service (for example, registering your account on our websites, handling complaints, requesting information), i.e. personal data, contact data, data necessary to fulfill your request will be used
to provide the services you have requested (for example, managing your account registration processes, managing authentication on the Website, managing your accounts, assisting you and handling any complaints, handling wish lists, tracking any question or contact request, which you can send to us or through our customer service);
manage your newsletter subscription if you are not registered with us.
Providing your personal data for the specified purposes is necessary; Failure to do so will make it impossible to fulfill your request.
Unless otherwise required to comply with local laws, data may be processed for these purposes without your consent as necessary to fulfill your request.
3.3 For CRM purposes if you register with us
Your personal data provided by you when filling out our forms or collected when you visit our boutiques, points of sale or websites and interact with us, i.e. personal data, contact data, data about your habits and profile, family data will be entered into our centralized CRM:
to offer you promotions, discounts and other specialized services, and to send you newsletters, other marketing and commercial communications about products, services and invitations to events about our brands (organized by us or our distribution chain), surveys and research, market analysis , invitations to contests, sweepstakes or promotions and other initiatives for registered customers or contacts of our brands ("marketing"). We may use traditional (mail and telephone) and/or digital and automated (email, SMS, MMS, telephone and other digital channels such as social media) and may send you these communications based on your profile if you have consented to our profiling (see clause 3.3.b) below);
to analyze your contacts with us, interests, preferences and buying habits, and to create individual or aggregated profiles based on this, in order to find out how to provide you with a better service, including providing you with a personalized sales experience in any boutique and point sales in Italy and abroad ("profiling"). We may also use personal data to create clusters and conduct market and statistical analysis aimed at identifying products and/or services of interest to customers of our brands and to improve our services (including websites). We will combine your data collected on the Websites with information we may have obtained through interactions with sellers in boutiques and/or points of sale. Processing of personal data for profiling is carried out in accordance with the guarantees and measures established by the current legislation.
Your input into the CRM system is optional and free of charge (based on your selective consent) and only if you provide your personal data both for marketing and profiling purposes in accordance with clauses 3.3.a) and b) and for one of them. , You may unsubscribe or opt-out at any time (see clause 8 below). Refusal to provide your personal data for both or one of these CRM purposes will in no way prevent you from using our services or making purchases, but we will not be able to inform you of the marketing initiatives and events described above. and we couldn't understand your interests and offer you a more personalized shopping experience.

4. HOW WE SHARE PERSONAL DATA

We provide your personal data collected to our affiliates, distributors and franchisees, including those located in other countries, and to other companies that provide services on our behalf (as described below), either at our direction or at the direction of a third party parties We will only provide personal data to those companies and organizations that are necessary to provide the services, and we will not allow them to use this personal data for any other purpose.
4.1 Sharing with Data Processors
When you purchase our products or use our online sales services, your personal data may be transferred by the e-commerce provider on this website to certain third-party organizations that provide services to the provider, including those that fulfill orders, ship products, process credit and debit payments. card payments and fraud control.
Your personal data may be transferred to third parties to monitor and analyze the Site's activities, host the Site's content, provide technical and organizational services functional for the above purposes, maintain a database of our customers, provide assistance in marketing and email administration, market analysis, surveys, contests, lotteries or promotions. Such third parties may access, store and process personal data to provide these services on our behalf, which may be in Italy, your country or abroad. Our service providers are not permitted to use personal data for any purpose other than the provision of contracted services.
Our subsidiaries operating our brand in other countries or on the Internet, as well as our business partners (franchises, distributors) who have points of sale or online sales on their websites, will process your personal data for CRM purposes as data processors. according to our instructions
4.2 Sharing with Other Third Parties
Your personal data may need to be transferred to payment management and fraud control companies acting independently as data controllers to provide you with online sales services.
In the event of any asset or corporate transaction (such as a merger or acquisition, our reorganization or liquidation), customer data is likely to be one of the transferred assets and we may transfer it to any of our successors to the extent permitted by law based on our legitimate interest. Your personal data will remain subject to any previously existing privacy policy, unless you agree otherwise.
We may also disclose your personal data to third parties when required by law in response to legal proceedings; in response to a request by law enforcement agencies on legal grounds; or to protect our rights, privacy, safety or property or the public.
In addition, to the extent permitted by law, we may also transfer personal data to third parties in the event of a complaint about the use of the Website and when we believe it is necessary to investigate, prevent or take action against illegal activity suspected of being fraudulent . or when we believe, in our sole discretion, that your use of the Website is inconsistent with the Website's terms.
A full list of designated data processors and third parties to whom the data is transferred can be obtained from the contact point below (clause 13).

5. CHILDREN'S PRIVACY

This site is a general audience website; However, our services are intended for people 18 years of age and older. We do not knowingly solicit or collect, use or disclose personal data provided by anyone under the age of 18, either online or in boutiques/points of sale. If we learn that we have collected a child's personal information, we will delete that information.
If you are under this age, please do not register or make an online purchase or ask an adult (ie your parent or legal guardian) to complete the necessary procedures.

6. STORAGE, AVAILABILITY AND TRANSFER OF PERSONAL DATA

Personal data collected through the Websites is processed primarily using electronic or web-based means, including web analytics services, hosted on the servers of our selected providers both in the European Union (e.g. Germany and Ireland, for online sales transactions on our directly managed Websites) as well as outside the European Union (eg the USA for our newsletter subscription services). In boutiques and points of sale, personal data may also be processed in printed form. In both cases, personal data will be transferred for CRM purposes to our centralized and secure database, which is stored in Italy and managed by our account managers and marketing team in Italy and abroad.
Access to personal data will be carried out on an as-needed basis and within the framework of multi-level access control tools only by authorized personnel of our boutiques, points of sale and local e-commerce provider (e.g. employees of the digital and information technology department, marketing, retail, administration, security departments). These personnel have been bound by confidentiality obligations and have been expressly designated as responsible for the processing as required by law. In particular, if you have consented to the processing of your personal data for CRM purposes, the relevant data may be read, changed and updated by our employees and employees in boutiques, points of sale and/or local e-commerce providers. (especially sales and marketing staff). The staff is based in Ukraine, trained and bound by confidentiality. We may use them to collect, use and disclose data in accordance with our instructions.
If we need to transfer personal data abroad to achieve the purposes of this Privacy Policy, including where data protection laws differ from those applicable in your country, we take steps to ensure that those communications are made in accordance with European data protection standards. or other local standards in the country where we collect data to keep your data secure and private.

7. SECURITY AND CONFIDENTIALITY OF PERSONAL DATA

We have adopted appropriate measures designed to protect your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. For example, when you provide any order information, we use Secure Socket Layer (SSL) technology, an encryption tool that keeps that information secure when transmitted over the Internet. We also use firewall technology, password management tools, and other technological and procedural safeguards while operating this website. Although we have implemented the above security measures for this website, you should be aware that 100% security is not possible. Therefore, you provide your personal information at your own risk and, to the maximum extent permitted by applicable law, we shall not be liable for any disclosure of your personal information due to the errors, omissions or unauthorized acts of third parties during or after its transmission. U.S. We recommend that you periodically update your network security software (such as anti-virus software) and check that your electronic communications service provider has adopted appropriate network security measures (such as firewalls and anti-spam filters); keep confidential and not share your username and password to access your account with anyone else; and sometimes change your password. anti-virus software) and ensure that your electronic communications service provider has adopted appropriate measures to secure data transmission over networks (for example, firewalls and spam filters); keep confidential and not share your username and password to access your account with anyone else; and sometimes change your password. anti-virus software) and ensure that your electronic communications service provider has adopted appropriate measures to secure data transmission over networks (for example, firewalls and spam filters); keep confidential and not share your username and password to access your account with anyone else; and sometimes change your password.
In the unlikely event that we believe that the security of your personal information in our possession or control has been or may have been breached, we will notify you of such development as required by applicable law using any of the methods below (by providing us with your e-mail address, you hereby consent to receive any such communication in electronic form through such e-mail address).

8. PRIVACY RIGHTS – MANAGING YOUR CHOICES

8.1 Your rights
At any time and free of charge, you can access your data, receive your electronic personal data in a structured, widely used machine-readable format and transfer them to another data controller (data portability) to have your data corrected, updated, amended or deleted ( subject to exceptions that may apply). You can update any information you have provided to us by contacting us at the addresses below. Requests to delete your data are subject to any applicable legal and documentary retention obligations imposed on us.
If you believe that we have a problem with the processing of your personal data, you have the right to lodge a complaint with your national and/or any other data protection authority in the EU or EEA.
To exercise these rights, you can send your request by sending an email to myclothingua@gmail.com or by regular mail to the address indicated below (clause 13). When contacting us, please be sure to provide us with your name, email address, mailing address, and/or telephone number(s) so that we can properly process your request.
8.2 Accuracy – keep personal data up to date
In order for us to better serve you, we recommend that you regularly review and update your personal information. If you are a registered user, you can view and edit your personal data through your account settings on the Website; otherwise, you can contact us (see clause 13) to help you update your personal data.
8.3 Managing your direct marketing and profiling choices
If you wish to opt-out of any CRM, marketing and/or profiling purposes, or manage your advertising preferences, you can simply send us your request (see Clause 13) or set out below or manage your opt-in account accordingly. , The same procedure applies if you wish to withdraw your consent to profiling.

9. DATA STORAGE

Personal data will be stored for the duration of the business relationship and for as long as necessary for the purposes described in this Privacy Policy (for example, if you subscribe to a newsletter, for the duration of your subscription; if you have a user account, until you close your account ). After this period, your personal data will only be retained in accordance with our legal and regulatory obligations (e.g. for 10 years for accounting purposes; for the duration of mandatory retention requirements for tax purposes, etc.) or so that we can maintain evidence our respective rights and obligations.
Your personal data processed for CRM purposes (clauses 3.3) will be stored until you close your account or withdraw your consent to the processing of your personal data for these purposes. Personal data relating to details of your purchases processed for profiling and marketing purposes will be retained for a limited period of time in accordance with the terms permitted by applicable law; After this period, personal data will be deleted or permanently anonymized.

10. LINKS, ADVERTISERS, SPONSORS AND ADVERTISEMENTS

This website may contain links to various websites owned or controlled by us, as well as links to third-party websites. If you choose to provide your personal information on any such linked website(s), that information will be governed by the privacy policy and security policies of such linked website, including websites operated and managed by our approved distributors. users, with the exception of data collected on them by our distributors for CRM purposes, where our privacy policy is posted - and is not governed by this privacy policy. You should review these other privacy policies as we are not responsible for and do not control the information transmitted or collected, used, disclosed or otherwise processed by third party websites.

11. DATA CONTROLLER – HOW TO CONTACT US

For the purposes of this Privacy Policy and the data processing described herein, please note that "We", "our", "us", "Company" - Natural person, entrepreneur Vygovska Maryana Yuriivna with legal address at: 03027, Kyiv, str. Dniprovska naberezhna, 26, e-mail: myclothingua@gmail.com
The Company has appointed a data protection officer to whom inquiries and complaints regarding the processing of personal data for CRM purposes may be addressed. The data protection officer can be contacted at: Kyiv, str. Dniprovska embankment, 26 sq. 171
The controller of the data collected in the local boutique, point of sale and/or on the local website for sales-related purposes in accordance with clause 3.1, the point of sale or online store where you make a purchase and/or which collected the data. The local supplier may need to process your personal data in accordance with the data protection regulations in force in the country where they are located. However, unless there is a conflicting mandatory rule applicable to that jurisdiction, the local provider undertakes to process your personal data in accordance with the principles stated in this Privacy Policy.

14. RENEWAL OF THIS POLICY - NOTICE

We reserve the right, in our sole discretion, to change, modify, add or remove portions of this Privacy Policy at any time by posting such revised Privacy Policy on this website page and updating the "Last Modified" date below. It is your responsibility to review this Privacy Policy from time to time for notice of any changes we have made. In some cases, we may provide additional notice of material changes to this Privacy Policy by adding a statement on the main page of this Website or, for registered users, by sending a notice by email or by adding a statement on your account page. By accepting such revised Privacy Policy by “clicking accept” in such email notification or in a statement on the account page (provided as required by applicable law), or by making a purchase on the Site or at any store after reviewing this Privacy Policy, or , otherwise, by using or submitting information to the Site after the posting of a revised Privacy Policy, you agree to such revised Privacy Policy. As a result of these changes, no processing of your data will take place without your express consent if required by applicable law.