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Privacy policy

The aim of this privacy policy is to provide you with clear, simple and complete information about how we process the personal data you give us or the data we may collect while you are browsing our website or interacting with us through our various shops and counters, how it may be transferred to third parties and your rights and options to control your personal information and protect your privacy.

Two entities are processing your personal data on the website www.acquadiparma.com (‘Website’):

- Acqua di Parma S.r.l., a limited liability company with headquarters located at 99, Ripamonti Street, 20141, Milan, registered in the companies register under no. 04215670375, VAT 04215670375;

- DIANA E-COMMERCE CORPORATION SRL (“Diana”), with registered office in Torreglia (PD) at Via San Daniele 137/139, postcode 35038, Italy, enrolment number in the Register of Enterprises of Padua, tax code and VAT number 05097740285, e-mail privacy@dianacorp.com.

Pursuant to Art. 26 of Regulation (EU) 2016/679 (“GDPR”), Acqua di Parma S.r.l. and Diana are joint data controllers for the management of products sales on this Website and the related activities, such as order processing, payment management, delivery of the products and after-sales activities (returns, refunds and complaints), as set forth in article IV), paragraph (ii), below.
The essence of the arrangement according to art. 26 GDPR between Acqua di Parma S.r.l. and Diana is available by a specific request that you may send through the contact details reported in article X).

For all other purposes, as set forth in article IV), paragraph (i), below, Acqua di Parma S.r.l. is the data controller of personal data collected on the Website, in shops and counters, in the sense of regulations applying to personal data, in particular GDPR.

Acqua di Parma S.r.l. and Diana pay particular attention to the processing, confidentiality and safety of your personal data.

I. What is personal data?

Personal data is any information about an identified physical person or a physical person that may be directly or indirectly identified via an identification number or one or more elements particular to them, such as their last name, first name, date of birth, customer number, order number, photo, etc.

II. When can we collect your personal data?

We can collect your personal data when you: - create a customer account on this Website or in Acqua di Parma S.r.l stores;
- order goods from this Website;
- make purchases or have a barber session in Acqua di Parma S.r.l stores;
- agree to receive marketing communications from us by email, telephone, SMS or post, depending on your selection;
-interact with Acqua di Parma S.r.l. via its official page on social networks;
- contact our customer service;
- send requests for information to Acqua di Parma S.r.l.;
- take part in an event we organise;
- browse on the Internet using cookies or when you click on advertisements for our products;
- reserve an appointment online through the MyAccount, eventually using the social login plugin;
- reserve an appointment online through the Facebook page of Acqua di Parma S.r.l.

III. What personal data might we collect?

(i) As part of the services we provide, we may need to collect certain data directly from you using electronic forms on this Website, mobile apps or in selected stores, or in paper form, for a range of purposes (see IV for a list of processing purposes).

Information we might collect includes:

• Your identity;
• Your gender;
• Your contact details (e.g. email address, phone number, postal adress);
• Your personal preferences in relation to the products we market or to this Website (language);
• Customer’s purchase history;
• Information relating to your orders, their tracking and your purchase invoices;
• Browsing data on the Website;
• Information you may provide for our customer service;
• Information related to our “barber waiver” in Acqua di Parma S.r.l stores;
• Specific information if you notify us of any undesirable side-effects concerning any of Acqua di Parma S.r.l. products;
• Your bank details if you place an order via this Website.

Personal data essential to Acqua di Parma S.r.l. and/or Diana is marked with an asterisk on all personal data collection forms on this Website, in electronic form at some of Acqua di Parma S.r.l. counters and stores, as well as off-line in paper form. If you do not fill in these compulsory fields, Acqua di Parma S.r.l. or Diana will probably be unable to respond to your request and/or provide you with the requested services. Other information is optional and enables us to get to know you better and improve our communications and services with respect to you.

(ii) We may also collect certain data generated by your purchases of products or services, online or in stores, particularly information regarding the amount and type of your purchases.

(iii) Lastly, we may collect information regarding the use of this Website, especially with respect to your browsing (pages visited, links clicked, etc.). Some of this information may be collected using cookies placed in your web browser when you browse this Website. For more information about cookies, read our cookie policy, available here.

IV. For what purpose is your personal data collected and used?

(i) Acqua di Parma S.r.l. processes your data to:

a) enable you to create a customer account on this Website, applications and at our counters and in our stores;
b) manage your access to your customer account on the Internet;
c) record purchases made at our counters or in our stores;
d) manage customer relations with respect to any requests for information or complaints you may send us via this Website, customer service or social network pages (not related to after-sales service);
e) trace and manage any alerts you may send us as part of our cosmetic vigilance obligations;
f) manage and optimise your customer experience by improving our knowledge of our customers;
g) propose appropriate, tailored services, particularly when we enhance our products and services;
h) conduct statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing;
i) subject to your consent, send you information on our offers, news and events on your chosen communication media;
j) manage your participation in any events to which you have signed up;
k) manage your reservation for an appointment received through this Website or Acqua di Parma S.r.l. Facebook page;
l) with your explicit consent, for sending you personalized newsletter and using third-party services to customize your profile;
m) contact information and purchase data for analysis and personalized communications by Acqua di Parma S.r.l.

(ii) As joint data controllers, Acqua di Parma S.r.l. and Diana process your data to:
• manage the sale of products through the Website, including:
  - order processing (processed by Diana and Acqua di Parma S.r.l.);
  - payment for the products (processed by Diana);
  - anti-fraud checks (processed by Diana);
  - invoicing of products sold (processed by Diana);
  - delivery of the products through couriers appointed (processed by Diana and Acqua di Parma S.r.l.);
  - after-sales activities (returns, refunds and complaints) regarding the products (processed by Diana and Acqua di Parma S.r.l.);

management of customer requests relating to the performance of the sales contract and after-sales activities (processed by Diana and Acqua di Parma S.r.l.).

V. What legal grounds legitimise the processing of your data?

Acqua di Parma S.r.l. processes your personal information:

• to perform the contract agreed between yourself and Acqua di Parma S.r.l., to manage your access to your customer account;
• within the framework of its legitimate interest for the purposes of securing its digital media (websites, applications, etc.) and combating fraud;
• when you have given your consent for the processing of your data (when requested), especially for the purposes of direct marketing, profiling activities, for managing our sales prospection and your browsing data via cookies;
• within the framework of compliance with our legal obligations, particularly fiscal obligations (conserving purchase invoices) and cosmetic vigilance with regard to Regulation (EU) 1223/2009 of 30 November 2009 on cosmetic products.

As joint data controllers, Diana and Acqua di Parma S.r.l. process your personal information:

• to perform the sales contract on the Website and the related after-sales activities;
• within the framework of legitimate interest (for the purposes of combating fraud or to defend or assert a right and/or for the prevention of fraud and other crimes or offences);
• within the framework of compliance with our legal obligations, particularly civil, fiscal obligations (e.g. conserving purchase invoices) and cosmetic vigilance with regard to Regulation (EU) 1223/2009 of 30 November 2009 on cosmetic products.

VI. Nature of the data provision

For the purposes of articles IV.i), letters from a), b), c), d), e), f), g), h), j) and k), and IV.ii), the provision of data is necessary to allow You to create and manage a customer account, to make a purchase, to contact Diana and Acqua di Parma S.r.l. and to receive the other services offered by Acqua di Parma S.r.l. Any failure to provide such data shall entail the impossibility for You to create and manage a customer account, to make a purchase, to contact Diana and Acqua di Parma S.r.l. and to receive the other services offered by Acqua di Parma S.r.l.

With regard to marketing and profiling purposes under articles IV.i), letters i), l) and m), the provision of personal data is optional and the processing of said data by Acqua di Parma S.r.l. shall be done only with Your prior explicit consent. Any refusal to provide the requested data for the purposes of articles IV.i), letters i), l) and m), however, shall entail the impossibility for Acqua di Parma S.r.l. to process the data provided for the subscription to marketing and profiling purposes, but does not prevent You from creating and managing a customer account, making a purchase, contacting Diana and Acqua di Parma S.r.l. and receiving the other services offered by Acqua di Parma S.r.l.

VII. Who are the recipients of your personal data?

Your personal data are processed by the personnel of Acqua di Parma S.r.l. and the personnel of Diana.

We ensure that only authorised people within Acqua di Parma S.r.l. or Diana have access to your personal data when this is necessary for the purpose of managing our commercial relations or meeting our legal obligations.

We may also share your personal data with;

• other entities of the LVMH Group, acting as data processors;
• subcontractors, such as:
  - site hosting and maintenance service providers and the providers of our electronic personal data collection solutions  at counters and in stores;
  - IT service providers;
  - logistic service providers;
  - marketing solution service providers;
  - sales prospection and social network communication service providers;
  - customer service providers;
  - service providers for managing cosmetic vigilance alerts;
  - event organisation service providers;
  - Diana, as data processor itself, concerning:

•management of the Website & maintenance;
•registration of site users (customers and prospects) on the Website;
•Customer care services (not related to after-sales service);

   - firms and other subjects that provide assistance, advice and services of a legal, fiscal, accounting, economic-financial, technical-organizational, data processing and communication nature;
   - subjects that provide banking, financial, insurance and debt collection services;
   - subsidiaries, parent companies, investee companies and affiliated companies;
   - third-party companies in the context of mergers, acquisitions or disposals of the company or a business unit;
• third parties wishing to know your main interests to constitute similar audiences and target prospects that match your profile. In the context of this specific data processing, Acqua di Parma S.r.l. is not the Data Controller relating to prospecting and you will not be subject to prospecting, your data is only used to constitute profiles similar to yours.

Lastly, Acqua di Parma S.r.l. or Diana may need to share your personal data with third parties to meet its legal, regulatory or treaty obligations, or to respond to requests from authorised legal authorities. The updated list of the data processors of personal data is available by a specific request to Acqua di Parma S.r.l. and Diana through the contact details reported in article X).

VIII. Transferring data abroad

Some recipients of your personal data may be located abroad, including outside of the European Economic Area such as the USA.

All data transfers outside of the European Economic Area are subject to appropriate guarantees, especially contractual, technical and organisational guarantees, that comply with applicable regulations relating to the protection of personal data. The transfer of personal data to subjects located in the USA will take place exclusively in accordance with the agreement between Diana and the non-EU recipients and in accordance with the standard contractual clauses adopted or approved by the European Commission (art. 46, paragraph II, letters C and D of the Regulation) or otherwise to subscribers to the Privacy Shield list, a self-certification mechanism for companies established in the USA who wish to receive personal data from the European Union in accordance with EU Implementing Decision 2016/1250 adopted by the European Commission on July 12, 2016.

A copy of this data is available by a specific request to Acqua di Parma S.r.l. and Diana through the contact details reported in article X).

IX. How long do we keep your data?

We keep and process your personal data for as long as it is required in order to fulfil the purposes described in this Privacy Policy and as long as it may be required by law such as for tax and accounting purposes.

Your personal data will be processed by Acqua di Parma:

#

PURPOSE

LEGAL BASE

PRESERVATION PERIOD

a-b

Managing and enabling the User to create a customer account on this Website, applications and at our counters and in our stores.

Execution of an agreement of which the concerned person is a party or the execution of pre-contractual measures upon request of the concerned person.

Until the User requests to cancel the account or, if that doesn’t happen, for 5 years from the User’s last contact with us.

c

Recording purchases made by the User at our counters or in our stores.

Execution of an agreement of which the concerned person is a party or the execution of pre-contractual measures upon request of the concerned person.

Until the User requests to cancel the account or, if that doesn’t happen, for 5 years from the User’s last contact with us.

d

Managing customer relations with respect to any requests for information or complaints the User might send us via this Website, customer service or social network pages (not related to after-sales service).

Execution of an agreement of which the concerned person is a party or the execution of pre-contractual measures upon request of the concerned person.

Until the User requests to cancel the account or, if that doesn’t happen, for 5 years from the User’s last contact with us.

e

Tracing and managing any alerts the User may send us as part of our cosmetic vigilance obligations;

Law obligations

For the whole duration of the investigation and later for not more than 10 years from the termination of the case.

f

Managing and optimising the User experience by improving our knowledge of our customers.

Legitimate interest

Until the User requests to cancel the account or, if that doesn’t happen, for 5 years from the User’s last contact with us.

g

Proposing appropriate, tailored services, particularly when we enhance our products and services.

Legitimate interest

User’s consent

Until the User requests to cancel the account or, if that doesn’t happen, for 5 years from the User’s last contact with us.

h

Conducting statistical analyses to develop management, measuring and reporting tools in order to adjust and improve our sales, marketing and product manufacturing;

Legitimate interest

Until the User requests to cancel the account or, if that doesn’t happen, for 5 years from the User’s last contact with us.

i

Sending the User information on our offers, news and events on the chosen communication media.

User’s consent

Until the User requests to cancel the account or, if that doesn’t happen, for 3 years from the User’s last contact with us.

j

Managing the User participation in any events to which he has signed up.

Execution of an agreement of which the concerned person is a party or the execution of pre-contractual measures upon request of the concerned person.

For the whole duration of the event.

k

Managing the User reservation for an appointment received through this Website or Acqua di Parma S.r.l. Facebook page.

Execution of an agreement of which the concerned person is a party or the execution of pre-contractual measures upon request of the concerned person.

Until the User requests to cancel the account or, if that doesn’t happen, for 3 years from the User’s last contact with us.

l

Sending to the User personalized newsletter and using third-party services to customize the User's profile.

User’s consent

Until the User requests to cancel the account or, if that doesn’t happen, for 13 months from the User’s last access.

m

Contact information and purchase data for analysis and personalized communications by Acqua di Parma S.r.l.

User’s consent

Until the User requests to cancel the account or, if that doesn’t happen, for 5 years from the User’s last contact with us.


Your personal data will be processed by Diana and Acqua di Parma for the following targets:

#

PURPOSE

LEGAL BASE

PRESERVATION PERIOD

A

Signing and executing the sales agreement of the products offered on the website including the following:
 

  • managing and executing the purchase order,
  • communicating information relevant to the order
  • managing payments
  • after-sale assistance
  • managing complaints and returns
  • fulfilling financial and fiscal obligations
  • preventing and proving frauds or other crimes
  • enforcing a right

Execution of an agreement of which the concerned person is a party or the execution of pre-contractual measures upon request of the concerned person.


Law obligations.
Legitimate interest

For the whole duration of the agreement and later for not more than 10 years from the termination.  Any invoice is stored 10 years.



Where cookies are placed on your computer, we shall keep them for no more than 13 months.

When we no longer need to use your personal data, it is removed from our systems and records or anonymized within 60 days from the terms indicated above, so that you can no longer be identified from it.

X. What are your rights and how can you exercise them?

Under current regulations, particularly the GDPR, you have the right to access and correct your personal data, request erasure, object to processing on legitimate grounds and obtain limitation or portability, insofar as this is applicable. You also have the right to withdraw consent at any time for data processing based on consent.

You can exercise these rights directly with Acqua di Parma S.r.l. by sending an email to DPO@acquadiparma.it or a non-registered letter by post to Acqua di Parma, Via Giuseppe Ripamonti 99, 20141, Milan, Italy, including a copy of a document proving your identity.

If, at any time, you no longer wish to receive details of our offers, news and events, you can unsubscribe using the hypertext link provided for this purpose in each mail we send you. You can also send us a non-registered letter Acqua di Parma, Via Giuseppe Ripamonti 99, 20141, Milan, Italy.

You may also lodge a complaint with the Autorità Garante per la protezione dei dati personali, Piazza di Montecitorio n. 121, 00186, Rome, Italy.

XI. Contact details of the Data Protection Officer (DPO)

For all questions relating to the collection and processing of your data by Acqua di Parma S.r.l., you can contact the Acqua di Parma S.r.l.’s Data Protection Officer at DPO@acquadiparma.it.

For all questions relating to the collection and processing of your data by Diana, you can contact the Diana’s Data Protection Officer at privacy@dianacorp.com.

 

 

 

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Acqua Di Parma Srl, with a capital of 420 000.00 € registered with the Trade and Commerce Register of Milano under number IT04215670375 with its registered office located at Via Ripamonti 99, 20141 Milano, Italy.

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