1. WHAT
IS COVERED BY THIS PRIVACY POLICY AND DO OTHER POLICIES APPLY TO
YOU?
This privacy policy covers situations where we, Pomellato, access,
collect, store, process, use, disclose or transfer your personal
information in paper or electronic form. It also covers situations where
approved partners or other members of Kering use your personal
information on our behalf.
In some cases, other policies apply to you. It may be the case when
you use certain products or services, and in this event:
You will be notified of these other policies while using the
products or services they apply to.
Such policies will supersede this privacy policy unless they
expressly refer to it.
This privacy policy does not cover products or services you might use
as provided by other companies acting on their own account.
Our privacy policy does not extend to services provided by other
companies acting on their own account, such as franchisees and licensees
or when you share information through social media (WeChat, WhatsApp,
Baidu, Kakao Talk, Facebook, Twitter, Instagram, etc.), or other online
platforms owned and managed by other companies. These other companies
have their own privacy policies in place, so remember that the way they
use any personal information you give them will be subject to their
rules and not ours.
Want to know more? You may be interested in the following
sections of our Privacy Policy:
2. WHAT
SPECIFIC TERMS APPLY TO YOU DEPENDING ON YOUR COUNTRY OF RESIDENCE?
The protection of your personal information is an essential part of
our activities. In order to provide you with a personalized experience,
we will apply the data protection laws of your country of residence.
This approach would also be consistent with consumer laws of the country
of your habitual residence and would hence allow us to better meet your
expectations regarding the protection of your personal information.
If you are a resident of any of the following countries/regions,
please make sure that you refer to the Annex containing specific
information for your jurisdiction:
If you are a resident of California or of certain other US
states, please refer to
Appendix 4 –
Specific information for U.S. residents
to obtain information about
the categories of personal information we may use, the sale of your
personal information and your rights over your personal
information.
3. WHO COLLECTS &
USES YOUR PERSONAL INFORMATION?
We, Pomellato S.p.A. ("
Pomellato
”), active in the
field of luxury, act as the “data controller”, which means that we
determine “why” and “how” your personal information is collected and
used. We are an
Italian
corporation, located in
Via Neera 37, 20141 – Milan, Italy
and registered under
number 00860690155 with the company registry of Milan.
To be able to deliver our products and services to you, we need to
share your personal information with approved partners or other members
of Kering who generally act as our “data processors”. All are bound by
an obligation to implement appropriate security measures to protect
personal information in their possession and are bound by a strict
confidentiality agreement and specific contractual terms on “how” and
“when” they are allowed to use your personal information on our
behalf.
Please be aware that certain approved partners, such as our
franchisees and licensees or social media, could also determine “why”
and “how” your personal information is used. They have their own privacy
and cookies policies, so remember that the personal information you give
them will be subject to their rules and not ours.
Your local legislation may not refer to the terms “data
controller” or “data processor”, but respectively to terms such as “data
user”, “owner”, “business”, “responsible party”, etc., and as “data
intermediary”, “operator”, etc. In order to understand our role, please
note that we, Pomellato, are the entity who decides on the methods and
purposes of the processing of your personal information by determining
“why” and “how” your personal information is collected and used. Our
“data processors” are entities who use your personal information on our
behalf by receiving instructions from us on “how” and “when” they are
allowed to use it.
Want to know more? You may be interested in the following
sections of our Privacy Policy:
Pomellato will collect, record, hold, organize, structure, store,
update, adapt, combine, consult, use, transfer and disclose your
personal information for the purposes described in this section. Your
personal information will not be further used for purposes incompatible
or inconsistent with the purposes for which it was collected, unless
permitted by the applicable legislation.
The processing of your personal information will comply with your
privacy legislation and rely on the legal bases set out in this section.
The legal bases listed in this section will also apply when we share
your data with third parties (as listed in the section
With whom do
we share your personal information?
) for the purposes mentioned
below.
A. To provide you with the products and services
you have purchased or otherwise requested
We will use your personal information to manage our relationship with
you and to perform our obligations under the contract you conclude with
us when you purchase or otherwise request products or services from us.
This can cover various activities such as internal accounting,
processing your payment or delivery.
To provide you with the products and services you have requested,
we will access, collect, store, process, use, disclose and transfer your
personal information for invoicing, payment management and internal
accounting.
Some of the operations mentioned above can be implemented by
partners of ours as identified in section “
With
whom do we
share your personal information?
” below, in particular the
registration, payment and delivery of your order. Your information may
be communicated, used or collected directly via the information system
of our partner.
Certain specific information may be required to provide you with
gift cards, customization services, or when you reserve a product or a
service, request the repair of a product, or purchase products or
services by phone, or on our website or a marketplace. In such cases, we
could access, collect, store and use your personal information for
delivery, warehouse and return management.
During your visit to our store, we may need to collect your
information in order to allow you to access our premises or when you
wish to obtain a particular service: request for tax on products or in
connection with our after-sales service, etc.
The purposes for which we
process your personal information are as follows:
The processing of your
personal information is justified on the following legal
basis:
Providing you with the
products and services you have purchased or otherwise requested either
in our stores or online.
This involves any action necessary to perform our obligations
under the sale or service contract you conclude with us (processing of
your payment, delivery, return management, etc.)
Performance of a
contract
B. To manage your Pomellato profile.
Once you have requested us to create your Pomellato profile, via
Pomellato websites or any other means, including our customer service,
your personal information will be linked to this profile, where we will
keep all the information we have on you. This could include personal
information we obtain directly from you as well as from other sources in
accordance with applicable legislation. This could also include
information about the purchases made when checking out as a guest or
when checking out using a profile. The information in your Pomellato
profile is crucial to provide you with the Pomellato personalized and
tailored experience, and in some cases is necessary in order to access
to some specific services or to purchase from our website, and thus it
needs to be kept up to date for the best experience.
Once you have asked us to create your Pomellato profile, we will
supplement it with personal information such as your purchases,
preferences and contact details. In this context, please be aware that
we use personal identification information, such as your email address
or phone number, to link an interaction or a purchase with your
Pomellato profile. This also applies when checking-out as a guest on our
website when making a purchase, as mentioned above, or in case you bind
your social media open ID account with your Pomellato profile (by using
dedicated QR Codes for example). In addition, we may use your date of
birth to determine that you are old enough to use our services.
In order to keep your personal information accurate, we will take
every reasonable step to ensure that personal information we hold is
properly updated. Subject to your applicable privacy legislation you may
have the right to have your information rectified at any time, and in
any event please let us know if any of your information needs updating
or correcting, and we will make our best efforts to detect and correct
inaccurate personal information (data cleansing) and delete any
duplicated dataset. This may require us to correct typographical errors
or inconsistent personal information.
The purposes for which we
process your personal information are as follows:
The processing of your
personal information is justified on the following legal
basis:
Administering, managing and
maintaining your Pomellato profile
once you have requested us
to create it.
This could include data cleansing and
deduplication.
Performance of a
contract
or our legitimate interest
(where
applicable)
Once your profile has been created upon your request, to
supplement it with the personal information you provide us during our
interactions and thus ensure we retain the most accurate and up-to-date
version of your profile (and such legitimate interest is not overridden
by your own interests or fundamental rights)
C. To provide you with tailored customer service and
assistance.
You should have the same unified experience no matter how we
communicate. Whether this happens in our stores, on our website, by
chat, by phone or by video, and whether you contact us or we contact
you
,
we want to provide you with relevant and tailored customer
service.
For this purpose of providing you the Pomellato experience, we will
collect, store, process, use, disclose and transfer your personal
information to be able to identify you. This will allow us to provide
you with the tailored assistance you are asking for or to share relevant
information with you. In addition, when you contact us, we may retain
the personal information you share with us to always provide you with
such a customised and personalised experience. This could happen if you
are an existing or potential customer. Your personal information will be
linked to your Pomellato profile, if you have requested us to create
one, or to a temporary record.
To provide you with a smooth and enjoyable customer experience, know
you better to provide you with tailored answers, and to improve the
quality and security of our services, we may rely on your consent,
proceed in accordance with our contract with you, or take all reasonable
steps to enter into a contract with you, or rely on our legitimate
interest to improve our services.
We will use the information we have about you to try to identify
you when you contact us (whether by phone, video chat, text message,
chat, social media, etc.). When we can identify you, we will be able to
access personal information available in your Pomellato profile or in
your temporary record, to know when you have previously interacted with
us and to provide you with the tailored assistance you are asking for.
This could include real-time or subsequent monitoring of your
interaction with us (for example on our website or in a store) to
identify the products you are looking at or what could be your specific
need.
To provide you with adequate customer service, you may be asked
if you need further assistance when you are on our website or in a
store. On our website, if you do not want to be contacted, kindly close
the chat navigation window. This service was implemented for you to
enjoy the same service as in one of our physical stores.
If we are not able to identify you, we may create a temporary
record to allow you to have a unified purchase experience. Indeed,
however you interact with us, we will do our best to avoid asking you
again for information you have already shared with us.
Your personal information, in particular your Pomellato profile
if you have created one or the temporary record we may create about you,
could enable our sales associates to contact you directly in relation to
the products and services you have purchased or otherwise requested,
such as when a product becomes available again or when an order you have
placed has been received in store, or to share with you any other
information you have requested from us.
In addition, the monitoring of our interaction (including, with
prior notice to you, via voice or video recording - such as real time
listening or analysis - or listening in real time) enables us to improve
the quality and safety of our services and to provide you with tailored
answers.
All our customers are important to us. However, some of our
customers and potential customers benefit from a more personalized
experience due to the important relationship they keep with Pomellato.
Our teams may need to collect and gather information on such customers
or potential customers in order to identify personalities who correspond
to the image and values of Pomellato to offer them unique support. This
may be the case when you participate in one of our selective projects or
when our Sales Associates offers you to participate in events or
contacts you for certain special occasions (for your birthdays or for a
particular event of your life).
The purposes for which we
process your personal information are as follows:
The processing of your
personal information is justified on the following legal
basis:
Administering, managing and
maintaining your Pomellato profile
This will be done if you have requested us to create your
Pomellato profile and if we are able to identify you. We will supplement
your Pomellato profile with the personal information you provide us with
when you contact us or when we contact you. This could include data
cleansing and deduplication.
Performance of a
contract
or our legitimate interest
(where
applicable)
Once your profile has been created upon your request, to
supplement it with the personal information you provide us during our
interactions and thus ensure we retain the most accurate and up-to-date
version of your profile (and such legitimate interest is not overridden
by your own interests or fundamental rights)
Administering, managing and
maintaining a temporary record
This will be done if we are not able to identify you. We will
supplement this temporary record with information you provide us with
when you contact us or when we contact you, to avoid asking you again
for information you have already shared with us and provide with you
tailored assistance about our products and services.
Taking steps at your
request prior to entering into a contract
or our legitimate interest
(where
applicable)
When we are not able to identify you, to supplement a temporary
record to provide you tailored assistance (and such interest is not
overridden by your own interests or fundamental rights)
Inbound interaction –
Providing you with the products, services or information you may request
when you contact us
Performance of a contract or
taking steps at your request prior to entering into a
contract
Outbound interaction -
Contacting you
directly
in connection with
the products, services and information you have requested
Performance of a contract
or taking steps at your request prior to entering into a
contract
or our legitimate interest
(where
applicable)
To provide you with an adequate answer when our interaction is
not related to the formation or performance of a contract (and such
interest is not overridden by your own interests or fundamental
rights)
Realtime interaction – To
allow you to try on our products virtually
Performance of a contract
or taking steps at your request prior to entering into a
contract
When we collect information to provide you with relevant
assistance about our products or services
Our legitimate interest
to provide you with
tailored assistance when we are not able to identify you (and when such
interest is not overridden by your own interests or fundamental
rights)
Or your consent
if your facial image is
pictured
Real-time or further
monitoring of our interaction
, to enable us to improve the
quality and safety of our service and provide you with better
answers.
This monitoring could be implemented during both inbound and
outbound interactions and could be carried out via voice or video
recording or listening in real time, with prior notice to
you.
Performance of a contract
or taking steps at your request prior to entering into a
contract
When we collect information to provide you with relevant
assistance about our products or services
Our legitimate interest
When we collect information to improve the quality and safety of
our service (and when such interest is not overridden by your own
interests or fundamental rights)
D. To enable you to receive relevant information and tailored
marketing content.
You will receive information and updates about us either at your
request (with your prior consent where required by law) or when we are
authorised by law to send you such information and updates directly, for
instance after a purchase. Such communication can be global or local,
and may include updates about our products and services, notifications,
invitations to events, offers, surveys, etc.
Our communications will be customised and specifically designed to be
of interest to you and will be updated with any new personal information
linked to your Pomellato profile. We will thus use your personal
information to send you tailored communications or other customised
advertisements or marketing campaigns. This use of your information
includes some profiling activity.
When you share your contact information with us, we may use this
personal information to contact you through related communication
channels (such as text message, MMS, e-mail, post, internet means,
social media or telephone), with your consent where required. You can of
course request us not to use a particular channel of communication or
opt-out (unsubscribe) from it by applying the opt-out option that will
always be shared with you. If you want to stop receiving communication
from us via all communication channels, please send an email to
privacy@pomellato.com.
As part of the
Pomellato
experience, we will always try
to customise and personalise your experience with us. This is why we
will use your personal information to send you tailored communications
or personalise your journey with us, but only with your prior consent
where it is required under applicable privacy legislation. Our
communications could include tailored product recommendations we think
you might like, personalised marketing content designed to suit your
interests, personalised events invitations or, at your request and where
available, personalised and customised products. For these purposes, we
will use the information you provide to us (for example your date of
birth, your country of residence, your preferred means of contact, etc.)
and/or jointly or independently, certain patterns we may observe when
interacting with you (for example where you prefer buying our products,
what type of products you like, which occasions you are shopping for,
etc.). With this information, we may create groups of similar customers
(called “persona”) to whom we can decide to offer personalised content
and experiences both in inbound or outbound interactions. In this
context, we may make inferences about you, as derived from your personal
information (
profiling
). For example, if you always
purchase our products from the same store (specific location or online),
we may consider this store as your preferred one. This will allow us to
customise your experience with Pomellato based on your interests and
shopping habits (i.e. tailored communication).
In order to
provide you with such customised and personalised experience, in our
stores or online, you may be required to log in or identify
yourself.
To enrich your personal information, we may use
cookies
or other online advertising technologies
. Via such technologies, we
will collect personal information related to your activities on social
media and your browsing activity across different websites and devices
(for example: to know if you have visited our website after opening a
newsletter you have received). Certain technologies may rely on services
provided by other companies acting on their own account (such as social
media WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter, Instagram,
or other online platforms). These companies have their own privacy and
cookies policies and the way they use the personal information you share
with them will be subject to their rules and not ours.
Personal information linked to your Pomellato profile (your
identification personal information such as your e-mail address, phone
number, social network id, etc.) will enable us to reach you on
third-party platforms or to create “lookalike campaigns”, allowing us to
find new people who are likely to be interested in our products because
they may be similar to you. We may conduct such campaigns through our
website, social media or other communication means such as search
engine. When this kind of campaigns are conducted, before it is shared,
your personal information is hashed and turned into short fingerprints
that cannot be reversed.
Using
cookies
or other online advertising technologies
may also enable us to show
you online advertisements that are “contextual” (meaning they are shown
according to the webpage you are browsing), or “behavioural” or
“interest based” (where advertisements are shown to you based on your
interests which we have inferred from your information including
demographic, geographic and interest-based data). We may use such
advertisements to display products or services that are most relevant to
you.
If you no longer want to see customised online advertisements,
you may request us to delete your Pomellato profile or modify your
cookie preferences – see “
cookies
or other online advertising technologies
”. In addition, some
third-party sites allow you to stop seeing advertisements from specific
advertisers, so you may also set your preferences on those
websites.
The purposes for which we
process your personal information are the following:
The processing of your
personal information is justified by the following legal
basis:
Sending or presenting you with tailored
communication
This includes communication such as updates about our products
and services, invitations to events, offers or surveys.
When you share your contact information with us, we will use such
personal information to contact you through related communication
channels (such as text message, MMS, e-mail, post, internet, social
media or telephone).
We will always do our best to provide you with tailored
communication based in particular on your interests and shopping habits,
and improve and customise our services notably via
profiling.
Performance of a
contract
When we are authorised by law to send you such communication
without your consent and such communication is within the scope of our
contractual relationship
Our legitimate interest
in providing you with
customised content
When such interest is not overridden by your own interests or
fundamental rights and we are authorised by law to send you such
communication without your consent
Your consent
, as provided when you create your
Pomellato profile
You can always withdraw your consent at any time
Updating and supplementing or enriching your personal
information
This includes conducting data cleansing and
deduplication.
This also includes enriching your personal information with
second party data or information related to your activities on social
media and your browsing activity across different websites and
devices.
Some of the technologies we use (including cookies) may rely on
services provided by other companies acting on their own account (such
as social media - WeChat, WhatsApp, Baidu, Kakao Talk, Facebook,
Twitter, Instagram or other online platforms).
You may have
provided your consent to cookies and other technologies through such
platforms
.
These other companies have their own privacy and
cookies policies and the way they use your personal information will be
subject to their rules and not ours.
Performance of a contract
or compliance with a legal obligation
When such update relates to the administration and management of
your Pomellato profile, including taking actions following a
rectification or erasure request.
Any other situation will require
your consent
,
as provided when you create your Pomellato profile
You can always withdraw your consent with us at any
time
Creating lookalike campaigns
Lookalike campaigns enables us to reach new people who are likely
to be interested in our products because they are similar to
you.
Some of the technologies we use (including cookies) may rely on
services provided by other companies acting on their account (such as
social media - WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter,
Instagram or other online platforms).
You may have provided
your consent to cookies and other technologies through such
platforms
.
These other companies have their own privacy and
cookies policies and the way they use your personal information will be
subject to their rules and not ours.
Your consent
when you accept, at the creation of your Pomellato profile, that we link
your personal information to certain patterns
(
Profiling
) (for example by accepting to receive
tailored communication).
You can always withdraw your consent with us at any
time.
You can always withdraw your consent with us at any
time
E. To send you non-marketing communications.
Non-marketing communications may be sent upon your request, and/or
may be important for your safety and the security of your personal
information.
You may still receive such communications even when you opt-out from
certain marketing communications. The information communicated may be
necessary for the correct performance of our contract with you or be
mandatory to comply with some of our legal obligations.
Non-marketing communications can include, but are not limited to:
emailing you to verify your identity when you sign up to our services;
emailing you for password and/or username reset; notifying you that a
particular service has been or will be suspended for maintenance or
terminated; notifying you of an upgrade, a rectification or an incident
affecting our services that may involve your personal information;
notifying you of an update to our privacy policy or Terms of Use; or
informing you about any products or services you have requested or
purchased.
We will never contact you to ask for your password. Please be
aware if you receive any request for this personal information.
The purposes for which we
process your personal information are as follows:
The processing of your
personal information is justified on the following legal
basis:
Providing you with the
services and information you requested
. For example identity
verification, password or username reset, etc.
Performance of a
contract
Providing you with the
services and information we need to send or provide you
. For
example information about the suspension of our services, about
incidents that may involve your personal information, etc.
Performance of a contract or
compliance with a legal obligation
Administering and managing
your Pomellato profile
once you have requested us to create
your Pomellato profile.
Performance of a
contract
F. To manage our social networks
Pomellato manages “Fan” pages available on several social networks.
We may need to process the information made available by the different
platforms or when you interact with our pages and publications.
When, as a user of a social media, you decide to interact with
our social media pages (e.g. when you follow one of our pages, when you
click "Like" on Facebook or "Follow" on Instagram or add a reaction to a
post, when you "share" or add a "comment", etc.), we have access to
public information in your profile. Your information is used for the
purpose of interacting with you through the social network in question
or to establish analyzes or statistics on the use of our pages or on the
performance of our communications. Our services may remove your comments
if they do not comply with our policies on the use of social networks
(e.g. if your comments are insulting, illegal or malicious).
When you visit our “Fan” page, when you do not have an account or
are not logged in to the relevant social network, we do not collect any
personal information about you, except for the aggregated data provided
to us by each social network.
Promote Pomellato’s activities
on social networks.
Performance of a
contract,
when you interact with us via the features proposed
by the social network
Or
Our legitimate interests
in communicating on our
activities
When such interest is not overridden by your own interests or
fundamental rights.
Analyze the habits of users
who visit our “Fan” pages or share our content.
Our legitimate
interests
in communicating on our activities
When such interest is not overridden by your own interests or
fundamental rights.
G. To conduct our business securely and protect our activities and
personnel.
To deliver our products and services safely to you, perform our
contract properly or comply with some of our legal obligations, we will
implement fraud prevention and detection measures. Such measures will
allow us to adequately perform our contract with you and/or protect our
legitimate interests in defending ourselves against fraud. We may
notably implement measures to ensure that you are complying with our
terms and conditions for sales, available in this website, offers and
programs, and to prevent and detect non-compliance or fraud by you. This
may include reviewing and assessing your dealings with us, your
eligibility to participate in certain sales, offers and programs, your
compliance with the terms and conditions of such sales, offers and
programs, and undertaking enforcement action and/or disciplinary action
where such non-compliance or fraud is suspected or identified.
We may use administrative and technical measures to protect, our
website, our systems, our networks, transactions occurring on our
website or in our stores, and any other necessary means to protect the
personal information we may access or store. For this purpose, we may
also be required to verify your identity or to take note of any
suspicious or actual non-compliance with our terms and conditions or
fraud we incurred with respect to your dealings with us. Such measures
may also be implemented for compliance purposes or to avoid sharing your
personal information with any untrusted third parties. For example, when
you purchase a product, your personal information will be associated
with a unique code placed into and/or printed on such product so that by
reading the unique code we can recognize the order as yours, to enable
us to assess your compliance with our terms and conditions or to detect
fraud by you, and to take enforcement and/or disciplinary action against
you in the event of suspected or identified non-compliance or fraud by
you.
In addition, we may implement certain measures to protect and
defend our rights and property, our employees and our business partners
in compliance with applicable laws, regulations and international
conventions. For example,
we can monitor our inbound and
outbound interaction with our customer service (including via voice or
video recording or listening in real-time, with prior notice to you);
also, mindful of the health of our employees, and for this sole purpose,
we implement an anti-malicious calls procedure so that any occurrence of
inappropriate behaviors such as harassment, insults or direct threats
from users will be reported to our dedicated team. This will generate a
warning to the concerned user, and they will be recorded on our
provisional list. The initial warning will set out the consequences of a
second incident occurring. A second incident will lead to the suspension
of any further calls from the user in question for a period of 4 months.
During this period, the user will still be able to contact our customer
services by other communication channels (e.g., regular mail or email)
so we can attend their queries and preserve their rights at any given
time.
The purposes for which we
process your personal information are the following:
The processing of your
personal information is justified by the following legal
basis:
Implementing fraud prevention,
detection and investigation measures and procedures against
inappropriate behaviors against our employees
to ensure
physical security and cybersecurity, to safely deliver you products and
services and to protect the health of our employees, also via voice or
video recording or listening in real time both inbound and outbound
conversations with our customer service, with prior notice to
you.
Performance of a contract
or compliance with a legal obligation
or our legitimate interests
in protecting
ourselves against fraud and in protecting our employees against
inappropriate behaviors (when such interest is not overridden by your
own interests or fundamental rights)
In accordance with applicable law,
implementing compliance-related and privacy-related
activities
Compliance with a legal
obligation
or our legitimate interest
(where
applicable)
Where the processing is not prescribed by law but is a regulatory
expectation (and such interest is not overridden by your own interests
or fundamental rights)
In accordance with applicable law,
implementing activities related to the protection of
intellectual property rights and management of litigation
cases
Compliance with a legal
obligation
or our legitimate interests
in protecting our
rights (when such interest is not overridden by your own interests or
fundamental rights)
or the regular exercise of our rights in lawsuits or
proceedings,
where applicable in your country of
residence
H. To assess and better understand our business.
To manage our activities, perform our obligations under our contract
with you and comply with our legal obligations, we may need to access
and use some of your personal information for finance, management or
legal purposes, or business-related analytics & market research
activities.
For example, this could occur when we use the invoices we have issued
in relation to your purchases for compliance or accountability purposes,
or when we analyse personal information to understand the
characteristics of our customers (what is the gender proportion, the
average age etc.).
In certain limited circumstances, such activity may be based on our
legitimate interest when related to business analytics & market
research activities.
Certain activities which are required when conducting a business
may involve the use of your personal information. This could include
internal processes (such as finance control, accounting, stock
management, production management, internal or external audit), certain
legal obligations (for example, record-keeping or tax declaration), or
analyses conducted in case of a merger or acquisition.
We may also conduct various business-related analytics &
market research activities, which may require us to access or otherwise
use some of your personal information, or to send you surveys or
customer satisfaction questions in order to gather new or additional
information. This notably enables us to analyse and learn how our
customers use and interact with us in order to improve products,
services and our business in general. It is also important for us to
conduct operations that allow us to analyze and measure the performance
of our marketing or communications campaigns. This may be the case, for
example, when you click on one of our ads on our business partners
website or when you make a purchase after viewing one of their ads.
Please be aware that to do this, we may use cookies or other online
advertising technologies.
The purposes for which we
process your personal information are the following:
The processing of your
personal information is justified by the following legal
basis:
Performing activities
relating to the sale or service contract you have concluded with
us.
For example, accounting, stock management, keeping of records,
etc.
Performance of a contract or
compliance with a legal obligation
Conducting business-related
analytics & market research activities
Performance of a
contract
Our legitimate interests
in improving our
products or services
When such interest is not overridden by your own interests or
fundamental rights.
Your consent,
when you answer surveys or
customer satisfaction questions or when we use cookies or other online
advertising technologies.
You can always withdraw your consent with us at any
time.
Sharing necessary information
with actual or potential buyers as part of a business
transfer
Our legitimate
interest
in disclosing information necessary to complete our
business transactions
Sharing necessary information
with auditors, law firms, similar corporate professional service
providers and data analysis providers
Compliance with a legal
obligation
Or our legitimate interest
of properly carrying
out our business including in compliance with applicable legislation and
to better understand and improve our business (when such interest is not
overridden by your own interests or fundamental rights)
I. To optimise and manage our website and other means of
communication.
We may take certain measures involving the use of your personal
information to administer, optimise and improve our means of digital or
physical communications such as our website, our mobile application, or
face-to-face interaction in our stores.
The use of your personal information will allow us to perform our
contractual obligations or improve our services in accordance with our
legitimate interest. Of course, when we use cookies or other online
advertising technologies requiring us to do so, we will always ensure
that we have duly obtained your prior consent.
We may use some of your personal information to administer,
optimise and improve our websites, our applications, our content and our
other digital offerings, including the services and products offered
through our websites, applications or any other digital means of
communication to ensure the most user-friendly online navigation
experience. We may use such personal information to fix operational
problems such as pages crashing and software bugs. Please be aware that
to do this, we may use cookies or other online advertising
technologies.
The purposes for which we
process your personal information are the following:
The processing of your
personal information is justified on the following legal
basis:
Fixing operational
problems
such as pages crashing and software bugs
Performance of a contract
in accordance with
the applicable Terms of Use of our services
Your consent
to cookies, when we use cookies or
other online advertising technologies
You can always withdraw your consent at any time.
Or our legitimate interests when
we use cookies
or other online advertising technologies for which consent is not
required under applicable law
When such interest is not overridden by your own interests or
fundamental rights
Understanding how our means
of communication are used
and administer, optimise and improve
them.
This can include auditing the downloading of personal information
from the Website.
Performance of a contract
in accordance with
the applicable Terms of Use of our services
Your consent
to cookies, when we use cookies or
other online advertising technologies
You can always withdraw your consent at any time.
Or our legitimate interests
to administer and
improve our means of communication and other systems, in particular when
using cookies or other online advertising technologies for which consent
is not required under applicable law
When our legitimate interest is not overridden by your own
interests or fundamental rights
5. WHAT PERSONAL
INFORMATION DO WE COLLECT?
When you interact with us or our approved partners, you may provide
us with the following categories of personal information (that may
include sensitive information in accordance with applicable
legislation).
This set of personal information enables us to identify you, manage
your Pomellato profile, provide you with customer service and assistance
and, in some cases, to contact you, including by sending you relevant
information and tailored marketing content on the ground of the legal
bases set out in this privacy policy.
The list below is provided to give you an overview of the type of
information we may collect. However, the collection of this information
is not systematic: only the information necessary to fulfill each
purpose will be collected and used.
It could include, when your applicable privacy legislation allows
us to collect such personal information, your first name, last name,
pseudonym, signature, email address, postal address, date of birth,
place of birth, login name, phone number, unique personal identifier,
customer number, online identifier, social media accounts (and related
information collected through social log-in), gender, country of
residence, image (in case of videocall with our sale assistants),
lifestyle/interests, Internet Protocol (IP) address, account name,
social security number, state identification card, driver’s license
number, passport number, nationality, or other similar identifiers,
physical characteristics or description (for example characteristics
such as your size where relevant to the products and services we would
offer you), and certain personal financial information.
We will take steps to minimise information that is collected to
what is necessary in relation to the purposes for which it is processed.
In some cases, the creation of your Pomellato profile will be mandatory
in order to access to some specific services or to purchase from our
website.
In some countries, some personal information could be considered
sensitive, special or protected. We will collect and use such
information only where no other option is available, and always comply
with the applicable privacy legislation to collect, protect and use
safely your personal information (in particular, by seeking your consent
where required).
If you are an employee of a Kering entity, we may process certain
information regarding your employment, and we invite you to refer to the
employee privacy policy that has been made available to you.
B. Transaction information & commercial information (including
audio)
This set of personal information enables us to provide you with the
products and services you have requested, manage your Pomellato profile,
provide you with relevant customer service and assistance, secure our
communications and to manage and better understand our business.
The list below is provided to give you an overview of the type of
information we may collect. However, the collection of this information
is not systematic: only the information necessary to fulfill each
purpose will be collected and used.
It could include personal information on the products and
services you purchase, obtain or consider, their price, size,
collection, when the product was bought, if it was returned, product
defects, comments you made on the product or the service we have
provided to you, purchasing and consumer histories or trends, etc. This
could also include personal financial information relating to how you
paid for your products or your bank details when you request a refund,
or audio recordings (and their transcript) when you contact our
customer service.
We will take steps to minimise
information that is collected to what is necessary in relation to the
purposes for which it is processed.
Pomellato may also have included unique codes or small devices
(such as RFID or NFC tags) in the products you have purchased, for fraud
prevention purposes (in particular to manage the supply chains, identify
unauthorized sales or other cases of fraud or non-compliance with our
terms and conditions of sale, and be able to confirm the authenticity of
the products) and to provide you with information you may request about
the products (including about their authenticity and how to take care of
them). Following your interaction with such technologies, you may create
a Pomellato profile (if you do not already have one), in which case we
could collect some of your personal information in accordance with the
terms of this Privacy Policy.
Some personal information (including the reference number of the
devices contained in the products you have purchased) will be linked to
your Pomellato profile when you identify yourself in the stores, through
customer services or on our website. In addition, when contacting our
customer service, we may record your conversation with prior notice to
you.
Under certain applicable privacy legislation, particular
transaction and commercial details are considered sensitive.
We
will collect, store and use such personal information with the highest
level of care in accordance with the applicable legislation and with
your consent where required.
C. Personal life information and inferences
This set of personal information enables us to always offer you the
optimum service by understanding you better. We use it to manage your
Pomellato profile, provide you with relevant customer service and
assistance and also, in certain circumstances, to contact you for
example by sending you relevant information, updates and tailored
marketing content.
The list below is provided to give you an overview of the type of
information we may collect. However, the collection of this information
is not systematic: only the information necessary to fulfill each
purpose will be collected and used.
It could include your preferences regarding fashion events, how
you have used certain products, food allergies when you explicitly
choose to share this information with us, personal information regarding
your relationships, including about your family members, your friends,
or the people you send invitations to, for example if you indicate to us
that you will offer them a gift or if you invite them to join a
Pomellato program (if you have obtained their consent to share such
information with us, where this is required by applicable law), your
life habits, how you use our website or third-party websites such as
social media, your answers to our surveys or any other personal
information we may collect when it is directly or indirectly linked to
you. We may draw inferences from any of the information identified above
to create a profile about you, reflecting your preferences,
characteristics, trends, predispositions, aptitudes and
attitudes.
Under certain applicable privacy legislation, some personal life
information is considered sensitive. In this context, we will collect,
store and use such personal information only where no other option is
available and with the highest level of care in compliance with the
applicable privacy legislation (including with your consent where
required).
D. User-generated content
This set of personal information enables you to provide us with
personal information relating to you or to third parties. In certain
circumstances it enables us to contact you.
The list below is provided to give you an overview of the type of
information we may collect. However, the collection of this information
is not systematic: only the information necessary to fulfill each
purpose will be collected and used.
It could include pictures of you (including the picture(s) taken
with virtual try-on) or other individuals, or any other type of content
such as texts, feedbacks, opinions, personal information regarding other
individuals you may provide us with (for example when participating in a
contest or sharing personal information with our sales associates or
through social media), “tagging” or “liking” our social media page or
any content published by us, or any personal information you may provide
in the public domain. You may remove such content at any time if you no
longer want us to use it.
You shall avoid sharing third-party personal information through
such means or you should ensure that they have given prior authorisation
to such sharing.
E. Technical, electronic & localisation information
This set of personal information enables better delivery of the
service you expect from us.
It could include personal information related to your interactions
with us and allows us to manage your Pomellato profile, provide relevant
customer service and tailored marketing content, establish
communications and conduct our business securely, assess and better
understand our business, and optimise and manage our website and other
means of communication.
The list below is provided to give you an overview of the type of
information we may collect. However, the collection of this information
is not systematic: only the information necessary to fulfill each
purpose will be collected and used.
This could happen in a store (e.g. when a purchase is made in a
specific store and then linked to a Pomellato profile), or when
contacting our customer services (why do you contact us? what means have
you used?) or when using our website (do you use tablets, phones,
computers? what use are you making of our website?).
Some personal information will be shared with us automatically
from the device or the service provider you are using (e.g. social
media). We can collect personal information shared by your device such
as your IP address, device type, unique device identification numbers
(device identifier), browser type, time zone settings, broad geographic
location (e.g. country or city-level location); online activity (such as
your internet and other electronic network activity information,
including, but not limited to, browsing history, search history, and
information regarding your interaction with websites, applications or
advertisements) and other technical personal information or personal
information shared by the service provider. Such service providers have
their own privacy and cookies policies, so remember that the personal
information you give them will be subject to their rules and not
ours.
In addition, we may be able to collect personal information on
how you have interacted with us, including certain personal navigation
information (including the pages accessed and links clicked, bugs and
errors, browsing patterns) and your preferences (such as your language
preference).
Some of this personal information may be collected using cookies
or other online advertising technologies.
Want to know more? You may be interested in the following
sections of our Privacy Policy:
When you interact with us, either online or in person, you may share
with us your personal information when:
You buy a product or subscribe to a service;
You create a Pomellato profile, join our loyalty scheme,
participate in a contest, join a reward program or link your social
media account to your Pomellato profile;
You subscribe to our newsletter;
You interact with us or seek advice and share personal
information through our websites, our social media pages, our sales
associates in a store or via chat, phone or video calls, at a trade
show, at events or through our customer services also through phone
calls, or you book an appointment via our website;
You use your device to browse activity across different
websites;
A personal shopper, or any other agent acting on your behalf
interacts with us in particular to buy a product or subscribe to a
service for you;
Your information is shared with us by our approved partners, with
your prior consent where required.
Want to know more? You may be interested in the following
sections of our Privacy Policy:
We mainly obtain information directly from you and process them by
automated means when you interact with us. When you interact with us,
either online or in person, we collect your personal information
through:
Our sales associates (in stores or via chat, phone or video call)
or our customer services (for example by phone or chat) when you share
personal information with us;
Our websites or our applications, whether you are registered or
not, by completing surveys, registration processes or forms. We may also
use cookies or other online advertising technologies for this
purpose;
Any means we make available to you - for example, when you buy a
product, we may collect certain personal information relating to your
payment such as the purchase price and date and product reference (we do
not keep any of your personal banking information for longer than
necessary to complete the transaction);
From third-party sources such as social media.
More broadly, we collect your personal information through any
means you may use to interact with our sales associates, whether in our
stores or through our customer services via phone, email, chat or text
message. Our sales associates or customer services may use various means
to collect your personal information during or after the
interaction.
In addition, we may obtain personal information from services
provided by other companies to update or supplement your personal
information, for example when you link your social media profile with
your Pomellato profile. These companies have their own privacy and
cookies policies in place, so remember that the personal information you
give them will be subject to their rules and not ours.
Want to know more? You may be interested in the following
sections of our Privacy Policy:
We mainly obtain information directly from you. From time to time, we
may also obtain information on you from third-party sources.
We will only gather such information when the third parties either
have obtained your consent or are otherwise legally allowed to share
such information. In certain limited circumstances, some third parties
may be required to disclose your personal information to us.
9. SHOULD
YOU ALWAYS SHARE YOUR PERSONAL INFORMATION WITH US?
You may not always be required to provide us with the personal
information that we are asking you for: any personal information that is
required is clearly marked as mandatory.
When you do not wish to share certain personal information with us,
you may simply not provide it to us, or opt-out of the processing of
your personal information when this option is offered to you.
However, if you choose not to provide certain personal information,
you may not be able to benefit from some of our services or to purchase
certain products for which the provision of such personal information is
necessary.
We may ask you to provide us with personal information to meet
certain legal requirements. In such cases, we will notify you in due
time and advise you as to whether your personal information is mandatory
or not (as well as of the possible consequences if you do not provide
your personal information).
Want to know more? You may be interested in the following
sections of our Privacy Policy:
10. FOR HOW LONG
DO WE KEEP YOUR PERSONAL INFORMATION?
We retain your personal information only for as long as it is needed
to fulfill the purposes for which it was collected. Please see
additional explanations below.
When you create a Pomellato profile, we are retaining your
personal information connected to such profile (as listed in the section
What personal
information do we collect?
) for 10 years from the last interaction
you initiated with Pomellato;
When you sign up exclusively to receive updates about Pomellato’s
new activities, exclusive products, tailored services, we retain your
personal information for 3 years from the last interaction you initiated
with us;
When you interact with our customer services, we retain the
recordings of the calls for 30 days (unless a longer retention period is
permitted by law). When we are unable to link your interaction to your
Pomellato profile, we will retain the other personal information you
share with us by e-mail, chat, text or instant message for 3 years after
this interaction with Pomellato.
Please note the above retention rules will not apply in the following
circumstances: (i) where we are legally required to retain your personal
information for a shorter or longer period (in such a case, we will
retain your personal information as long as this legal requirement is
applicable); or (ii) in case of an actual or reasonably potential
dispute (in such a case, we will retain your personal information until
said dispute concludes).
Last interaction shall be defined as the last contact you
initiated which is traceable by our systems or by one of our employee.
Last contact could be the last time a call, sales email, short message,
in-app message or meeting was proposed to you and to which you responded
favorably. For instance, clicking on a link included in an email (except
for a link to unsubscribe from receiving marketing content), having a
chat on our website or attending an appointment in one of our stores are
considered a last contact. Conversely, opening an email or visiting our
website without logging in would not qualify as last contact.
Before deleting your personal information from your Pomellato or
customer profile, we will contact you to inform you of such deletion and
you may ask us to keep your personal information. By not answering you
agree to the deletion of any personal information that we are not
legally obliged to keep for longer in accordance with legal, tax and
accounting requirements.
We will destroy your personal information without delay once it is
no longer necessary (e.g., if the purposes of collection/use of the
personal information have been accomplished, if the statutory retention
period expires) in a way that prevents such personal information from
being restored or recovered. If printed on paper, the personal
information will be destroyed by shredding, incinerating, or some other
similar methods and, if saved in electronic form, the personal
information will be destroyed by technical methods which ensure that the
personal information cannot be restored or recovered
thereafter.
In case of an actual or reasonably potential dispute, we may also
retain your personal information for longer according to the applicable
statute of limitations so that we have an accurate record of your
dealings with us in the event of any complaints or challenges.
It is also possible that certain information which we consider to
be important for Pomellato history or patrimony may be retained by us
for longer periods exclusively for archival purposes, for historical
purposes or for statistical purposes. This may be the case when some of
our notable customers have benefited from our services or bought our
products.
Additional information for South Korean
residents
:
We may retain certain personal information in accordance with the
following legal requirements:
Records on contracts and withdrawal of subscriptions: 5 years
(as required under the Act on Consumer Protection in Electronic Commerce
Transactions)
Records on consumer complaints and processing of disputes: 3
years (as required under the Act on Consumer Protection in Electronic
Commerce Transactions)
Records of log-ins: 3 months (as required under the
Protection of Communications Secrets Act)
Want to know more? You may be interested in the following
sections of our Privacy Policy
We,
Pomellato,
are strongly committed to keeping
your personal information safe.
To do so, we design our services with your safety in mind. Within our
group, we have dedicated teams managing and ensuring the security and
privacy of your personal information. We have adopted specific technical
and organisational security measures, in accordance with applicable laws
and regulations, to protect personal information against accidental or
unlawful destruction, accidental loss, alteration, unauthorised
disclosure or access.
For example, whenever personal information is passed between your
device and our servers, we ensure that it is encrypted using Secure
Sockets Layer (“SSL”) and/or other security methods. We implement Hyper
Text Transfer Protocol over Secure Socket Layer (“HTTPS”) in order to
protect your connection to our website. All your personal information is
stored on secured servers.
We have also established a specialised personal information security
management system. For example, we strictly control the scope of
authorisation of our employees who have access to the personal
information that we collect and process. We thus disclose or provide
access to your personal information only on a strict need to know basis
to our employees or to the third parties listed in the section
With whom do
we share your personal information?
, and only through secured
systems. We regularly review our information collection, storage and
processing practices, including physical security measures, to guard
against any unauthorised access and use.
We conduct security and privacy protection training courses and tests
on a regular basis to enhance our employees’ awareness of the importance
of protecting personal information. We take commercially reasonable
steps to make sure that our business partners and third-party service
providers are able to protect your personal information. Our employees
and those of our business partners and third-party service providers who
have access to your personal information are subject to enforceable
contractual obligations of confidentiality and specific contractual
privacy provisions.
In the event of a security incident resulting in any breach of
personal information, as qualified by law, we have an emergency response
plan in place to prevent the expansion of such security incidents. In
addition, we will report such personal information breach to the
relevant supervisory authority as required by applicable law, and inform
you via an appropriate channel as and where required by applicable
law.
Please also note that in order to keep your personal information
secure, we may from time to time, have to reset your password.
However, you should be aware that no service can be completely
secure, and you play a key role in keeping your personal information
safe. For the best possible protection of your personal information
outside the limits of our control, your devices should be protected
(e.g. by updated antivirus software) and your internet service providers
should take appropriate measures for the security of personal
information transmission over the network (e.g. with firewalls and
anti-spam filtering). You accept the inherent security implications of
interacting over the Internet and will not hold us or our partners
responsible for any security incident or breach of personal information
unless it is due to our negligence.
If you have any concerns that your personal information has
been put at risk, for example if someone could have found out your
password, please contact us as soon as possible.
Want to know more? You may be interested in the following
sections of our Privacy Policy:
12. WHERE DO
WE TRANSFER & STORE YOUR PERSONAL INFORMATION?
We operate globally and may transfer your personal information to
other companies within Kering or to approved partners in locations
around the world. We want you to have the best service and customer
experience, whether online or in person all over the world. For this
purpose, we may have to share your personal information outside the
country where you have first shared it with us. When we do so, it will
always be for the purposes described in this privacy policy and where we
are satisfied with the levels of protection and security implemented in
compliance with applicable privacy legislation. This sharing of your
personal information is necessary to enable us to perform the contracts
we have with you or take steps at your request, prior to entering into a
contract, in order to offer you a global customer experience.
The personal information we collect from you will be mainly stored in
servers located in the European Union, United States and Switzerland,
where it will be afforded the level of protection required by applicable
privacy legislation. However, this may vary depending on the country in
which the information is collected or applicable legislation. For more
information about the location where your personal information is
stored, you can contact us at
privacy@pomellato.com
(or
see
How can you contact us?
)
Your personal information will be mainly stored in servers
located in the People’s Republic of China, the European Union, the
United States and Switzerland if you are a Chinese customer or if your
personal information is collected in the People’s Republic of
China.
You will be considered as a Chinese customer if the personal
Information you provide us is mainly linked to China Mainland (for
example, your primary address is in the People’s Republic of China, your
phone number is a Chinese phone number, you shop on a Chinese dedicated
website or e-commerce channel such as the WeChat mini program or if you
inform us that your country of residence is China Mainland)
When we share, use or transfer personal information from China,
we, according to Chinese privacy law and applicable cross-border
assessment regulation, will conduct the assessment and ensure these
activities are compliant. Our parent company Kering S.A is the receiver
of your personal information transferred to European Union and
Switzerland. The contact of Kering S.A is 40 rue de Sèvres, 75007 Paris,
France or you can contact us via email address at
privacy@kering.com.
Personal information we collect from you in the Russian
Federation or if you are a Russian resident may also be stored in
servers located in the Russian Federation and may be transferred outside
the Russian Federation in compliance with applicable
legislation.
You should be aware that personal information stored outside the
country where it was collected may be available to government
authorities of the countries where it is stored, under applicable data
disclosure laws of those countries.
We want to ensure that your personal information is always safely
used and available to you, wherever you want to access it and for
whatever reason you wish to use it.
When we share, use, or transfer personal information outside the
country in which the information is collected, we will put in place
appropriate measures to legitimize such transfer under applicable
privacy legislation, which may include, as applicable, obtaining your
consent or implementing adequate contractual safeguards. In particular,
if we transfer your personal information from the European Union or
Switzerland to a country for which no adequation decision has been
adopted by the relevant authorities, we use standard contractual clauses
approved by the relevant authorities (such as European Commission). You
can contact us at
privacy@pomellato.com
(or see
How can you
contact us?
) for more
information about these safeguards including how to obtain copies of
this information.
Want to know more? You may be interested in the following
sections of our Privacy Policy:
13. WITH WHOM DO
WE SHARE YOUR PERSONAL INFORMATION?
We may share and disclose your personal information for business
purposes with the categories of recipients listed below. We may also
receive personal information about you from some of them as our
third-party sources. The processing of personal information by such
third parties relies on the legal bases listed for the relevant purposes
in the section
Why do we collect
your personal information?
(or the relevant appendix for your
jurisdiction). If you would like more information about the sharing of
your personal information, including the list of recipients, please
contact our privacy team and Data Protection Officer at
privacy@pomellato.com
(or see
How can you contact us?
)
A. Approved partners acting as service providers
To use your personal information, we rely on approved partners.
All approved partners are bound by an obligation to implement
appropriate security measures to protect personal information in their
possession and bound by a strict confidentiality agreement and specific
contractual provisions on “
how
” and
“
when
” they are allowed to collect and use your
personal information. Your personal information may be accessible to the
following authorised personnel on a need-to-know basis:
Kering and other affiliates of our group
Our parent company Kering and its affiliates are our main
approved partners. They will have access to your personal information
but will never use it in contradiction to this privacy policy.
Kering and its affiliates enable us to: offer you our products
and services (e.g. via wholesale management and sales processes);
provide you with our customer service (e.g. responding when you contact
us by phone, mail, text message, chat or social media); manage your
Pomellato profile (e.g. by keeping your information safe and performing
IT-related functions attached to your Pomellato profile); and, through
shared services, to manage and better understand our business.
These partners mainly enable us to provide you with the products
and services you have requested (e.g. ensuring your bank can proceed
with payment, or delivering a product you have purchased on our
website).
For sake of clarity, please note that such partners also carry
out processing activities in parallel for their own purposes, acting
then as data controllers (see Approved partners acting also on their own
account below). In this respect, our privacy policy does not extend to
the processing activities carried out by these partners where the latter
are acting on their own account, as data controller for the performance
of their services.
This can be the case when payment services provider carries out
fraud detection processes. These other companies have their own privacy
policies in place, so remember that the way they use any personal
information you give them will be subject to their rules and not
ours.
They can also be involved in creating and/or managing your
Pomellato profile (e.g. collecting your personal information and consent
on our behalf so that we can set up your profile, linking your purchase
to your Pomellato profile so you can easily find it again, or providing
your personal information when you access your Pomellato
profile).
Marketing services, advertising providers, communication (email,
SMS, MMS) providers
They help us manage your Pomellato profile, provide you with
relevant information, updates, and tailored marketing content (e.g. by
sending you emails based on your previous purchases or on sweepstakes,
contests and advertisements you have browsed), and send you
non-marketing communications. We may also use postal delivery providers.
They enable us to send you any communication and marketing content (e.g.
letters and event invitations).
IT service providers
These partners enable us to:
Provide you with the products and services you have requested
(e.g. by managing our e-commerce website and our applications, etc.) and
manage your Pomellato profile (e.g. by making sure it is available at
any time when you interact with us, and linking your purchases to
it);
Provide you with relevant customer service (e.g. by allowing
you to use chat services);
Send you relevant information, updates and marketing content
(e.g. by sending you tailored emails, SMS, MMS, chat messages
etc.);
Send you non-marketing communications (e.g. by emailing you
to verify your identity when you sign up);
Undertake transactions securely (e.g. by identifying
potential behaviour that could be a threat to your personal information
or guarding against third-party misuse of your payment details to
purchase products);
Assess and better understand our business (e.g. by providing
personal information visualisation tools); and
Optimise and manage our website and other means of
communication (e.g. by ensuring that our website is always available
based on your browsing habits).
Audit, law firms and similar corporate professional service
providers, data analysis providers
These partners enable us to better understand and conduct our
business (they include accountants, lawyers and auditors who may need to
use your personal information). In addition, data analysis providers may
enable us to provide you with relevant information, updates and
marketing content (e.g. by analysing your answers to a survey, providing
insights and helping us to analyse trends and improve our products and
services).
B. Approved partners acting also on their own account
To use some of your personal information (see “
Why do
we collect
your personal information?
”), we rely on approved partners. Certain
approved partners may be able to determine “why” and “how” your personal
information is used.
Social networks
We manage our fan pages on the social networks listed below, a
social network operated by our services. We use our fan pages to inform
our community about our company, our products, our services and our
offerings, as well as about current developments and to communicate with
our users. You can send us messages, as well as share, comment or "like"
our messages. We process the profiles of users of our products and
services (in particular the user's name) and our interactions with them
(for example the content of messages or comments) to process the
information requests they submit and respond to their questions. The
legal basis for such data processing is the provision of the services
requested by the user concerned on social network, or if your country of
residency doesn’t acknowledge the performance of a contract as a valid
legal basis, then please consider that the actual legal basis is your
consent when interacting with us via our social networks.
We may also use statistical functions provided by social networks
on how our users use our fan page. These data statistics are based on
personal data collected during a user's visit, or on the user's
interaction with our content. Our legitimate interest in this regard is
the improvement and optimization of our fan page, which is also in the
interest of our users, or if your country of residency doesn’t
acknowledge legitimate interest as a valid legal basis, then please
consider that the actual legal basis is your consent when interacting
with us via our fan page.
Lastly, social networks enable us to provide you with relevant
information and updates, marketing content (e.g. advertisements based on
look-alike profiles) and relevant customer service (e.g. when you use
social media to contact us). Please be aware that they have their own
privacy and cookies policies in place, so the personal information you
give them will be subject to their rules and not ours.
Retailers (including online), resellers, franchisees and
licensees
Certain points of sale, carrying out their business under the
Pomellato name, may act as independent data controllers and are able to
determine “why” and “how” they use the personal information you share
with them. Please be aware that our privacy policy does not extend to
services provided by other companies on their own account. They have
their own privacy policies in place, so remember that any personal
information you give them will be subject to their rules and not
ours.
C. Actual or potential buyers as part of a business
transfer
We may disclose your personal information to an actual or a
potential buyer (and its agents and advisers) in relation to any actual
or proposed divestiture, merger, acquisition, joint venture, bankruptcy,
dissolution, reorganisation, or any other similar transaction or
proceeding in compliance with applicable laws and regulations. Where
this is required, we will take steps to minimise any data that is
shared.
D. Law enforcement body, regulatory body, government agency, court,
lawyers to comply with laws and defend our rights and interests
We may disclose your personal information to any competent law
enforcement body, regulatory body, government agency, court or other
third party where we believe disclosure is (i) required as a matter of
applicable law or regulation, (ii) necessary to exercise, establish or
defend our legal rights, or (iii) necessary to protect your interests or
those of any other person, and on the legal basis set out in this
privacy policy.
Where this is required, we will take steps to
minimise any data that is shared.
E. At your request or for our legitimate interest or compliance
with laws and regulations
We may disclose your personal information to any other person:
with your consent; where we have an overriding legitimate interest (on
balance with your interests) to do so; or where we have a legal or
regulatory obligation to do so.
Want to know more? You may be interested in the following
sections of our Privacy Policy:
Protecting the safety and privacy of children is very important to
us.
By creating your Pomellato profile, or by registering through any
means, or by placing an order, you confirm that you have reached the age
of consent in your country of residence (or, if you are under the age of
consent, that your parent(s) or legal guardian(s) also agree(s) to such
registration or order when they can give you such authorization under
the law of your country of residence).
If we become aware (including through a request from your parent(s)
or legal guardian(s)) that we have inadvertently received personal
information in contradiction to the above, we will delete such personal
information from our records.
If you are a minor, and have created a Pomellato profile, we may
collect the categories of personal information mentioned in the section
What personal
information do we collect?
,
and use your personal information
for the purposes listed in the section
Why do we collect
your personal information?
,
unless prohibited by applicable
laws. You, or your parent(s) or legal guardian(s), when permitted or
required under the laws of your country of residence, may exercise over
your personal information the rights listed in the section
What
are your rights regarding your personal information?
Want to know more? You may be interested in the following
sections of our Privacy Policy:
15. WHAT
ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?
Subject to your applicable privacy legislation, you may be entitled
to one or more of the following rights and exercise them on your own or
via a legal representative acting on your behalf. We,
Pomellato
, are committed to protecting your rights and
allowing you to exercise them. You will never be discriminated against
when you exercise your right in good faith under any applicable privacy
law.
If you need any further information regarding your rights, how to
exercise any of your rights, or if you have any complaints or questions
regarding our privacy practices, please contact our privacy team and
Data Protection Officer at
privacy@pomellato.com
or by
completing the form available
here
(or see
How can you contact
us?
).
Under certain circumstances you may have the right to request
access to and obtain a copy of any of your personal information that we
may hold. Such right of access also includes the right to receive
information in particular about the purposes of the processing, the
categories of personal information concerned, the categories of
recipients to whom your information may be disclosed, and the envisaged
period for the retention of your information.
You may also request correction of any inaccurate personal
information relating to you and to request the deletion of your personal
information. You can see and update most of this personal information
yourself online, or by contacting our customer services, or by emailing
our privacy team at
privacy@pomellato.com
or by
completing the form available
here
(or see
How can you contact
us?
).
Specifically, subject to your applicable privacy legislation,
your right of access may include:
the right to request whether and how your personal
information is processed and whether it has been shared with a third
party in the preceding 12 months, in particular if you are an Aruban
resident.
the right to obtain information about the existence of your
personal information in our information system, the owner or operator of
your personal information, the sources from which your personal
information has been obtained (and proof of the legality of the method
of collection of such information), the purposes, timing and methods of
processing of your personal information, including the persons who may
have access to such information and the information systems with which
your personal information may be exchanged, the legal justification for
and legal consequences resulting from the collection, processing and
transfer to third parties of your personal information, and where
applicable the existence of a compliance certificate and completion of
the state examination of the information system in which your personal
information is recorded, in particular if you are a resident of
Azerbaijan.
the right to obtain confirmation that we process personal
information about you, to request information about the public and
private entities with whom we have shared your personal information, and
to request information about the possibility of denying consent and the
consequences of such denial, in particular if you are a Brazilian
resident.
if we cannot satisfy your request for correction, the right
to request that a statement of correction be attached to your
information noting that a correction has been sought but not made, in
particular if you are a resident of New Zealand.
the right to be informed of any disclosure of inaccurate
personal information about you, in particular if you are a resident of
Qatar.
B. Right to withdraw consent
Where processing of your personal information is based on your
consent, you have the right to withdraw it at any time. For example, if
you no longer wish to receive electronic marketing communications, you
can change the settings in your Pomellato profile, use the ‘unsubscribe’
link provided in our emails, text the STOP number in our text messages,
or contact us directly and we will stop sending you communications.
Please note that the withdrawal of your consent will not affect the
lawfulness of processing based on your consent as carried out before
such withdrawal.
Under certain conditions, you may have the right to receive
personal information you have provided to us within a structured,
commonly used and machine-readable format, and also to require us to
transmit it to another data controller where this is technically
feasible.
D. Right to restriction of processing
Subject to privacy legislation applicable to you, you may have
the right to restrict our processing of your personal information in
particular where:
you contest the accuracy of the personal information (until
we have taken sufficient steps to correct or verify its
accuracy);
the processing is unlawful, but you do not want us to erase
the personal information;
we no longer need your personal information for the purposes
of the processing, but you require such personal information to
establish, exercise or defend legal claims; or
you have objected to processing that has been justified on
legitimate interest grounds, pending verification as to whether we have
compelling legitimate grounds to continue processing.
Where personal information is subject to restriction in this way,
we will only process it with your consent or to establish, exercise or
defend legal claims, in accordance with local legislation.
Specifically, subject to your applicable privacy legislation,
your right to restriction of processing may include:
the right to apply for the transfer of your personal
information to an archive, and the right to demand a ban on the
collection and processing of your personal information, in particular if
you are a resident of Azerbaijan.
the right to request the anonymization, blocking or deletion
of any unnecessary or excessive personal information or personal
information processed unlawfully, in particular if you are a Brazilian
resident.
the right to request us to stop transferring your personal
information to a third party, in particular if you are a Vietnamese
resident.
E. Right to object to processing
Where we rely on legitimate interest to process personal
information, you may have the right to object to that processing. In
this case, we must stop using your personal information for that purpose
unless we can either demonstrate compelling legitimate grounds for
processing that override your interests, rights and freedoms or where we
need to process the personal information in order to establish, exercise
or defend legal claims. Where we rely on legitimate interest as a
justification for processing, we believe that we can demonstrate such
compelling legitimate grounds, but we will consider each case on an
individual basis.
Where your personal information is processed for direct marketing
purposes, you may also have the right to object to this at any time.
This includes profiling to the extent that it is related to such direct
marketing. For example, if you wish to object to receiving electronic
marketing communications, you can change the settings in your Pomellato
profile, or use the ‘unsubscribe’ link provided in our emails, or text
the STOP number in our text messages, or contact us directly and we will
stop sending you communications.
To exercise rights on behalf of a deceased individual, you may be
required to provide us with proof that you are an immediate family
member or executor of the deceased person. Subject to applicable privacy
laws, we may not be able to support your request. Please be informed
that under certain laws (for example in France), you can define
directives relating to the storage, erasure and communication of your
personal information after your death.
G. Right to lodge a complaint
You also have the right to lodge a complaint with your local
supervisory authority if you consider that the processing of your
personal information infringes applicable law.
If you are a resident of a Member State of the European Economic
Area, you may refer to the list of data protection authorities in the
European Economic Area available
here
. If
you are a resident of Qatar, you may contact your data protection
authority, the Compliance and Data Protection (CDP) department, through
the channels listed
here
.
Under applicable legislation, you may have the right to bring
complaints relating to the processing of your personal information
before civil courts.
H. Modalities of response to your requests, additional information
or assistance
If you need any further information regarding your rights or how to
exercise any of your rights, or if you have any complaints or questions
regarding our privacy practices, please contact our privacy team and
Data Protection Officer at
privacy@pomellato.com
or by
completing the form available
here
(or see
How can you contact
us?
).
To help protect your privacy and maintain security, we will
take steps and may require you to provide certain information to verify
your identity before granting you access to your personal information or
complying with your request.
Where permissible under applicable law, we reserve the right to
charge a fee for instance if your request is manifestly unfounded or
excessive, to cover the administrative costs incurred by your request.
We will endeavour to respond to your request as soon as possible and in
any case within the applicable timeframe.
In certain jurisdictions (such as if you are a Californian
resident), if you ask us to provide you with specific pieces of personal
information, we will require you to sign a declaration under penalty of
perjury that you are the person whose personal information is the
subject of the request.
If you designate an authorised agent to make an access, deletion
or opt-out of sale request on your behalf (a) we may require you to
provide the authorised agent written permission to do so, and (b) for
access and deletion requests, we may require you to verify your own
identity directly with us.
Want to know more? You may be interested in the following
sections of our Customer Privacy Policy:
We may occasionally make changes to this privacy policy, for example
to comply with new requirements imposed by applicable laws or technical
requirements. We will post the updated privacy policy on our website. We
therefore encourage you to review this page every so often.
We may also notify you in case of material changes and, where
required by applicable law, we will seek your consent to those
changes.
If we wish to process your personal information for a new purpose not
described in this privacy policy, where necessary we will inform you and
where required we will seek your consent.
Want to know more? You may be interested in the following
sections of our Privacy Policy:
17. DO
WE USE COOKIES OR OTHER ONLINE ADVERTISING TECHNOLOGIES
We use cookies to personalize content and ads, to provide social
media features and to analyze our traffic data. We also share
information on your use of our site with our social media, advertising
and analytics partners. You can read more about any of our purposes or
the vendors that we use by clicking on ‘Cookie Settings.’ This
preference center is accessible at any time through the ‘Cookie
Settings’ button located on every page.
When you visit any website or use an application, it may store or
retrieve information using your browser, mostly in the form of cookies.
This information might be personal information about you, your
preferences or your device and is mostly used to make the site work as
you expect it to. The information does not usually directly identify
you, but it can give you a more personalized web experience. Because we
respect your right to privacy, you can choose not to allow some types of
cookies.
At any time, you have the option to accept or decline the use of
cookies using the on/off settings of the preference center, by clicking
on the button below:
1. What is a cookie?
A cookie is a small piece of data (text file) that a website –
when visited by a user – asks your browser to place on your device in
order to remember information about you, such as your language
preference or login information. Those cookies are set by us and are
called first party cookies. We also use third-party cookies – which are
cookies from a domain other than that of the website you are visiting –
for our advertising and marketing initiatives.
2. Why do we use cookie?
Cookies are used for various purposes, such as allowing the user
to navigate between pages seamlessly, implementing the user’s
preferences and improving their overall browsing experience, by
customising the content according to their navigation and user profile
as a Pomellato customer. They can also help ensure that the adverts seen
online by the user are more relevant to them and their
interests.
3. What types of cookies do we use?
We use several types of cookies which have different durations.
In particular we use:
Session cookies, which only last for the duration of a
browsing session and facilitate your experience on our website;
and
Persistent cookies, which last for more than one visit and
memorise your preferred settings regarding our website.
These cookies can also be categorised as follows, depending on
who sets them:
First party cookies, which are supplied by the publisher of
the website you are visiting, so that it functions
properly.
Third party cookies, which are set on the website by third
parties, and are intended to collect data in different ways and for
several purposes, for example: collection of analytics data and
information on social interactions and behaviours, and also for
promotional activities.
4. What categories of cookie are on our website?
The types of cookies used on our website serve different purposes
and can fall into one of the categories below. Please to the Preference
center to see what type of cookies is relevant.
Strictly necessary cookies
These cookies are necessary for the website to function and
cannot be switched off in our systems. They are usually only set in
response to actions made by you that amount to a request for services,
such as setting your privacy preferences, logging in or filling in
forms. This allows us to authenticate and record your sessions, to
secure traffic or to detect certain malicious activities. For the
website, you can set your browser to block or alert you about these
cookies, but some parts of the website will then not work. These cookies
do not store any personally identifiable information.
Performance & analytics cookies
These cookies allow us to collect behavioral data and determine
traffic sources, so we can
Measure the traffic on the website. They help us to find out
which pages are the most and least popular and see how visitors move
around the website by distinguishing users and sessions, determining new
sessions/visits and counting the number of pages viewed in the current
session and the recording type. We will also track the traffic source or
campaign that explains how you reach our website, via which partners for
example, to measure the impact and the effectiveness of our partnership
with other merchants or our advertising campaign.
Understand by who and how our site is used. Performance and
analytics cookies are also used to rationalize traffic counting and user
behavior across several platform integrations. They allow us to store
visitor custom variable information, test different versions of our
website or our content, and allow third-party providers helping us
analyze and optimize our content.
In order to obtain accurate analytics while enabling you to make
your choice regarding the use of cookies and other tracking tools, we've
implemented a dedicated solution allowing us to record and counting your
preferences. If you prefer not to be tracked, this system will help us
complete our analysis and reports by looking at other users similar to
you. This information doesn't let us know who you are or keep tracking
your browsing on our website.
Functionality cookies
These cookies enable the personalization of website content by
recognizing you and remembering your preferences. They may be set by us
or by third-party providers whose services we have added to our pages.
If you do not allow these cookies, some or all of these services may not
function properly.
Profiling and targeting cookies
These cookies may be set through our website by us or our
advertising partners. They may be used to build a persona based on your
navigation and your interests to personalize your experience by
providing adapted content, features and products or show you relevant
advertisements on other sites. We may also use the information collected
through these trackers to push advertisements, on partners' websites or
social networks, to people who can share the same interests as
you.
They do not directly store personal information but are based on
uniquely identifying your browser and devices.
If you do not allow these cookies, you will experience less
targeted advertising.
Social cookies
These cookies are set by a range of social media services that we
have added to the site and which enable you to share our content with
your friends and networks. They can track your browser across other
sites and build a profile based on your interests. This may influence
the content and messages you see on other websites you visit. If you do
not allow these cookies, you may not be able to use or see these sharing
tools.
Chat feature cookies
These cookies are necessary for the activation of the chat
functionality allowing us to locate you, to put you in contact with our
teams and to give you the possibility of exchanging with us (via chat or
video calls). This use will be associated with a monitoring of your
experience on the site (including a live monitoring of your navigation
on our site or mobile application) allowing us to assist you as best as
possible and to recommend the products that best meet your expectations
and preferences. If you do not accept these cookies, the chat
functionality will not be accessible.
5. How to customize your cookie settings
When you first visit our website, you are required to accept or
decline the use of cookies before proceeding. At any time, you have the
option to accept or decline the use of cookies using the on/off settings
of the preference center, by clicking on the ‘Cookie Settings’ button
located on every page:
Because we respect your right to privacy, you can choose not to
allow some types of cookies by using our Cookie Settings. Click on the
different category headings to find out more and to change our default
settings. Please note that blocking some types of cookies may affect
your experience of the site and the services we are able to
offer.
If you prefer, you can set your browser to reject cookies. If you
use multiple browsers (e.g. Internet Explorer, Microsoft Edge, Google
Chrome, Firefox, etc.), you must repeat this procedure for each one, and
if you connect to the web from multiple devices (e.g. from work and at
home), then you will need to set your preferences on each browser on
each device.
Please note that if you completely disable cookies from the
browser, some of the functionalities might be lost, for example, normal
browsing of the site and purchasing activity, while any personalised
activity such as the advertising you receive when you visit this website
will not be tailored to your interests.
For more information on third-party cookies (e.g. advertising or
targeting cookies) and how to disable them directly from the browser
instead of through Cookie Settings , we invite you to read the relevant
privacy policy and opt-out guidelines which can be found here:
https://www.youronlinechoices.com/
6. Do we share data collected through cookies?
We may collect information on our website through cookies and
share it with third parties such as social networks or advertising
platforms, as well as other companies within Kering, advertising
agencies/providers and IT providers (e.g. hosting providers), with your
consent where required.
7. Do we sell your personal information?
Sale of your personal information
If you choose to enable third party cookies via Cookie Settings,
third parties (such as approved analytics and advertising partners) will
collect your personal information via automated technologies on our
websites, primarily in an effort to provide you with content and
advertisements that may be of interest to you and on the legal bases set
out in this privacy policy.
The choice is
yours
.
You may elect not to send your personal
information to them at any time.
Please note that deciding not to share your information via third
party cookies does not mean you will stop seeing ads, but these ads will
not be tailored to you based on information derived from your activities
on our websites.
Please also note that depending on your selection, we may still
share your information in ways that are not a “sale” or “sharing” under
applicable U.S. state law, such as with our service providers, for our
own online advertising purposes.
If you are a California resident you also have the right to
submit a Shine the Light Request, which means you may request that we
provide you with a list of certain categories of personal information we
have disclosed to third parties for their direct marketing purposes
during the immediately preceding calendar year, as well as the identity
of those third parties. Any such disclosures will be made consistent
with your choices in Cookie Settings. You may contact us at the
information below for a listing.
8. How to contact us
If you have any questions regarding our privacy practices or how
we handle your data, please contact our privacy team and Data Protection
Officer by sending an email to
privacy@pomellato.com
or
by completing the form available
here
(or see
How can you contact
us?
).
18. HOW CAN YOU CONTACT US?
If you have any questions regarding our privacy practices or how we handle your information, please contact our privacy team and Data Protection Officer by sending an email to privacy@pomellato.com. or by using the form available here.
Californian residents may also call our toll-free number: [800-254-6020].
APPENDIX
1 - Specific information for Australian residents ABOUT THE USE OF YOUR
PERSONAL INFORMATION
Pomellato will collect, hold, use and disclose your personal
information for the following primary purposes.
A. To provide you with the products and services you have purchased
or otherwise requested
We will use your personal information to manage our relationship with
you and to perform our obligations under the contract you conclude with
us when you purchase or otherwise request products or services from us.
This can cover various activities such as internal accounting,
processing your payment or delivery.
To provide you with the products and services you have requested,
we will access, collect, store and use your personal information for
invoicing, payment management and internal accounting.
Some of the operations mentioned above can be implemented by
partners of ours as identified in section “
With
whom do we
share your personal information?
” in particular the registration,
payment and delivery of your order. Your information may be
communicated, used or collected directly via the information system of
our partner.
Certain specific information may be required to provide you with
gift cards, customization services, or when you reserve a product or a
service, request the repair of a product, or purchase products or
services by phone, or on our website or a marketplace. In such cases, we
could access, collect, store and use your personal information for
delivery, warehouse and return management.
During your visit to our store, we may need to collect your
information in order to allow you to access our premises or when you
wish to obtain a particular service: request for tax on products or in
connection with our after-sales service, etc.
B. To manage your Pomellato profile.
Once you have requested us to create your Pomellato profile, via
Pomellato websites or any other means, including our customer service,
your personal information will be linked to this profile, where we will
keep all the information we have on you. This could include personal
information we obtain directly from you as well as from other sources in
accordance with applicable legislation. This could also include
information about the purchases made when checking out as a guest or
when checking out using a profile. The information in your Pomellato
profile is crucial to provide you with the Pomellato personalized and
tailored experience, and in some cases is necessary in order to access
to some specific services or to purchase from our website, and thus it
needs to be kept up to date for the best experience.
Once you have asked us to create your Pomellato profile, we will
supplement it with personal information such as your purchases,
preferences and contact details. In this context, please be aware that
we use personal identification information, such as your email address
or phone number, to link an interaction or a purchase with your
Pomellato profile. This also applies when checking-out as a guest on our
website when making a purchase, as mentioned above, or in case you bind
your social media open ID account with your Pomellato profile (by using
dedicated QR Codes for example). In addition, we may use your date of
birth to determine that you are old enough to use our services.
In order to keep your personal information accurate, we will take
every reasonable step to ensure that personal information we hold is
properly updated. Subject to your applicable privacy legislation you may
have the right to have your information rectified at any time, and in
event please let us know if any of your information needs updating or
correcting, and we will make our best efforts to detect and correct
inaccurate personal information (data cleansing) and delete any
duplicated dataset. This may require us to correct typographical errors
or inconsistent personal information.
C. To provide you with tailored customer service and
assistance.
You should have the same unified experience no matter how we
communicate. Whether this happens in our stores, on our website, by
chat, by phone or by video, and whether you contact us or we contact
you
,
we want to provide you with relevant and tailored customer
service.
For this purpose of providing you the Pomellato experience, we will
collect, store and use your personal information to be able to identify
you. This will allow us to provide you with the tailored assistance you
are asking for or to share relevant information with you. In addition,
when you contact us, we may retain the personal information you share
with us to always provide you with such a customised and personalised
experience. This could happen if you are an existing or potential
customer. Your personal information will be linked to your Pomellato
profile, if you have requested us to create one, or to a temporary
record.
To provide you with a smooth and enjoyable customer experience, know
you better to provide you with tailored answers, and to improve the
quality and security of our services, we may rely on your consent,
proceed in accordance with our contract with you, or take all reasonable
steps to enter into a contract with you, or rely on our legitimate
interest to improve our services.
We will use the information we have about you to try to identify
you when you contact us (whether by phone, video chat, text message,
chat, social media, etc.). When we can identify you, we will be able to
access personal information available in your Pomellato profile or in
your temporary record, to know when you have previously interacted with
us and to provide you with the tailored assistance you are asking for.
This could include real-time or subsequent monitoring of your
interaction with us (for example on our website or in a store) to
identify the products you are looking at or what could be your specific
need.
To provide you with adequate customer service, you may be asked
if you need further assistance when you are on our website or in a
store. On our website, if you do not want to be contacted, kindly close
the chat navigation window. This service was implemented for you to
enjoy the same service as in one of our physical stores.
If we are not able to identify you, we may create a temporary
record to allow you to have a unified purchase experience. Indeed,
however you interact with us, we will do our best to avoid asking you
again for information you have already shared with us.
Your personal information, in particular your Pomellato profile
if you have created one or the temporary record we may create about you,
could enable our sales associates to contact you directly in relation to
the products and services you have purchased or otherwise requested,
such as when a product becomes available again or when an order you have
placed has been received in store, or to share with you any other
information you have requested from us. In addition, the monitoring of
our interaction (including, with prior notice to you, via voice or video
recording – such as real time listening or analysis – or listening in
real time,) enables us to improve the quality and safety of our services
and to provide you with tailored answers.
All our customers are important to us. However, some of our
customers and potential customers benefit from a more personalized
experience due to the important relationship they keep with Pomellato.
Our teams may need to collect and gather information on such customers
or potential customers in order to identify personalities who correspond
to the image and values of Pomellato to offer them unique support. This
may be the case when you participate in one of our selective projects or
when our Sales Associates offers you to participate in events or
contacts you for certain special occasions (for your birthdays or for a
particular event of your life).
D. To enable you to receive relevant information and tailored
marketing content.
You will receive information and updates about us You will receive
information and updates about us either at your request (with your prior
consent where required by law) or when we are authorised by law to send
you such information and updates directly, for instance after a
purchase. Such communication can be global or local, and may include
updates about our products and services, notifications, invitations to
events, offers, surveys, etc.
Our communications will be customised and specifically designed to be
of interest to you, and will be updated with any new personal
information linked to your Pomellato profile. We will thus use your
personal information to send you tailored communications or other
customised advertisements or marketing campaigns. This use of your data
includes some profiling activity.
When you share your contact information with us, we may use this
personal information to contact you through related communication
channels (such as text message, MMS, e-mail, post, internet means,
social media or telephone), with your consent where required. You can of
course request us not to use a particular channel of communication or
opt-out (unsubscribe) from it by applying the opt-out option that will
always be shared with you. If you want to stop receiving communication
from us via all communication channels, please send an email to
privacy@pomellato.com
As part of the
Pomellato experience
, we will always try
to customise and personalise your experience with us. This is why we
will use your personal information to send you tailored communications
or personalise your journey with us, but only with your prior consent
where it is required under applicable privacy legislation. Our
communications could include tailored product recommendations we think
you might like, personalised marketing content designed to suit your
interests, personalised events invitations or, at your request and where
available, personalised and customised products. For these purposes, we
will use the information you provide to us (for example your date of
birth, your country of residence, your preferred means of contact, etc.)
and/or jointly or independently, certain patterns we may observe when
interacting with you (for example where you prefer buying our products,
what type of products you like, which occasions you are shopping for,
etc.). With this information, we may create groups of similar customers
(called “persona”) to whom we can decide to offer personalised content
and experiences both in inbound or outbound interactions. In this
context, we may make inferences about you, as derived from your personal
information (
profiling
). For example, if you always
purchase our products from the same store (specific location or online),
we may consider this store as your preferred one. This will allow us to
customise your experience with Pomellato based on your interests and
shopping habits (i.e. tailored communication).
In order to
provide you with such customised and personalised experience, in our
stores or online, you may be required to log in or identify
yourself.
To enrich your personal information, we may use
cookies
or other online advertising technologies
. Via such technologies, we
will collect personal information related to your activities on social
media and your browsing activity across different websites and devices
(for example: to know if you have visited our website after opening a
newsletter you have received). Certain technologies may rely on services
provided by other companies acting on their own account (such as social
media WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter, Instagram,
or other online platforms). These companies have their own privacy and
cookies policies and the way they use the personal information you share
with them will be subject to their rules and not ours.
Personal information linked to your Pomellato profile (your
identification personal information such as your e-mail address, phone
number, social network id, etc.) will enable us to reach you on
third-party platforms or to create “lookalike campaigns”, allowing us to
find new people who are likely to be interested in our products because
they may be similar to you. We may conduct such campaigns through our
website, social media or other communication means such as search
engine. When this kind of campaigns are conducted, before it is shared,
your personal information is hashed and turned into short fingerprints
that cannot be reversed.
Using
cookies
or other online advertising technologies
may also enable us to show
you online advertisements that are “contextual” (meaning they are shown
according to the webpage you are browsing), or “behavioural” or
“interest based” (where advertisements are shown to you based on your
interests which we have inferred from your information including
demographic, geographic and interest-based data). We may use such
advertisements to display products or services that are most relevant to
you.
If you no longer want to see customised online advertisements,
you may request us to delete your Pomellato profile or modify your
cookie preferences – see “
cookies
or other online advertising technologies
”. In addition, some
third-party sites allow you to stop seeing advertisements from specific
advertisers, so you may also set your preferences on those
websites.
E. To send you non-marketing communications.
Non-marketing communications may be sent upon your request, and/or
may be important for your safety and the security of your personal
information.
You may still receive such communications even when you opt-out from
certain marketing communications. The information communicated may be
necessary for the correct performance of our contract with you or be
mandatory to comply with some of our legal obligations.
Non-marketing communications can include, but are not limited to:
emailing you to verify your identity when you sign up to our services;
emailing you for password and/or username reset; notifying you that a
particular service has been or will be suspended for maintenance or
terminated; notifying you of an upgrade, a rectification or an incident
affecting our services that may involve your personal information;
notifying you of an update to our privacy policy or Terms of Use; or
informing you about any products or services you have requested or
purchased.
We will never contact you to ask for your password. Please be
aware if you receive any request for this personal information.
F. To manage our social networks
Pomellato manages “Fan” pages available on several social networks.
We may need to process the information made available by the different
platforms or when you interact with our pages and publications.
When, as a user, you decide to interact with our social media
pages (e.g. when you follow one of our pages, when you click "Like" on
Facebook or "Follow" on Instagram or add a reaction to a post, when you
"share" or add a "comment", etc.), we have access to public information
in your profile. Your information is used for the purpose of interacting
with you through the social network in question or to establish analyzes
or statistics on the use of our pages or on the performance of our
communications. Our services may remove your comments if they do not
comply with our policies on the use of social networks (e.g. if your
comments are insulting, illegal or malicious).
When you visit our “Fan” page, when you do not have an account or
are not logged in to the relevant social network, we do not collect any
personal information about you, except for the aggregated data provided
to us by each social network.
G. To conduct our business securely and protect our activities and
personnel.
To deliver our products and services safely to you, perform our
contract properly or comply with some of our legal obligations, we will
implement fraud prevention and detection measures. Such measures will
allow us to adequately perform our contract with you and/or protect our
legitimate interests in defending ourselves against fraud. We may
notably implement measures to ensure that you are complying with our
terms and conditions for sales, available on this website, offers and
programs, and to prevent and detect non-compliance or fraud by you. This
may include reviewing and assessing your dealings with us, your
eligibility to participate in certain sales, offers and programs, your
compliance with the terms and conditions of such sales, offers and
programs, and undertaking enforcement action and/or disciplinary action
where such non-compliance or fraud is suspected or identified.
We may use administrative and technical measures to protect, our
website, our systems, our networks, transactions occurring on our
website or in our stores, and any other necessary means to protect the
personal information we may access or store. For this purpose, we may
also be required to verify your identity or to take note of any
suspicious or actual non-compliance with our terms and conditions or
fraud we incurred with respect to your dealings with us. Such measures
may also be implemented for compliance purposes or to avoid sharing your
personal information with any untrusted third parties. For example, when
you purchase a product, your personal information will be associated
with a unique code placed into and/or printed on such product so that by
reading the unique code we can recognize the order as yours, to enable
us to assess your compliance with our terms and conditions or to detect
fraud by you, and to take enforcement and/or disciplinary action against
you in the event of suspected or identified non-compliance or fraud by
you.
In addition, we may implement certain measures to protect and
defend our rights and property, our employees and our business partners
in compliance with applicable laws, regulations and international
conventions. For example,
we can monitor our inbound and
outbound interaction with our customer service (including via voice or
video recording or listening in real time, with prior notice to you);
also, mindful of the health of our employees, and for this sole purpose,
we implement an anti-malicious calls procedure so that any occurrence of
inappropriate behaviors such as harassment, insults or direct threats
from users will be reported to our dedicated team. This will generate a
warning to the concerned user and they will be recorded on our
provisional list. The initial warning will set out the consequences of a
second incident occurring. A second incident will lead to the suspension
of any further calls from the user in question for a period of 4 months.
During this period, the user will still be able to contact our customer
services by other communication channels (e.g., regular mail or email)
so we can attend their queries and preserve their rights at any given
time.
H. To assess and better understand our business.
To manage our activities, perform our obligations under our contract
with you and comply with our legal obligations, we may need to access
and use some of your personal information for finance, management or
legal purposes, or business-related analytics & market research
activities.
For example, this could occur when we use the invoices we have issued
in relation to your purchases for compliance or accountability purposes,
or when we analyse personal information to understand the
characteristics of our customers (what is the gender proportion, the
average age etc.).
In certain limited circumstances, such activity may be based on our
legitimate interest when related to business analytics & market
research activities.
Certain activities which are required when conducting a business
may involve the use of your personal information. This could include
internal processes (such as finance control, accounting, stock
management, production management, internal or external audit), certain
legal obligations (for example, record-keeping or tax declaration), or
analyses conducted in case of a merger or acquisition.
We may also conduct various business-related analytics &
market research activities, which may require us to access or otherwise
use some of your personal information, or to send you surveys or
customer satisfaction questions in order to gather new or additional
information. This notably enables us to analyse and learn how our
customers use and interact with us in order to improve products,
services and our business in general. It is also important for us to
conduct operations that allow us to analyze and measure the performance
of our marketing or communications campaigns. This may be the case, for
example, when you click on one of our ads on our business partners
website or when you make a purchase after viewing one of their ads.
Please be aware that to do this, we may use cookies or other online
advertising technologies.
I. To optimise and manage our website and other means of
communication.
We may take certain measures involving the use of your personal
information to administer, optimise and improve our means of digital or
physical communications such as our website, our mobile application, or
face-to-face interaction in our stores.
The use of your personal information will allow us to perform our
contractual obligations or improve our services in accordance with our
legitimate interest. Of course, when we use cookies or other online
advertising technologies requiring us to do so, we will always ensure
that we have duly obtained your prior consent.
We may use some of your personal information to administer,
optimise and improve our websites, our applications, our content and our
other digital offerings, including the services and products offered
through our websites, applications or any other digital means of
communication to ensure the most user-friendly online navigation
experience. We may use such personal information to fix operational
problems such as pages crashing and software bugs. Please be aware that
to do this, we may use
cookies
or other online advertising technologies
.
Your personal information may be collected, used, held or disclosed
for other purposes with your consent or where otherwise permitted by
applicable legislation.
APPENDIX
2 - Specific information for residents of Qatar, Vietnam, China, Kuwait,
SAUDI ARABIA, Mexico, Chile, South Korea OR AZERBAIJAN about the use of
your personal information
Pomellato will collect, record, hold, organize, structure, store,
update, adapt, combine, consult, use, transfer and disclose your
personal information for the following purposes. Your personal
information will not be further used for purposes incompatible or
inconsistent with the purposes for which it was collected, unless
permitted by the applicable legislation.
The processing of your personal information is justified on the legal
bases set out in this section. The legal bases listed in this section
will also apply when we share your data with third parties (as listed in
the section
With whom do
we share your personal information?
) for one of the purposes
mentioned below.
When we require information from you for the below mentioned
purposes, we generally request you to submit this to us voluntarily,
i.e. you have the right to consent or not to consent to the collection
and processing of your personal data. If you choose not to provide
certain personal information, you may not be able to benefit from some
of our services for which the provision of such personal information is
necessary.
A. To provide you with the products and services you have purchased
or otherwise requested
We will use your personal information to manage our relationship with
you and to perform our obligations under the contract you conclude with
us when you purchase or otherwise request products or services from us.
This can cover various activities such as internal accounting,
processing your payment or delivery.
To provide you with the products and services you have requested,
we will access, collect, store, process, use, disclose and transfer your
personal information for invoicing, payment management and internal
accounting.
Some of the operations mentioned above can be implemented by
partners of ours as identified in section “
With
whom do we
share your personal information?
”, in particular the registration,
payment and delivery of your order. Your information may be
communicated, used or collected directly via the information system of
our partner.
Certain specific information may be required to provide you with
gift cards, customization services, or when you reserve a product or a
service, request the repair of a product, or purchase products or
services by phone, or on our website or a marketplace. In such cases, we
could access, collect, store and use your personal information for
delivery, warehouse and return management.
During your visit to our store, we may need to collect your
information in order to allow you to access our premises or when you
wish to obtain a particular service: request for tax on products or in
connection with our after-sales service, etc.
The purposes for
which we process your personal information are as
follows:
Providing you
with the products and services you have purchased or otherwise requested
either in our stores or online.
This involves any action necessary to perform our obligations
under the sale or service contract you conclude with us (processing of
your payment, delivery, return management, etc.)
For purchases made on our website, the contract is our Terms and
Conditions of Sale.
The processing of
your personal information is justified on the following legal
basis:
Qatar
Vietnam, China and Saudi
Arabia
Kuwait, Mexico, Chile, South
Korea and Azerbaijan
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent
,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,.
B. To manage your Pomellato profile.
Once you have requested us to create your Pomellato profile, via
Pomellato websites or any other means, including our customer service,
your personal information will be linked to this profile, where we will
keep all the information we have on you. This could include personal
information we obtain directly from you as well as from other sources in
accordance with applicable legislation. This could also include
information about the purchases made when checking out as a guest or
when checking out using a profile. The information in your Pomellato
profile is crucial to provide you with the Pomellato personalized and
tailored experience, and in some cases is necessary in order to access
to some specific services or to purchase from our website, and thus it
needs to be kept up to date for the best experience.
Once you have asked us to create your Pomellato profile, we will
supplement it with personal information such as your purchases,
preferences and contact details. In this context, please be aware that
we use personal identification information, such as your email address
or phone number, to link an interaction or a purchase with your
Pomellato profile. This also applies when checking-out as a guest on our
website when making a purchase, as mentioned above, or in case you bind
your social media open ID account with your Pomellato profile (by using
dedicated QR Codes for example). In addition, we may use your date of
birth to determine that you are old enough to use our services.
In order to keep your personal information accurate, we will take
every reasonable step to ensure that personal information we hold is
properly updated. Subject to your applicable privacy legislation you may
have the right to have your information rectified at any time, and in
event please let us know if any of your information needs updating or
correcting, and we will make our best efforts to detect and correct
inaccurate personal information (data cleansing) and delete any
duplicated dataset. This may require us to correct typographical errors
or inconsistent personal information.
The purposes for
which we process your personal information are as
follows:
Administering,
managing and maintaining your Pomellato profile
once you have
requested us to create it.
This could include data cleansing and
deduplication.
The processing of
your personal information is justified on the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China Mexico, Chile,
South Korea and Azerbaijan
Our legitimate
interest
Once your profile has been created upon your request, to
supplement it with the personal information you provide us during our
interactions and thus ensure we retain the most accurate and up-to-date
version of your profile (and such legitimate interest is not overridden
by your own interests or fundamental rights)
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent
,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
C. To provide you with tailored customer service and
assistance.
You should have the same unified experience no matter how we
communicate. Whether this happens in our stores, on our website, by
chat, by phone or by video, and whether you contact us or we contact
you
,
we want to provide you with relevant and tailored customer
service.
For this purpose of providing you the Pomellato experience, we will
collect, store, process, use, disclose and transfer your personal
information to be able to identify you. This will allow us to provide
you with the tailored assistance you are asking for or to share relevant
information with you. In addition, when you contact us, we may retain
the personal information you share with us to always provide you with
such a customised and personalised experience. This could happen if you
are an existing or potential customer. Your personal information will be
linked to your Pomellato profile, if you have requested us to create
one, or to a temporary record.
To provide you with a smooth and enjoyable customer experience, know
you better to provide you with tailored answers, and to improve the
quality and security of our services, we may rely on your consent,
proceed in accordance with our contract with you, or take all reasonable
steps to enter into a contract with you, or rely on our legitimate
interest to improve our services.
We will use the information we have about you to try to identify
you when you contact us (whether by phone, video chat, text message,
chat, social media, etc.). When we can identify you, we will be able to
access personal information available in your Pomellato profile or in
your temporary record, to know when you have previously interacted with
us and to provide you with the tailored assistance you are asking for.
This could include real-time or subsequent monitoring of your
interaction with us (for example on our website or in a store) to
identify the products you are looking at or what could be your specific
need.
To provide you with adequate customer service, you may be asked
if you need further assistance when you are on our website or in a
store. On our website, if you do not want to be contacted, kindly close
the chat navigation window. This service was implemented for you to
enjoy the same service as in one of our physical stores.
If we are not able to identify you, we may create a temporary
record to allow you to have a unified purchase experience. Indeed,
however you interact with us, we will do our best to avoid asking you
again for information you have already shared with us.
Your personal information, in particular your Pomellato profile
if you have created one or the temporary record we may create about you,
could enable our sales associates to contact you directly in relation to
the products and services you have purchased or otherwise requested,
such as when a product becomes available again or when an order you have
placed has been received in store, or to share with you any other
information you have requested from us. In addition, the monitoring of
our interaction (including, with prior notice to you, via voice or video
recording – such as real time listening or analysis – or listening in
real time,) enables us to improve the quality and safety of our services
and to provide you with tailored answers.
All our customers are important to us. However, some of our
customers and potential customers benefit from a more personalized
experience due to the important relationship they keep with Pomellato.
Our teams may need to collect and gather information on such customers
or potential customers in order to identify personalities who correspond
to the image and values of Pomellato to offer them unique support. This
may be the case when you participate in one of our selective projects or
when our Sales Associates offers you to participate in events or
contacts you for certain special occasions (for your birthdays or for a
particular event of your life).
The purposes for
which we process your personal information are as
follows:
Administering,
managing and maintaining your Pomellato profile
This will be done if you have requested us to create your
Pomellato profile and if we are able to identify you. We will supplement
your Pomellato profile with the personal information you provide us with
when you contact us or when we contact you. This could include data
cleansing and deduplication.
The processing of
your personal information is justified on the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Our legitimate
interest
Once your profile has been created upon your request, to
supplement it with the personal information you provide us during our
interactions and thus ensure we retain the most accurate and up-to-date
version of your profile (and such legitimate interest is not overridden
by your own interests or fundamental rights)
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent
,
as provided when you create your Pomellato profile or otherwise choose
to enter into a contract or voluntarily share your information with
us,
Your consent
, as
provided when you create your Pomellato profile or otherwise choose to
enter into a contract or voluntarily share your information with
us,
The purposes for
which we process your personal information are as
follows:
Administering,
managing and maintaining a temporary record
This will be done if we are not able to identify you. We will
supplement this temporary record with information you provide us with
when you contact us or when we contact you, to avoid asking you again
for information you have already shared with us and provide with you
tailored assistance about our products and services.
The processing of
your personal information is justified on the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Our legitimate
interest
When we are not able to identify you, to supplement a temporary
record to provide you tailored assistance (and such interest is not
overridden by your own interests or fundamental rights)
Your
consent
As deemed obtained when you choose to enter into a contract or
voluntarily share your information with us
Your
consent
As deemed obtained when you choose to enter into a contract or
voluntarily share your information with us
The purposes for
which we process your personal information are as
follows:
Inbound
interaction –
Providing you with the products, services or
information you may request
when you contact
us
The processing of
your personal information is justified on the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico,
Chile, South Korea and Azerbaijan
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
Your consent,
as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
The purposes for
which we process your personal information are as
follows:
Outbound
interaction - Contacting you
directly
in
connection with the products, services and information you have
requested
The processing of
your personal information is justified on the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico,
Chile, South Korea and Azerbaijan
Our legitimate
interest
To provide you with an adequate answer when our interaction is
not related to the formation or performance of a contract (and such
interest is not overridden by your own interests or fundamental
rights)
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent
,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
The purposes for
which we process your personal information are as
follows:
Realtime
interaction –
To allow you to try on our products
virtually
The processing of
your personal information is justified on the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico,
Chile, South Korea and Azerbaijan
Our legitimate
interest
To provide you with tailored assistance when we are not able to
identify you (and when such interest is not overridden by your own
interests or fundamental rights)
Or your consent
if your facial image is
pictured
Performance of a
contract
When we collect information to provide you with relevant
assistance about our products or services
Any other situation will require
your consent
,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
We will notably rely on your
consent
if your
facial image is pictured.
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
The purposes for
which we process your personal information are as
follows:
Real-time or further monitoring of our
interaction
, to enable us to improve the quality and safety of
our service and provide you with better answers.
This monitoring could be implemented during both inbound and
outbound interactions and could be carried out via voice or video
recording or listening in real time, with prior notice to
you.
The processing of
your personal information is justified on the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Our legitimate
interest
When we collect information to improve the quality and safety of
our service (and when such interest is not overridden by your own
interests or fundamental rights)
Your consent
, as deemed obtained when you choose
to enter into a contract or voluntarily share your information with
us.
When we collect information to provide you with relevant
assistance about our products or services
D. To enable you to receive relevant information and tailored
marketing content.
You will receive information and updates about us either at your
request (with your prior consent where required by law) or when we are
authorised by law to send you such information and updates directly, for
instance after a purchase. Such communication can be global or local,
and may include updates about our products and services, notifications,
invitations to events, offers, surveys, etc.
Our communications will be customised and specifically designed to be
of interest to you, and will be updated with any new personal
information linked to your Pomellato profile. We will thus use your
personal information to send you tailored communications or other
customised advertisements or marketing campaigns. This use of your
information includes some profiling activity.
When you share your contact information with us, we may use this
personal information to contact you through related communication
channels (such as text message, MMS, e-mail, post, internet means,
social media or telephone), with your consent where required. You can of
course request us not to use a particular channel of communication or
opt-out (unsubscribe) from it by applying the opt-out option that will
always be shared with you. If you want to stop receiving communication
from us via all communication channels, please send an email to
privacy@pomellato.com.
As part of the
Pomellato
experience, we will always try
to customise and personalise your experience with us. This is why we
will use your personal information to send you tailored communications
or personalise your journey with us, but only with your prior consent
where it is required under applicable privacy legislation. Our
communications could include tailored product recommendations we think
you might like, personalised marketing content designed to suit your
interests, personalised events invitations or, at your request and where
available, personalised and customised products. For these purposes, we
will use the information you provide to us (for example your date of
birth, your country of residence, your preferred means of contact, etc.)
and/or jointly or independently, certain patterns we may observe when
interacting with you (for example where you prefer buying our products,
what type of products you like, which occasions you are shopping for,
etc.). With this information, we may create groups of similar customers
(called “persona”) to whom we can decide to offer personalised content
and experiences both in inbound or outbound interactions. In this
context, we may make inferences about you, as derived from your personal
information (
profiling
). For example, if you always
purchase our products from the same store (specific location or online),
we may consider this store as your preferred one. This will allow us to
customise your experience with Pomellato based on your interests and
shopping habits (i.e. tailored communication).
In order to
provide you with such customised and personalised experience, in our
stores or online, you may be required to log in or identify
yourself.
To enrich your personal information, we may use
cookies
or other online advertising technologies
. Via such technologies, we
will collect personal information related to your activities on social
media and your browsing activity across different websites and devices
(for example: to know if you have visited our website after opening a
newsletter you have received). Certain technologies may rely on services
provided by other companies acting on their own account (such as social
media WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter, Instagram,
or other online platforms). These companies have their own privacy and
cookies policies and the way they use the personal information you share
with them will be subject to their rules and not ours.
Personal information linked to your Pomellato profile (your
identification personal information such as your e-mail address, phone
number, social network id, etc.) will enable us to reach you on
third-party platforms or to create “lookalike campaigns”, allowing us to
find new people who are likely to be interested in our products because
they may be similar to you. We may conduct such campaigns through our
website, social media or other communication means such as search
engine. When this kind of campaigns are conducted, before it is shared,
your personal information is hashed and turned into short fingerprints
that cannot be reversed.
Using
cookies
or other online advertising technologies
may also enable us to show
you online advertisements that are “contextual" (meaning they are shown
according to the webpage you are browsing), or “behavioural" or
“interest based" (where advertisements are shown to you based on your
interests which we have inferred from your information including
demographic, geographic and interest-based data). We may use such
advertisements to display products or services that are most relevant to
you.
If you no longer want to see customised online advertisements,
you may request us to delete your Pomellato profile or modify your
cookie preferences – see "
cookies
or other online advertising technologies
". In addition, some
third-party sites allow you to stop seeing advertisements from specific
advertisers, so you may also set your preferences on those
websites.
The purposes for
which we process your personal information are as
follows:
Sending or presenting you with tailored
communication
This includes communication such as updates about our products
and services, invitations to events, offers, surveys.
When you share your contact information with us, we will use such
personal information to contact you through related communication
channels (such as text message, MMS, e-mail, post, internet, social
media or telephone).
We will always do our best to provide you with tailored
communication based in particular on your interests and shopping habits,
and improve and customise our services notably via
profiling.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Our legitimate
interest
in providing you with customised content
When such interest is not overridden by your own interests or
fundamental rights and we are authorised by law to send you such
communication without your consent
Your consent,
as provided when you create your
Pomellato profile
Your consent,
as
provided when you create your Pomellato profile.
Your consent,
as
provided when you create your Pomellato profile.
The purposes for
which we process your personal information are as
follows:
Updating and supplementing or enriching
your personal information
This includes conducting data cleansing and
deduplication.
This also includes enriching your personal information with
second party data or information related to your activities on social
media and your browsing activity across different websites and
devices.
Some of the technologies we use (including cookies) may rely on
services provided by other companies acting on their own account (such
as social media - WeChat, WhatsApp, Baidu, Kakao Talk, Facebook,
Twitter, Instagram or other online platforms).
You may have
provided your consent to cookies and other technologies through such
platforms
.
These other companies have their own privacy and
cookies policies and the way they use your personal information will be
subject to their rules and not ours.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us
Or compliance with a legal obligation
When such update relates to the administration and management of
your Pomellato profile, including taking actions following a
rectification or erasure request.
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online, and such update relates to the administration and management of
your Pomellato profile
Or
compliance with a legal obligation
When taking actions following a rectification or erasure
request.
Any other situation will require
your consent,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
Compliance with a legal
obligation
When taking actions following a rectification or erasure
request.
Any other situation will require
your consent,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
The purposes for
which we process your personal information are as
follows:
Creating
lookalike campaigns
Lookalike campaigns enables us to reach new people who are likely
to be interested in our products because they are similar to
you.
Some of the technologies we use (including cookies) may rely on
services provided by other companies acting on their account (such as
social media - WeChat, WhatsApp, Baidu, Kakao Talk, Facebook, Twitter,
Instagram or other online platforms).
You may have provided
your consent to cookies and other technologies through such
platforms
.
These other companies have their own privacy and
cookies policies and the way they use your personal information will be
subject to their rules and not ours.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico,
Chile, South Korea and Azerbaijan
Your consent
when
you accept, at the creation of your Pomellato profile, that we link your
personal information to certain patterns (
Profiling
)
(for example by accepting to receive tailored communication).
Your consent,
when
you accept, at the creation of your Pomellato profile, that we link your
personal information to certain patterns (
Profiling
)
(for example by accepting to receive tailored communication).
Your consent,
when
you accept, at the creation of your Pomellato profile, that we link your
personal information to certain patterns (
Profiling
)
(for example by accepting to receive tailored communication).
The purposes for
which we process your personal information are as
follows:
Online
advertisement
Presenting you with online advertisements that are “contextual",
“behavioural", “interest- based" or “tailored”, including by using
cookies or other online advertising technologies
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Your consent
to
cookies or other online advertising technologies
Your consent
to
cookies or other online advertising technologies
Your consent
to
cookies or other online advertising technologies
E. To send you non-marketing communications.
Non-marketing communications may be sent upon your request, and/or
may be important for your safety and the security of your personal
information.
You may still receive such communications even when you opt-out from
certain marketing communications. The information communicated may be
necessary for the correct performance of our contract with you or be
mandatory to comply with some of our legal obligations.
Non-marketing communications can include, but are not limited to:
emailing you to verify your identity when you sign up to our services;
emailing you for password and/or username reset; notifying you that a
particular service has been or will be suspended for maintenance or
terminated; notifying you of an upgrade, a rectification or an incident
affecting our services that may involve your personal information;
notifying you of an update to our privacy policy or Terms of Use; or
informing you about any products or services you have requested or
purchased.
We will never contact you to ask for your password. Please be
aware if you receive any request for this personal information.
The purposes for
which we process your personal information are as
follows:
Providing you with
the services and information you requested
. For example
identity verification, password or username reset, etc.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us
Your consent,
as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us
The purposes for
which we process your personal information are as
follows:
Providing you with
the services and information we need to send or provide you
.
For example information about the suspension of our services, about
incidents that may involve your personal information, etc.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
Or compliance with a legal
obligation
Compliance with a legal
obligation
,
Or performance of a contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online,
Otherwise
your consent,
as provided when you
create your Pomellato profile or deemed obtain when you otherwise choose
to enter into a contract or voluntarily share your information with
us
Compliance with a legal
obligation
Or
your consent,
as provided
when you create your Pomellato profile or deemed obtain when you
otherwise choose to enter into a contract or voluntarily share your
information with us
The purposes for
which we process your personal information are as
follows:
Administering and
managing your Pomellato profile
once you have requested us to
create your Pomellato profile
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico,
Chile, South Korea and Azerbaijan
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
Your consent,
as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us.
F. To manage our social networks
Pomellato manages “Fan” pages available on several social networks.
We may need to process the information made available by the different
platforms or when you interact with our pages and publications.
When, as a user, you decide to interact with our social media
pages (e.g. when you follow one of our pages, when you click "Like" on
Facebook or "Follow" on Instagram or add a reaction to a post, when you
"share" or add a "comment", etc.), we have access to public information
in your profile. Your information is used for the purpose of interacting
with you through the social network in question or to establish analyzes
or statistics on the use of our pages or on the performance of our
communications. Our services may remove your comments if they do not
comply with our policies on the use of social networks (e.g. if your
comments are insulting, illegal or malicious).
When you visit our “Fan” page, when you do not have an account or
are not logged in to the relevant social network, we do not collect any
personal information about you, except for the aggregated data provided
to us by each social network.
The purposes for
which we process your personal information are as
follows:
Promote Pomellato's
activities on social networks.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Our legitimate
interests
in communicating on our activities
When such interest is not overridden by your own interests or
fundamental rights.
Your consent,
when you interact with
us
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online, including when you interact with us via the features proposed by
the social network
Otherwise
your consent,
as provided when you
create your Pomellato profile or deemed obtain when you otherwise choose
to enter into a contract or voluntarily share your information with
us
Compliance with a legal
obligation
Or
your consent,
as provided
when you create your Pomellato profile or deemed obtain when you
otherwise choose to enter into a contract or voluntarily share your
information with us
The purposes for
which we process your personal information are as
follows:
Analyze the habits of
users who visit our “Fan” pages or share our content.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Our legitimate
interests
in communicating on our activities
When such interest is not overridden by your own interests or
fundamental rights.
Your consent,
when you interact with
us
Your consent,
when
you interact with us
Your consent,
when
you interact with us
G. To conduct our business securely and protect our activities and
personnel.
To deliver our products and services safely to you, perform our
contract properly or comply with some of our legal obligations, we will
implement fraud prevention and detection measures. Such measures will
allow us to adequately perform our contract with you and/or protect our
legitimate interests in defending ourselves against fraud. We may
notably implement measures to ensure that you are complying with our
terms and conditions for sales, available in this website, offers and
programs, and to prevent and detect non-compliance or fraud by you. This
may include reviewing and assessing your dealings with us, your
eligibility to participate in certain sales, offers and programs, your
compliance with the terms and conditions of such sales, offers and
programs, and undertaking enforcement action and/or disciplinary action
where such non-compliance or fraud is suspected or identified.
We may use administrative and technical measures to protect, our
website, our systems, our networks, transactions occurring on our
website or in our stores, and any other necessary means to protect the
personal information we may access or store. For this purpose, we may
also be required to verify your identity or to take note of any
suspicious or actual non-compliance with our terms and conditions or
fraud we incurred with respect to your dealings with us. Such measures
may also be implemented for compliance purposes or to avoid sharing your
personal information with any untrusted third parties. For example, when
you purchase a product, your personal information will be associated
with a unique code placed into and/or printed on such product so that by
reading the unique code we can recognize the order as yours, to enable
us to assess your compliance with our terms and conditions or to detect
fraud by you, and to take enforcement and/or disciplinary action against
you in the event of suspected or identified non-compliance or fraud by
you.
In addition, we may implement certain measures to protect and
defend our rights and property, our employees and our business partners
in compliance with applicable laws, regulations and international
conventions. For example,
we can monitor our inbound and
outbound interaction with our customer service (including via voice or
video recording or listening in real time, with prior notice to you);
also, mindful of the health of our employees, and for this sole purpose,
we implement an anti-malicious calls procedure so that any occurrence of
inappropriate behaviors such as harassment, insults or direct threats
from users will be reported to our dedicated team. This will generate a
warning to the concerned user and they will be recorded on our
provisional list. The initial warning will set out the consequences of a
second incident occurring. A second incident will lead to the suspension
of any further calls from the user in question for a period of 4 months.
During this period, the user will still be able to contact our customer
services by other communication channels (e.g., regular mail or email)
so we can attend their queries and preserve their rights at any given
time.
The purposes for
which we process your personal information are as
follows:
Implementing fraud
prevention, detection and investigation measures and procedures against
inappropriate behaviors against our employees
to ensure
physical security and cybersecurity, to safely deliver you products and
services and to protect the health of our employees, also via voice or
video recording or listening in real time both inbound and outbound
conversations with our customer service, with prior notice to
you.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Compliance with a legal
obligation
or our legitimate interests
in protecting
ourselves against fraud, protecting our employees against inappropriate
behaviors, preventing criminal activity or collecting relevant
information thereon or initiating an investigation thereof, and
collecting information necessary for the investigation of any criminal
activity, based on an official request from the investigating
authorities (when such interest is not overridden by your own interests
or fundamental rights)
Compliance with a legal
obligation
,
or performance of a contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Otherwise
your consent,
as provided when you
create your Pomellato profile or deemed obtain when you otherwise choose
to enter into a contract or voluntarily share your information with
us
Compliance with a legal
obligation
Or
your consent,
as provided
when you create your Pomellato profile or deemed obtain when you
otherwise choose to enter into a contract or voluntarily share your
information with us
The purposes for
which we process your personal information are as
follows:
In accordance with
applicable law,
implementing compliance-related and
privacy-related activities
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Compliance with a legal
obligation
or our legitimate interest
Where the processing is not prescribed by law but is a regulatory
expectation (and such interest is not overridden by your own interests
or fundamental rights)
Compliance with a legal
obligation
Or your consent,
as provided when you create
your Pomellato profile or deemed obtain when you otherwise choose to
enter into a contract or voluntarily share your information with
us
Compliance with a legal
obligation
Or your consent,
as provided when you create
your Pomellato profile or deemed obtain when you otherwise choose to
enter into a contract or voluntarily share your information with
us
The purposes for
which we process your personal information are as
follows:
In accordance with
applicable law,
implementing activities related to the
protection of intellectual property rights and management of litigation
cases
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico,
Chile, South Korea and Azerbaijan
Compliance with a legal
obligation
or our legitimate interests
in protecting our
rights (when such interest is not overridden by your own interests or
fundamental rights)
Compliance with a legal
obligation
Or your consent,
as provided when you create
your Pomellato profile or deemed obtain when you otherwise choose to
enter into a contract or voluntarily share your information with
us
Compliance with a legal
obligation
Or your consent,
as provided when you create
your Pomellato profile or deemed obtain when you otherwise choose to
enter into a contract or voluntarily share your information with
us
H. To assess and better understand our business.
To manage our activities, perform our obligations under our contract
with you and comply with our legal obligations, we may need to access
and use some of your personal information for finance, management or
legal purposes, or business-related analytics & market research
activities.
For example, this could occur when we use the invoices we have issued
in relation to your purchases for compliance or accountability purposes,
or when we analyse personal information to understand the
characteristics of our customers (what is the gender proportion, the
average age etc.).
In certain limited circumstances, such activity may be based on our
legitimate interest when related to business analytics & market
research activities.
Certain activities which are required when conducting a business
may involve the use of your personal information. This could include
internal processes (such as finance control, accounting, stock
management, production management, internal or external audit), certain
legal obligations (for example, record-keeping or tax declaration), or
analyses conducted in case of a merger or acquisition.
We may also conduct various business-related analytics &
market research activities, which may require us to access or otherwise
use some of your personal information, or to send you surveys or
customer satisfaction questions in order to gather new or additional
information. This notably enables us to analyse and learn how our
customers use and interact with us in order to improve products,
services and our business in general. It is also important for us to
conduct operations that allow us to analyze and measure the performance
of our marketing or communications campaigns. This may be the case, for
example, when you click on one of our ads on our business partners
website or when you make a purchase after viewing one of their ads.
Please be aware that to do this, we may use cookies or other online
advertising technologies.
The purposes for
which we process your personal information are as
follows:
Performing
activities relating to the sale or service contract you have concluded
with us.
For example, accounting, stock management, keeping of records,
etc.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam, China and Saudi
Arabia
Kuwait, Mexico, Chile, South
Korea and Azerbaijan
Compliance with a legal
obligation
Or your consent
, as provided when you create
your Pomellato profile or deemed obtain when you otherwise choose to
enter into a contract or voluntarily share your information with
us.
Compliance with a legal
obligation
,
or performance of a contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online,
Otherwise
your consent,
as provided when you
create your Pomellato profile or deemed obtain when you otherwise choose
to enter into a contract or voluntarily share your information with
us
Compliance with a legal
obligation
,
Or
your consent,
as provided
when you create your Pomellato profile or deemed obtain when you
otherwise choose to enter into a contract or voluntarily share your
information with us
The purposes for
which we process your personal information are as
follows:
Conducting
business-related analytics & market research
activities
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Our legitimate
interests
in improving our products or services
When such interest is not overridden by your own interests or
fundamental rights.
Your consent,
when you answer surveys or
customer satisfaction questions or when we use cookies or other online
advertising technologies.
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us
Your consent,
as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
The purposes for
which we process your personal information are as
follows:
Sharing necessary
information with actual or potential buyers as part of a business
transfer
The processing of
your personal information is justified by the following legal
basis:
Qatar and
China
Vietnam and Saudi
Arabia
Kuwait, Mexico, Chile, South
Korea and Azerbaijan
Our legitimate
interest
in disclosing information necessary to complete our
business transactions
Your consent,
as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us
Your consent,
as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us
The purposes for
which we process your personal information are as
follows:
Sharing necessary
information with auditors, law firms and similar corporate professional
service providers, data analysis providers
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico,
Chile, South Korea and Azerbaijan
Compliance with a legal
obligation
Or our legitimate interest
of properly carrying
out our business including in compliance with applicable legislation and
to better understand and improve our business (when such interest is not
overridden by your own interests or fundamental rights)
Compliance with a legal
obligation,
Or your consent,
as provided when you create
your Pomellato profile or deemed obtain when you otherwise choose to
enter into a contract or voluntarily share your information with
us
Compliance with a legal
obligation,
Or your consent,
as provided when you create
your Pomellato profile or deemed obtain when you otherwise choose to
enter into a contract or voluntarily share your information with
us
I. To optimise and manage our website and other means of
communication.
We may take certain measures involving the use of your personal
information to administer, optimise and improve our means of digital or
physical communications such as our website, our mobile application, or
face-to-face interaction in our stores.
The use of your personal information will allow us to perform our
contractual obligations or improve our services in accordance with our
legitimate interest. Of course, when we use cookies or other online
advertising technologies requiring us to do so, we will always ensure
that we have duly obtained your prior consent.
We may use some of your personal information to administer,
optimise and improve our websites, our applications, our content and our
other digital offerings, including the services and products offered
through our websites, applications or any other digital means of
communication to ensure the most user-friendly online navigation
experience. We may use such personal information to fix operational
problems such as pages crashing and software bugs. Please be aware that
to do this, we may use
cookies
or other online advertising technologies
.
The purposes for
which we process your personal information are as
follows:
Fixing operational
problems
such as pages crashing and software bugs
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
When such interest is not overridden by your own interests or
fundamental rights
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
Your consent,
as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
The purposes for
which we process your personal information are as
follows:
Understanding how our means of
communication are used
and administer, optimise and improve
them.
This can include auditing the downloading of personal information
from the Website.
The processing of
your personal information is justified by the following legal
basis:
Qatar
Vietnam and Saudi
Arabia
Kuwait, China, Mexico, Chile,
South Korea and Azerbaijan
Your consent
, as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
Or our legitimate interests
to administer and
improve our means of communication and other systems, in particular when
using
cookies
or other online advertising technologies
for which consent is not
required under applicable law
When our legitimate interest is not overridden by your own
interests or fundamental rights
Performance of a
contract
When you provided us with your personal information in relation
to an online purchase or any other request for products or services made
online
Any other situation will require
your consent,
as provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
Your consent,
as
provided when you create your Pomellato profile or deemed obtain when
you otherwise choose to enter into a contract or voluntarily share your
information with us,
APPENDIX
3 - Specific information on text and instant messages for residents of
the United States or Guam residents
This section applies when you provide prior express consent to
receive text messages or instant messages from Pomellato. Messages that
you may receive from us may include one time or recurring text or
instant messages relating to our products, our services, our activities
or including any other information that you have requested. At
enrollment for recurring messaging programs, we will specify the
approximate frequency of messages.
You may opt-out of receiving future messages by texting STOP to the
number indicated in our message. For help or for more information, you
may contact us at
privacy@pomellato.com
(or see
How can you
contact us?
).
Messages are subject to the terms and conditions of your mobile
carrier. Standard message and data rates may apply. Marketing and
non-marketing text and instant messages may be sent to your mobile
number using an automatic dialing system.
We cannot guarantee timing or receipt of the messages, as this may be
affected by forces outside of our control. In the event that a message
is delayed, or not received, we are not responsible for any related
impacts.
You agree to provide us with a valid mobile number. If you change
your mobile phone number, you agree to opt out of receipt of texts and
instant messages prior to changing your mobile number.
Appendix 4 –
Specific information for US residents
A. What personal information do we collect
This section is meant to provide supplemental or specific information
for residents of California and certain other US states. We encourage
you to read the full privacy policy as well.
The personal information we collect about you includes information
within the below categories of data. Note that the “Category” column
listed below refers to the category of personal data as defined under
California law and represents the categories of personal information
that we have collected, and how it has been shared over the past 12
months. Inclusion of a category in the list below indicates only that we
may collect some information within that category. We do not necessarily
collect all information listed in a particular category, nor do we
collect all categories of information for all individuals. We have
collected and shared personal information in each of the below
categories with our affiliates and service providers, as well as with
government entities as necessary, for our business purposes within the
last 12 months. We have not necessarily shared all information listed in
a category.
Category
Source
Purpose of
processing
Identifiers such as a real name, alias,
postal address, unique personal identifier, online identifier Internet
Protocol address, email address, account name, social security number,
driver’s license number, passport number, or other similar identifiers,
including information about your vehicle.
We may collect information in this
category directly from you or your interactions with our websites,
applications, or sales associates, both in person and via phone, email,
chat, or text messages.
We may also collect information in this category from the third party
sources set out in the “
Who
Are Our Third-Party Sources
” section.
This set of personal information
enables us to identify you, manage your Pomellato profile, provide you
with customer service and assistance and, in some cases, to contact you,
including by sending you relevant information and tailored marketing
content.
In addition, some of our goods may be equipped with tags (e.g. RFID
or NFC) and/or a printed code, which could be associated with your
personal information, in order to detect security incidents and to
protect against malicious, deceptive, fraudulent or illegal
activity.
Commercial information, including records
of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or
tendencies.
We may collect information in this
category directly from you or your interactions with our websites,
applications, or sales associates, both in person and via phone, email,
chat, or text messages.
We may also collect information in this category from the third party
sources set out in the “
Who
Are Our Third-Party Sources
” section.
This set of personal information enables
us to provide you with the products and services you have requested,
manage your Pomellato profile, provide you with relevant customer
service and assistance, secure our communications and to manage and
better understand our business.
Internet or other electronic network
activity information, including, but not limited to, browsing history,
search history, and information regarding a consumer’s interaction with
an Internet Web site, application, or advertisement.
We may collect information in this
category from the use of cookies.
This set of personal information enables
us to always offer you the optimum service by understanding you better.
We use it to manage your Pomellato profile, provide you with relevant
customer service and assistance and also, in certain circumstances, to
contact you for example by sending you relevant information, updates and
tailored marketing content.
Geolocation data.
We may collect information in this
category directly from you or your interactions with our websites,
applications, or sales associates, both in person and via phone, email,
chat, or text messages.
We may also collect information in this category from the third party
sources set out in the “
Who
Are Our Third-Party Sources
” section.
We may also collect this information from the use of
cookies.
This set of personal information
enables better delivery of the service you expect from us.
It could include personal information related to your interactions
with us and allows us to manage your Pomellato profile, provide relevant
customer service and tailored marketing content, establish
communications and conduct our business securely, assess and better
understand our business, and optimise and manage our website and other
means of communication.
Audio, electronic, visual, thermal,
olfactory, or similar information.
We may collect information in this
category directly from you or your interactions with our websites,
applications, or sales associates, both in person and via phone, email,
chat, or text messages.
We may also collect information in this category from the third party
sources set out in the “
Who
Are Our Third-Party Sources
” section.
This data (e.g. recordings of customer
service calls, tags (e.g. RFID or NFC) and/or printed codes which could
be associated with your personal information) is processed to answer
your queries, detect security incidents, protect against malicious,
deceptive, fraudulent or illegal activity, and for compliance
management.
Inferences (defined as “the derivation of
information, data, assumptions, or conclusions from facts, evidence, or
another source of information or data”) drawn from any of the
information identified in this subdivision to create a profile about a
consumer reflecting the consumer’s preferences, characteristics,
psychological trends, preferences, predispositions, behavior, attitudes,
intelligence, abilities, and aptitudes.
We may collect information in this
category directly from you or your interactions with our websites,
applications, or sales associates, both in person and via phone, email,
chat, or text messages.
We may also collect information in this category from the third party
sources set out in the “
Who
Are Our Third-Party Sources
” section.
We may also collect this information from the use of
cookies.
This set of personal information enables
us to always offer you the optimum service by understanding you better.
We use it to manage your Pomellato profile, provide you with relevant
customer service and assistance and also, in certain circumstances, to
contact you for example by sending you relevant information, updates and
tailored marketing content.
In addition to the categories of information above, we also collect
the following categories of sensitive personal information:
Category
Source
Purpose of
processing
Social security number, driver’s license
number or other state ID number, and passport information.
We may collect information in this
category directly from you or your interactions with our websites,
applications, or sales associates, both in person and via phone, email,
chat, or text messages.
We may also collect information in this category from the third party
sources set out in the “
Who
Are Our Third-Party Sources
” section.
This set of personal information
enables us to identify you, manage your Pomellato profile, provide you
with customer service and assistance and, in some cases, to contact you,
including by sending you relevant information and tailored marketing
content.
In addition, some of our goods may be equipped with tags (e.g. RFID
or NFC) and/or a printed code, which could be associated with your
personal information, in order to detect security incidents and to
protect against malicious, deceptive, fraudulent or illegal
activity.
Personal data of a known child.
We may collect information in this
category directly from you or your interactions with our websites,
applications, or sales associates, both in person and via phone, email,
chat, or text messages.
We may also collect information in this category from the third party
sources set out in the “
Who
Are Our Third-Party Sources
” section.
We may also collect this information from the use of
cookies.
This set of personal information
enables us to identify you, manage your Pomellato profile, provide you
with customer service and assistance and, in some cases, to contact you,
including by sending you relevant information and tailored marketing
content.
In addition, some of our goods may be equipped with tags (e.g. RFID
or NFC) and/or a printed code, which could be associated with your
personal information, in order to detect security incidents and to
protect against malicious, deceptive, fraudulent or illegal
activity.
DO WE “SELL” OR “SHARE” YOUR PERSONAL INFORMATION?
As set out in our Cookie Policy, if you choose to enable third party
cookies via Cookie Settings, third parties (such as approved analytics
and advertising partners) will collect your personal information via
automated technologies on our websites and applications, primarily in an
effort to provide you with content and advertisements that may be of
interest to you and on the legal bases set out in this privacy policy.
The choice is yours. You may elect not to send your personal
data to them at any time.
We have implemented a cookie “door” to ensure your cookie preferences
are honored. We also have tools in place to better detect requests made
using the Global Privacy Controls (“GPC”) signal as requests to opt-out
of the sharing of personal information to the extent required by
applicable law. If you wish to manage your cookie preferences directly
with us, please go to our cookies settings or make a request using one
of the methods outlined in Section C of this appendix.
Please note that deciding not to share your information via third
party cookies does not mean you will stop seeing ads, but these ads will
not be tailored to you based on information derived from your activities
on our websites.
Please also note that depending on your selection, we may still share
your information in ways that are not a “sale” or “sharing” under
applicable state laws, such as with our service providers, for our own
online advertising purposes.
B. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL
INFORMATION?
Subject to certain conditions and limitations, you may have the
following rights with respect to personal information about you:
Right of access/Right to know – You may be entitled to request
that we disclose to you personal information we have collected about
you, in the preceding 12 months, the categories of sources from which
the information was collected, the purposes of collecting the
information, the categories of third parties we have shared the
information with, and the categories of personal information that have
been shared with third parties for a business purpose. Before providing
any of this information, we must be able to verify your
identity.
Right of data portability – In some instances, you may have the
right to receive the information about you in a portable and readily
usable format.
Right to have personal information erased – Subject to certain
conditions, you may be entitled to request that we delete personal
information about you. We will not delete personal information about you
when the information is required to fulfill a legal obligation, is
necessary to exercise or defend legal claims, or where we are required
or permitted to retain the information by law.
Right to correct – You may also request correction of any
inaccurate personal information relating to you and to request the
deletion of your personal information. You can see and update most of
this personal information yourself online.
Right to opt-out of the sale or sharing of personal information –
You have the right to opt-out of information sharing that constitutes
“sharing” personal information, as defined by applicable law.
Depending on your state of residency, these rights may not apply to
pseudonymous data if the information necessary to identify the consumer
is kept separately and is subject to controls that prevent access to the
information. Pseudonymous data is personal data that can no longer be
attributed to a specific individual without the use of additional
information, if the additional information is kept separately and is
subject measures to ensure that personal data is not attributed to the
specific individual.
Data solely retained for data backup or archive purposes is
principally excluded from these rights until it is restored to an active
system or next accessed or used for a sale, disclosure, or commercial
purpose.
If you chose to exercise any of these rights, we will not
discriminate against you on the basis of choosing to exercise your
privacy rights.
Additional Information for Residents of California:
If you are a California resident you also have the right to submit a
Shine the Light Request, which means you may request that we provide you
with a list of certain categories of personal information we have
disclosed to third parties for their direct marketing purposes during
the immediately preceding calendar year, as well as the identity of
those third parties. Any such disclosures will be made consistent with
your choices in Cookie Settings. You may contact us at the information
below for a listing.
Verification of your request
Before providing you with the above rights, we must be able to verify
your identity. In order to verify your identity, you will need to submit
information about yourself, including, to the extent applicable,
providing your account login credentials or other account information,
answers to security questions, your name, government identification
number we already have on file, date of birth, contact information, or
other personal identifying information. We will match this information
against information we have previously collected about you to verify
your identity and your request. To the extent you maintain an account
with us, we will require you to login to that account as part of
submitting your request. If we are unable to verify your identity as
part of your request, we will not be able to satisfy your request. We
are not obligated to collect additional information in order to enable
you to verify your identity. For deletion requests, you will be required
to submit a verifiable request for deletion and then to confirm
separately that you want personal information about you deleted.
If you would like to appoint an authorized agent to make a request on
your behalf, we require you to verify your identity with us directly
before we provide any requested information to your approved agent.
Alternatively, your authorized agent may provide evidence of having
power of attorney or acting as a conservator for you. Note that we may
require you to verify your identity with us directly before we provide
any requested information to your authorized agent unless your
authorized agent has power of attorney or acts as a conservator, in
which case we will not contact you directly. We may also request that
any authorized agents verify their identity and may reach out to you
directly to confirm that you have provided the agent with your
permission to submit the request on your behalf.
How to make your request
Depending on where you reside, you may be entitled to make either one
or two requests per calendar year, free of charge. You will be charged a
fee for subsequent requests exceeding this limit. Under applicable
privacy law, and for the protection of your personal information, we may
be limited in what personal information we can disclose.
In your request, please attest to your state of residency and provide
a current address for your response. You may request this information in
writing by contacting us at
privacy@pomellato.com
, by
completing the form available
here
or calling our toll-free number
800-254-6020.
Additional Information for Residents of California and
Colorado:
For residents of California and Colorado, we will
maintain all of your privacy rights requests for at least 2 years. This
information will not be used for any other purpose except to review
compliance processes; it will not be shared except as necessary to
comply with a legal obligation. For residents of Colorado, sensitive
data which we no longer have consent to process will be deleted or
rendered permanently anonymized or inaccessible within a reasonable
period of time after withdrawal of consent.
When can you expect to hear from us
We will confirm receipt of your request within 10 business days and
provide information about how we will process the request, including the
verification process and expected response time. Please allow up to
forty-five (45) days for a response, from the day the request is
received. We may require an additional forty-five (45) calendar day
extension. Residents of Iowa should allow up to ninety (90) days for a
response, not including the additional forty-five (45) calendar day
extension.
Depending on your state of residency, you may be entitled to appeal
our decision with regard to your request.
Additional Information: to the extent permitted by applicable law, we
may charge a reasonable fee to comply with your request. This statement
is available in alternative formats upon request. Please contact
privacy@pomellato.com
or
800-254-6020
to
request this statement in an alternative format.