PRIVACY NOTICE

Data privacy is of high importance for arianna_razzano and we want to be open and transparent with our processing of your personal data.

We therefore have a policy setting out how your personal data will be processed and protected.

Who is the controller of your personal data?
The Belgium company, arianna_razzano, is the controller of the personal data you submit to us and responsible for your personal data under applicable data protection law.

arianna_razzano
Mäster Samuelsgatan 46
106 38 Antwerp
Belgium

Companies register: –
Company registration number: 0000000000
Authorised representative: Arianna Razzano
VAT registration number: VAT NO. 00000000000

Where do we store your data?
The data that we collect from you is stored within the European Economic Area (“EEA”) but may also be transferred to and processed in a country outside of the EEA. Any such transfer of your personal data will be carried out in compliance with applicable laws.

For transfers outside the EEA, arianna_razzano will use Standard Contractual Clauses and Shields as safeguards for countries without adequacy decisions from the European Commission.

Who can access your data?

The local arianna_razzano company will only act as  the personal data processor and processes the personal data on behalf of the Belgium company.

Data that is forwarded to third parties, is only used to provide you with our services. You will find categories of third parties under every specific process below.

What is the legal ground for processing?
For every specific process of personal data we collect from you, we will inform you whether the provision of personal data is statutory or required to enter a contract and whether it is an obligation to provide the personal data and possible consequences if you choose not to.

What are your rights?
Right to access:
You have the right to request information about the personal data we hold on you at any time. You can contact arianna_razzano and we will provide you with your personal data via e-mail.

Right to portability:
Whenever arianna_razzano processes your personal data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.

Right to rectification:
You have the right to request rectification of your personal data if the data is incorrect, including the right to have incomplete personal data completed. 

If you have an arianna_razzano account (arianna_razzano membership), you can edit your personal data under your account pages.

Right to erasure:
You have the right to erase any personal data processed by arianna_razzano at any time except for the following situations:

*you have an ongoing matter with Customer Service
*you have an open order which has not yet been shipped or partially shipped
*you have an unsettled debt with arianna_razzano regardless of the payment method
*if you are suspected or have misused our services within the last four years
*your debt has been sold to a third party within the last three years or one year for deceased customers
*your credit application has been rejected within the last three months
*if you have made any purchase, we will keep your personal data in connection to your transaction for book-keeping purposes

Your right to object to processing based on legitimate interest: 
You have the right to object to processing of your personal data that is based on arianna_razzano’s legitimate interest. arianna_razzano will not continue to process the personal data unless we can demostrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.

Your right to object to direct marketing:
You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.

You can opt out from direct marketing by the following means:

* following the instruction in each marketing emails
* by editing the settings of your arianna_razzano account

Right to restriction:
You have the right to request that arianna_razzano restricts the process of your personal data under the following circumstances:

* if you  object to a processing based arianna_razzano:s legitimate interest, arianna_razzano shall restrict all processing of such data pending the verification of the legitimate interest.
* if you have claim that your personal data is incorrect, arianna_razzano must restrict all processing of such data pending the verification of the accuracy of the personal data.
* if the processing is unlawful you can oppose the erasure of personal data and instead request the restriction of the use of your personal data instead
* if arianna_razzano no longer needs the personal data but it is required by you to defend legal claims.

How can you exercise your rights?
We take data protection very seriously and therefore we have dedicated customer service personnel to handle your requests in relation to your rights stated above. You can always reach them at info@ariannarazzano.com.

Right to complain with a supervisory authority:
If you consider arianna_razzano to process your personal data in an incorrect way you can contact us. You also have the right to raise a complaint to a supervisory authority.

Updates to our Privacy Notice:
We may need to update our Privacy Notice. The latest version of the Privacy Notice is always available on our website. We will communicate any material changes to the Privacy Notice, for example the purpose of why we use your personal data, or your rights.

Online purchase

Why do we use your personal data?
We will use your personal data to manage your purchase online at arianna_razzano by processing your orders and returns via our online services and send you notifications of delivery status or in the event of any problems with the delivery of your items.

We will use your personal data to manage your payments.

We will also use your data in order to handle complaints and warranty matters for products.

Your personal data is being used to identify you and to  validate your legal age for shopping online and to confirm your address with external partners.

We want to offer you different payment alternatives and will carry out analysis in order to find out what payment alternatives are available to you, including your payment history and credit checks.

What types of personal data do we process?
We will process the following categories of personal data:

* contact information such as name, address, email address and telephone number
* payment information and payment history
* credit information
* order information

If you have an arianna_razzano account, we will also process your personal data submitted in relation to the account and arianna_razzano membership such as:

* account or membership ID
* shopping history

Who has access to your personal data?
Your personal data that is forwarded to third parties, is only used to provide you with the services mentioned above, companies to validate your address, communication agencies to send you order confirmation, warehouse and distribution suppliers in connection with the delivery of your order. Payment service providers for your payment. Credit reference agencies for identity and credit checks and debt collection agencies.

Please be aware that many of these recipient companies have an independent right or obligation to process your personal data.

What is the legal ground to process your personal data?
The processing of your personal data is necessary for arianna_razzano to fulfil the service of managing and delivering the order to you.

How long do we save your data?
We will keep your data as long as you are an active customer.

Automated decision making:
When you apply for credit as a method of payment we will perform an automated decision-making process regarding your credit application. You have the right to to express your point of view and to contest the decision with a member of staff.

ariannarazzano.com account

Why do we use your personal data?
We will use your personal data to create and manage your personal account in order to give you a personalised and relevant experience at arianna_razzano. 

We will provide you with your order history, details around your orders and enable you to handle your account settings (including marketing preferences). We will also provide you with easy ways to maintain accurate and updated information such as contact details and payment information.

Furthermore, we will enable you to save items in your shopping bag, offer you size recommendations and enable you to rate and review the products you’ve purchased from uIn order to provide you with relevant product recommendations arianna_razzano will process your navigation and browsing on our digital platforms (including website and app), your shopping history and product reviews as well as the data you submitted to us through your account.

What types of personal data do we collect?
We will always process your e-mail address and password that you submit to us when you sign up for arianna_razzano account.

We will process following categories of personal data if you choose to provide it to us:

*  contact information such as name, address, telephone number
* date of birth
* gender
* country
* account settings
* encrypted payment card information

We will process the following categories of personal data if you make a purchase

* order history
* delivery information
* payment history

We will also process the following categories of personal data connected to your cookies

* click history
* navigation and browsing history

Who has access to your personal data?
Data that is forwarded to third parties, is only used to provide you with the services mentioned above, to optimize the website we use, website agencies and analysis tools for product rating.

What is the legal ground to process your personal data?
The processing of your personal data for your account is based on your consent when you create your arianna_razzano account.

The processing of your personal data provide you with relevant product information is based on our legitimate interest.

Your right to withdraw your consent:
You have the right to withdraw your consent from the processing of your personal data at any time. When you do so your account will cease to exist and arianna_razzano will not be able to provide you with the services mentioned above.

How long do we save your data?
We will keep your data for as long as you have an active arianna_razzano account.

You have the right to terminate your account at any time, if you choose to do so your account will cease to exist and you will be considered inactive. We will keep your personal data if there are any legal requirements and if there is an open dispute.

We will consider you an inactive account owner if you haven’t

* opened an e-mail within 1 year,
* not placed any orders within 3 years or
* not logged in within 2 years
* made any Club activites within 3 years

After your account has been terminated your data will be deleted.

Your right to object to processing of your data:
You have the right to object to processing of your personal data that is based on H&M’s legitimate interest by contacting info@ariannarazzano.com. Your account will then be deleted and we will not be able to carry out our services to you.

Customer service

Why do we use your personal data?
We will use your personal data to manage your queries, to handle complaints and warranty matters for products and technical  support matters through e-mail, our chat function, telephone and through social media.

We may also contact you if there is a problem with your order.

What types of personal data do we process?
We will process any data you provide to us, including the following categories

* contact information such as name, address, e-mail address and telephone number
* birth date
* payment information and payment history
* credit information
* order information
* account or member number
* all correspondence in the matter

Who has access to your personal data?
Data that is forwarded to third parties, is only used to provide you with the services mentioned above. If you are a customer within the Asian region your data will be transferred to our external customer service agency.

What is the legal ground to process your personal data?
The processing of your personal data is based on arianna_razzano’s legitimate interest.

How long do we keep your data?
We will keep your data for 100 days for telephone and  e-mails logs and correspondence and for 12 months for case management.

For in store complaints your personal data will be saved for 2 years, except for the US where it is saved for 5 years.

Your right to object to processing based on legitimate interest:
You have the right to object to the processing of your personal data that is based on arianna_razzano’s legitmite interest. arianna_razzano will not continue to process the personal data unless we can demonstrate a legitimate ground for the process which overrides your interest and rights or due to legal claims.

Fulfilment of legal obligations

Why do we use your personal data?
We will use your personal data to comply with obligations in laws, court rulings and decisions from authorities.

This includes using your personal data to collect and verify accounting data to comply with our book-keeping rules.

What types of personal data do we process?
We will process following categories of personal data
*customer number
*order number
*name
*postal address
*transaction amount
*transaction date

Who has access to your personal data?

We will share your personal data with IT companies that provide book-keeping system solutions.

What is the legal ground to process your personal data?
The processing of your personal data is necessary for arianna_razzano to fulfil its legal obligation.

How long do we save your data?
We will save your data in compliance with the book-keeping rules in your country.

Cookies

A cookie is a small text file that is saved to, and, during subsequent visits, retrieved from your computer or mobile device. If you use our services, we will assume that you agree to the use of such cookie.

How do we use cookies?
We use permanent cookies to store your choice of start page and to store your details if you select “Remember me” when you log in.

We will use cookies to save your favourite products.

We use session cookies for example when you use the product filtration function, to check whether you are logged in or if you put an item in your shopping bag.

We use both first- and third-party cookies to collect statistics and user data in aggregate and individual form in analysis tools to optimise our site and to present you with relevant marketing material.

Some third-party cookies are set by services that appear on our pages and are not in our control. They are set by social media providers such as Twitter, Facebook and Vimeo and relate to the ability of users to share content on this site, as indicated by their respective icon.

We also use third-party cookies which performs cross-site tracking in order for us to give you marketing in other sites/channels.

What types of personal data do we process?
We will only connect your cookie ID to your personal data submitted and gathered in relation to your account, including your arianna_razzano membership, if you are logged in to your account.

Who has access to your personal data?

Data that is forwarded to third parties is only used to provide you with the services mentioned above, analysis tool in order to collect statistics to optimize our site and present you with relevant material.

What is the legal ground to process your personal data?
We will only connect your cookies to your personal data if you are logged in to your arianna_razzano account.

If you are logged in to your account, the legal ground based on our legitimate interest is fulfilment of the arianna_razzano membership terms and conditions.

How long do we save your data?
arianna_razzano does not save your personal data. You can easily erase cookies from your computer or mobile device using your browser. For instructions on how to handle and delete cookies please look under “Help” in your browser. You can choose to disable cookies, or to receive a notification each time a new cookie is sent to your computer or mobile device. Please note that if you choose to disable cookies, you will not be able to take advantage of all our features.

Prevention of misuse and crime

Why do we use your personal data?
We  will use your personal data for loss prevention management by securing that terms and conditions are being followed and to detect and prevent misuse of our services.

We will also use your personal data via video surveillance for security reasons. This data will be used to be able to follow up on incidents and to prevent and report criminal offences in our stores.

Your personal data will be used to prevent and investigate abuse of our services online and losses and fraud, by analysing online shopping behavior.

What types of personal data do we process?
We will process the following categories of personal data:
*contact information such as name, address, telephone number and e-mail address
*club membership ID
*customer number
*video footage
* order history
* delivery information
* payment history

Who has access to your personal data?
Your personal data that is forwarded to third parties, is only used for purposes  mentioned above. We will share your data with companies for exception based reporting.

Incidents and fraud may be shared with insurance companies, legal authorities or local and global law enforcements to complete investigations. Please be aware that such recipients will have an independent right or obligation to process your personal data.

What is the legal ground to process your personal data?
The processing of your personal data to prevent misuse of our services is based on our legitimate interest.

How long do we save your data?
We will keep your data for the time we need to prevent and/or report potentional fraud and other offenses.

Video footage will be saved in compliance with local legislation, for a maximum of 30 days.

Your right to object to the processing of your data:
You have the right to object to the processing of your personal data that is based on arianna_razzano’s legitimate interest by contacting dataprotection.ie@hm.com. Your account will then be deleted and we will not be able to carry out our services to you.