The data Controller and the data Processor
The Controller of the personal data processing is: VF International Sagl – Kipling DIVISION, Via Laveggio 5, 6855 - Stabio, Switzerland, VAT CHE-111.650.898 , Contact us.
What categories of data are processed; what are the purposes of the data processing
In general, the visit and consultation of the Website does not imply collection and processing of user’s personal data. The processing of user’s personal data who visits and consults the Website is limited to so-called surfing data, namely data whose transmission to the Website is implied in the functioning of the information systems managing the Website and in the use of Internet communications protocols. Surfing data include, for example, IP addresses or domain names of computers used by users who connect to the Website and other parameters relating to the type of used information operating system. Surfing data, including the above specified data, as well as, for example, the number of visits, the time spent on the Website, etc., are collected and processed by VF exclusively for statistical purposes and in aggregated form in relation to the access and use of the Website for purposes of monitoring and enhancing the correct functioning and content of the Website. By nature, surfing data may lead to identification of users if they are associated with data held by third parties; however, VF does not collect surfing data in order to associate them with identified users.Said data may also serve for purposes of assessing possible responsibilities in case of offences against or through the Website. VF keeps the user’s surfing data only for the maximum period of time allowed under applicable laws and then makes said data anonymous.
Furthermore, VF collects and processes personal data voluntarily provided by user for a number of purposes, including when user interacts with the Website's functionalities and requests the services offered by the Website, for example upon user's subscription to the Website; user's subscription to newsletter or mailing list or loyalty programs; user's purchase of products through the Website, which includes all activities relating to the purchase of goods, such as for example delivery of goods, billing issues, returning and exchanging of goods, receiving refunds, purchase and use of gift cards and e-gift cards, as applicable, payment related activities, including use of vouchers, as well as fraud prevention; and customer support and interaction with our call centre; user's participation to promotions and other initiatives realized through the Website, such as for example contests and sweepstakes; user's request of information to VF or user sending a question, communication or feedback to VF through traditional mail or through the Website. We will process user’s personal data also to comply with laws, regulations and Community legislation, and to assess and defend a legal right. We may process user’s personal data also when user contacts our customer support and call centre, which may communicate with user and thus process user’s personal data through e-mail, chat and telephone. User may finalize the purchase of our products also through telephone calling our call centre, following the procedure specified in our Terms and Conditions of Sale [/terms-conditions-sale/]. The call centre will assist user in closing transactions over the phone and processing user’s order on user’s behalf and for said purpose it will collect user’s personal data and credit card details. The call centre will also register user’s phone number for purpose of call-back and back-office services in order to provide user with the requested support and information. Marketing, statistical and profiling activities as above specified may also be performed by the call centre, subject to user’s consent. In some cases, for purposes of internal training, quality control and verification, the call may be recorded and the e-mails may be saved to the extent not prohibited by applicable laws. User will always be informed in advance of the recording of the communication, and user will have the opportunity to object to such recording, save when this is necessary for verification purposes in relation to your purchase or other reasons, to the extent allowed under applicable laws.
Subject to the user’s consent, that is optional, VF may further process user’s personal data for survey purposes; for marketing purposes, i.e. for sending to user, also through e-mail or other electronic communications means such as SMS, MMS, fax, etc., promotional information and material on products and services of the VF group, on special initiatives on prices and promotions of the VF group and on initiatives such as events, exhibitions and fairs organized by the VF group or to which the VF group takes part; and for profiling purposes. For the above-described marketing and profiling activities, user’s personal data may also be shared with other companies of the VF group. User will always have the opportunity to object, at any time and for free, to the processing of his/her personal data for direct marketing purposes, including the sending of promotional information and material; in each communication there will be a specific section describing how to revoke consent (easily and free of charge).
Place where the data are stored
Personal data collected through the Website will be processed by VF; the company Rackspace Ltd, as data Processor, provides for VF hosting services for the web site and related database.
Conditions and features of the personal data processing
Personal data collected by VF are mainly processed through electronic and automated means but also without the same (paper processing), under procedures and logics that conform with the above-specified data processing purposes. User's personal data are processed according to Privacy Law, including security and confidentiality issues, and are kept only for the time necessary for the above-specified processing purposes or as required by applicable laws.
Security and quality of personal data
VF is committed to protect security of the user’s personal data. Personal data are processed by VF in compliance with the security requirements as set forth by applicable laws in order to prevent loss and destruction, even accidental, of data, unauthorized access to data, unlawful or unfair use of data. Moreover, information systems and software programs are configured so that personal and identification data are used only to the extent necessary for the above-specified purposes.
VF deploys a variety of advanced security technologies and procedures to help protect user’s personal data against the above-mentioned risks. For example, personal data provided by user are stored on secured servers placed in controlled locations. Moreover, encryption techniques such as the Secure Socket Layer (SSL) protocol are used for the transmission of some data through the Internet.
User may help VF to update and maintain accuracy of personal data provided by user to VF by notifying VF of any amendment relating to user’s address, title, telephone number or electronic mail (e-mail) address. Registered user may perform the foregoing on-line following the instructions reported on relevant user’s profile pages of the Website.
Scope of personal data communication
User's personal data may also be communicated to institutions, authorities, public entities, banks and financial institutions, professionals, independent consultants, also in associate form, business partners and third party service providers to which VF may revert to for performance of professional, technical and organizational services functional to the managing of the Website and related activities, such as for example the sales of goods and related activities, the managing of functionalities offered by the Website and of the initiatives and services that user may subscribe to and require through the Website, and for services strictly functional to achievement of the other above-mentioned purposes. For the same purposes, for example for the purchase of goods through telephone by our call centre, as well as for marketing and profiling activities, user’s personal data may be also communicated to other companies of the VF group , that will process them in accordance with Privacy Law.
The activities of customer support and managing of our call centre are performed by VF NORTHERN EUROPE Limited, acting as data processor of VF. Moreover, for closing transactions and payment processing we revert to third party service providers for managing and support of the e-com platform. These service providers are bound by contract obligations so that they will implement adequate security measures to protect security and confidentiality of user’s personal data and credit card information.
The third parties receiving user’s personal data as above specified will process data as data Processors (e.g., VF NORTHERN EUROPE Limited for the purpose of customer support and call center, and other third party services providers), as the case may be, according to Privacy Law. These third parties will be provided only with the information necessary to performance of their respective functions; they agree to use the information received only for the above-mentioned purposes, to keep it confidential and secure and to comply with applicable law and the instructions received from VF.
Personal data may also be communicated to third parties in case of mergers, acquisitions, transfer of any of our assets, products, websites or operations.
The third parties receiving your personal data are established within or outside the European Economic Area, including in countries that may not offer the same level of data protection as in the European Economic Area, such as in the United States. VF will take appropriate safeguard so that data remain subject to appropriate level of protection in accordance with Privacy Law for the purposes above specified.
Except for the foregoing, user’s personal data will not be shared with third parties, natural persons or legal entities, that are unrelated to, or that do not perform a business, professional or technical function for VF. User’s personal data may however be communicated further to legitimate recipients as permitted by applicable laws and regulations, such as for example in case of judicial processes, request by competent courts and authorities or other legal obligation, to protect and defend the rights and property of VF and the Website. User’s personal data will not be communicated to third parties for their own marketing purposes.
Providing of personal data
Except for the foregoing description in relation to surfing data (please refer to the above section “What categories of data are processed ”), provision of personal data by user is necessary for performance of the services and functionalities offered by the Website required by user, such as user's subscription to the Website, to newsletters or mailing lists, managing user's purchase of products through the Website and related activities, managing user's participation to promotions and other initiatives realized through the Website such as for example contests and sweepstakes, replying to and managing user’s request of information, questions, communication or feedback to VF, or other information sent by the user. Provision of user’s personal data for the activities necessary to comply with applicable legislation is mandatory. In the above referenced circumstances, denial of providing personal data by user would make it impossible for VF to comply with contractual obligations or to provide user with the requested services, products or information.
Providing of data by user for the above-mentioned survey purposes, marketing purposes, and profiling purposes is optional; denial of providing personal data by user for such purposes will have no consequences on compliance by VF with its contractual obligations and on the provision of services, products or information requested by user.
User’s privacy rights
User is entitled at any moment to enforce the rights as provided by Privacy Law, including but not limited to the right to request access to personal data VF holds about user (including to obtain at any moment confirmation that user’s personal data exist or do not exist, verify their content, origin and accuracy), to ask for their rectification, integration, updating, or deletion, and to oppose their processing for legitimate reason (including to object, at any time and for free, to the processing of his/her personal data for direct marketing purposes).
For any query or request relating to the personal data processing by VF and to enforce the rights under the applicable privacy law, user may contact VF NORTHERN EUROPE Limited, acting as data Processor of VF, as follows: “VF NORTHERN EUROPE Limited – Kipling E-commerce Customer Service”, 2 Experian Way, Nottingham,NG2 1EP, United Kingdom ; or by sending an e-mail through the proper form provided at the following link: "Contact us".