POLICY FOR PROCESSING OF PERSONAL DATA
Pursuant to and by the effect of Article 13 of the European Regulation 2016/679 concerning the protection of individuals with regard to the processing of personal data (GENERAL DATA PROTECTION REGULATION – GDPR).
The Data Controller for personal data is Vipop a company incorporated under the laws of Hong Kong SAR, which offices are at unit 2004-2006, 20 F Alliance bldg, 133 Connaught road central, Sheung Wan, Hong Kong. The Company has named the Data Protection Officer, pursuant to and by the effect of Article 37 and the European Regulation 2016/679, with a separate paper. In case a customer wants to have more details, he can ask sending an email to firstname.lastname@example.org.
The Data Protection Officer can be contacted for questions or concerns regarding the processing of personal data at the email: email@example.com.
The personal data subject to processing is collected directly by Vipop or by third parties expressly authorized by the Data Controller, or communicated by the Company to such third parties for the pursuit of the purposes described below.
Legal Basis and Purpose of Processing
The personal data provided by the User when browsing the website www.vipop.com are processed by the Data Controller in accordance with the current regulations for the protection of personal data.
The legal basis of the processing is identified in the provision of its services by the Company, in the management and facilitation of the website, as well as in the establishment, execution and possible termination of online sales contract concluded between the parties, and in the obligations of the same contract connected either directly and/or indirectly deriving from it.
The processing of your personal data by Vipop is aimed at pursuing the following purposes:
1) SUBSCRIPTION TO THE Vipop NEWSLETTER: In the case that you decide to subscribe to the “Vipop Newsletter”, only after your express and specific consent, your personal data will be processed by the Data Controller for sending of commercial or promotional communications, relative updates, for example, to the latest trends, new arrivals, exclusive offers, special events and promotions.
2) REGISTRATION ON vipop.com: In the case that you decide to register on the website www.vipop.com, only after your express and specific consent, personal data will be processed by the Data Controller for the purpose of registration on www.vipop.com. In particular, in providing your name, last name, email address and the setting of an access password, these will be processed for the creation of your personal account, to speed up the purchase process, to allow you to view the status of orders and receive updates on purchases made, as well as change personal settings and update your account, view the history of returns and requests for the exchange of goods, save favorite items in your Wishlist.
3) ONLINE SHOPPING ACTIVITIES: The personal data you provide will be used for the establishment, management, execution and/or conclusion of the online sales contract. The data you provide will be processed by the Data Controller for the purpose of managing the purchase order with reference to, for example, payment, shipment, management of returns, customer support, administrative and accounting purposes related to the management of the order and the fulfillment of obligations under the current legislation. In case of payment by credit card, the fundamental information for the execution of the transaction (credit/debit card number, expiration date, security code) will be processed by companies in charge of the anti-fraud control using an encrypted protocol and without any third parties being able to access it in any way. This information will never be displayed or stored by the seller Vipop.
4) PROFILING OF THE PHYSICAL PERSON: Only after your express and explicit consent, the personal data you provided may be processed by the Data Controller for profiling activities, or analysis of your preferences aimed at creating personalized content and offers.
Nature of Processing
In relation to the purposes referenced in the previous points, providing your personal data and consent to its processing is mandatory.
Failure to provide consent will make it impossible for Vipop to allow you to register with www.vipop.com, create a personal account, speed up the purchase process, view the status of orders and receive updates on purchases, the possibility to update personal settings and account preferences, view the history of returns and exchange requests, save favorite items in the Wishlist or to enroll in later, if you so wish, eventuals loyalty programs. It will impossible for Vipop also to proceed with the establishment, management, execution and/or conclusion of the online sales contract, therefore making it impossible to perform, for example, activities related to payment, shipment, management of returns, customer support, administrative and accounting purposes related to the management of the order and the fulfillment of obligations under current legislation, to perform profiling activities, or to perform analysis of your preferences aimed at creating personalized content and offers.
Personal Data Processing – The Data Controller processes the personal data provided by the User when browsing the website www.vipop.com, in the event of any registration/subscription to the services/programs made available by vipop and/or the possible purchase of goods made available by vipop. Examples of personal data are name, last name and email address, in addition to the data necessary for the conclusion of the online sales contract, such as: the functional data for the execution of payment, shipment and exchange of purchased goods.
Methods of Processing and Storing Data – The processing of personal data is performed by the Data Controller in compliance with the provisions of the current legislation on Privacy. The Data Controller processes personal data using IT and/or telematic tools and with organizational and logical procedures strictly related to the purposes indicated in this policy, as well as adopting the appropriate security measures to prevent access, disclosure, unauthorized modification or destruction of personal data, its loss and its illicit and incorrect use. However, the Company cannot guarantee its Users that the measures taken for website security and the transmission of data and information on the website are capable of limiting or excluding any risk of unauthorized access or loss of data by devices pertaining to the User. For this reason, it is suggested that the Users of the website make sure that their computer is equipped with adequate software to protect the transmission of data (such as updated antivirus) and that its Internet provider has adopted appropriate measures for the security of the transmission of data on the network. The Company also undertakes to process the data according to the principles of correctness, lawfulness and transparency, to collect the data to the extent necessary and exact for processing and to allow its use only by personnel for authorized purposes. The management and storage of personal data acquired will take place in archives or on servers.
In relation to the different purposes for which data is collected, personal data will be kept for the time strictly necessary to achieve that purpose and, in any case, in accordance with the current relevant regulations.
In any case, the Company will take care to avoid the use of data indefinitely by proceeding, on a regular basis, to verify appropriately the effective permanence of the interest of the User to which they refer.
Data Processors and Recipients – The data collected will not be disseminated in any way, but will be treated within the limits and for the purposes described by the employees of the Company on the basis of appropriate operating instructions (for example, administrative, commercial, marketing, legal personnel, system administrators, etc.). Some data processing may also be performed by third parties, appointed as External Data Processors for processing, of which the Data Controller relies on or could be used in the management of the contractual relationship, the provision of services offered and organizational needs of its activities. In particular, the data could be communicated to:
a) Persons, public and private, that can access the data by virtue of the provision of law, regulation or community legislation, within the limits set by these rules;
b) Persons who need access to data for purposes related to the contractual relationship existing between the parties, within the limits strictly necessary for the performance of auxiliary tasks (such as, for example, banks and lenders, technical service providers, hosting providers, IT companies, communication agencies, mail carriers and shipping companies);
c) Consultants, within the limits necessary for carrying out their professional duties.
The updated list of External Data Processors and other persons authorized to process the data is kept at the Data Controller’s registered office and is available to the interested party, following a request sent via email to firstname.lastname@example.org.
Transfer of Data Abroad – The management and storage of personal data will be carried out on servers of the Owner and/or third-party companies accordingly with the laws.
Your personal data may be transferred abroad, in accordance with the provisions of current legislation, in countries inside and outside the European Union.
The transfer to countries outside the EU, in addition to cases in which this is guaranteed by an Adequacy Decisions by the Commission, is carried out in such a way as to provide appropriate and opportune guarantees pursuant to Articles 46, 47 or 49 of the Regulation.
Rights of Interested Party – As the interested party, you may exercise, at any time, the rights provided to you in Articles 15, 16, 17, 18, 20 and 21 of the GDPR which, in particular, confer the rights to:
a) Obtain from the Data Controller, pursuant to Article 15, confirmation of the existence or not of personal data being processed and, in this case, obtain access to the data and information such as: (i) the purposes of the processing; (ii) the categories of personal data; (iii) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients located in Third Countries or International Organizations; (iv) when possible, the retention period of the personal data provided or, if not possible, the criteria used to determine this period;
b) Obtain from the Data Controller, pursuant to Article 16, the correction of inaccurate personal data without undue delay; taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, by providing an additional declaration;
c) Obtain from the Data Controller, pursuant to Article 17, the deletion of their personal data without undue delay. The Owner has the obligation to cancel, without undue delay, personal data if there is one of the reasons indicated in paragraph 1 of Article 17;
d) Obtain from the Data Controller, pursuant to Article 18, restriction of processing when one of the hypotheses governed by paragraph 1 of Article 18 occurs;
e) Obtain from the Data Controller, pursuant to Article 20, the portability of data or to receive in a structured, commonly used and machine-readable format, their personal data provided to a Data Controller. The Data Subject also has the right to transmit such data to another Data Controller without impediments by the first Data Controller to whom it has provided them, if the conditions indicated in Article 20 paragraph 1 are met. Finally, the Data Subject has the right to obtain the direct transmission of personal data from one Data Controller to another, if technically feasible;
f) Object to, in whole or in part, pursuant to Article 21, the processing of their personal data.
To exercise these rights, the User can send their requests to email@example.com.
It should also be noted that the Data Subject has the right to revoke the consent at any time without prejudice to the lawfulness of the processing based on the consent given prior to the revocation, without prejudice to the consequences indicated above regarding a refusal to provide such personal data. The Data Subject also has the right to lodge a complaint with a Control Authority.
You can make requests regarding these rights by sending an email to firstname.lastname@example.org.
Vipop will respond to requests made by the interested party within one month, except in cases of particular complexity, for which it may take up to a maximum of three months. In any case, the Data Controller will provide the interested party with the reason for the delayed response within one month of the request. The outcome of the request will be provided in writing or in electronic format. In case of request for rectification, cancellation and limitation of processing, the Data Controller will communicate the results of the requests received by the Data Subject to each of the recipients of their data, unless this proves impossible or involves a disproportionate effort.
The Company specifies that a contribution may be requested from the Interested Party if the applications manifest to be unfounded, excessive or repetitive; in this regard, the Data Controller will provide a register to track the requests for intervention.