Privacy Policy for Stoic Couture

Stoic Couture (hereinafter referred to as “Stoic Couture”, “Data Controller”, or “Company”), with its registered office in [Your Address], informs users, in compliance with EU Regulation 679/2016 (“GDPR”) and relevant national data protection laws (collectively referred to as “Privacy Regulation”), that personal data (“Data”) of users of the website (“Data Subjects”) will be processed in the manner and for the purposes described in this policy.

1. Data Controllers and Joint Controllers of the Processing

Stoic Couture is the Data Controller for data collected through this website.

For Facebook Business Tools (e.g., Facebook Cookies, plug-ins, and Pixels), Stoic Couture and Facebook Ireland Limited, located at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), act as joint data controllers under a Joint Controllership Agreement. This arrangement measures user interaction with websites and provides targeted advertising on Facebook. More details on how Facebook Ireland processes data and how to exercise your rights can be found in Facebook Ireland’s Data Policy.

2. Data Protection Officer

As per Article 37 GDPR, Stoic Couture has appointed a Data Protection Officer (DPO), who can be contacted at [Your DPO Email Address].

3. Personal Data Processed

The following Data are processed:

  • Browsing Data: IP addresses or domain names of users’ computers, URI addresses of requested resources, and other data associated with internet communication protocols. This information, while not collected to identify users, could potentially identify them when combined with data held by third parties. This data is used for anonymous statistical analysis of website usage and to ensure proper website functionality, and it is deleted immediately after processing.
  • Data Provided by Users: This includes identification data such as name, email, phone number, etc., provided during website registration, form submissions, or when requesting services like newsletters.
  • Cookies: For details on the cookies used on the Stoic Couture website, please refer to our Cookie Policy.

4. Minimum Age

Protecting minors’ privacy and safety is crucial. By registering on the website, filling out forms, or subscribing to the newsletter, users confirm they are at least 16 years old or meet the minimum age requirement of their country of residence.

5. Purposes and Legal Bases of Data Processing

Personal data collected through the Stoic Couture website is processed for the following purposes:

Without prior consent for:

  • Service Provision:
    • Using the website and technical support.
    • Managing contact requests.
    • Registration and access to the “My Stoic Couture” area.
    • Handling payments and product purchases.
  • Legal Compliance:
    • Fulfilling legal obligations under national and European laws.
  • Legitimate Interest of the Data Controller:
    • Website management and maintenance.
    • Conducting statistical analysis to improve website navigation.
    • Preventing or detecting fraudulent activities and protecting the Company’s rights in legal matters.
    • Sending commercial communications related to Stoic Couture products and services to existing customers.

Only with prior consent for:

  • Marketing:
    • Sending promotional messages, newsletters, and commercial offers about Stoic Couture products and services.
    • Conducting market research and customer satisfaction surveys.
  • Profiling:
    • Analyzing data to provide personalized services and offers based on user interests and behavior.
  • Facebook Tools:
    • Using Facebook Business Tools to measure interactions with the website and provide targeted advertising on Facebook.
  • Custom Audiences:
    • Using Facebook Custom Audience to deliver targeted advertising based on user interests and behavior on the website.

For more information on Facebook’s data processing and the legal basis for their activities, please refer to Facebook’s Terms and Conditions.

6. Data Provision

The provision of Data with respect to the purposes referred to in paragraph A) is mandatory and any refusal will make it impossible for the Company to carry out the contractual obligations undertaken and the execution of legal obligations, or to respond to your requests. As regards the purposes referred to in letter B), the provision of personal data is optional and their use is conditional on the release of an explicit consent by the Data Subject. Any refusal to grant consent has no effect other than that of not being able to inform the interested parties about initiatives of the Company that might interest them and of not being able to proceed with the analysis of their purchasing habits and preferences, as well as the use of measurement tools and interaction with Facebook.

7. Modalities of Processing Activities

The processing of Data of Data Subjects is carried out – with electronic modalities – by means of the operations of collection, registration, updating, organization, conservation, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, cancellation and destruction of the Data. Data will be processed by the Company and its employees using computer systems (as well as manual means) in accordance with the principles of fairness, loyalty and transparency provided for by the applicable legislation on personal data protection and protecting the confidentiality of the Data Subject and his/her rights through the adoption of appropriate technical and organizational measures to ensure a level of security appropriate to the risk. Specific security measures are observed to prevent data loss, illegal or incorrect use and unauthorized access.

8. Data Retention

With reference to the purposes set forth in points A) of par. 5 (Purposes of the processing), Data will be processed for the entire duration of the relationship in order to achieve the aforementioned purposes. Data functional to the fulfilment of eventual legal obligations will be stored also afterwards, in compliance with such obligations and in accordance with the retention periods provided for by the applicable regulations from time to time.

For Data provided for the purposes of B, nos. 1. (marketing) and 2. (profiling) referred to in par. 5 (Purposes of the processing), due to the fact that the personal data stored relate purchases of ‘high-end’ products and that the average annual frequency of purchase, for each customer, is spaced out over time, Data provided by you will be retained for a maximum period of 7 years, considering that this time span is appropriate and proportionate to both the purposes that are intended to be achieved and the type of personal data being processed. Upon expiry of this period, the data will be deleted or made anonymous and in any case the Data Subjects may always provide new consent to the processing to the Company for the same purposes.

For the Data provided for the purposes under point B, no. 3. (use of Facebook Business Tools) of par. 5 (Purposes of the processing), the Data will be processed in accordance with the provisions of Facebook’s Data Policy, available at Facebook Data Policy.

For the Data provided for the purposes set forth in point B, no. 4 (use of Facebook custom audience services) of par. 5 (Purposes of the processing), the Data will be processed by Stoic Couture for the duration of its contractual relationship with Facebook and until the Data Subject’s consent is modified or the Data Subject requests cancellation.

9. Scope of Processing, Communication, Dissemination

Data processing is carried out by Stoic Couture’s internal staff appointed for this purpose as Data Processor or person in charge of processing. The Data collected for the execution of the above-mentioned purposes will also be processed by third parties appointed for this purpose as external Data Processors, or, as the case may be, communicated to the same as independent Data Controllers, and namely to:

Recipient/Scope of Data Communication What We May Share
Companies that are part of our corporate group for the purposes specified above Name, email address, residence, phone number, date of birth, demographic information, order history, IP address, payment information, preferences, transaction information, Website usage information.
Persons, companies, associations or professional firms providing assistance and consultancy to Stoic Couture, as well as accounting, administrative, legal, tax and financial matters Name, email address, residence, phone number, date of birth, demographic information, order history, IP address, payment information, preferences, transaction information, Website usage information.
Companies, bodies, associations that perform services related and instrumental to allow the navigation on the Website by the Data Subject, as well as couriers for the delivery of catalogs and / or products purchased, our stores, customer service, analysis and market research, management of payments by credit card, maintenance of computer systems. Name, email address, residence, phone number, date of birth, demographic information, order history, IP address, payment information, preferences, transaction information, Website usage information.
For payments handled by Klarna (as long as this service is available in your country), you will find more information here. With respect to the processing carried out by Klarna as an independent data controller, you can refer to the following links: EU: Klarna EU. US: Klarna US Name, billing address, shipping address, e-mail address, phone number, payment information.
Public administrations for the performance of institutional functions within the limits established by law and regulations Name, email address, residence, phone number, date of birth, demographic information, order history, IP address, payment information, preferences, transaction information, Website usage information.

Furthermore, the Data may be made accessible, communicated and transferred to Public Bodies, Judicial Authorities, Police Bodies, who will process Data as independent controllers in order to follow up on requests for verification or where expressly provided for by law.

The complete and updated list of the subjects that process Data as Data Processors and Independent Data Controller is available on request at Stoic Couture, with registered office in [Your Address].

10. Extra EU Data Transfers

The Company may transfer Data outside the European Union. To ensure compliance with privacy regulations, the Company evaluates the impact of data transfers and implements the most suitable safeguards (such as adequacy decisions or Standard Contractual Clauses). For more details on the transfer of personal data collected through cookies, including third-party cookies, please refer to Versace’s Cookie Policy and the privacy policies of each third party, available on their respective websites and linked within Versace’s Cookie Policy.

11. Data Subjects’ Rights

Data Subjects have the right to exercise the rights provided by the European Regulation (Articles 15-21) in relation to data processing, including:

  • The right to receive confirmation of the existence of their personal data and access their content (right of access);
  • The right to update, modify, and/or correct their personal data (right of rectification);
  • The right to request the deletion or limitation of data processed unlawfully, including data that is no longer necessary for the purposes for which it was collected (right to be forgotten and right to limitation);
  • The right to object to the processing of personal data (right to object);
  • The right to withdraw consent, without affecting the lawfulness of processing based on consent before its withdrawal;
  • The right to lodge a complaint with the Supervisory Authority in case of a breach of data protection regulations;
  • The right to receive a copy of the personal data provided to the Company in a structured, commonly used, and machine-readable format, and request that such data be transmitted to another data controller (right to data portability).

Requests can be addressed to the Company by sending an email to support@stoiccouture.com or by regular mail to:

{Address Here}
 

12. US and Canada Applicable Laws and Rights

In line with applicable laws and our commitment to respecting your trust in us regarding your information, you have certain rights concerning our processing of your personal information. These rights and the processes to exercise them are explained below. We will not discriminate against you for exercising any of your applicable privacy rights.

For additional rights specific to residents of certain countries, provinces, states, or locations, please refer to the Additional Specific Privacy Rights section below.

Accessing, Correcting, and Deleting Personal Information

Access to Your Personal Information: You have the right to confirm whether we have collected or processed personal information about you and to request a copy of the personal information we have, which we will provide in electronic form.
Data Correction: You have the right to request that we correct any incomplete or inaccurate personal information that we process about you. Some corrections can be made directly through your online account.
Deletion of Personal Information: You have the right to request the deletion of personal information that we process about you, except under certain circumstances (e.g., if we need to retain such information to fulfill an order or a contract, comply with a legal obligation, or to establish, exercise, or defend legal claims).

Process to Submit an Access, Deletion, or Correction Request

You may submit a request directly or through an Authorized Agent as follows:

  • Directly by You:
    Submit a Request via Email
    Call us at {Number} and provide the requested information.
  • Authorized Agent:
    If you designate an authorized agent to submit a request on your behalf using the above-indicated channels, you must (1) complete and sign a power of attorney or written authorization and (2) have the authorized agent attach the signed documents when submitting a request on your behalf.

For your privacy and security, we may require you to verify your identity before providing copies of your personal information, deleting, or correcting the requested information. Additionally, we will only provide a copy of your personal information to you, even if you use an Authorized Agent to submit the request.

Managing Marketing Communications

Opt-Out / Unsubscribe – Direct Mail:
To opt out of receiving direct mail from us, please contact us at support@stoiccouture.com (for US and Canadian customers) and specify “Opt-Out of Direct Mail” in the subject line. Note that we may still contact you via direct mail regarding your account, relationship, activities, transactions, and communications with us.

Unsubscribe from Email Marketing:
To unsubscribe from receiving promotional emails from us, follow the unsubscribe instructions in each promotional email you receive. Note that we may still contact you regarding your accounts, relationship, activities, transactions, and communications with us.

Opt-Out – Text Messages (SMS or MMS):
Note that Versace will not carry out any promotional and/or marketing activity via SMS or MMS in the US and Canada.

Additional Specific Privacy Rights

Browser Do-Not-Track Signals

Some web browsers and devices allow you to broadcast a preference not to be “tracked” online. At this time, we do not alter your experience based on whether such a signal is broadcast. To learn more about browser tracking signals and “Do Not Track,” please visit http://allaboutdnt.org.

Canadian Residents

Withdrawal of Consent to Process:
Canadian Residents have the right to withdraw consent to processing similar to the deletion right. To withdraw consent to processing, please submit a deletion request using the process described above (Process to Submit an Access, Deletion, or Correction Request).

Colorado, Connecticut, Virginia, and Utah Residents

Right to Opt-Out of Targeted Advertising:
In addition to the rights listed above, residents of Colorado, Connecticut, Virginia, and Utah have the right to opt-out of our Targeted Advertising. To opt-out of targeted advertising, you or your Authorized Agent may submit a request using the process described above (Process to Submit an Access, Deletion, or Correction Request).

California Residents

California Shine the Light:
Residents of California may request that we stop sharing their personal information with third parties for their direct marketing purposes. Such request will apply as of the date of your request, and we will not be responsible for any communications you may receive from third parties that received your personal information prior to that request. In these cases, please opt out from or contact that third party directly.

Process to Submit a Request under CA’s Shine the Light Law:

  • Please submit a written request via email to: support@stoiccouture.com
  • Include the following:
    • Email Subject Line Must Contain: Exercising my rights under CA Shine the Light
    • Email Body Must Contain: Your first name, last name, and email address associated with your Versace account

California Privacy Rights (CCPA and CPRA) Notice Rights:
The California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) require businesses to provide certain notices to consumers about their information practices concerning personal information. The required information can be found as follows:

  • A list of the categories of personal information that we collect is located in Section 3 “Personal Data processed”;
  • Details regarding the sources from which we obtain personal information can be obtained by writing to support@stoiccouture.com

    13. Redirect to External Sites

    Stoic Couture’s website uses social plug-ins. Social plug-ins are special tools that integrate social network features directly into the website (e.g., the Facebook “Like” button). All social plug-ins on the website are identified by their respective social network logos.

    When you visit a page on our website and interact with a plug-in (e.g., by clicking the “Like” button or leaving a comment), the corresponding information is transmitted by your browser directly to the social networking platform (e.g., Facebook) and stored there. For details on the purpose, type, and methods of collection, processing, use, and storage of personal data by the social networking platform, as well as how to exercise your rights, please refer to the social network’s privacy policy, such as Facebook’s Data Policy.

    Stoic Couture’s website may also contain links, including hyperlinks, widgets, banners, and cross-references to external sites and platforms operated by parties other than Stoic Couture. For information on the purposes, type, and manner of collection, processing, use, and storage of personal data by such platforms, please refer to their respective privacy policies.

    14. Modifications to This Privacy Policy

    This Privacy Policy may be updated over time. We encourage users to periodically check this page. The policy will include the date of the latest update.

    Version of July 2024