Geox S.p.A., Via Feltrina Centro, 16, 31044 Biadene di Montebelluna – Treviso – Italy – No. Treviso Company register no. VAT registration and tax code: IT03348440268, Soc. Share capital € 25.920.733,10, fully paid-up. (hereafter “Geox”)
Geox Retail S.r.l., a sole-shareholder company, Via Feltrina Centro 16, 31044 Biadene di Montebelluna – Treviso (Italy) No. – Treviso Company register no., VAT registration and tax code: IT05563231009
Geox Asia Pacific Limited, 20/F., W Square, 314-324 Hennessy Road, Wan Chai, Hong Kong, registered with the Companies Registry under number 919983
Geox Macau Limited, Av. Da Praia Grande, Nr. 417 – 429 Edificio Praia Grande Commercial Centre 17 andar E, Macau, registered with the Macao Companies and Moveable Assets Registry under number 43761(SO)
(hereafter collectively “Geox Retail“)
are joint proprietors in the processing of your personal data, gathered and processed via the Website (hereafter “we” or “Geox and Geox Retail“).
1. OUR POLICY
Everyone has the right to protect their own personal data. Geox and Geox Retail respect the right of users of the Website (hereafter “Users”) to be informed if their personal data is gathered or processed. When handling data that may directly or indirectly identify you, we endeavour to respect the principle of strict necessity. For this reason, we have configured the Website so that the use of your personal data is reduced to a minimum. The use of your personal data is excluded completely when the purposes for which the data is required can be fulfilled using anonymous data (i.e., for statistical research aimed at improving services). We may also use methods that allow individuals to be identified only in the event of necessity or on the request of the forces of law, regulation and order (i.e. data pertaining to internet traffic and the duration of your stay or your IP address).
All decisions pertaining to the purposes and methods used to process your personal data and the instruments used to achieve this, including the security profile, are the responsibility of Geox and Geox Retail, as joint proprietors of the personal data of Users of the Website, in accordance with legislative decree n° 196 of 30th June 2003 of the Italian Law, Personal Data (Privacy) Ordinance (Cap. 486) of the law of Hong Kong SAR, and Personal Data Protection Act of the laws of Macao SAR (hereafter collectively “Privacy Codes”) .
2. WHO PROCESSES YOUR PERSONAL DATA
Geox and Geox Retail are joint Proprietors of the processing of Users’ personal data, in accordance with the Privacy Codes. Together they decide the purposes and methods used to process data and the instruments used to do this, also with regards to the security profile.
Exclusively for organisational and functional purposes, we have identified and nominated certain external Data Controllers in accordance with the Privacy Codes. Their job is to supervise any data processing strictly connected and correlated with the fulfilment of services on the Website, including subscription to the Benefeet loyalty scheme.
These Data Controllers were chosen because they demonstrated that they possess experience, ability and reliability, and provided suitable guarantees in accordance with applicable legislation governing data processing, including data security profiles. The Data Controllers process Users’ data in accordance with the instructions provided jointly by Geox and Geox Retail.
We periodically check that the Data Controllers have promptly carried out the tasks assigned to them and that they continue to provide suitable guarantees of full compliance with regulations governing the protection of personal data. For a complete4 list of Data Controllers that process your data, please contact: Geox and Geox Retail at the address given above or send an email to firstname.lastname@example.org.
Geox and Geox Retail have also identified and designated in writing, in accordance the Privacy Codes, those subjects charged with the processing of Users’ personal data, and in particular of Users belonging to Benefeet, in the figures of the Marketing Team. These subjects perform the data processing operations entrusted to them in accordance with the instructions given by and under the supervision of Managers.
3. HOW AND TO WHAT END YOUR PERSONAL DATA IS USED
Your personal data is gathered and processed by Geox and Geox Retail for purposes strictly connected with the use of the Website and its services and in particular (i) to allow you to subscribe to the “Benefeet” loyalty scheme and (ii) to monitor the use and correct operation of the Website.
Please note that if at any time you decide to subscribe to Benefeet, you will be provided with specific details concerning the processing of your personal data in connection with the management of the loyalty scheme, with the possibility of giving your consent to the types of data processing that interest you most.
Your personal data is processed mainly in electronic format but in some cases also in hardcopy format. Your personal data will be stored in a form that allows you to be identified only for the time strictly necessary for the purposes for which the data was gathered and subsequently processed, and in any case within the limits of the law: subsequent to this, the data will be destroyed.
Should you subscribe to Benefeet, in order to ensure that your personal data is correct and up to date, or in any case pertinent and complete, please contact: Geox and Geox Retail at the address given above or send an email to email@example.com in order to access your personal data and update it.
4. WHAT HAPPENS IF YOU DO NOT CONSENT TO THE USE OF YOUR PERSONAL DATA
WHAT HAPPENS IF YOU DO NOT CONSENT TO THE USE OF YOUR PERSONAL DATA The provision of your personal data via the compilation of forms presented on the Website at any designated stores of Geox Retail is optional. Failure to provide this data, however, may result in the inability to access specific services and obtain what was potentially requested (e.g. to proceed with subscription to Benefeet): failure to provide the requested data may therefore, in some cases, prevent you from accessing the services provided by the Website and/or Benefeet program. On a case-by-case basis, and whenever necessary, we will inform you of the mandatory or optional nature of the provision of your personal data. We will use the (*) symbol to indicate mandatory, i.e. required, data. Please remember that failure to provide personal data indicated as “optional”, will have no consequences unless specified otherwise in the specific details provided during the data gathering phase.
5. WHO WE PROVIDE WITH YOUR PERSONAL DATA
Personal data may be made available to third-party companies that carry out specific services as Data Controllers on behalf of Geox and Geox Retail. The names of these companies will be specified on a case-by-case basis. These companies process data autonomously exclusively for the purpose of executing and managing the Benefeet program and only when this purpose is not incompatible with the purposes for which the data was originally gathered and subsequently processed, and in any case in compliance with the Privacy Codes. Data shall not be communicated, given or in any other way transferred, to other third parties, unless Users have been informed in advance and provided their consent, where this is required by Privacy Codes. The data will not be communicated or disclosed to third parties except within the limits and under the conditions explicitly stated in specific statements supplied on a case-by-case basis to the User and, if necessary, following authorisation from the same. In particular, your data may, for example, be communicated to the forces of laws, regulations and orders or judicial authorities in accordance with the Privacy Codes, following a formal request made by these subjects.
In addition, your data may become known to third-party companies nominated by Geox and Geox Retail as external Data Controllers in accordance with the Privacy Codes, charged with the management of the Website and our IT systems. You may obtain an updated list of data controllers at any time by writing Geox and Geox Retail at the address given above. Your personal data shall not be transferred overseas to countries other than Italy, the Hong Kong SAR and the Macao SAR.
6. HOW WE GATHER YOUR DATA
Geox and Geox Retail gather personal data and other information directly from Users during the course of the processes and services provided at any designated store of Geox Retail via the Website. This data is processed by Geox and Geox Retail within the limits and for the purposes set out in paragraph 3 and in any case illustrated in the statement provided to the User at the time of data collection. With reference to the collection of personal data via cookies, please see paragraph 8 below.
7. SECURITY MEASURES
This Website uses automatic systems for data collection, such as “Cookies”: these are devices sent from the Website server to the User’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.). They are stored on the User’s hard drive when they visit the Website. Cookies allow the Website to identify the User’s PC via information stored inside them, each time the User accesses the Website using that PC. Cookies allow us to facilitate User navigation within the Website. Cookies do not collect information that directly identifies the user. Geox and Geox Retail cannot access any personal information that could directly identify the User (i.e. name, surname) via cookies unless provided directly by the User. The cookies reside on our server and no one may access the information contained in them. Once saved on your computer, cookies may only be read by the Website that created them (in this instance www.benefeet.geox.com). Cookies may be “session cookies” (i.e. stored exclusively for the duration of the Website navigation session and deleted when the browser is closed) or “permanent cookies” (stored for a longer time period, until expiry or until they are deleted by the User).
8.1 Types of cookies used on www.benefeet.geox.com
|Name of cookie||Properties and purpose of cookie|
|SESS[32 random letters]||This cookie is used to allow you to access the private areas of the Website without having to log-in again. This cookie has a validity of 24 days. The information gathered is not communicated or passed on to third parties. This cookie does not record which Websites are visited by Users (other than www.benefeet.geox.com).|
Please note that your consent is only requested the first time you access the Website: subsequently, thanks to the use of a technical cookie, your consent is saved in order to allow you to access the pages of the Website directly when you return to it (without prejudice to your right to deactivate/activate cookies at any time, or to delete them (see point 8.2): in this case, your consent will be requested once again upon your return).
No other user profiling tools are used on this Website (e.g. spyware).
8.2 Information on cookies issued by the Website:
With regards to the cookies used by the Website, we are able to provide the following information:
1) The domain name from which the Website server issues cookies is: www.benefeet.geox.com
2) Purpose of the data collection: cookies are used for the purposes of (i) allowing easier and quicker navigation within the website (technical cookies); (ii) to improve the navigation experience by analysing User preferences (e.g. pages visited, products selected etc.) (profiling cookies).
3) Gathered data: the Uniform Resource Identifiers (URI) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the data response from the server (successful, error, etc.) and other parameters associated with the User’s operating system and IT environment.
4) Validity of cookies: this Website uses both session cookies (i.e. cookies that are automatically deleted when your browser is closed), and permanent cookies (i.e. cookies that are saved until they are deleted by the User)
5) The need to accept cookies: the acceptance of cookies is optional; however, failure to accept technical cookies, although navigation is permitted, may mean that it is impossible to provide some Website content and functions.
6) The communication of data: information gathered by cookies is confidential and is not passed on to third parties.
8.3 Third party cookies
The Website uses “third-party cookies”, i.e. cookies issued and managed by subjects other than Geox and Geox Retail, for purposes selected by these third parties, including profiling. Below is a list of third-party cookies used on the Website with links to the privacy statements issued by the third parties that manage these cookies.
In detail, the following cookies are used:
|Subject issuing the cookies||Purpose of the cookies||Link to statement and consent forms|
|Google Analytics: these cookies make a record of User navigation without obscuring the IP. This allows for detailed analyses of User navigation of the Website and information on preferences. This information is analysed in aggregated form, exclusively for statistical purposes.
The names of the cookies used are: __utma
8.4 Deactivating/deleting cookies using your web browser
Cookies can in any case be deactivated/deleted at any time using the settings on your web browser. In particular, and if the user does not wish to receive cookies, it is possible to adjust the settings in the browser in order to be warned of the presence of a cookie and to decide whether to accept it or not; it is also possible to automatically reject all cookies by activating the appropriate option in the browser. To do this, consult the information on the User Manual for your browser (a.k.a. Help Page), or by clicking on the following links:
– Internet explorer (http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies)
– Chrome (https://support.google.com/chrome/answer/95647?hl=it)
– Firefox (https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie)
– Safari (https://www.apple.com/legal/privacy/it/cookies/)
– Opera (http://help.opera.com/Windows/10.00/it/cookies.html).
9. YOUR RIGHT TO ACCESS YOUR DATA
In accordance the Privacy Codes, you have the right, including but not limited to, obtaining – from Geox and Geox Retail – information on the processing of your data, including 1) obtaining, without delay, confirmation as to whether or not personal data concerning you exists and receiving a copy of such data (if any); 2) obtaining: a) information on the source of the personal data, on data processing purposes and modalities, on the logic applied to the data processing, if the latter is carried out with the aid of electronic means, the identification details of the data controller, the data processors and the entities or categories of entities to whom or which the data may be communicated and who or which may acquire the data in their capacity as data processors or entrusted parties; the updating, rectification, or – where interested therein – integration of the data; b) the rectification, erasure, anonymisation or blocking of data which have been processed in violation of the law, notification to third parties to whom the data have been disclosed of any such rectification, erasure, anonymisation or blocking of data (in which case the third parties are required to rectify, erase or block the data accordingly unless otherwise proven impossible), including those for which storage is not necessary in relation to the goals for which it was collected or subsequently processed; 3) objecting, at any time on request and free of charge, in whole or in part, to the processing of personal data where it is carried out for commercial purposes or for the delivery of advertising materials or for direct sales or else for the performance of market surveys or commercial communications (including without limitation before the data are disclosed for the first time to third parties for direct marketing purposes). You may freely and at any time exercise your rights as provided by the Privacy Codes, addressing your request to Geox and Geox Retail at this email address: firstname.lastname@example.org. We shall then endeavour to provide a suitable reply.
If you would to receive further information on how Geox and Geox Retail handle your personal data, please send an e-mail to the following address: email@example.com.
To find out about your rights and to keep up to date on privacy regulations, we recommend you visit the following websites :
Hong Kong SAR: www.pcpd.org.hk
Macao SAR: www.gpdp.gov.mo
11. APPLICABLE LEGISLATION