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Data Protection Policy

APPOINTMENT BOOKING FORM

 

26 July 2021 Version

 

 

1. DATA CONTROLLER

By completing this form and therefore request an appointment, we inform you that your personal data will be processed by PRONOVIAS GROUP ITALIA S.P.A.., a company located in Via Montenapoleone 8, 20121 Milano, (hereinafter, PGI).

PRONOVIAS GROUP ITALIA S.P.A. is part of the international corporate group Pronovias Group, which includes all those affiliated companies under its various brands: “Pronovias”, “St. Patrick", "White One", "Nicole", and "Ladybird", companies that you can consult at any time at [see link]. Your data will be processed by PRONOVIAS GROUP ITALIA S.P.A.. as the management company for all the Pronovias Group's products and brands.

 

2. PURPOSES AND LEGAL BASIS

The data will be processed for the purpose of handling your request for an appointment at the store you select, and for contacting you, both PGI and the store where you have the appointment, for anything necessary in relation to the said appointment (e.g. confirmation of the appointment or change of date or time), by any means including electronic means such as email, telephone, SMS or any others suited to such purposes (including instant messaging applications).

The legal basis for processing your data for making an appointment is based on our legitimate interest in being able adequately to supply the service you request of us. This legitimate interest also covers the sending of your personal identification and contact data to the store where you make the appointment, which will in turn process it to provide the service, i.e. in the performance of the store's personalized service.

Your data will also be used to create a Customer account, or to update the data if you already have one, with which we can offer you personalized attention and services by gathering and processing the information you supply to us, such as future events, tastes or preferences, as set out in the Preparation of Profiles section below.

The creation of a Customer account is also done on the basis of our legitimate commercial interest in being able to offer you the best possible services on the basis of your needs and preferences, and to keep a historical record of our relations with you. You can obtain further information on how we handle the Customer Account in section three (3) below on Preparation of Profiles.

And if you visit our stores we will be able to send you satisfaction surveys both on the quality of the service received and on our products, based on our legitimate interest in knowing your opinion and whether you are satisfied with the attention received during the appointment, and drawing up improvement plans for customer service.

We may also process your data for the following purposes, provided you have given your consent by marking the box provided in the form:

  • Sending you a PGI newsletter, which will be personalized and adapted to your interests.
  • Sending you additional information relating to PGI such as opinion surveys, invitations to events, etc.

These mailings may be adapted and personalized according to the interests of users, based either on the products and services ordered or any data we are able to deduce or obtain from your browsing habits, interest in particular content or reaction to our communications among other data sources, as set out in section below on Commercial Mailings.

 

3. PREPARATION OF PROFILES

As stated above at PGI we prepare profiles of the Customers who interact with us, creating a user or customer account containing all of the information gathered using the various data gathering channels both physical and online. The profile may be complete or incomplete depending on the type of interaction. We prepare these profiles on the basis of our legitimate business interests, which include knowing our customers and improving our services on the basis of their preferences and needs.

We set out below the various profile options depending on your relationship with us and any options you have selected:

3.1 Profile in store or customer service: We may ask you in our stores or by way of our telephone customer service to supply us with personal data, for reasons including maintaining a commercial relationship, providing personalized attention or handling bookings for appointments. For this we create a Customer file where we store all relevant information such as for example preferred styles of clothing, colors, whether you are interested in a wedding dress or a party dress, etc. This information helps us to adapt the service we provide and keep you informed of news or events in the stores you have visited (e.g. arrival of new collections or new colors, trunk shows or private sales, etc.), the store continuing direct mailing in addition to any information we send from PGI (e.g. by email if you have consented to this).

And if you visit our stores we may send you satisfaction surveys both on the quality of the service received and on our products. This helps us to improve on a day-by-day basis. These satisfaction surveys may be sent electronically even if you have not agreed to receive commercial mailings, as it is not advertising, it is the best way we have of ensuring we have given you the best in-store service in line with the quality standards of the Pronovias Group, and we thus have a legitimate interest in processing your contact and mailing data for these purposes. If you think the service was inadequate we may contact you by telephone or any other means of mailing you have indicated to deal with any incident which may have occurred during your visit to the store.

3.2 Online profile: The new technologies allow us to prepare much more precise profiles analyzing not just the preferences you expressed in our stores but also the following:

  • Information provided on booking an appointment, e.g. the date of an event, including your wedding; the type of environment in which the event or your weddding will be held; your preferences on the shape or neckline of the dress; your budget for the dress;

  • Information provided at the time of creating a user account, e.g. identification or contact data or your address;

  • Behaviour in the web site (content you access, type of dresses visited, favourite colours, how often you vist the website ...), which helps us to understand what you like;

  • Behaviour in relation to our newsletter (what type of content makes you click or open the newsletter; how often you open our communications);

  • Relevant information based on the dresses you include in the “My favourites” section (type of dress, colours, and other characteristics which help us to understand your preferences in our products).

These profiles may be combined either by physical channels (visiting a store or customer service) or online via the website, app, social networks, etc.

3.3 Use of the information generated in user profiles: Any information we gather on our customers is used for various purposes which may be put in two main groups, (i) purposes relating to a personalized service adapted to our customers, and (ii) purely advertising purposes.

As regards personalized service knowing your preferences means that all of our Pronovias stores can anticipate your needs and hence offer added value in our services. For example knowing your dress preferences means staff cannot just show you dresses which match those preferences (e.g. long or short party dresses, with a particular neckline or color, etc.), if you have booked an appointment they can make a prior selection of all the dresses or products which might match, including available sizes and colors.

If you have a coming event, particularly in the case of your wedding, knowing the date means we can see the dresses available for fittings and the availability of sizes and types of dress.

The generating of these profiles also allows us to improve our advertising as we can personalize and adapt the content of our advertising to your interests, the type of advertising we send you or the regularity with which we send it.

For example if we know of your interest in our new collections we will inform you each time they are presented and put on sale. And if you have shown an interest in our events, for example the presentation of new collections, we can invite you to them also taking into account your location and where the presentation is being held.

All contacts can be made both electronically, as stated above, and by telephone, both directly from PGI by way of Customer Service and directly from the store, in order to inform you of the arrival of new dresses, confirm future visits or bookings or generally preserve our ties with you.

Personalization of the content means we can ensure we send information which will be of interest to you. For example if we know you have a preference for long dresses we will prioritize news or promotions of this type of dress.

And depending on your interaction with us we can offer you special promotions, competitions or participation in events exclusively for customers.

In the following section on Mailings you can obtain further information on how we send mailings, the channels used and the platforms we work with to improve our advertising capacity.

All of the information contained in the Customer account, and therefore all information on your profile and preferences, is accessible by PGI stores, which use it to improve the personalized service at the store. All data is at all times the property of San Patrick, S.L.U., although the store, particularly in the case of franchises, may ask you for additional data for its own use during your visit to the store.

 

4.  PROMOTIONAL MESSAGING

PGI shall process the data you provide us in order to send you promotional messages when we have previously obtained your consent to do so. If you provide that to us, we will send you information, advertising, surveys, invitations to events, or promotions concerning products and/or services related to our business activity. Coinciding with the time of data collection, customers may decide whether or not to receive this type of messaging from us and may at any time withdraw their prior consent.

If you agree for us to send you promotional messages by electronic means (email, SMS, instant messaging or on social networks, among others), you are hereby advised that all messages sent by PGI may be tailored and customized according to your tastes, based on the products and services you have previously requested, or on the basis of data that we may infer or obtain from your browsing habits, interest shown in given content, or reaction to our messages, among others, as explained in the Profiling section.

Customization is done in a partially automated way, in the sense that PGI determines the parameters of the customization, but the technological platform is the one that actually generates the customer profile. As a general rule, we do not send out mass messages that are not segmented by means of the above procedure, as we consider that it is in the interest of both PGI and our customers to send or receive information that is timely and relevant, as well as because mass messaging would not serve to reduce or alter the number of messages received, but only their content. In this regard, if you object to receiving targeted messages for advertising or promotional purposes, please do not subscribe to promotional messaging and/or newsletters.

The promotional electronic messaging discussed above may be sent via the following channels:

  • Mailings by email, SMS or MMS o direct messaging (whatsapp, telegram, Facebook Messenger, direct messages in forum or social network applications, etc):

    If we possess the appropriate information (email, mobile phone number, etc.) we may send you promotional messages by such means. As a general rule, the communication channel will be limited to email, wherever possible, although certain messages may relate to another one of the purposes indicated (e.g. sending reminders, events or surveys).

  • Commercial mailings in third party platforms (e.g. social networks):

    Some third-party platforms (i.e., websites, online communities, or apps, for example) allow outside advertisers to use such platforms to place advertising directly targeting PGI customers who also have a user account on the platform.

    To do so, the platform may require the advertiser (PGI) to establish the identity of its customers by providing an encrypted and protected means to do so using the technical tools provided by the platforms themselves, with matching based on basic identifying data, such as an email address or phone number.

    Once the identity of a customer and the existence of their user account on the platform has been established, PGI can create what is commonly referred to as a "custom audience" comprised of those customers who have agreed to receive advertising on that platform, and may thus display PGI advertising directly on the user's profile.

    For example, among social networks, this type of activity can be found on Facebook (Custom Audience), Twitter (Custom Audiences), or Google (Customer Match).

    Such activity is solely intended for advertising purposes, so your data shall only be used if you have previously agreed to receive promotional messages from us.

    In addition, such third-party platforms may also allow their advertisers, to use their tools to identify users who, within their platform user base, have a "similar profile" to that of PGI customers.

    The procedure for identifying and accrediting the identity of customers is the same as that indicated earlier.

    For example, on social media sites, this type of activity can be found on Facebook (Lookalike Audience), Twitter (Custom Audiences), or Google (Similar Audiences).

    In this case, since the data is not used for a purpose directly relating to sending advertising to our Customers, but rather for sending it to those who, without being customers, possess a profile similar to that of our Customers, we will use the basic data of all our Customers (and not only those who may have agreed to receive promotional messaging) to identify potential customers on that platform. Thus, the advertising will be aimed only at those potential customers who have consented on that particular platform to receive promotional messaging. We conduct such processing based on our legitimate business interest in expanding our client base, but you may object to your data being processed for such purposes at any time.

    As indicated in the preceding paragraphs, the services in question only request basic identifying data; namely, we do not provide all your personal data, not even the preferences that we may already be aware of. Rather, they are limited to an email account or phone number that is shared in an encrypted and protected format using the technical tools provided by the platforms themselves and which is sufficient for the social network to identify you in its database.

    In addition, secure data communication methods, including data encryption prior to upload, are used to ensure data confidentiality and security.

    Finally, we do not obtain data about you directly from such third-party platforms; namely, we may obtain anonymous and statistical data, but never accurate information identifying your interests or indicating whether or not you have seen a particular advertisement, unless you choose to interact with us or with the specific ad.

    If you do not wish us to use your data for advertising purposes on third-party platforms, you may contact us at the e-mail and postal addresses below. If we are already using them on those platforms, we shall delete them during the next update of the data provided.

You may revoke your consent to the receipt of promotional electronic messaging and/or advertising at any time by simply following the instructions given at the foot of any of the electronic messages, by sending an email to the privacy@pronoviasgroup.com  email address, or by postal mail addressed to Via Montenapoleone 8, 20121 Milano, attaching in either case a copy of your personal identity documentation or passport and indicating "Ref. Data Protection" as reference on the envelope (in case of opting for postal mail) or in the subject line (if you opt for email), stating that you wish to revoke your consent to the receipt of promotional messaging by electronic means.

 

5. DATA TRANSFER

Your data shall not be transferred, sold, leased or otherwise made available to any third party, except to those NFG service providers who perform specific services for the company (such as sending out the newsletter to service providers, to marketing or customer service providers, or to providers of storage or data and database management services, and so on), but in no case may it be employed for their own purposes.

Without prejudice to the foregoing, the data you provide us on this form may be shared with or transferred to the stores in which the events you wish to attend are held, and which may be managed by a member company in the Pronovias Group in the case of own stores, or by other third-party firms (for example, in the case of wholesalers, who are managed by third parties). In any event, you will have access to the basic information regarding any such third parties on the form itself. These third parties will process your data only in order to manage your attendance at the event, although they may request your consent for additional processing.

 

6. INTERNATIONAL DATA TRANSFER

As NFG is part of an international corporate group with stores and distributors around the world, your data may be processed outside the European Union or the European Economic Area (EU and EEA, respectively), for example, in our own stores or those of third party distributors located in the United States, among others, or to international suppliers that may provide their services from outside the EU.

Regardless, we shall ensure that any such data processing is consistently protected under appropriate security protocols and through the mechanisms provided for by prevailing norms and legislation, which may include, among others:

  • Model Clauses approved by the EU: These are contracts approved by European regulators which provide sufficient guarantees to ensure that data processing meets the requirements established by the EU General Data Protection Regulation.

  • Third-party certifications: For example, Privacy Shield, a framework agreement between the EU and the United States that establishes a standardized framework for the processing of data in accordance with the requirements of the EU General Data Protection Regulation.

 

7. DATA PROCESSING AND RETENTION PERIOD

Customer Account data, and therefore all data related to your interactions with us, including any inquiries you have made to us, appointments you have requested, events you have attended, preferences and tastes provided about dresses, answers on satisfaction surveys, shall be retained by us for a period of five (5) years from the date of your last interaction with us, understanding as such the use of our website, reading our electronic messages, or visiting any of our stores, among others.

Also, if you have subscribed to our newsletter, we shall process your data until we deem that, by any means available according to the technology existing at any given time, you no longer have an interest in our products (such as in the event you do not use your user account to browse our website, or not open our emails). In any case, you may unsubscribe from the newsletter at any time.

At the end of the period indicated in the first paragraph of this section 7, or whenever any of the above conditions hold, we shall retain your data, duly blocked, for the period of time necessary to comply with our legal obligations (e.g., the Consumer and User Defense Act, as well as mercantile or tax law, may require us to retain certain data for a specific period of time). In addition, whenever possible, we shall also store them for statistical or market research purposes in an anonymous format.

 

8. EXERCISING YOUR RIGHTS

You may choose to object to any of the data processing indicated above at any time without any negative impact on your status as a customer or NFG contact.

Please note that if, in the course of your visit to any store you provide additional data to any company other than a member of the Pronovias Group, you must exercise your rights to that data before that third party in accordance with the information that, pursuant to law, must be provided at the time your data is gathered.

Similarly, you may exercise your rights of access, rectification, deletion, limitation and/or portability in relation to the data you have provided to any member company in the Pronovias Group by giving written notice addressed to NICOLE FASHION GROUP S.p.A. at the firm's postal address, Via Montenapoleone 8, 20121 Milano, or via email addressed to privacy@nicolespose.it.

In addition, you may file a complaint with the Pronovias Group Data Protection Committee if you consider that NFG has processed your data in a manner which contravenes this General Privacy Policy, or any other prevailing and applicable norm or legislation, by sending an email addressed to gdprcomitee@pronovias.com as well as, in the event you do not receive a response or that you do not agree with the information received, filing the appropriate complaint with the competent Supervisory Authority.

Note that we may ask you for documentation proving your identity to carry out your request, provided that local regulations in force so require.

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