4. PROMOTIONAL MESSAGING
NFG 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 NFG 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 NFG 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 NFG 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:
- Messages sent by email, SMS, MMS or direct messaging (WhatsApp, telegram, Facebook Messenger, direct messages in Forums or on Social Media platforms, and so on):
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).
- Promotional messaging on 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 NFG customers who also have a user account on the platform.
To do so, the platform may require the advertiser (NFG) 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, NFG 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 NFG 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 NFG 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 email@example.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.
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.
You may request additional information at any time about the protocols in place in each case.
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 below at any time without any negative impact on your status as a customer or NFG contact.
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 firstname.lastname@example.org.
Note: that we may ask you for documentation proving your identity to carry out your request, provided that local regulations in force so require.