1. WHO COLLECTS YOUR PERSONAL DATA
Who collects and processes the Personal Data, as data controllers (hereinafter "Data Controllers" or "Controllers") are JUNSEIWAN.
In order to fulfil technical issues connected to the Site, the Data Controllers may or shall appoint some data processors or any elected third party (hereinafter collectively, the "Processors") that processes the Data on our behalf. These subjects were appointed because of their technical skills related to purposes and modalities of the processing, guarantees offered in relation to security measures adopted and in compliance to applicable data protection laws. These subjects are under our control and you could request a full list writing an email to email@example.com
2. WHY WE COLLECT YOUR PERSONAL DATA
Personal Data will be processed for the following purposes:
(a). administrative and accounting purposes: execution of sales contract, accounting and fulfilment of legal obligations, after-sales services. The legal basis for this data processing is: execution of a contract of which you are a part. The Data collected for this purpose will be kept for the entire duration of the contractual relationship and for 10 years after the termination of the same;
(b). for marketing or commercial purposes: dispatch of advertising material or direct sales material, market research, commercial communication, customised or automated systems via e-mail or other communication systems via communication networks such as, by way of example but not limited to SMS, MMS, Facebook, Facebook Messenger, Instagram, Whatsapp, WeChat, etc., and/or via traditional communication methods like post mail or telephonic contact. The legal basis for this data processing is with your consent. The data collected for any of these purposes shall be retained until the withdrawal of your consent;
(c). for profiling purposes: analysis of your consumer choices consistent in automated processing of the Personal Data included data relating to purchases details in stores and websites of data controllers worldwide. This processing is finalised to predict your purchase preferences and to create clients profiles. The legal basis for this data processing is: your consent. The Data collected for this purpose will be retained until the withdrawal of your consent.
For the purposes of letter a., Data Controllers could collect and process the following Personal Data:
- personal information: first name, middle name, surname, name and surname in the local alphabet, occupation, nationality;
- during your visit(s) in physical stores, we may or shall collect the following data; but not limited to: address of residence, city of residence, province of residence/state of residence, country of residence, zip code, email address, phone number, mobile number;
- during your visit to our Site, we shall collect the following data; but not limited to: billing and shipping address, method of delivery and payment, details of payments for transactions such as name of the holder of the debit/credit card or other means and forms of payment details, date of expiration, CCV code, building/apartment, preferred contact method, additional addresses, secondary email, secondary phone or mobile number, and/or contact method(s)
- requests can be made to the customer service of JUNSEIWAN of any relevant or private information of the customer that does not want to be used.
- data collected during your visit to the Site: birthday, alleged age groups, date of birth, country, nationality, gender, method and date of registration, language, categories of preferred products, mode of use of services, and/or other preferences;
- data concerning purchases made online and in-stores: detail(s) of the product(s) purchased, size, price, discount, unit, colour, fit, model, collection, level of expenditure calculated, abandoned shopping cart, tax/VAT code or VAT exemption(s), passport number, transaction address, notes related to the discount on a personal basis, purchase channel(s), purchase frequency, purchase preference (discount or full priced), preferred season labels;
- data regarding participation of any or all of our commercial activities.
- data collected during navigation or during online store purchases or the use the Site: data related to browsing behaviours and/or the use or services held on Data Controllers' Site or any kind of property related to Data Controllers, by using, for example, cookies or information about pages that have been visited or searched, or related to on the Site, etc.
The Personal Data includes: IP addresses and/or the domain names of the computers used by any user connecting with this website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), other parameters related to the user's operating system and computer environment, data related to browsing behaviour of the user on the Site, information about pages that have been visited or searched, in order to select and return specific advertisements to the user of the Site
In the processing of Personal Data that may directly or indirectly identify you or yourself, we respect a principle of strict privacy. For this reason, we configured the Site in such a way that the use of Personal Data is reduce to a minimum and to limit the processing of Personal Data that could identify the data subject only when needed or at the request of the authorities and the police (as, for example, for traffic data and the time you spend on the Site or your IP address) or for the assessment of responsibility in case of hypothetical crimes against the Site.
Some Personal Data are strictly necessary to operate the Site, others are used only to obtain anonymous statistical information about the Site and to check its correct functionings. From time to time you will be informed about obligation or optional nature of the communication of Personal Data and possible consequences. 3. WHAT HAPPENED IF YOU DO NOT PROVIDE THE PERSONAL DATA
Some Personal Data that we will point out during the registration procedure or purchase are required in order to execute the purchase and to pursue the administrative and accounting purposes (letter a. of the Paragraph 2).
Providing and processing of Personal Data for profiling and marketing purposes (letters b. and c. of paragraph 2) is optional and therefore their inclusion in our Customer Relationship Management (CRM) systems by JUNSEIWAN Community of the Data Controllers and Department that allow the processing of the Personal Data for any commercial, marketing or profiling purposes will take place only with your consent.
You may at any time revoke your consent to the profiling and/or marketing purposes (letters b. and c. of Paragraph 2) contacting individually data controllers to the addresses above mentioned. Failing to provide the Personal Data and/or withhold your consent preclude the pursuit of profiling and marketing purposes but will not have any effect on your ability to finalise your purchases.
4. HOW WE WILL PROCESS THE PERSONAL DATA
The Personal Data provided and/or collected by data controllers will be processed and stored by automated tools and systems; while in some cases, they will be processed and stored on paper. In particular, Personal Data processed for profiling and marketing purposes will be stored in the Site's CRM systems that allow the processing of Personal Data for marketing and profiling purposes of data controllers and/or data processors whose server is located in the United States of America and/or France. You acknowledge that the Personal Data is being transferred abroad, also outside European Union, and may become accessible to governments under a lawful order made in that country.
The Personal Data collected for administrative and accounting purposes (letter a. of Paragraph 2) shall be stored for the time necessary to perform any of the purposes, or the provision of legal warranties in accordance with the terms of the retention required by the applicable law. The Personal Data collected for marketing and profiling purposes (letters b. and/or c. of Paragraph 2) will be stored until the client asks to revoke the registration or the consent to the processing of the Personal Data.
On expiry of the retention terms indicated above, the Personal Data will be automatically erased or made permanently and irreversibly anonymous.
5. WHO WILL PROCESS THE PERSONAL DATA
The Personal Data will be processed by:
- employees and associates of the Data Controllers designated as persons in charge of the processing;
- employees and associates of the data processors designated by data controllers including (i) subjects that manage the traditional or online stores and that may view, edit and update the Personal Data entered into the CRM systems by which the Data Controllers process for marketing and profiling purposes (ii) subjects that manage storing of the Personal Data on behalf of the data controllers in accordance to local agreements and laws;
- third party members in or outside the EU, data processors, used by the Data Controllers in particular for acquisition services and data entry of personal data, shipping, distribution of promotional material, after sales support, market research, management and maintenance of the CRM systems by which the data controllers process for marketing and profiling purposes and others data controllers IT systems.
6. YOUR RIGHTS
According to Chapter III of Regulation (EU) 2016/679 and other local applicable data protection laws (see details below related to your Country), you can at any time request information on personal data collected, used, disclosed or processed by the data controllers (right of access), as well as request for integration, rectification or erasure and object to their processing. Furthermore, starting from 25th of May 2018 (when the Regulation EU 2016/679 will apply), you will be able to exercise also the following rights: restriction of processing, data portability and lodge a complaint with a supervisory authority.
In particular, you have the right to object and withdraw your consent, in whole or in part, to the collection, use, disclosure or processing of your personal data for purposes of dispatch of advertising material, direct selling or for the fulfilment of marketing surveys or commercial communications via both automated (e-mail, other systems of digital or tele-communication ways as by way of example through SMS, MMS, Facebook, Facebook Messenger, Instagram, Whatsapp, WeChat, etc. or traditional communications through post mail.
If you prefer that the processing of your personal data is carried out solely by means of traditional contact methods, you may object to the processing of your personal data by means of automated contact methods.
In order to exercise your rights above and/or submit an inquiries or complaints with regard to the processing of your personal data, you may send a request to the data controllers by writing to firstname.lastname@example.org
In order to request for more information or exercise your rights, you may contact us at email@example.com