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Privacy Policy EN

Privacy policy

Privacy Policy of www.ahtzirilagarde.com

This Site collects some Personal Data from its Users.

Contact Info

Data Controller

Ahtziri Lagarde

Partita IVA 09951731216

Owner contact email: desk@ahtzirilagarde.com

Types of data collected

Among the personal data collected by this Site, either independently or through third parties, there are: name and surname; date of birth; e-mail; password; billing address; POSTAL CODE; city; country; province; shipping address; usage data; tracking tools.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.

Personal data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Site.

Unless otherwise specified, all data requested by this site are mandatory. If the User refuses to communicate them, it may be impossible for this Site to provide the Service. In cases where this Site indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.

Users who have doubts about which data are mandatory are encouraged to contact the owner.

Any use of Cookies – or of other tracking tools – by this Site or by the owners of third party services used by this Site, unless otherwise specified, is intended to provide the Service requested by the User, in addition to further purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Site and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

Method and place of processing of the collected data

Processing methods

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.

The processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Site (administrative, commercial, marketing, legal, system administrators) or external subjects (such as suppliers of third party technical services, postal couriers) may have access to the Data. hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

Legal basis of the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;

the processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures;

the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

the processing is necessary for the execution of a task of public interest or for the exercise of public authority vested in the Data Controller;

the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place

The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.

The User’s Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

In case of superior protection, the User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as for example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the opening details.

Retention period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.

Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of processing the collected data

The User Data is collected to allow the Owner to provide the Service, comply with legal obligations, respond to requests or executive actions, protect their rights and interests (or those of Users or third parties), identify any malicious activities. or fraudulent, as well as for the following purposes: Registration and authentication, Contacting the User, Registration and authentication provided directly by this Site and Displaying content from external platforms.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the “Details on the processing of Personal Data” section.

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contact the user

Contact form (this Site)

By filling in the contact form with their data, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the form header.

Personal Data processed: email; first name.

Registration and authentication

By registering or authenticating, the User allows this Site to identify him and give him access to dedicated services.

Depending on what is indicated below, the registration and authentication services could be provided with the help of third parties. If this happens, this Site will be able to access some Data stored by the third party service used for registration or identification.

Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to learn more, please refer to the description of each service.

Log In with PayPal (Paypal)

Log In with PayPal is a registration and authentication service provided by PayPal Inc. and connected to the PayPal network.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Consult the Paypal privacy policy – Privacy Policy.

Registration and authentication provided directly by this Site.

By registering or authenticating, the User allows this Site to identify him and give him access to dedicated services. Personal Data is collected and stored solely for registration or identification purposes. The data collected are only those necessary to provide the service requested by the user.

Direct registration (this Site)

The User registers by filling out the registration form and providing his Personal Data directly to this Site.

Personal Data processed: Name; Last name; Date of birth; e-mail; billing address; POSTAL CODE; city; province; country; User ID; password.

Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Site and interact with them.

This type of service may still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

Google Fonts (Google LLC)

Google Fonts is a font style visualization service managed by Google LLC that allows this Site to integrate such content within its pages.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States – Privacy Policy.

User rights

Users can exercise certain rights with reference to the Data processed by the Data Controller.

In case of higher protection, the User can exercise all the rights listed below. In any other case, the User can contact the owner to find out which rights are applicable in your case and how to exercise them.

In particular, the User has the right to:

withdraw consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed.

oppose the processing of their data. The user can oppose the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.

access their data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.

verify and request rectification. The User can verify the correctness of their Data and request its updating or correction.

obtain the limitation of the treatment. When certain conditions are met, the User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.

obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.

receive their data or have them transferred to another owner. The User has the right to receive his / her Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its unhindered transfer to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures connected to it.

propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object

When Personal Data are processed in the public interest, in the exercise of public authority vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise the User’s rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Applicability of the higher level of protection

While most of the provisions of this document apply to all Users, some are expressly subject to the applicability of a higher level of protection to the processing of Personal Data.

This higher level of protection is always guaranteed when the treatment:

it is performed by a Data Controller based in the EU; that is, it concerns Personal Data of Users located in the EU and is functional to the offer of goods or services for consideration or free of charge to such Users; that is, it concerns Personal Data of Users located in the EU and allows the Owner to monitor the behavior of such Users to the extent that such behavior takes place within the Union.

Further information on the treatment

Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Site or related Services by the User.

The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Site may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System log and maintenance

For needs related to operation and maintenance, this Site and any third party services used by it may collect system logs, which are files that record the interactions and which may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This Site does not support “Do Not Track” requests.

To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Site as well as, if technically and legally feasible, by sending a notification to Users through one of the extremes of contact he has. Please therefore consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Definitions and legal references

Personal Data (or Data)

Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data

This is the information collected automatically through this Site (including from third-party applications integrated into this Site), including: the IP addresses or domain names of the computers used by the User who connects with this Site, the addresses in URI notation ( Uniform Resource Identifier), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Site, with particular reference to sequence of the pages consulted, the parameters relating to the operating system and the IT environment of the User.

User

The individual using this Site who, unless otherwise specified, coincides with the Data Subject.

Interested

The natural person to whom the Personal Data refers.

Data Processor (or Manager)

The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of this Site. The Data Controller, unless otherwise specified, is the owner of this Site.

This site

The hardware or software tool through which the Personal Data of Users are collected and processed.

Service

The service provided by this site as defined in the relative terms (if any) on this site.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookies

Cookies are Tracking Tools which consist of small pieces of data stored in the User’s browser.

Tracking Tool

By Tracking Tool we mean any technology – eg. Cookies, unique identifiers, web beacons, integrated scripts, e-tags and fingerprinting – which allow users to be tracked, for example by collecting or saving information on the User’s device.

In addition to the aforementioned reasons, your data is also collected and used for the eventual sale of products, the conditions below.

How do we collect information about you?

We may collect information about you in a variety of ways, all in full compliance with the law applicable in the country where you are located.

• You can provide us with the information directly (eg by filling out a form or contacting us by phone).

• We may collect information automatically (eg when you use the website or any app that may be available).

• We may acquire information from third parties (eg, where permitted by law, information publicly available on social media platforms such as Facebook, Instagram, TikTok, etc.).

In this statement we refer to all the methods by which you can get in touch with us by defining them as “contact points”. Ahtziri Lagarde’s touchpoints include both physical and digital ones.

We may collect information that you provide to us directly. This will usually happen when:

You sign up as a member of our databases (including loyalty programs); register to receive newsletters, email alerts or marketing communications;

purchase Ahtziri Lagarde products or services at a point of sale;

• you contact us through a contact point, for example by e-mail, social media or by telephone;

• download, or use, a digital contact point (for example an app or website);

We may collect information about you automatically. This will usually happen when:

• communicate with us (for example through a contact point or social media platforms);

• use Ahtziri Lagarde’s contact points (eg through tracking mechanisms on the app or on a website); or

• publish public posts on social media platforms that we follow.

We may also collect information about you automatically through the use of cookies and similar tracking technologies on Ahtziri Lagarde’s digital contact points or you receive an electronic message from us. The specific cookies and technologies used will depend on the Ahtziri Lagarde point of contact in question. For information regarding cookies (including those of Google Analytics) and similar technologies used on a contact point, including how to accept or reject cookies, we invite you to read the information on cookies made available on or through this point of contact. contact. These devices may include Google analytical cookies (see www.google.com/policies/privacy/partners/).

Where permitted by law, we have the right to request information about you from third parties. This includes publicly available profile information (such as your preferences and interests) on third party social media sites (such as Facebook, Instagram, TikTok, etc.), and marketing lists acquired from external marketing agencies.

We may also collect information in other contexts that will be communicated to you at the time of collection.

What information about you do we collect?

We can collect various types of information about you, all in full compliance with the legislation applicable in the country where you are:

• information necessary to fulfill your orders;

• information necessary to provide services;

• information you provide us in forms or surveys;

information about your location, where you are willing to share it with us on your mobile phone operating system;

information you provide to us in communications (for example, phone calls, chats, e-mails) that you entertain with contact points;

information about your preferences and interests;

information about your experiences in using our products and services.

The information we collect directly from you will be clear from the context in which you provide it. For instance:

• if you order a product through one of our contact points, you will provide your name, contact details, billing information and the products you have chosen, so that we can process your order;

• you can provide information regarding your product preferences and interests so that we can offer you products and services of your interest;

• if you make an appointment to meet us or someone who supports our products or services, we may collect your name and contact information;

• We may collect information that allows us to verify your age, such as a copy of an identity document or a photograph of your face.

The information we automatically collect will generally concern:

• details regarding your visit or phone call (for example time and duration);

• at a point of sale or during an event (including in areas in the immediate vicinity), the frequency of your visits, the areas visited and for how long, and the purchases made;

your use of Ahtziri Lagarde’s digital touchpoints (the pages you visited, the page you came from and the page you visited after leaving, the search terms entered or the links you clicked on within the point of contact) contact, when you accessed the contact point for the first time); to do this we may use cookies and similar tracking technologies.

your use of third-party websites in which the information collected will be similar to that described in the previous point (to do this we may use cookies and similar tracking technologies (such as pixels / web beacons);

 your device (for example your IP address or unique device identifier, location data, details regarding any cookies that we may have saved on your device).

The information we collect from third parties will typically be publicly available profile information (such as your preferences and interests), for example from public social media posts.

For what purposes do we use the information about you and on what legal basis?

In this section we describe the purposes for which we use your personal information. However, the information has global validity therefore, if the regulations of a country limit or prohibit certain activities described therein, we will not use the information concerning you for such purposes in that country. Notwithstanding the foregoing, we use your information for the following purposes:

• Comply with regulatory obligations

• Selling you our products, which includes fulfilling your orders and processing your payments

• Provide you with sales related services, including handling your inquiries and inquiries

• Marketing our products, where permitted by law, also by managing loyalty programs, product improvements, market research, developing marketing strategies, managing marketing campaigns and personalizing your experience at the points of sale that sell Ahtziri Lagarde products and at events

• To allow us or our business partners to inform you of potential opportunities to participate in the marketing or promotion of Ahtziri Lagarde’s products

• Support all of the above activities, including by managing your accounts, allowing you to use Ahtziri Lagarde’s contact points, having correspondence with you, managing your appointments with us or with someone who supports our products or services (for example in about a new product, or for after-sales service), personalizing your experience on Ahtziri Lagarde’s touchpoints, as well as through administration and troubleshooting activities

• For business analysis, including improving Ahtziri Lagarde’s products, outlets and events, as well as the information we or our affiliates provide to our customers

For other purposes that we will communicate to you, or which results will keep clear from the context, when the information about you is collected for the first time

The legal basis for our use of information about you is one of the following (which we will explain in more detail in the “Find out more” section):

• the fulfillment of a legal obligation to which we are subject;

• the execution of a contract to which you are a party or the execution of pre-contractual measures adopted at your request;

• a legitimate business interest over which the interests or fundamental rights and freedoms you have to protect your personal information do not prevail;

• if none of the above applies, your consent (which we will ask before processing the information).

The purposes for which we use the information concerning you, with the respective collection methods and the legal basis for their use, are:

Purpose

Fulfillment of regulatory obligations

Method of collection and legal basis of the processing

This information is usually provided to us directly by you. We use them because they are necessary in order to comply with a legal obligation to sell products exclusively to adults or, in countries where no such legal obligation exists, because we have a legitimate business interest in selling our products exclusively to adults. over which your interests, rights and freedoms to protect age information about you do not prevail

Purpose

Selling our products

• fulfill your orders (including by sending receipts)

• process your payments

Method of collection and legal basis of the processing

This information is typically provided to us directly by you (usually your name, address, email address, payment information). We will use them to fulfill our contractual obligations to you as the purchaser of our products.

Purpose

Provide sales related services

• manage your questions and requests, and information about your experiences with our products and services

• correspond with you

• general administration and problem-solving activities

• manage loyalty programs

Method of collection and legal basis of the processing

This information is usually provided to us directly by you. We use them because we have a legitimate business interest in providing sales-related services to our customers over which your interests, rights and freedoms to protect information about you do not prevail.

Purpose

Marketing our products (where permitted by law)

• understand your preferences (for example which products or events might interest you or could be tailored to your needs) and, where permitted by law, sell to you personally

• manage loyalty programs

• manage and invite you to participate in surveys or market research

• for market research

• develop marketing strategies

• manage marketing campaigns

• personalize your experience with Ahtziri Lagarde’s contact points (for example, personalize your visit, for example with greetings or suggestions that may interest you)

Method of collection and legal basis of the processing

This is usually a combination of information provided by you (for example your name, contact details and social media contact details); information that we collect automatically (for example, using technology to monitor the use of Ahtziri Lagarde’s contact points) and, where permitted by law, information we acquire from third parties (such as public posts on social media). We use them because we have a legitimate business interest in marketing our products, managing Ahtziri Lagarde’s contact points and personalizing your experience – an interest over which your interests, rights and freedom to protect information about you do not prevail.

Purpose

Marketing our products (where permitted by law)

• manage and provide you with information regarding Ahtziri Lagarde affiliates, their promotions, products and services, points of sale, events and the regulation of our products, and develop and improve tools to pursue these purposes

Method of collection and legal basis of the processing

This is usually a combination of information provided by you (for example your name, contact details and your pseudonyms on social media), information that we automatically collect (for example using cookies and similar technologies) and, where permitted by law, information that we acquire from third parties (such as public social media posts). We use them because we have a legitimate business interest in marketing those aspects over which your interests, rights and freedoms to protect information about you do not prevail. In some countries, where required by law, we will send you such materials electronically only with your consent.

Purpose

Support for all the aforementioned purposes

• manage your accounts

• allow you to use Ahtziri Lagarde’s contact points (for example, allowing you to maintain access to sections of a contact point that are reserved only for authorized users, manage your language preferences, associate your cart with you)

• correspond with you

• manage your appointments with us or with someone who supports our products or services (for example about a new product, or for after-sales assistance)

• improve your experience

• administration and troubleshooting

Method of collection and legal basis of the processing

This is usually a combination of information you provide us (usually your name, password (or equivalent) and information we automatically collect (for example, information about your device, cookies and similar tracking technologies). We use them because they match the purpose of using the information we are supporting. For example, when we manage your account to support a sale or to provide after-sales service, we use the information to fulfill our contractual obligations to you as a buyer of our products; when we manage your account to show you our products , we support marketing and therefore we use them because we have a legitimate commercial interest in marketing our products over which your interests, rights and freedom to protect the information concerning you do not prevail, and the same applies to other information acquired in a similar context.

Purpose

Commercial analysis and improvements

• allow us or our business partners to inform you of potential opportunities to participate in the promotion of Ahtziri Lagarde’s products

• for commercial analysis and improvements (including for Ahtziri Lagarde’s products, the points of sale that sell Ahtziri Lagarde’s products, events, Ahtziri Lagarde’s digital contact points as well as the information that we (or our affiliates) provide to our customers)

Method of collection and legal basis of the processing

This is usually a combination of information that you provide to us, information that we automatically collect and, where permitted by law, information that we acquire from third parties. We use them because we have a legitimate business interest in analyzing and improving our business results, our products, Ahtziri Lagarde contact points, outlets and events, as well as to invite others to participate in the promotion of Ahtziri Lagarde products, over which your interests, rights and freedoms to protect information concerning you do not prevail.

If the use of the information concerning you is not based on one of the previous legal bases, we will ask for your consent before processing the information (such cases will be clear from the context). In some circumstances, we may use information about you in ways other than those described above. In this case, we will provide you with a supplement to the privacy policy explaining this use and which must be read in conjunction with this information.

Who do we share your information with and for what purposes?

Information about you can be shared with:

• Affiliate of Ahtziri Lagarde;

• third parties who provide products or services to Ahtziri Lagarde’s affiliates or to you;

• business partners and advertisers carefully selected by Ahtziri Lagarde’s affiliates (in areas related to our products, or consistent with their style and image) so that they can contact you with offers that they consider to be of interest to you, in accordance with your preferences, and

• other third parties, where required or permitted by law.

Sharing of data with third parties

• We may share information about you with third parties who provide products or services to Ahtziri Lagarde’s affiliates or to you (such as consultants, payment service providers, shipping service providers, resellers).

• We may share information about you with other third parties where required or permitted by law, for example: regulatory authorities; public entities; in response to a request from law enforcement or other public officials; where we believe that disclosure is necessary or appropriate in order to prevent physical harm or financial loss or in connection with an investigation into suspected or actual illegal activities; and in the context of corporate restructuring.

Where could information about you be sent?

Information concerning you can be transferred around the world (this means that if the information is collected in the European Economic Area, it could be transferred outside it).

In using the information as described in this statement, the information concerning you may be transferred within or outside the country or territory in which it was collected, even in a country or territory that may not have protection standards. equivalent data. In all cases mentioned, the transfer will be:

• subject to appropriate safeguards, for example EU standard contracts; ; or

• necessary in order to fulfill obligations under a contract between you and us (or the execution of pre-contractual measures taken at your request) or in order to enter into or perform a contract concluded in your interest between us and a third party, for example in relation to travel arrangements. In any case, adequate security measures will be taken in these countries or territories for the protection of personal information, in accordance with the legal provisions applicable to data protection.

How do we protect information about you?

We implement appropriate technical and organizational measures to protect the personal information in our possession from unauthorized disclosure, use, alteration or destruction. Where appropriate, we use encryption procedures and other technologies that can assist us in protecting the information you provide. We also ask our service providers to adhere to strict data privacy and security requirements.

How long will your information be kept?

We will keep information about you for the period necessary to achieve the purposes for which it was collected. We will then proceed to cancel them. This period varies according to the purposes for which the information was collected. We inform you that, in some circumstances, you have the right to ask us to delete the information and that we are sometimes legally obliged to keep the information acquired, for example for tax and accounting purposes.

We usually store data based on the criteria described in the following table:

Criteria:

commercial activities intended for you (including marketing communications) (if you use digital touchpoints and are contactable)

Typical explanation / retention policy:

Much of the information contained in your marketing profile is retained for the duration of our business relationship with you; for example, as long as you continue to use digital touchpoints, or respond to our communications. However, certain elements of your marketing profile, such as records regarding how we interact with you, naturally become obsolete after a certain period of time, so we will automatically delete them after defined periods (usually 3 years) to the extent that this it is necessary or appropriate for the purposes for which we collected them.

Criteria:

commercial activity intended for you (including marketing communications) (if you are no longer in contact with us)

Typical explanation / retention policy:

This scenario is the same as the previous one, but if we no longer have contact with you for a long period (usually 2 years) we will stop sending you marketing communications and delete the history of your responses to them. This will be the case, for example, if you never click on an event invitation, log in to a digital contact point or contact our customer support during this time. The reason is that in such circumstances we assume that you prefer not to receive communications.

Criteria:

commercial activity intended for you (including marketing communications) (if you are not contactable)

Typical explanation / retention policy:

If you have signed up to receive marketing communications, but the information you have given us to contact you does not work, we will keep your data for a period usually limited to 6 months to allow you to return and correct it.

Criteria:

commercial activity intended for you (including marketing communications) (incomplete registrations)

Typical explanation / retention policy:

If you start to register in a database but do not complete the process (for example, if you do not complete the age verification process or do not accept the terms of use of the touchpoint), we will only keep your data for 6 months to allow you to return and complete the process.

Criteria:

market research

Typical explanation / retention policy:

If you are not registered with us for other purposes (e.g. marketing communications, customer service) and we use publicly available information about you in order to understand the market or your preferences, we will keep the information about you for a period limited in order to carry out the specific part of the market research.

Criteria:

shopping

Typical explanation / retention policy:

If you purchase goods, we will keep the related data for the period necessary to complete the sale and to comply with any legal obligations (for example for the purposes of tax and accounting records).

Criteria:

customer assistance

Typical explanation / retention policy:

If you contact customer service, we will proceed to record the relevant information, including details of your inquiry and our response and will keep it as long as it remains relevant to our relationship, for example if we need to replace a device under warranty or if yours recent requests are relevant. Temporary recordings (for example, the automatic recording of a phone call asking us to refer you to a point of sale) may only be relevant until more permanent recordings are made and therefore will only be kept temporarily.

Criteria:

system audit logs

Typical explanation / retention policy:

System audit logs are usually kept for a limited period of a few months.

Criteria:

Business analytics

Typical explanation / retention policy:

The data relating to the so-called Business analytics are usually collected automatically when you use Ahtziri Lagarde touchpoints and are anonymized / aggregated shortly thereafter.

What rights and faculties do you have?

You may have all or some of the following rights in relation to the information we hold about you:

• ask us to give you access to the information mentioned;

• ask us to correct, update or delete them;

• ask us to restrict their use, in certain circumstances;

• oppose their use, in some circumstances;

• withdraw your consent to their use;

• data portability, in some circumstances;

• revoke the authorization for their use (opt out) for direct marketing activities; And

• file a complaint with the supervisory authority for the protection of personal data in your country (if any). We offer you simple ways to exercise these rights, such as unsubscribe links, or indicating a delivery address, in the messages you receive. Some mobile applications we offer may also send you push messages, for example about new products or services. The sending of such messages can be disabled through the settings of your phone or application.

The rights you can exercise depend on the laws of your country. If you are located in the European Economic Area, you will enjoy the rights listed in the following table. If you are elsewhere, you can contact us (see the paragraph “Who should you contact if you have any questions?” At the end of this policy) for further information.

Right in relation to the information we hold about you:

ask us to give you access to them

Other details (note: all these rights are subject to some legal limits):

This is a confirmation of:

if we process information about you;

our name and contact details;

the purpose of the processing;

the categories of information concerned;

the categories of subjects with whom we share information and, if any subject is outside the EEA and does not benefit from an adequacy decision by the European Commission, the appropriate safeguards to protect the information;

the source of the information (if known), if we have not collected it from you;

the existence of automated decision-making processes (to the extent that we have them, which will have been brought to your attention), including profiling, which produce legal effects that affect you, or that affect you in a similar way, and information concerning the logic involved, as well as the importance and expected consequences of such processing for you; And

the criteria for establishing the retention period of the information.

Upon your request, we will provide you with a copy of the information about you that we use (provided this does not affect the rights and freedoms of others).

Right in relation to the information we hold about you:

request us to correct or update them

Other details (note: all these rights are subject to some legal limits):

This applies if the information we hold about is inaccurate or incomplete.

Right in relation to the information we hold about you:

ask us to delete them

Other details (note: all these rights are subject to some legal limits):

This applies if:

the information in our possession is no longer necessary in relation to the purpose for which we use it;

we use the information based on your consent and you withdraw that consent (in this case, we will remember not to contact you further, unless you tell us that you want us to delete all information about you, in which case we will respect your wishes) ;

we use the information on the basis of a legitimate interest and we believe that, following your objection, we do not have an overriding interest in continuing to use it;

the information was obtained or used unlawfully; or

the cancellation is necessary to fulfill a legal obligation.

Right in relation to the information we hold about you:

ask us to restrict their processing

Other details (note: all these rights are subject to some legal limits):

This right applies, temporarily while we are investigating your case, if you:

you dispute the accuracy of the information we use; or

you have objected to our use of the information on the basis of a legitimate interest

(if you exercise your right in these cases, we will notify you before using the information again). This right applies in any cases where:

the use we have made of your data is illegal and you oppose the deletion of the data; or

we no longer need the data, but you intend to take legal action.

Right in relation to the information we hold about you:

you object to the processing

Other details (note: all these rights are subject to some legal limits):

In this case you have two rights:

if we use your information for direct marketing, you can revoke the authorization (“opt out”) (without giving reasons for the choice) and we will comply with this request; And

if we use information about you on the basis of a legitimate interest for purposes other than direct marketing, you can object to our use for those purposes by providing an explanation of your particular situation, and we will consider that objection.

Right in relation to the information we hold about you:

withdraw your consent to their use

Other details (note: all these rights are subject to some legal limits):

This applies if the legal basis on which we use the information concerning you is your consent. Such cases will be clear from the context (for example, if you have given your consent using the preference center in one of your apps, you can withdraw consent by deactivating the corresponding command

Right in relation to the information we hold about you:

data portability

Other details (note: all these rights are subject to some legal limits):

Self:

you have provided us with the data; And

we use this data by automatic means and on the basis of your consent or for the purpose of fulfilling our contractual obligations towards you,

then you will have the right to have the data returned to you in a commonly used format, as well as the right to ask us to pass the data on to someone else if this is technically feasible for us.

Right in relation to the information we hold about you:

file a complaint with the supervisory authority in your country

Other details (note: all these rights are subject to some legal limits):

Each country of the European Economic Area must have one or more public authorities competent in this area.

Their contact details are listed here:

http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

For other countries, consult the website of the respective authority.

Who should you contact if you have any questions?

If you have any questions, or wish to exercise one of your rights, you can find the contact details at the top of this privacy policy.

If your country has a data protection authority, you will have the right to contact it to raise any questions or concerns. If the relevant Ahtziri Lagarde affiliate cannot answer your questions or concerns, you also have the right to bring a judicial remedy before a national court.

Changes to this information

This information (and any supplement to the privacy policy) may be updated from time to time. Where required by law, we will notify you of the changes; in addition, if required by law, we will ask for your consent for such changes.

Legal references

This privacy statement is drawn up on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy applies exclusively to this Site.

Last modified: July 28, 2022