Privacy notice
PRIVACY POLICY
REPLAY values your privacy and is committed to providing you with clear and transparent information in respect of how your Personal Data is treated.
With this in mind this Policy explains:
- Who controls your Personal Data
- What Personal Data does REPLAY collect
- How Personal Data is collected
- For what purpose do we process your Personal Data
- How long do we keep the Personal Data
- Who can see my Personal Data
- How does REPLAY protect Personal Data
- What are your rights in respect of your Personal Data
- How can you exercise your rights in relation to Personal Data?/Contact Information
- Updates to our Privacy Policy
WHO CONTROLS YOUR PERSONAL DATA?
The Data Controller is Fashion Box S.p.A. (“REPLAY”), with fiscal code IT03676290269, whose registered officeis situated at Via Marcoai, 1 - 31011 Asolo – Fraz. Casella TV - Italy.
WHAT PERSONAL DATA DOES REPLAY COLLECT?
Depending on the services you are using REPLAY may collect the following Personal Data: Name, Address, Email Address, Phone number, Purchase and Payment Information (excluding credit/debit card or other payment method details), Account Password and Login details, Date of Birth, Gender, Social media account details, details of your communications with Customer Service, IP Address, Device Information, Website/Browsing History (including location data) and Cookie information.
Please note that REPLAY does not knowingly solicit Personal Data from children or send them requests for personal data. Although visitors of all ages may visit our Website, we do not intentionally collect personal data from those under the age of 16. If, following a notification or discovery by other means, a child under 16 has been improperly registered on our Website or to any other service we offer, by using false information, we will cancel the account and delete the relevant Personal Data from our records.
HOW PERSONAL DATA IS COLLECTED?
REPLAY collects Personal Data when you:
• Purchase products through www.replayjeans.com including the mobile site (the “Website”) and through stores
• Register a “My Account” through the Website
• Apply for a “Replay Just For Friends” membership
• Subscribe to our newsletters
• Engage with us via social media
• Register or use our in-store WIFI (in any of our stores where this service is available)
• Enter our competitions, prize draws or promotions and complete surveys we have sent you
• Use our customer services team or contact us for any reason, e.g. order queries, complaints, website issues via our phone, email and post
• Browse the Website
We use cookies on our Website. For more information on cookies, please see our Cookie Notice below.
FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?
Personal Data shall be processed for the following purpose, as applicable:
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How we use your Name and Contact Details
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For what purpose?
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To process and deliver your orders
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To perform our contract with you
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To manage any issues during order fulfilment
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To perform our contract with you
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To register your Account or Just for Friends Membership
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To perform our contract with you
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To Send you information about new products, services, offers, promotions and competitions
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To keep you updated: this information shall be sent to you if you have consented to receive newsletters and/or other marketing materials
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To verify your identity
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For the legitimate interest of fraud prevention and detection
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To effect any prize draws in respect of competitions
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To conduct any competition you have entered into. For the purposes of participating in the competition you shall have given your consent to use your Personal Data.
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To send you service emails or communications required by law
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To comply with our legal obligations
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How we use your Purchase and Payment Information
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For what purpose?
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To provide customer support, authorise delivery and refunds
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To perform our contract with you
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Fraud Prevention and Detection
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For the legitimate interest of fraud prevention and detection
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How we use your Password and Login details
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For what purpose?
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To verify your identity
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For the legitimate interest of verifying that the account is accessed by the right person
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How we use your Date of Birth
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For what purpose?
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To verify your age
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For the purposes of verifying eligibility to register on the Website and participate in any competition or survey. To comply with our legal obligations
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How we use details of your communications with Customer Service
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For what purpose?
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To provide customer service and support
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To perform our contract with you
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How we use details regarding your Purchase History
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For what purpose?
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Your purchase history will be held by us in order to provide you with the necessary customer service and support
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To perform our contract with you
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How we use details regarding your Saved Items, IP Address, Device Information, Website/Browsing History (including location data) and Cookie information.
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For what purpose?
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Device details are necessary to use any in-store wi-fi service and to re-connect when re-visiting our stores
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To perform our contract with you and to fulfil oue legal obligations
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To provide you with details of products, services and offers that we think you might like
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To personalise your Website and improve your browsing experience. We will do this only where you have consented to the use of cookies
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To show you advertising during navigation on other platforms, including social media
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To personalise your Website and improve your browsing experience. We will do this only where you have consented to the use of cookies
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How we use details of your responses to competitions, promotions, prize-draws and surveys
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For what purpose?
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To conduct any competition, promotion, prize-draw or survey you have entered into
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To perform our contract with you
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REPLAY may utilise the above Personal Data (including details regarding your age, gender and social media) for other reasons of legitimate interest which can include guaranteeing the security of the Website and understanding trends, requirements and customer satisfaction in order to improve the goods and services we offer to the customer. REPLAY may also aggregate Personal Data and may share this with third parties, using it for research and data analysis purposes as well as improving the Website and developing services.
Please note that if you do not consent to the processing of your Personal Data where it is necessary for REPLAY to perform its contract with you, REPLAY will not be able to provide you with the requested service.
HOW LONG DO WE KEEP PERSONAL DATA?
REPLAY will keep the Personal Data only for a period that is reasonably necessary, namely for as long as:
· you have an Account;
· it is necessary to fulfil any aspects in respect of your purchases or other services requested by you; or
· fulfil legal requirements, prevent fraud or enforce our rights.
whichever is longer.
This means that REPLAY may keep the Personal Data for a reasonable time, including after you have deleted your Account or stopped using the services of REPLAY.
WHO CAN SEE YOUR PERSONAL DATA?
REPLAY will not sell, rent or otherwise make any your Personal Data commercially available to any third party. However, it is necessary to share Personal Data with our affiliate companies and with certain third-parties in order to perform contracts and provide our services, namely:
· REPLAY group member companies;
· Companies involved in the fulfilment of purchases, including payment service providers and delivery companies.
· Service providers, such as the e-commerce customer service operator, who at present is TFOUR Srl of Via Durini 4, Milan, Italy, and other marketing agencies, advertising partners and website hosts.
· Companies approved by you, such as social media sites (if you choose to link your accounts to the Website).
In order to provide the services REPLAY may have to transfer your Personal Data to locations outside the European Economic Area (the “EEA”). The level of protection in respect of Personal Data in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement standard contractual clauses in order to ensure that Personal Data is protected and secure.
We strongly advise that when clicking any third-party link (for example Social Media links) and using any third-party service through our Website, you read the privacy policy and any terms of use of said third-party prior to submitting any of your personal data, as in such case the contents of such policy shall govern how your personal data is treated by said third party.
HOW DOES REPLAY PROTECT PERSONAL DATA?
REPLAY uses a range of technical and organisational measures to protect Personal Data from unauthorised access, use and disclosure. The Website uses data security technologies such as firewalls, access control procedures and cryptographic mechanisms to prevent any unauthorised access to data and guarantee data confidentiality.
WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA?
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Right of access
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You have the right to access the Personal Data REPLAY holds about you
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Right to Rectification
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You have the right to request the correction of inaccurate personal Data REPLAY holds about you
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Right to erasure
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The right to request that we delete your Personal Data, or stop processing it or collecting it (except in the event that retention of said data is still necessary for the purpose it was collected/processed or for legal reasons).
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Right to restriction of Processing
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You have the right to request the restriction of the processing of your Personal Data, in which case we will only continue to process Personal Data if we can demonstrate we have an overriding legitimate ground for doing so.
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Right to data portability
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You have right to receive the Personal Data in a structured, commonly-used and machine-readable format if the data has been received on the basis of consent or contract, and to have such data transmitted from REPLAY to you or another service provider if this is technically feasible.
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Right to object
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You may object to the processing of Personal Data based on certain grounds including to stop direct marketing.
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Automated individual decision making
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You have the right not to be subject to a decision based solely on automated processing, including profiling, however, it will not be possible to exercise said right in cases where the decision is necessary for the performance of a contract or where it is based on your explicit consent.
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Right to lodge a complaint
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You have the right to lodge a complaint to the Italian Data Protection Agency.
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HOW CAN YOU EXERCISE YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA? / CONTACT INFORMATION
Should you:
· Require any clarification or require further information regarding this Privacy Notice; or
· Wish to exercise any of your rights as set out above, or have a complaint
Please contact our Customer Service Team at customer-service@replayjeans.com.
Alternatively, REPLAY has appointed a Data Protection Officer to deal with any issue relating specifically to the processing of your Personal Data and you may contact the Data Protection Officer via email at privacy@replay.it or by post at Fashion Box S.p.A. Via Marcoai, 1 - 31011 Asolo – Fraz. Casella TV – Italy (marking the letter “to the attention of The Data Protection Officer”)
UPDATES TO OUR PRIVACY POLICY
REPLAY may update its Privacy Policy from time to time. Any significant changes will be communicated via the Website or by other means of contact such as email so that you are always informed of any modifications and are free to review such changes prior to using REPLAY’S services.